Article 6 is quoted as the direct special rule for a paraglider pilot.
Why this is a useful start
Why this helps
Article 22(3)(1) is cited correctly as a separate exception, not as Article 22(2)(1).
The older 79/2017 VASP rulebook and its mass wording are kept as a transition and compatibility question.
The term in plain language
Vanaerodromsko slijetanje i polijetanje means landing and take-off outside an aerodrome. It is an aviation-location question. It is not a synonym for airspace permission, landowner consent, pilot qualification, passenger consent, or a tourism-service license.
Read Article 22 in order
The new Air Transport Law should be read in sequence:
- Article 22(1) sets the ordinary aerodrome rule.
- Article 22(2) describes outside-aerodrome use with ACV approval for the cases to which that framework applies.
- Article 22(3)(1) says the approval rule does not apply to aircraft whose landing place, because of their characteristics, cannot be determined in advance. Other items cover emergency, medical, search and rescue, firefighting, military, and special-purpose operations.
- Article 22(4) and following paragraphs describe the approval and responsibility structure for the remaining cases.
That sequence matters. The law does not say “every movement outside an aerodrome is automatically the same.” It creates a general structure and exceptions.
Then read the special paraglider rule
Article 6 of the paraglider rulebook says directly:
“Pilotu paraglajdera nije potrebno odobrenje za vanaerodromsko slijetanje i polijetanje paraglajderom.”
That is the clearest text in the current source set for the narrow VASP question. It should be quoted accurately and then bounded. The rulebook also imposes pilot-document, safety, tandem, and passenger-information requirements; it does not transform a paraglider into an unregulated activity.
Planned landing is not the same as guaranteed landing
A pilot may plan to land in a particular field. That practical plan does not necessarily mean the characteristics of a paraglider allow the landing place to be determined or guaranteed in advance in the sense used by Article 22(3)(1).
This distinction is useful for analysis, but it is not presented as established court or ACV interpretation. A recurring commercial operation with a defined landing area should therefore not rely only on the Article 22(3)(1) exception. It must be read with Article 6, the actual operation, and current authority practice.
The older 79/2017 rulebook
The ACV legislation index still publishes the Rulebook on outside-aerodrome landing and take-off, adopted in 2017. Its text contains older exclusions, including aircraft for which the landing place cannot be determined in advance and an operational-mass threshold. After the new law, that wording should be treated as a transition and compatibility question until current ACV application is confirmed. It is not a safe standalone argument that every paraglider is exempt because of mass.
Three separate checks
| Check | Practical question |
|---|---|
| VASP | Is the outside-aerodrome approval framework engaged for this aircraft and operation? |
| Airspace | May this flight use this airspace, at this time, under current restrictions and procedures? |
| Land / site | May the pilot launch or land on this particular land, and under what local conditions? |
Add the pilot and passenger qualification check, the weather decision, and the commercial/tourism or event check where the facts require them.
Source status
Primary routes: the Air Transport Law, the paraglider rulebook, and the ACV legislation index. The public ACV paraglider reminder confirms that valid documents, technical equipment, suitable weather, locations, distances, and airspace still matter.
This is a controlled draft, last source review 30 August 2026. It does not replace a formal ACV answer for a named operation.
Quick answers
Quick answers
What is VASP?
VASP is the Montenegrin abbreviation for outside-aerodrome take-off and landing: vanaerodromsko slijetanje i polijetanje.
Does Article 6 say a paraglider pilot needs VASP approval?
It says: “Pilotu paraglajdera nije potrebno odobrenje za vanaerodromsko slijetanje i polijetanje paraglajderom.” That sentence is a strong textual basis, not a general flight permission.
Does a planned landing field remove the Article 22 issue?
Not automatically. A planned field and an aircraft whose landing place can be determined or guaranteed in advance are not necessarily the same legal fact. This is an interpretation that needs careful application to the operation.
What are the three permissions to keep apart?
VASP approval, airspace use, and land or site permission are separate. A conclusion on one does not grant the other two.
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