Zeynep Gizem OzpinarAbove the Aegean lies an imaginary boundary that Athens has imposed for years, treating a line drawn for civil aviation as a unilateral declaration of sovereignty.
On that basis, the Greek General Staff regularly issues “violations and infringements” bulletins, systematically labelling Turkish aircraft activities that comply with international law as “airspace violations”.
Greek media carry the same framing in the same language, and a 10-nautical-mile airspace claim, resting on no international treaty, is planted in the public mind day after day.
This pattern produced its most recent example a few days ago.
On October 5, 2026, two Turkish F-16s came into close contact with Greek fighter jets off Meis.
Greek authorities announced a tally of seven aircraft for that day (two armed F-16s, one maritime patrol aircraft and four unmanned aerial vehicles) and released the figures as “seven FIR infringements and nine violations of national airspace”.
Those figures were released on the eve of US Secretary of State Marco Rubio’s visit to Athens on 6 October, and a fresh “15 violations” bulletin was announced on the day of the visit.
Yet flight information region (FIR) responsibility and sovereignty over national airspace belong to different categories. Turkish aircraft fly within the Athens FIR while remaining in international airspace, and Athens counts that airspace as its own on a legally invalid basis.
Greece thereby merges two separate categories under a single heading of sovereignty violation in its political discourse, keeping its maximalist claim alive.
This is precisely where the real issue surfaces: a flight information region, which carries a technical aviation responsibility, is being turned into a state boundary in political discourse and into propaganda against Türkiye.
Limits drawn by international law
Sovereignty over national airspace finds its legal basis in the 1944 Convention on International Civil Aviation.
Article 1 affirms that every state has complete and exclusive sovereignty over the airspace above its territory, and Article 2 defines “territory” as the land areas and the adjacent territorial waters under that state’s sovereignty. The extent of airspace is therefore tied to the extent of territorial waters.
That principle of sovereignty offers no basis for attributing sovereignty to FIRs responsible for providing air traffic services in international airspace.
An official working paper (A35-WP/109) submitted by the United States to the 35th Session of the Assembly of ICAO (International Civil Aviation Organization) states that FIR arrangements bear no direct relation to sovereignty, that delegating air traffic service responsibility to another state does not derogate from national sovereignty, and that the authority of the state providing that service is limited to technical and operational considerations.
The paper grounds these findings in ICAO Annex 11, which governs air traffic services.
Air traffic service responsibility in those parts of the Athens FIR that cover international airspace therefore confers no right on Greece to establish sovereignty over those areas or to require prior flight plans from state aircraft.
This is the legal distinction on which Türkiye’s objection rests: air traffic service responsibility is not equated with sovereign authority, and its Ministry of Foreign Affairs records plainly state that “there is no such concept” as a “FIR violation”.
Türkiye’s refusal to meet the flight plan request also rests on the Convention itself. Article 3 states that the Convention applies to civil aircraft and not to state aircraft, so no flight-plan obligation arises for military aircraft.
That same article establishes the authorisation requirement for flights over another state's territory, and the band between 6 and 10 nautical miles falls outside the definition of territory in Article 2.
As for the provision Greek military authorities invoke, it obliges states, when issuing regulations for their own state aircraft, to have due regard for the safety of civil aircraft navigation.
It gives no state the authority to request another's flight plans.
Athens’ own official statements carry the argument to a more striking point. Greece’s Ministry of Foreign Affairs states plainly on its “Athens FIR” page that the FIR arrangement does not concern sovereignty; it concerns only jurisdiction.
Even so, statements Greek military authorities publish under the heading of FIR violation systematically blur the distinction between air traffic service responsibility and sovereignty over national airspace.
On its own page of terms, the General Staff defines national airspace as 10 nautical miles based on a 1931 decree and states that entry into the Athens FIR without a flight plan counts as an infringement.
Two institutions of the same state tell two different versions of the law on the same question. Through military bulletins, a responsibility officially acknowledged to bear no relation to sovereignty is converted into a stream of data that feeds a claim of sovereignty.
This claim traces back to a decree that entered into force in 1931.
Its title in the United Nations repository of national legislation on the law of the sea reveals the nature of the instrument, which defines the extent of territorial waters for the purposes of aviation and the control thereof and fixes the territorial waters referred to in Civil Aviation Act No. 5017 at 10 nautical miles from the coast.
Greece’s actual territorial waters at that date measured 3 nautical miles.
When Athens extended them to 6 nautical miles in 1936, it retained the 10-mile figure devised for aviation purposes, creating a 4-mile gap between sovereignty at sea and airspace, one that has lasted to this day.
One territorial sea for aviation, another for seafaring…
The Greek Ministry of Foreign Affairs recounts how the claim was promulgated on its own website. According to the ministry, the 10-mile limit was entered into aeronautical information publications and maps; the ministry submitted the maps to ICAO in 1955, and the minutes of the 1958 regional meeting referred to them.
Every document offered as the basis of a sovereignty boundary consists of domestic legislation and technical aviation records, and none of them carries the character of a treaty that establishes a boundary.
Türkiye rejects this claim.
Its Ministry of Foreign Affairs records that the band between 6 and 10 nautical miles forms part of international airspace, describes the Greek thesis as arbitrary, and defines it as an attempt to reduce the international airspace of the Aegean by 50 percent.
Indeed, a claim to airspace wider than the territorial waters beneath it finds no basis in the Convention or in general practice.
One of Athens’ closest allies has confirmed this maximalist claim's legal weakness through its official position.
A report prepared under the Eastern Mediterranean Security and Energy Partnership Act of 2019 stated that Washington officially recognises airspace of up to 6 nautical miles in the Aegean and does not share the Greek government’s view.
The report also noted that Congress could not be provided with the list of Turkish violations it requested because the boundaries are disputed.
Airspace coinciding with territorial waters is settled international practice, and Greece’s thesis falls outside it.
A claim resting on a domestic decree and unrecognised internationally amounts to nothing more than a unilateral, maximalist political choice.
Narrative of victimhood
When Athens presents its legal disputes with Türkiye to international opinion, it positions itself as the party whose sovereignty and security are under threat, and it has turned this into something close to a policy.
By framing the Aegean disagreements as a challenge to Greece’s rights, this approach equates Türkiye’s legal objections with threats and places Athens’ theses at the centre of the debate.
Official statements from the Greek Ministry of Foreign Affairs regarding disputes in Turkish-Greek relations provide clear examples of this approach.
On issues such as Aegean airspace, the demilitarised status of the islands, maritime jurisdiction, and FIR responsibility, Athens presents its own theses as legal facts while characterising Türkiye’s objections as a challenge to Greek sovereignty.
This narrative merges disputes with different legal bases and different historical trajectories into a single discourse of “Turkish pressure”.
This pushes Greece’s own maximalist choices into the background and automatically recasts Türkiye’s objections, grounded in international law, as problematic conduct.
Carrying this discourse to the European Union level is also politically striking. The European Commission’s November 4, 2025 Türkiye report offers a current example of bilateral disputes entering the language of an institutional text.
That report records that Türkiye has conducted no unauthorised flights over Greek islands since 2023. Its overall narrative, however, treats the Aegean disputes through Greece’s claims and lends Athens’ theses an institutional weight they have not earned.
Greece continues to broaden its political support for its theses by bringing bilateral disputes onto the EU agenda. Using EU membership for that purpose does nothing to turn Athens’ claims into theses that international law accepts.
Athens’ avoidance of judicial settlement on this question marks the weakest point in the narrative. Greece’s January 14, 2015 declaration recognising the International Court of Justice's compulsory jurisdiction excludes from the Court’s jurisdiction disputes concerning state boundaries or sovereignty over its territory, and, in framing that exception, expressly lists disputes over the breadth and limits of its territorial sea and airspace.
A party that claims its sovereignty has been violated has, by its own hand, closed off the compulsory judicial route that would determine where that sovereignty's boundary runs.
Confidence in a legal position does not require shielding it from review.
Resolving the Aegean disputes requires a consistent assessment based on the relevant international instruments and the parties' legal grounds.
Athens needs to stop manufacturing tension over imaginary boundaries; otherwise, no genuine ground for dialogue in the Aegean can be established, even in the long term.
