Restarting Flights: Ukraine’s Aviation Insurance Facility

On 10 September 2025, Boryspil International Airport announced that it had entered into strategic negotiations with the London insurance market to design a sustainable aviation insurance framework for Ukraine. According to the airport’s press release, the talks — held in London on 9 August 2025 with Willis Towers Watson (WTW) and leading international reinsurers, and coordinated by Ukraine’s Ministry for Development of Communities and Territories together with the State Aviation Administration — aimed to prepare a mechanism that would allow Ukraine’s skies to reopen for commercial flights in safe, controlled conditions once the war ends.

At first glance, the initiative appeared to be a step towards national recovery. In fact, it may signal something broader: the attempt to build a dedicated aviation restart facility, similar in spirit to the Unity Facility that Marsh developed for maritime insurance. WTW is now may testing whether a pooled reinsurance structure, backed by state participation, can be adapted for civil aviation.

This effort comes at a critical moment. The incursion of nineteen Russian drones into Polish airspace showed how quickly European skies can become contested. GPS interference incidents, including those affecting senior EU officials, underline that aviation risks spill beyond battlefields into civil airspace. In this environment, Ukraine’s project is not simply about restarting flights — it may be treated as creating a layered insurance model that can withstand wartime disruption and meet European regulatory standards.

The Boryspil–WTW initiative may therefore be more than a domestic experiment. Positioned by the airport itself as a pilot for Ukraine’s entire airport sector, it could also represent the first attempt to design an internationally recognized insurance facility for aviation in a high-risk environment. This step may set a precedent not only for Ukraine but for the wider region.

This article, therefore, proceeds from the immediate facts — Boryspil’s press release and the London negotiations — to the broader context of Ukraine’s closed skies. Any restart cannot simply revive the old model; it must be built anew to address three interlocking challenges. First, the insurance architecture must comply with the acquis of EU aviation law. Second, it must align with Ukraine’s obligations under the EU–Ukraine Common Aviation Area Agreement. Third, it must incorporate solutions to modern wartime risks, including drone incursions, cyber, and GPS interference. The task is not only to design an insurance facility, but also to specify where Ukrainian law requires amendment, so that the resulting framework is both credible for international reinsurers and recognized by European regulators.

On 24 February 2022, Ukraine officially closed all its flight information regions (FIRs) to civil aviation. The decision, formalized through NOTAMs and reinforced by the European Union Aviation Safety Agency (EASA) via a Conflict Zone Information Bulletin (CZIB), created a complete “Do Not Fly” status over the country. Unlike the years of localized conflict between 2014 and 2021, when air traffic continued with partial route restrictions despite the tragedy of MH17, the full-scale invasion became an unambiguous interruption of civil aviation.

The economic and legal shockwaves reached the market later that year. Western sanctions — imposed in response to Russia’s invasion — required leasing companies to terminate contracts with Russian airlines. Moscow retaliated by prohibiting the repossession of more than 400 foreign-owned aircraft, effectively holding them on Russian territory. This wartime decision created unprecedented difficulties for lessors and insurers, triggering multibillion-dollar claims under war-risk and contingent coverage and exposing the fragility of traditional insurance structures.

For the insurance community, these events illustrated a more profound shift. The closure of Ukraine’s skies, combined with politically motivated sanctions and retaliatory aircraft seizures, did not fit neatly into conventional categories of “war” or “peace.” Aviation insurers and reinsurers suddenly faced exposures that standard hull and liability policies could not capture.

The impact of GPS jamming in Northern Europe illustrates the scale of exposure. According to Sweden’s Transport Agency, incidents of GPS signal interference in the Baltic Sea have risen sharply: 55 cases were reported in 2023, 495 in 2024, and 733 already in 2025. Experts have traced the jamming sources to Russian territory. While the absolute numbers may appear modest, each incident can affect multiple flights, resulting in costly diversions, delays, and increased fuel consumption. For reinsurers, such events are no longer hypothetical, and they expect to integrate this category of risk into liability coverage explicitly.

In this environment, sanctions, asset seizures, cyber vulnerabilities, and hybrid hostilities blur the boundaries of insurability, compelling a fundamental redesign of coverage models.

Restarting Ukraine’s skies requires not just an insurance package but a regulatory foundation aligned with European standards. Aviation insurance obligations in the EU are defined primarily by Regulation (EC) No 785/2004 on insurance requirements for air carriers and aircraft operators, which mandates minimum insurance coverage for air carriers and aircraft operators to cover their liability for passengers, baggage, cargo, and third parties, including risks like war and terrorism. This regulation ensures a common standard for insurance across all EU Member States by setting specific minimum coverage amounts, such as 250,000 Special Drawing Rights (SDRs) per passenger. Ukraine, as a party to the Common Aviation Area Agreement (CAA), is obliged to approximate its legislation to these rules.

In practice, Ukraine has already moved in this direction. The State Aviation Administration adopted the Aviation Rules of Ukraine “Rules of Air Passenger and Baggage Carriage” on 26 November 2018, explicitly citing EU Regulation 785/2004 in its preamble. Section XXVI (“Obligations of the air carrier and compensation for damage”) initially prescribed a minimum passenger liability coverage of 250,000 SDRs, mirroring the EU requirement. However, following the UIA aircraft crash in Iran, the State Aviation Administration amended this provision (Order No. 1126 of 14 August 2020), reducing the minimum to 128,821 SDRs. Although this adjustment remained consistent with the Montreal Convention, which sets the lower threshold, it created a clear divergence from the higher EU standard. The move raised questions as to why alignment with EU Regulation 785/2004 was weakened, particularly given that Ukraine’s broader commitments under the Common Aviation Area Agreement anticipate complete harmonization with EU aviation law and that the general framework of Ukrainian aviation insurance requirements continues to prescribe 250,000 SDRs per passenger.

An equally important dimension of aviation insurance is third-party liability (TPL) — compensation for damage caused on the ground. Ukraine regulates this area through the Aviation Rules of Ukraine “Procedure and Conditions of Civil Aviation Risk Insurance” (Aviation Rules No. 768 (2023)), which replaced the earlier Cabinet of Ministers Resolution No. 676. 

For domestic flights Ukraine applies thresholds derived from ECAC Recommendation 25/1 (2002), such as 4.2 million SDR for an Embraer 190, compared to 150 million SDR under Regulation (EC) No 785/2004.  By contrast, for international flights, including those performed by Ukrainian operators into EU territory, Aviation Rules No. 768 explicitly require compliance with international agreements and the legislation of destination states. In practice, this means adhering to Regulation 785/2004, which has far higher thresholds and requires the compulsory inclusion of war and terrorism risks.

This dual-track system creates both opportunities and risks. On the one hand, Ukrainian operators enjoy lower insurance costs on domestic routes, a non-trivial relief in a depressed market. On the other, third parties in Ukraine receive far weaker protection than their EU counterparts, with potential compensation levels an order of magnitude lower. This asymmetry undermines the principle of uniform standards under the EU–Ukraine Common Aviation Area Agreement.

A further distinction lies in war-risk coverage. Under Regulation 785/2004, war and terrorism are part of compulsory insurance, subject only to temporary exclusions via the escape clause. In Ukraine, war-risk insurance for domestic flights remains entirely optional, left to contractual discretion. Even for international flights, the obligation arises only because foreign jurisdictions demand it, not because Ukraine embeds it in its own domestic framework.

This dual-track system lowers insurance costs on domestic routes but leaves third parties in Ukraine far less protected than their EU counterparts. It undermines the principle of a level playing field under the EU–Ukraine Common Aviation Area Agreement. While such divergence may appear to “encourage” the resumption of flights by reducing operator expenses, it risks deterring reinsurers and regulators. In this sense, the gap is not just a weakness but also an opportunity for reform, providing a clear path for Ukraine to align with EU standards and enhance its market credibility.

For airports, insurance programs typically cover property (terminals, runways, equipment), business interruption, and liability for accidents on airport premises. War and terrorism risks are usually placed under separate reinsurance clauses in international markets.

EU law does not prescribe direct statutory minimums for airport liability insurance. Instead, requirements are embedded in the certification framework of the European Union Aviation Safety Agency (EASA) and the standards of ICAO Annex 14 (Aerodromes). Both oblige airports to demonstrate adequate financial security, including liability cover, as a precondition for certification. In practice, this means that European airports must maintain levels of coverage consistent with Regulation (EC) No 785/2004 — often hundreds of millions of Special Drawing Rights (SDRs) — to satisfy certification requirements and maintain access to international traffic rights.

Ukraine has established its own framework through the Aviation Rules No. 768 (2023). These Rules introduced explicit requirements for airports to maintain liability insurance for damage caused to third parties.

The limits vary depending on the ICAO code of the aerodrome:

• Code E/F airports (Boryspil, Lviv, Odesa): 1.624 billion UAH (≈ €40 million).
• Code C/D airports: significantly lower thresholds.
• Small airfields, heliports, or A/B aerodromes: from 130,000 UAH up to 5 million UAH.

The divergence is not just numerical but systemic. ICAO Annex 14 does not prescribe absolute figures, but insists on adequate financial security as a condition of certification. EASA certification practice interprets this as requiring alignment with the robust liability thresholds of Regulation 785/2004. By contrast, Ukraine has codified fixed sums that fall far below international benchmarks, creating the risk that Ukrainian airports, even if insured domestically, would not meet the adequacy test in a European certification review.

The second gap lies in war-risk coverage. Under Regulation 785/2004, war and terrorism risks are formally part of the scope of compulsory insurance. However, insurers may temporarily exclude them in case of a significant deterioration of circumstances (the so-called escape clause). This establishes a legal presumption that such risks must be covered. In Ukraine, however, war-risk coverage is entirely optional and left to contractual discretion.

The result is a structural divergence. Ukraine formally requires airports to hold liability insurance. Still, the prescribed minimums are an order of magnitude lower than European practice, and the complete absence of mandatory war-risk coverage leaves third parties and airport operators exposed in precisely the scenarios most likely to materialize. For a restart, this creates a dual challenge:

• Regulatory harmonization — raising thresholds and integrating war-risk coverage in line with Regulation 785/2004 and ICAO/EASA certification standards.
• Market acceptance — convincing international reinsurers and European regulators that Ukrainian airports can meet the same standards of financial security as EU airports.

Without closing this gap, Ukraine risks building a domestic insurance framework that is legally valid at home but not credible abroad — a contradiction that could obstruct the resumption of international flights.

From this perspective, it is highly plausible that the issue of liability thresholds was central to Boryspil Airport’s September 2025 discussions with insurers and reinsurers in London. International underwriters would be quick to highlight that Ukraine’s current Aviation Rules No. 768 (2023) set liability minima far below the benchmarks embedded in Regulation 785/2004 and applied in EASA certification practice.

This regulatory divergence presents a paradox. On the one hand, lower thresholds reduce operators’ premium costs. They may therefore appear to “encourage” the resumption of flights by making restart financially more attainable for Ukrainian airports and carriers. On the other hand, the same divergence undermines credibility with reinsurers and European regulators, who expect harmonization with EU standards as a precondition for market access.

In practice, therefore, any restart framework will have to confront this misalignment directly. International insurers are unlikely to commit capacity to a Ukrainian facility without assurances that liability coverage will converge with EU norms. What may appear domestically as a pragmatic easing of operator costs could, internationally, be interpreted as a systemic gap, and hence an obstacle rather than an enabler of flight resumption. These regulatory discrepancies are not just technical gaps — they are precisely the issues that reinsurers will expect a restart facility to address before committing capacity.

For aircraft lessors, the central concern is asset protection and repossession rights. Standard leasing practice requires operators to maintain hull and liability coverage naming the lessor as an additional insured, ensuring that the lessor’s financial interest in the aircraft is protected and that repossession is possible in case of default.

Regulation (EC) No 785/2004 does not directly regulate lessors. Its provisions apply to operators, not owners. Nevertheless, European practice indirectly protects lessors: delivery of aircraft to an EU operator cannot proceed without proof of compliant insurance, and lessors rely on the robustness of EU enforcement mechanisms to secure repossession if insurance or operational obligations are breached.

In Ukraine, the framework is weaker. The country has acceded to the Cape Town Convention and its Aircraft Protocol, which introduced the Irrevocable Deregistration and Export Request Authorization (IDERA) mechanism, designed to simplify repossession. However, implementation is limited:

• IDERA is recorded only with the State Aviation Administration of Ukraine, but is not automatically recognized by customs and border authorities. This gap means that, in practice, deregistration may be possible on paper, but physical export can still be blocked.
• Court practice in Ukraine remains inconsistent. While there are isolated cases involving detained or disputed aircraft — often in the context of bankruptcy or an operator’s default under a lease — there is no established jurisprudence ensuring swift enforcement of lessors’ rights under the Cape Town Convention. As a result, lessors typically rely on foreign courts, most often in London or New York, to pursue claims. Yet even when a foreign judgment or arbitral award is recognized in Ukraine, enforcement in the context of aircraft repossession remains problematic. Obtaining a paper enforcement order is rarely the issue; the real obstacle is that such an order does not guarantee physical access to the aircraft, which can remain blocked by customs, airport authorities, or competing creditor claims. This gap undermines the very efficiency that the Cape Town system and the IDERA mechanism were designed to provide and remains a core barrier to restoring lessor confidence in the Ukrainian market.

This regulatory weakness matters for the restart. If Ukraine wants to attract foreign-leased aircraft back into its fleet, insurers and lessors alike will demand credible repossession mechanisms. Without them, insurers will either increase premiums sharply to reflect enforcement risk or decline cover altogether.

The restart challenge is therefore twofold:

• Legal harmonization — Ukraine must strengthen its implementation of the Cape Town Convention, ensuring that IDERA is binding not only on the aviation registry but also on customs and law enforcement agencies.
• Judicial practice — Because Ukrainian courts have little experience in recognizing and enforcing lessor rights swiftly and transparently, repossession cases remain unpredictable. To reduce uncertainty in situations of operator default or insolvency, Ukraine could adopt two complementary approaches. First, it would be advisable to draw on the jurisprudence of more experienced jurisdictions — such as English or New York courts — by issuing interpretative recommendations or judicial training materials that reflect international leasing standards. Second, Ukraine could consider legislative specialization by assigning repossession disputes to a specific court, similar to the way the Kyiv Court of Appeal is designated to hear recognition and enforcement of foreign arbitral awards. Concentrating these cases in one forum would promote consistency, accelerate proceedings, and send a clear signal to lessors that Ukraine is serious about harmonizing its enforcement practice with international norms.

Unless these steps are taken, Ukraine risks not a shortage of insurance capacity but a shortage of aircraft themselves, as lessors may prefer to keep their assets out of the jurisdiction until enforcement standards are aligned with international expectations. Unless Ukraine strengthens Cape Town enforcement and guarantees repossession rights, lessors will insist that the restart facility include contractual protections and state-backed assurances.

Air Navigation Service Providers (ANSPs) are organizations that provide air navigation services en route and within airport (aerodrome) zones in the airspace of Ukraine, as well as in international airspace over the high seas, where, under international agreements, Ukraine bears responsibility for flight safety and the organization of air traffic services. In practice, this refers primarily to UkSATSE, as well as to airport-based air traffic control services. They carry liability for service interruptions, air traffic management errors, and operational incidents that may cause damage to aircraft, passengers, or third parties on the ground.

In Europe, Eurocontrol standards and the EASA certification framework require ANSPs to demonstrate adequate liability insurance as a condition of their operating approval. While EU law does not prescribe fixed sums, adequacy is assessed against catastrophic scenarios, and regulators expect that war-risk coverage is integrated into compulsory insurance.

ANSPs, such as UkSATSE and airport-based control services, are explicitly covered under Aviation Rules No. 768 (2023). The rules set a threshold of 300 million SDR for UkSATSE, broadly consistent with international expectations, but only 5 million UAH (≈€120,000) for airport-based ANSPs. This disparity creates a structural vulnerability: one systemic provider is adequately insured, while local providers remain critically underinsured. Beyond air traffic management, other service providers, such as ground handling and fuel operators, also create potential exposures.

It is vital to distinguish ANSPs from third-party service providers such as ground handling or fuel operators. While aviation-specific insurance rules do not cover the latter, they too represent potential “weak links” in the insurance chain — and thus require integration into any restart facility.

In addition to airlines, airports, and ANSPs, the aviation services chain also includes third parties that are not air navigation service providers but directly affect the safety and continuity of aviation operations. These include ground handling companies, fuel operators, technical service providers, and other contractors.

In the EU, their liability is usually addressed through:

• civil law and contractual obligations (with airports and airlines), and
• professional liability insurance, required as a condition of market access or certification.

In Ukraine, however, there is no unified system in place that establishes minimum insurance thresholds for these categories of providers. Each contractor effectively determines the scope of its own coverage, creating a potential “weak link” in the insurance architecture: one inadequately insured subcontractor could complicate compensation in the event of an accident or incident.

For any restart facility, third-party coverage must be explicitly integrated into the overall model. Without transparent and enforceable requirements for ground handlers, fuel suppliers, and other service providers, international reinsurers are likely to see the Ukrainian market as incomplete, with excessive risks concentrated at the points of interaction between core aviation participants.

This gap means that even if airlines, airports, and ANSPs are brought into alignment with EU standards, the absence of robust rules for third-party providers could undermine the credibility of Ukraine’s entire restart facility in the eyes of the insurance market.

All of the instruments listed below already appear in the Annex to the EU–Ukraine Common Aviation Area Agreement (CAA), making their implementation not optional but legally binding over time:

• Regulation (EC) No 785/2004: Insurance requirements for air carriers and operators.
• Regulation (EC) No 1008/2008: Licensing rules, linking validity of an operating license to continuous insurance compliance.
• Regulation (EU) 2018/1139 (EASA Basic Regulation): Certification of operators, airports, and ANSPs with adequate liability cover.

Regulation (EC) No 785/2004 (Insurance Requirements for Air Carriers and Aircraft Operators)

What it requires: Minimum insurance levels for passengers (250,000 SDRs), baggage, cargo, and third parties; compulsory coverage of war and terrorism risks (with temporary exclusion possible).

Ukraine’s status: Implemented in part through the 2018 Aviation Rules on passenger and baggage carriage, but thresholds were lowered in 2020 (128,821 SDRs per passenger), diverging from the EU standard; TPL limits remain far below EU benchmarks; war-risk coverage is optional.

To implement: Restore alignment at 250,000 SDRs for passengers, raise TPL limits in line with EU thresholds, and integrate war-risk coverage into compulsory insurance.

Regulation (EC) No 1008/2008 (Common Rules for the Operation of Air Services)

What it requires: Insurance is a condition for granting and holding an operating license; operators must provide continuous proof of coverage throughout the license validity.

Ukraine’s status: The  Air Code of Ukraine (2011), Section XVI “Aviation Insurance” expressly provides that aviation entities are obliged to insure crew, passengers, third parties, aircraft, and airport/ANSP liability (Articles 117–118). Thus, compulsory aviation insurance is embedded at the level of primary legislation. However, secondary regulation is fragmented:

• The Licensing Conditions for passenger and dangerous goods transport by air (Order No. 134 of 10 March 2017) do not contain any explicit requirement for insurance.
• The Rules on granting operators’ permission to depart from and arrive at Ukrainian airports ( Order No. 897/703 of 28 November 2005) require valid compulsory insurance policies as a condition for flight clearance.
• The Aviation Rules of Ukraine “Technical requirements and administrative procedures for flight operations in civil aviation” ( Order No. 682 of 5 July 2018) require a third-party liability insurance policy to be kept on board every aircraft engaged in operations.

These provisions exist but remain scattered and inconsistently linked to licensing. In practice, insurance compliance is not embedded as a condition for granting or maintaining an operating license, as required by Regulation 1008/2008.

To implement: Consolidate the regulatory framework by aligning secondary legislation with the Air Code, embedding explicit insurance requirements into the licensing process itself, and ensuring continuous oversight of insurance compliance by the State Aviation Administration.

Regulation (EU) 2018/1139 (EASA Basic Regulation)

What it requires: Certification of airports, ANSPs, and operators must include adequate liability insurance as part of safety oversight.

Ukraine’s status: Structural compatibility exists (Ukraine has certification systems for airports and ANSPs), but legislation does not explicitly embed insurance as part of certification.

To implement: Formalize insurance adequacy as a condition of certification and regulatory oversight for all aviation entities, in line with EASA practice.

All of the above instruments — Regulation (EC) No 785/2004, Regulation (EC) No 1008/2008, and Regulation (EU) 2018/1139 — are explicitly listed in the annexes to the EU–Ukraine Common Aviation Area Agreement signed in 2021. This means that Ukraine is already committed to approximating its legislation to these standards. The restart facility, therefore, cannot be seen as a temporary or ad hoc arrangement: it must be designed in a way that ensures compliance with the acquis, both to gain international recognition and to secure Ukraine’s eventual full integration into the European aviation market.

Airport insurance is not the same as airline insurance, and the concerns of lessors differ again. EU law recognizes these distinctions but unifies them under a common principle: compulsory minimum liability cover and transparent certification standards across all aviation actors. This ensures that, regardless of whether the insured party is an airport, an airline, or a lessor, the system guarantees a baseline of protection acceptable to regulators, insurers, and the traveling public.

For Ukraine, the implication is clear. Any restart facility must integrate a layered insurance architecture that covers carriers, airports, lessors, ANSPs, and service providers, with legal harmonization of the kind required by the EU acquis. Without transposing the relevant EU instruments into national law (Regulation 785/2004, Regulation 1008/2008, Regulation 2018/1139), Ukraine risks creating an insurance model that works domestically but lacks international recognition. Such a gap would undermine confidence among reinsurers, lessors, and European regulators, effectively blocking integration into the European Common Aviation Area and delaying the reopening of Ukraine’s skies.

Restarting civil aviation in Ukraine cannot rely on fragmented fixes. To attract reinsurers, leasing companies, and European regulators, the country needs a composite facility that reflects both the diversity of aviation risks and the principles of EU law. A workable model would rest on four pillars:

• State Participation as a Backstop

1. The state should act as a guarantor of last resort, providing a stop-loss mechanism to absorb catastrophic losses above market capacity.
2. Without a state backstop, international reinsurers are unlikely to deploy sufficient capacity in a high-risk environment.

• A Reinsurance Pool with International Brokers

1. Core risks (hull, liability, business interruption, war) should be ceded into a pooled facility coordinated by major international brokers.
2. The pool would aggregate risk across carriers, airports, lessors, and ANSPs, enabling diversification and clearer actuarial modelling.
3. Transparent participation by leading London and continental European reinsurers would be essential for credibility.

• Layered Architecture Across the Aviation Sector

• Airlines and passengers: Hull, passenger liability, baggage/cargo liability, with war-risk embedded in compulsory cover.
• Airports: Property, third-party liability, and business interruption, with war-risk coverage linked to certification.
• Lessors: Hull and repossession protection, explicitly tied to Cape Town/IDERA enforcement mechanisms recognized by customs and courts.
• ANSPs and service providers: Liability for operational accidents and war-risk, harmonized with Eurocontrol/EASA certification expectations.

Each layer must be compatible with EU minimum liability standards (Reg. 785/2004) and integrated into certification/licensing processes (Reg. 1008/2008, Reg. 2018/1139).

Phased Implementation:

• Phase 1: Limited cargo operations on low-risk western routes (e.g., Lviv, Uzhhorod).
• Phase 2: Controlled passenger operations with a narrow geographical scope.
• Phase 3: Full-scale reopening of Ukraine’s skies once market capacity and regulatory harmonization are secured.

Ukraine already has a precedent for creating a state-backed insurance mechanism in the maritime sector. In March 2023, Marsh, in cooperation with the UK Government, Lloyd’s, and leading international reinsurers, launched the Unity Facility to provide war-risk cover for ships exporting Ukrainian grain and other cargo through the Black Sea.

The model was simple but effective:

• Ukrainian state banks provided guarantees (a backstop), absorbing part of the catastrophic risk.
• This allowed international reinsurers to commit capacity through a pooled facility coordinated in London.
• As a result, coverage for maritime war risks — which had virtually disappeared from the private market — became available again, enabling Ukrainian exports to continue under safer and more predictable conditions.

Why this matters for aviation: the challenges are remarkably similar. Without a state backstop, private insurers are unlikely to provide capacity for Ukraine’s war-affected skies. But with government participation, international brokers and reinsurers can replicate the model — pooling risk across carriers, airports, lessors, and ANSPs. Just as the Unity Facility unlocked grain exports, a Restart Facility for aviation could unlock the reopening of Ukraine’s skies.

It is in this context that WTW’s current negotiations with Boryspil Airport and London reinsurers can be understood. Much like Marsh’s maritime initiative, WTW is exploring the creation of a pooled facility, backed by government participation, to deliver a sustainable model for aviation. In effect, Ukraine now has the opportunity to replicate the “Unity principle” for air transport.

Israel offers another precedent for insuring aviation in a high-risk environment. Facing decades of security threats and periodic missile or drone attacks, Israel developed a state-backed war-risk insurance scheme for its airlines. Under this model:

• The government provides guarantees for catastrophic war losses.
• Private insurers cover the baseline aviation risks, with war-risk premiums co-financed by the state.
• Airports and airspace remain operational even during hostilities, with only temporary closures in moments of acute attack.

The Israeli example shows that civil aviation can function under persistent threat, provided that insurance structures clearly allocate responsibilities between the market and the state. For Ukraine, adapting such a model would mean embedding permanent state participation in war-risk coverage, rather than treating it as a temporary or ad hoc measure.

Restarting Ukraine’s skies will require more than reopening airports or reactivating airlines. It will demand a layered insurance model that integrates carriers, airports, lessors, ANSPs, and third-party providers into a coherent structure, underpinned by EU-aligned legislation and credible reinsurance support.

Ukraine faces a choice: preserve a fragmented domestic system with lower thresholds that ease operator costs in the short term, or harmonize fully with EU standards and create a facility that the international market will accept. The latter is the only path to a sustainable restart — and potentially to setting a precedent for aviation insurance in other high-risk regions.