The I-16 type 28 was a variant of the Soviet single-engine monoplane fighter developed in the 1930s by the Experimental Design Bureau of aircraft designer Nikolai Polikarpov. The I-16 was one of the world’s first mass-produced monoplane fighters with retractable landing gear. Production of the type 28 began in 1939. Like the I-16 type 24, it was equipped with an M-63 engine. However, it had more powerful armament. Instead of ShKAS machine guns, it was fitted with ShVAK cannons mounted in the wings. Over a hundred I-16 type 28s were built between 1938 and 1939. These fighters were used by the Red Army Air Force during the Khalkhin Gol battles, as well as during the Great Patriotic War.

The I-16 type 28 has been in the game since the start of the Open Beta Test prior to Update 1.27. In combat, the aircraft is virtually identical to the I-16 type 27: its suspended armament allows it to destroy ground targets, including enemy armored vehicles. However, the I-16 is much better suited for dogfights due to its excellent maneuverability, good armament, and decent climb rate. Conversely, the aircraft’s armor and survivability leave much to be desired; the 6-mm armor plate does not provide reliable protection. Another drawback is the aircraft's speed; fighters, especially German ones, can easily outrun the I-16 in level flight.