Most people in the aviation world know that it's legal to fly a Super Cub without a radio in the US. Is it legal in other parts of the world, specifically Germany?

I stumbled across this section in a copy of the German AIP VFR:

GEN 1-12 Radio and Air Navigation Equipment of Aircraft (NfL II-11/05)


  1. Radio and air navigation equipment for VFR flights

(1) For VFR flights, aeroplanes, rotorcraft, powered gliders, gliders, aerodynamically controlled ultralight aircraft, gyrocopters, airships, and free balloons shall be equipped with one VHF transceiver covering at least those frequencies in the range 118.000 to 136.975 MHz that are required for the planned flight; the transmitter output power and receiver sensitivity shall be at least such as to ensure clear radio-telephony communication with the ATC and AIS units, taking into account the operational characteristics of the aircraft and the route flown.


(3) Para 1 does not apply to flights at aerodromes without an ATC unit which are conducted during the day and which do not leave the vicinity of the departure aerodrome (Art. 3a para 3 of the German Aviation Regulation [LuftVO]). Local regulations of the responsible authority of a Land (Art. 21a para 1 of the German Aviation Regulation [LuftVO]) shall remain unaffected.

Does this mean cross country flight without a radio is illegal in Germany? Or is the part "shall be equipped with one VHF transceiver covering at least those frequencies ... that required for the planned flight" a loophole meaning you can go as long as you don't cross into any areas where radio is required? (thus effectively rendering 3.(3) above superfluous)

I understand that as long as you remain in class E and G airspace, I don't actually have to talk to anyone; would I still be legally required to carry a radio?

Ignore the other airspace classes for now, as C has mandatory radio communication and F has its own can-of-worms rules in Germany, and neither A or B are used at all (class F is about to be discontinued and replaced with class G and a Radio Mandatory Zone in accordance with EU regulation 923/2012 "SERA")

  • $\begingroup$ Where did you read that class F in Germany has mandatory radio communication? This only applies to IFR flights, not to VFR. $\endgroup$ – SentryRaven Jul 1 '14 at 11:05
  • $\begingroup$ @SentryRaven you're right. Sorry. There's something about having mandatory radio monitoring when an "F(HX)" is not active or something. I'm not sure, I've removed that part. $\endgroup$ – falstro Jul 1 '14 at 11:19
  • $\begingroup$ Even when the F(HX) is active, you are not required to be in contact with the AFIS or ATC. F(HX) is uncontrolled airspace and does not require a clearance, as long as you are operating under VFR. Check this: gesetze-im-internet.de/luftvo/anlage_5_75.html $\endgroup$ – SentryRaven Jul 1 '14 at 11:27
  • $\begingroup$ @SentryRaven exactly, not when it's active, but when it's inactive you're required to monitor the frequency in case it is activated. Or something like that. Or maybe not. I'm not sure :) $\endgroup$ – falstro Jul 1 '14 at 11:28
  • $\begingroup$ No, not at all. It says "entfällt" where VFR flights are mentioned, there is no requirement for me to monitor the frequency or be in contact. F(HX) are technically only there to provide separation between IFR/IFR and to ensure that weather minima are met. If I fly around in CAVOK, I pretty much couldn't care less if the F(HX) is active or not. This is the legal theory, but not good airmanship. $\endgroup$ – SentryRaven Jul 1 '14 at 11:31

paragraph 3 clearly states that the only exception to the requirement to carry a radio set is when you're not leaving the immediate vicinity of the airfield, and then only when there's no ATC coverage.
That effectively means you can fly a few circuits at low altitude over a small field, but even then many of those would be close enough to a larger airport that has ATC coverage that they'd be covered by that airport's ATC system rather than having their own.

The only "loophole" would be if you could convince authorities that your flight wasn't planned, good luck with that.
Effectively that'd most likely mean you're having to prove to them that you went to the airfield without wanting to fly, just jumped into an aircraft, took off, and started zooming around the sky. Something that's so far out there nobody's going to buy it.

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    $\begingroup$ It does say the "frequencies required for the planned flight", but airspace E and G has no required radio communication, thus no required frequencies? Although you could argue that you still need a VHF transceiver, it just doesn't have to work. :) $\endgroup$ – falstro Jul 1 '14 at 11:25
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    $\begingroup$ Each flight which leaves the vicinity of the airfield as described in Art21 LuftVO is a planned flight. And with this, you need to have radio equipment installed in the range of 118.000 to 136.975 MHz. $\endgroup$ – SentryRaven Jul 1 '14 at 11:33
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    $\begingroup$ @SentryRaven yes, I'm not contesting that the flight is planned, I'm asking about the "required frequencies" for said flight. Or is that not actually what the regulation says? $\endgroup$ – falstro Jul 1 '14 at 11:38
  • $\begingroup$ @falstro it means just that, you need a radio set capable of tuning in on any frequency you may encounter, and that includes emergency frequencies. And no, there's very little uncontrolled airspace in Europe, it's not the US. And you should know better than claiming "it just doesn't have to work". If it's on the aircraft, it should work. $\endgroup$ – jwenting Jul 1 '14 at 12:38
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    $\begingroup$ That's not true, there's a bunch of uncontrolled airspace in Europe. Except for control zones, controlled airspace very rarely reach below 1000 ft AGL. And just like in the US, class E covers everything above a certain altitude, in Germany, it's 2500 ft AGL unless lowered, e.g. to 1000 ft AGL. In contrast to the US there's no surface E in Germany, the only surface airspace are D-CTR, G and F, of which the first covers a very limited space around controlled airports, and the latter two are uncontrolled. And even so, E is controlled, you are still not required to use the radio. $\endgroup$ – falstro Jul 1 '14 at 12:46

"Does this mean cross country flight without a radio is illegal in Germany?"

I fly my glider in Germany with one of the many glider clubs in the country. This is correct, you must have a radio for non-local flights, and it doesn't matter if you think you don't have to talk to anyone. You have to have it, period, and if you think you found a loophole, just wait until an inspector decides to ramp check you after a flight. It doesn't have to be a permanently installed radio -- a handheld will do. If someone can afford an aircraft in Germany that can do cross-country flights but can't afford even a handheld radio, maybe that person should consider some other hobby.

  • $\begingroup$ Does this apply to hang gliders and paragliders? In the UK the radios these use (if any) are low power with a different frequency range to GA $\endgroup$ – Dave Gremlin Jun 11 '19 at 20:01
  • $\begingroup$ Yes, it does. If you have a radio that does not meet the German requirements, then you can't fly cross country until you beg, borrow or buy one. $\endgroup$ – Juan Jimenez Jun 12 '19 at 8:41

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