Light aircraft insurance in Moldova: the new SDR limits

In aviation, an insurance policy is not judged only by its annual premium or by the large amount printed on the certificate. For pilots, aircraft owners and general aviation operators, the question that matters is a different one: does the policy meet the legal minimum limits for the flight you are making?

In the Republic of Moldova, civil liability and the minimum insurance requirements for air carriers and aircraft operators are governed by Law no. 118/2020. It largely mirrors the European approach set out in Regulation (EC) No 785/2004, the act that lays down the minimum insurance requirements for aircraft in the European Union.

Moldovan legislation was recently amended, and the changes came into force on 28 February 2025. For general aviation, the most important change is a higher minimum passenger limit for non-commercial operations with aircraft of up to 2,700 kg MTOM.

What MTOM and SDR mean

MTOM stands for Maximum Take-Off Mass, the highest mass at which the aircraft is certified to take off. It is not what the aircraft actually weighs on the day of the flight, but the maximum mass recorded in its documents.

SDR (special drawing rights), or DST in Romanian (Drepturi Speciale de Tragere), is a unit of account defined by the International Monetary Fund. In aviation, many liability limits are expressed in SDR rather than in euro or dollars, because the SDR reflects a basket of international currencies and is updated over time.

This is why a policy issued in euro has to be checked against the value of the SDR on the date it is issued or checked. An amount that looks sufficient today may fall short if the SDR rises against the euro.

The new passenger limit in Moldova

For non-commercial operations in aircraft with an MTOM of 2,700 kg or less, the minimum passenger insurance limit in Moldova is now:

This is a significant change. Previously, this category used a threshold of 100,000 SDR per passenger. The new limit of 151,880 SDR reflects the international update of the liability limits in the Montreal Convention.

For pilots and aircraft owners, the practical takeaway is simple: if the policy shows only 100,000 SDR, or a euro amount below the equivalent of 151,880 SDR per passenger, it needs to be checked again.

Passenger or crew member?

Under Regulation (EC) No 785/2004, a passenger is any person on board with the operator's consent, except members of the flight or cabin crew who are actually on duty.

This means that anyone on board must be treated as a passenger unless they have a real operational role. What counts is not only how they are listed in the flight plan, but what they actually do during the flight. Unless they are a student pilot, an instructor, an examiner, a technician or someone else with clear operational duties, they must be covered as a passenger.

The distinction matters if there is an accident. If the insurer finds that someone was declared a crew member artificially, just to avoid passenger cover, the claim payment may be disputed.

Moldova vs the EU and other countries

In the European Union, the general rule is set by Regulation (EC) No 785/2004. For passengers, the standard limit is 250,000 SDR per passenger.

However, for non-commercial operations with aircraft of up to 2,700 kg MTOM, member states may allow a lower limit, but not less than 100,000 SDR per passenger.

Some countries have used this derogation, while others keep the standard limit. Moldova has taken a position of its own: for this category it has set a minimum limit of 151,880 SDR per passenger.

The euro amounts are approximate and should be updated using the applicable SDR rate.

Caution: compliant in Moldova does not automatically mean compliant in the EU

One point that matters a great deal to pilots who fly internationally is the gap between Moldova's requirements and the EU's requirements for third-party liability.

In Moldova, for certain local general aviation operations, the limit for damage caused to third parties on the ground can be much lower. In the EU, however, Regulation 785/2004 sets much higher limits, depending on MTOM.

So a policy that is sufficient for local flights in Moldova may not be enough for flights to Romania, Poland, Germany, France or other EU countries.

If the policy contains wording such as "EUR 120,000 for damage caused to third parties on the ground", look at this limit carefully. For flights in the EU, a sub-limit like this is below the European minimum even for the lightest category of aircraft.

What a pilot should check before flying

For a practical check, pilots and aircraft owners should look at the following points in their policy:

Third-party limits are calculated according to MTOM.

Is a limit per passenger stated?

The limit must apply per passenger, not only per occurrence.

Is the limit expressed in SDR, or as a sufficient equivalent in EUR?

The SDR fluctuates, and the euro amount has to cover the legal threshold.

Are there sub-limits for third parties on the ground?

A sub-limit can make the policy insufficient for the EU.

Is the territory where you fly covered?

Moldova, the EU, EASA or other countries may have different requirements.

What correct policy wording looks like

In Moldova, for an aircraft with an MTOM of 2,700 kg or less used for non-commercial flights, clear wording could be:

Passenger Legal Liability: not less than 151,880 SDR per passenger for non-commercial operations with aircraft of 2,700 kg MTOM or less, in accordance with the applicable legislation of the Republic of Moldova.

For flights in the EU, the certificate should also include wording such as:

Third Party Legal Liability: not less than the minimum amount required under Article 7 of Regulation (EC) No 785/2004, according to the aircraft MTOM, per accident and for each and every aircraft.

If the policy uses a combined limit, the wording could be:

Combined Single Limit for Third Party and Passenger Legal Liability, per occurrence, in compliance with the applicable aviation insurance requirements.

What matters is that the combined limit is high enough for every requirement that applies, passengers and third parties included.

Conclusion

The amendment to Law no. 118/2020 means that pilots and aircraft owners in Moldova need to check their insurance policies more carefully. For non-commercial flights with aircraft of up to 2,700 kg MTOM, the minimum passenger limit is now 151,880 SDR per passenger (higher, which also means a more expensive premium).

This limit should not be confused with third-party liability, nor with the EU requirements for international flights. For flights in EU/EASA airspace, third-party limits can be much higher and depend strictly on MTOM.

Our advice at iAsig is to check your policy not just by its total amount in euro, but against four elements: MTOM, the limit per passenger, the third-party limit and the territory covered. In aviation, a good policy is not the cheapest one, but the one that is still valid at the exact moment you need it.

Main sources: Civil Aviation Authority of the Republic of Moldova, Law no. 118/2020, Regulation (EC) No 785/2004