The German customs authority’s Financial Control of Undeclared Work (FKS) carried out coordinated inspections at multiple airports last week, examining 13 wet-lease flights for possible breaches of German labour and social-security law. Details of the operation were released on 15 September in an official bulletin and reported by AOL/News.de. Wet-leasing allows airlines to rent an aircraft complete with crew from another carrier—an increasingly common practice amid summer capacity crunches. While legal, the model often involves cross-border contracts that can obscure employer obligations. During the raid, investigators interviewed cockpit and cabin crews, reviewed contracts and payroll records, and found preliminary evidence of bogus self-employment, unlawful temporary-agency work and potential minimum-wage violations. The sweep was conducted in partnership with the European Labour Authority (ELA) and enforcement bodies from Ireland, Croatia, Lithuania and the Czech Republic, underscoring the EU’s growing focus on fair mobility in aviation. Parallel checks took place the same day in Greece and Lithuania, with German officials participating remotely. For airlines operating to, from or within Germany, the message is clear: even short-term wet-lease or ACMI (Aircraft, Crew, Maintenance, Insurance) arrangements must comply with German Posted-Workers Act requirements, including documentation in German and real-time availability of social-insurance evidence. Non-compliance can trigger fines of up to €500 000 per worker and jeopardise future slot allocations. Travel-management companies should alert clients that crew rotations may face spot checks this autumn, potentially delaying flight departures. Employers seconding technical staff to line-maintenance providers at German airports should also prepare A1 certificates and wage records for on-site inspection.
