After the start of the full-scale invasion of Russia, the Ukrainian aviation industry was on the verge of survival. Civil aviation has practically stopped, and aviation enterprises have been hit by the loss of access to critical components of Soviet and Russian origin, which cannot be quickly replaced, for example, with components of their own production. At the same time, this industry remains key to Ukraine's defense capability.
UNN spoke with Ruslan Melnychenko, head of the legal committee of the Aerospace Association of Ukraine and lawyer, about the real state of aviation in the context of the war, legal risks for business, blocking critical supplies due to the inconsistency of regulators, and why the issue of using Soviet equipment is not a choice, but a forced step.
– How has the state of the Ukrainian aviation industry changed since the beginning of the full-scale war?
First of all, it should be understood that we have lost an entire industry in its pre-war form. The civil aviation industry has suffered extremely heavy losses, which is due, in particular, to the impossibility of civil aircraft flying in the airspace of Ukraine. Companies that focused on the domestic market or flights to/from Ukraine have been virtually destroyed. Only those who managed to reformat themselves for international contracts or military logistics remained.
But at the same time, the aviation infrastructure — airfields, repair plants, technical bases — is preserved and even partially functioning. And it is critical, because aviation today is part of defense capability. This includes not only combat helicopters, but also medical evacuation, transportation, and humanitarian logistics.
– What is the fate of the Soviet air fleet, which is still actively used?
As of now, Ukraine operates more than 300 units of military and more than 200 units of civil aviation equipment of Soviet origin. These are Mi-8, Mi-17 helicopters, Antonov aircraft — everything that has been preserved since the USSR. That is, today 90% of the available aircraft are of Soviet origin, and the infrastructure for their maintenance has been formed over decades.
Ukraine has a unique system for supporting the operation of Soviet aircraft and has the potential to become an alternative center for their maintenance.
We have a historically unique infrastructure for their maintenance — this is our strength. However, the problem is different: these machines need parts, repair documentation, technical support. And most of this is either of Russian origin or was once supplied from Russia.
Today we are dealing with a paradox: the equipment is still suitable, there are specialists, the infrastructure is working, but there are no parts. Or — there are, but they are under sanction risk.
If the Ukrainian aviation industry does not reach a common decision on the further operation of Soviet-era aircraft designed in Russia, the operation of these types of aircraft will be completely stopped. In fact, this will mean the loss of the Ukrainian aviation school, which has Soviet approval. Ukraine's transition to Western technology with the abandonment of the operation of Soviet-designed aircraft will completely stop the domestic aviation industry.
The state should officially allow Ukrainian enterprises, until they are replaced by domestic or Western analogues, to import from abroad, except for the aggressor state, components, spare parts and consumables, developed by the former USSR or Russia, provided that such components were manufactured before the full-scale invasion of Ukraine. Otherwise, Ukraine will lose its status as one of the leading aviation countries in the world.
In addition, Russia is actively spreading disinformation about the "malfunction" or "danger" of Ukrainian aviation in order to undermine confidence in it among international partners and potential investors. In addition, the aggressor state can use its influence in organizations such as ICAO, the UN to deny certain certifications, question safety standards or try to introduce restrictions for Ukrainian aviation. It may also try to discredit Ukrainian import substitution efforts by spreading rumors about the use of counterfeit or uncertified spare parts. This creates additional pressure and requires Ukraine to maintain extremely strict quality control.
– How is the industry trying to survive in such conditions?
This is a real struggle for survival. Parts are searched for literally all over the world: in Poland, Bulgaria, Slovakia, even in Latin America. These are old stocks, often manufactured before 2014 or even before 1991. They are usually purchased from warehouses in several stages, without the Russian element, in order not to fall under sanctions or financial monitoring.
The problem is not only with the purchases themselves, but also with the fact that Ukraine often has an overly formalized approach: customs sees the marking "made in USSR" or "Russia" — and blocks the cargo. Although this product has been in circulation in EU countries for decades and has nothing to do with supporting the aggressor.
– This sounds like a direct threat to the functioning of the industry. Why is this not being resolved at the state level?
There are several reasons. First, fear. Both among officials and entrepreneurs. Because any step can be interpreted as "cooperation with Russia." Second, legal uncertainty. Our legislation does not have clear criteria for what constitutes "economic ties with the aggressor." Because of this, many companies are simply afraid to act — because they do not want to become an object of pressure.
Third, a lack of understanding at the level of society. For many citizens, unfortunately, the word "Russian part" is unambiguous. But the problem is deeper: either we use these parts from third countries, or we stop all aviation. And then it is no longer a question of morality, but a question of life and death — literally.
– What risks do companies that still continue to operate in such conditions face?
There is a risk of criminal prosecution — for example, under the articles of the Criminal Code on collaborationism or treason. Especially if law enforcement officers decide to interpret the supply of parts with the "wrong" marking as cooperation with Russia. Add to this information pressure, "black PR", commissioned media campaigns — and you get a picture in which it becomes almost impossible to work honestly and transparently.
At the same time, the state itself depends on this industry: military aviation is served by the same enterprises that are working on the verge of survival. If they are stopped tomorrow — who will repair the helicopters of the Armed Forces?
– Is import substitution of Soviet components realistic in the short term?
No. We do not have a full production cycle. We never did. The most critical components — electronics, navigation, composite materials — were manufactured in Russia. Replacing them means creating new technologies from scratch, undergoing certification, and developing technical regulations. This is 5–10 years and billions in investment.
The only thing that is realistic now is partial import substitution where possible, and legalization of purchases of what already exists in the world. Especially — in the warehouses of NATO countries, which themselves once operated Soviet equipment.
It is worth noting that the economic efficiency of operating, for example, Soviet-made helicopters demonstrates extremely high profitability. The average service life after overhaul is on average 8-10 years, while maintenance is almost completely provided by domestic components.
The structure of expenses and revenues shows impressive economic efficiency: with moderate expenses for maintenance and overhaul, the industry generates significant foreign exchange earnings. More than half of the cost of overhaul is work performed by Ukrainian enterprises.
– What solutions could stabilize the situation?
At a minimum, we need:
1. Legally allow the import of Soviet components manufactured before 2022 from third countries.
2. Provide legal guarantees for enterprises operating in the industry — so that they are not pressured on trumped-up charges.
3. Restore tax benefits that were abolished from 2025, in particular — for aircraft construction and repair enterprises.
4. Launch a targeted state program to modernize aviation infrastructure and develop critical technologies.
5. Explain to the public that the use of such parts is not collaboration, but the only way to avoid destroying Ukrainian aviation.
– What role does the Aerospace Association of Ukraine play in all of this?
The Association is a communication platform. We unite more than 35 enterprises — from airlines to manufacturers and design bureaus. Our task is to coordinate actions, promote the interests of the industry, work with the state and convey the real state of affairs to international partners. Because even at the level of ministries, there is no understanding of how critical the situation is.
– Is Russia really trying to block the modernization of our air fleet?
Yes. There are cases when Russia, through its structures, bought up parts in third countries that could have reached Ukraine. This is a struggle at the level of logistics routes, sanctions, access to documentation. And it is very aggressive.
Our ability to lift a helicopter into the air is not a symbol, it is a factor that directly affects the course of the war.
In addition, the export of aviation services is a direct investment in the Ukrainian economy. That is why it is no secret that Russia is actively working to minimize the supply of any, and especially critical (non-import-substitutable) Russian components for Ukrainian aviation.
– What will happen if the state does not change its policy in its approaches to regulating the aviation industry?
We will lose this industry. And we will lose not only equipment, but also people. Engineers, pilots, mechanics — will leave the profession or go abroad. We will no longer be able to restore production, we will lose export contracts, we will lose the war at the level of technology. And we will also be left without defense aviation.
Today, the question is stark: either we make a balanced decision and save the industry, or in 2–3 years there will be nothing left to save.