Frequently Asked Questions - Licensing Issues

Please select your question category

Search FAQs
View all frequently asked questions
View FAQ Tags
FAQs - Licensing Issues

The CAA have advised that, as well as Head of Training, for PPL applications they will accept CFI and FI as signatories.

For Commercial Pilots, the CAA have indicated that they wil accept a more Senior Commercial Pilot as signatory.

AOPA Comment:
7 Apr 2013 -






TAGS: certify, EASA

A member has advised that, although his UK ATPL(A) (which includes embedded IMCR privileges) was converted to a Part-FCL CPL, the CAA has refused to issue him with a valid IR(R).

This appears to stem from a recent policy change and needs to be reviewed with some urgency.  In accordance with previous policy, any UK professional aeroplane pilot licence shall, upon conversion, include a valid IR(R) with a validity period of 25 months from the date of conversion.

AOPA COMMENT: 7 Apr 2013 - CAA Head of Licensing and Training Standards has confirmed that UK (non-JAR) professional pilot licences include embedded IMCR privileges and that, when such licences are converted to part-FCL licences, such licences will indeed include an IR(R) valid for 25 months from the date of conversion.  The Licensing Team have been rebriefed accordingly. RESOLVED.

CAA IN-2012/136 explained the revised requirements for PPL/FEs to attend a seminar under FCL.1025(b)(2) and an associated Article 14(4) derogation which expired in November 2013.

No ATOs currently offer such seminars, although one is due to do so by the end of Feb 2013.
However, one AOPA IC member considers that organisation approved to conduct FE courses already have an embedded right to conduct such seminars for individual FEs.

Issue Solution: The CAA is requested to clarify whether organisations approved to conduct FE approval courses do, in fact, have the rights to fulfil the seminar requirements of FCL.1025(b)(2) for individual FE reauthorisation purposes

AOPA COMMENT: 7 Apr 2013 - Although OnTrack Aviation now offer such seminars, we have also requested that the CAA consider granting equivalence to the FCL.1025(b)(2) to those ATOs whose FIEs have approval to conduct initial FE(PPL) training and assessment of competence, perhaps as part of an individual’s formal FE revalidation process.


No direct conversion process has yet been defined for the direct conversion of an NPPL(SSEA) to Part-FCL PPL(A) SEP(L).  However, a similar process does exist for the conversion of an NPPL(SLMG) to Part-FCL PPL(A) TMG.

Chmn. NPPL P&SC considers that an NPPL(SSEA) holder should be able to convert the licence to a Part-FCL PPL(A) SEP(Land) without first needing to convert to a LAPL(A).

Initial response from the CAA is that, provided an applicant meets the pre-requisites for both NPPL(SSEA) to LAPL(A) conversion and LAPL(A) to PPL(A) SEP(Land) upgrade, there will be no requirement to apply for a LAPL.

The specific process will be included in next amendment to CAP 804, together with any clarification.

AOPA COMMENT: 7 Apr 2013 - At the 3-4 April 2003 Part-FCL Implementation Forum, EASA was asked by IAOPA whether the PPL Q X-C, if previously completed during LAPL training, could be credited for the LAPL-to-PPL conversion course, provided that the supervised solo navigation flight time required for the conversion course was achieved.  Regrettably, certain nations (‘a rule is a  rule’) opposed this and others abstained.  There is therefore insufficient support to merit drafting an Alternative Means of Compliance, so the 150nm / 2 landaway Q X-C requirement of the LAPL-to-PPL course must also be completed by NPPL holders converting to a part-FCL PPL.  Further details will be included in CAP804.

A number of pilots have yet to achieve ICAO Level 6 English assessment.

AOPA previously offered to conduct ‘other means’ English Language assessment at formal seminars and safety bonus events; regrettably this was refused by the CAA. 

However, we feel that anyone who has ever been a PPL examiner can certainly make a valid assessment of a British pilot’s standard of English and again wish to provide such an assessment service at formal seminars or safety bonus events, using nominated AOPA IC members who hold, or have held, FE authorisation.

AOPA wish to be able to offer this as a complimentary service at the Duxford Safety Bonus Day on 13 Apr 2013 and at the Duxford AOPA Event Day on 14 Sep 2013.

AOPA COMMENT: 7 Apr 2013 - The CAA has confirmed that AOPA may provide such an assessment service at formal seminars and safety bonus events provided that an AOPA FE is available on the day.  It should be remembered that FEs may only assess at Level 6; assessments at lower levels may only be made by designated assessors. RESOLVED.


Part-FCL FCL.740.A(b)(1)(ii) has amended the previous wording of JAR-FCL 1.245(c)(1)(ii)(C), restricting the exemptions applicable to the SEP Class Rating training flight exemption. 

In UK. many PPL/FEs are unaware of this; as a result they may have unwittingly revalidated pilots who may not have met all the specific revalidation requirements.

IAOPA Europe has proposed to EASA that FCL.740.A(b)(1)(ii) should be amended to read:   ‘Applicants shall be exempted from this flight if they have passed any other skill test, proficiency check or assessment of competence for the same category of aircraft.'

This proposal was unanimously supported at a previous FCL Partnership Group meeting; however, due to the length of time it will take for FCL.002 to raise an NPA and the risk of UK pilots flying with technically invalid licences, IAOPA Europe recommends that the UK adopts an Article 14(4) exemption as soon as possible, using the wording proposed above.

AOPA COMMENT: 7 Apr 2013 - This issue has been passed to the CAA with a request for urgent action to be taken.

23 May 2013 - The CAA has advised that a Regulation 14(4) exemption has now been notified to the EC by the FCO.  In effect, this restores the situation to pre-EASA times; hence, for example an IMC flight test or an FI revalidation assessment of competence will now be accepted in lieu of the dual training flight requirement.  For further information, see the relevant News item.

It is expected that this exemption will eventually become part of the Aircrew Regulation after consideration by EASA FCL.002, with minor text changes only.


Under part-FCL, the previous consolidated revalidation requirements applicable for UK pilots who held both SEP(Land) and SEP(Sea) Class Ratings are no longer available, significantly increasing costs for such pilots.

IAOPA Europe will raise this topic at the next FCL-IF meeting in early April as it seems to be an unintended consequence of Part-FCL. 

The pre-Sep 2012 UK CAA requirement will be proposed as a recommended solution.

AOPA COMMENT: 7 Apr 2013 - This topic was raised at the April Part-FCL Implementation Forum and has been referred to FCL.002.  However, although a consolidated revalidation process will be proposed by FCL.002, the associated Notice of Proposed Amendment will not be published before the end of 2013, so in the mean time, pilots who hold both ratings will be required to meet the revalidation requirements for both ratings independently. PENDING.

One of the more significant benefits of the AOPA GIC was 'to provide a qualification which can be accepted by the UK CAA as a credit towards other JAR-FCL instructor qualifications issued by the UK CAA such as the Class Rating Instructor (CRI), the Instrument Rating Instructor (IRI), or the Flight Instructor (Aeroplane) Rating (FI(A)).'

Are similar credits allowable under Part-FCL?

The CAA should confirm whether AOPA GIC graduates may receive appropriate credits towards Part-FCL instructor qualifications.

AOPA COMMENT: 7 Apr 2013 - AOPA and the CAA have agreed to investigate the feasibility of ATOs being permitted to include prior completion of the GIC as an acceptable option for part of their formal FI course approval. PENDING.


There are at present a  number of legacy BCPL instructors that were granted BCPLs on the introduction of JAR as they were PPL Instructors and the new requirement was for all instructors to hold a commercial licence.

All of these instructors will be in the older age bracket, experienced and some may indeed hold CFI positions.

If the present policy is pursued they will not be able to obtain a restricted CPL unless they do the full set of commercial exams and it means that some of them may well not be able to instruct at equivalent level ie CPL, ATPL, IMC, IR, ME, Aerobatic etc and will consequently be disadvantaged.

It seems that its within the CAAs gambit to replace these BCPLs with a restricted CPL with no loss of status or privilege.

It was after all convenient for the CAA to grant these legacy instructor BCPLs when it suited them now is the time to reciprocate.

Solution :

CAA issue restricted CPLs to all BCPL instructors. Those that have not taken the full CPL exams being restricted to instruction only.

AOPA Comment: 7 Apr 2013 - The CAA has already answered this.  BCPL holders who had completed the full BCPL course were deemed to hold ‘full’ CPLs for part-FCL conversion purposes.  Restricted BCPL holders were deemed to hold PPL privileges only; however, for part-FCL conversion purposes, these privileges include the right to receive remuneration for conducting flight instruction.  As R/BCPL/FI holders were existing FIs, there is no requirement for them to take the CPL exams in order to maintain their rights to be paid for work as FIs.  They have not lost any privileges, for example, a PPL/FI with aerobatic instructional privileges may teach an ATPL holder aerobatics.  To instruct a CPL course, the FI must hold a CPL, but to instruct for a rating, the FI must hold that rating him/herself in addition to any additional instructional requirements. RESOLVED.


AOPA COMMENT: Under EASA, it is not possible to hold more than one Part-FCL licence for the same aircraft category.  For example, you may hold a LAPL(H) and a PPL(A) at the same time, but not a LAPL(A) and a PPL(A).  As the Part FCL PPL(A) does not contain LAPL(A) privileges, you would need to decide which licence you require. If you wish the CAA to issue a Part-FCL PPL(A) and in the future you are unable, or do not wish, to obtain a Part-MED Class 1 or 2 medical and instead wish to hold a Part-MED LAPL medical, you would be required at that time to surrender your Part FCL PPL(A) and to apply for a LAPL(A). RESOLVED.


If a pilot has been flying on a UK-issued PPL under ORS4 no. 912 or ORS4 no.913 exemption with a NPPL Medical Declaration and a valid SSEA Class Rating, does he/she need to renew his/her SEP Class Rating if he/she is now able to hold a Part-MED Class 2 Medical Certificate and wishes to convert to a part-FCL PPL(A) with SEP Class Rating?


AOPA Comment:.

5 Jul 2013 - The CAA has advised that no renewal proficiency check is required for such pilots converting to a Part-FCL PPL(A), provided that their SSEA Class Rating is valid at the time. However, all other requirements for the conversion of a UK PPL(A) to a Part-FCL PPL(A) (e.g. use of radio navaids) must be met.


If a pilot has been flying on a UK-issued PPL under ORS4 no. 912 or ORS4 no.913 exemption with a NPPL Medical Declaration and a valid SSEA Class Rating, can he/she convert his/her PPL(A) to a LAPL(A) if he/she is now able to hold a Part-MED LAPL Medical Certificate and wishes to convert to a Part-FCL LAPL(A) with SEP privileges?

AOPA Comment:

5 Jul 2013 - The CAA has advised that such pilots need to meet the same criteria as are required for the conversion of a NPPL(A) SSEA to LAPL(A) and listed in CAP 804 Section 4, Part P.


FCL.105.A states that ‘Holders of an LAPL(A) shall only carry passengers after they have completed, after the issuance of the licence, 10 hours of flight time as PIC on aeroplanes or TMG.’

Does this apply to pilots converting to a LAPL(A) from another aeroplane pilot licence?

AOPA Comment:

3 Jul 2013 - The CAA has advised that all PIC time gained since the issue of the licence being converted will be credited towards this requirements. CAP 804 will be amended to make this clearer and the CAA Licensing Team have been briefed accordingly.


Nature of Problem: If a Part-FCL pilot licence includes a lapsed Rating on the back of the licence, may an Examiner renew the Rating if it has lapsed by less than 3 years without the applicant needing to send the licence to the CAA?

Issue Solution: No. The CAA has stated that "where a lapsed rating is shown on the back of a Part-FCL licence (regardless of when it lapsed), the licence must be sent to the CAA to have the rating reinstated on the active side of the licence and Certificate of Revalidation page. The Examiner cannot renew the rating on the licence by endorsing the licence in the field."

Nature of Problem.
An instructor member wants to know if its worth revalidating his instructor rating if he's lost his medical. He now has a LAPL. Is there anything he can do with his instructor rating.

Issue Solution. Although a PPL with a Class 2 Medical Certificate can include an FI or CRI certificate, a LAPL cannot include any instructional privileges.


The 25% rule was introduced in COMMISSION REGULATION (EU) 2015/445.  IAOPA (Europe) sought clarification from EASA in June 2015 due to the fact that the word 'required' is ambiguous.  Does this mean the mandatory flight instruction (e.g. 25 hours for the PPL) or the actual flight instruction the applicant needed ('required') to meet the standard to be ready for the Skill Test?  For example, if he/she had needed 40 hours of dual flight instruction, would the '25%' figure mean 6.25 or 10 hours? We assumed that it meant 6.25, but this ambiguity should be resolved. 

Meeting delegates agreed that the 25% rule should at this moment be based on the minimum hours established in the ATO course approval. However, this issue should be reviewed by the GA task on simplifying the balloon requirements to further clarify the intent as the task is already considering changing the 25% requirement to 50%.

So at the moment, EASA considers that the 25% means 6.25 for the PPL; however, we are still waiting for the final decision.  Nevertheless, the UK CAA may permit a less restrictive interpretation; unfortunately there was no UK CAA delegate at the meeting but subsequent conversations indicated that the UK CAA was in favour of considering the 25% as being applicable to the actual dual training which the applicant required to be ready for the Skill Test.


Nick Wilcock

IAOPA (Europe) FCL Representative

3-axis Microlight flight time is now acceptable towards revalidation of SEP/TMG/SLMG Class Ratings included in national UK pilot licences. Where are the details of this found so we can start to apply them?

The change in SEP Class Rating revalidation requirements stems from the ANO2016 amendment.  ANO2016 Schedule 8 Part 3 Chapter 1 paragraph 1 now includes the following table:

Table 1

Ratings for Aeroplanes

Column 1



Column 2



Column 3


You are here: Home Frequently Asked Questions Licensing Issues