General Aviation

Published on April 7th, 2020 | by Mark Dwyer


IAA Licence/Rating Extension for General Aviation– FAQ

I’ve been asked lots of questions about this over the last few days so I’ve put together this frequently asked question article about extending your licence during the COVID-19 pandemic. If your question is not answered, feel free to contact me at and I’ll add it. The answers below are based on IAA Aeronautical Notice P33 Issue 2 published on 6th April 2020. If you hold a UK Part-FCL licence, the relevant exemption can be found here. I’ll do my best to maintain the article if the Notice is updated but in any case, the text in the notice will always take precedence over what is written here.

Is this an automatic extension of my licence or rating?

NO! If you wish to extend your class, instrument or type rating you must follow the procedure outlined in the P33 Notice; however, you have to keep in mind that a certificate from any of the aviation colleges is required. At the very least it involves your knowledge being assessed by an appropriately qualified examiner or flight instructor with FCL.945 privileges (SEP only), completion of an IAA form and endorsing the rating page of your licence.

My SEP Rating expired on 31st March, can I use this process to renew it?

Yes. If your rating has expired within the period of the notice (29th February to 31st July 2020) then you may use the procedure outlined in P33 to extend the validity of your rating.

I hold a single pilot, single engine instrument rating, does P33 apply to me?

Yes, you can extend an instrument rating using this process, refer to section 1 (a)(i) of the notice for full details. If you pass an assessment by an appropriately qualified examiner, you may have your rating extended by 4 months.

What is an assessment by an appropriately qualified Examiner of Flight Instructor with FCL.945 privileges?

In order to extend the privileges of your rating, the examiner and the IAA must be satisfied that you are still competent to operate an aircraft within the scope of your licence. To do this, you will need to be assessed by an examiner or FCL.945 instructor. This will vary from examiner to examiner but will be broadly similar. Due to social distancing restrictions, it will most likely be in the form of a phone call / video call / skype / whatsapp call etc. The examiner will ask a number of questions to determine your knowledge level or normal and emergency procedures has been maintained to exercise the privileges of your licence safely. They will be structured around Part-FCL Appendix 9 which specifies the content of a Licence Skills Test or Licence Proficiency Check. Some examples of questions may be:

  • What would you do in the event of a brake failure during taxi?
  • What would you do in the event of an engine failure after takeoff?
  • What’s the best glide speed of your airplane?
  • Tell me about the drills you would do in the event of an engine fire in flight?
  • What are the requirements for flying into Class C airspace in Ireland?
  • What are the in-flight visibility requirements for flying VFR in Class G airspace?
  • Where can you find information about licensed aerodromes in the country?
  • How do you access NOTAMs for your flight?
  • What is a RMZ/TMZ and is there anywhere in Ireland you might find one?

These are the types of questions you will generally be asked during you normal refresher training flight with your instructor. Refresh your knowledge in advance.

Some Flight instructors are authorised to sign certificates of revalidation for SEP ratings, these have a privilege called FCL.945. If they have this privilege, they may conduct the assessment.

Are there any other requirements to extend the validity of my SEP?

Yes. You must meet the LAPL(A) recency requirements in order to be eligible for an extension to your rating. they are;

Within the 2 years preceding the original expiry date of the class rating, the holder has completed the following:

  • 12 hours of flight time in the relevant class as PIC or flying dual or solo under the supervision of an instructor, including;
  • 12 take-offs and landings, and
  • refresher training of at least 1 hour of total flight time with an instructor

In this case the 1 hour refresher training can be replaced by an assessment of knowledge by an appropriately qualified examiner or a flight instructor with FCL.945 privileges.

I usually renew my SEP by LPC every two years, can I extend my rating?

Unfortunately not. If you don’t meet the hours requirements above, you will need attempt to revalidate it before it expires or renew it if it expires.

Do I still need to do 3 takeoffs and 3 landings in 90 days?

Yes but remember this requirement only applies to carrying passengers. If you do not have 3 take offs and 3 landings in 90 days, you are permitted to do these solo and then carry passengers. A word of caution; think carefully about doing this. Would you be able to deal with an emergency just after takeoff? Would you be able to manage an engine failure at 200ft without having flown for 90 days? I’d strongly recommend going flying with an instructor if you’re not current. There are plenty around the country that would be more than happy to help you out. If your aircraft has not flown for some time, please see this useful IAA leaflet on Recommendations for Aircraft and Components with Low Utilisation

I hold an Instructor Certificate (FI or CRI), what do I need to do?

P33 automatically extends the validity of instructor and examiner certificates for 8 months or 30th November, whichever occurs first. The only requirement is to print a copy of the notice and keep it with your licence.

I have already started my PPL theory exams, do I need to finish them within 18 months?

The IAA have suspended all theoretical knowledge exams until further notice. Once you have started the exams, an additional six months has been granted (i.e. 24 months total) to complete all exams. The existing pass mark and number of attempts remain.

I won’t be able to complete my PPL within 24 months of passing my exams, is there an extension available?

Yes. P33 grants an additional 6 months (i.e. 30 months) to complete your training and have your licensed issued. In the case of CPL/IR/ATPL exams, there is also an additional 6 months granted (i.e. 42 months).

I have an ELP Level 4 or 5 that expires soon, can it be extended?

If you have an English Language Proficiency Level 4 or 5 that expires prior to 31st July it is automatically extended by 8 months once you print a copy of P33 and keep it with your licence. If you hold ELP Level 6, it is valid for the lifetime of the holder and no action is required.

My medical expires before 31st July, what can I do? ***UPDATED ANSWER***

If you are unable to revalidate your medical by normal means, you may have the validity of your Class 1 medical extended for 4 months or to the 30th November whichever occurs first subject to the following:

  • The holder shall hold a current medical certificate appropriate to the licence held, which is without restrictions, other than visual;
  • The validity period of the certificate expires between 29 February and 31 July 2020;
  • The holder shall make a declaration of fitness on IAA Form Number RPPL.F.DCV19d declaring that their medical fitness has not decreased since the issuance of the current medical certificate;
  • The holder shall retain a copy of this declaration when exercising the privileges of the associated flight crew licence.

Extending a Class 2 medical is not possible under P33. The notice states that and extension may be possible where “the medical certificate holder is unable to complete a medical assessment with an Aeromedical Examiner“. Class 2 Aeromedical examinations have been available at all times in Ireland during the pandemic so there was no basis for a medical extension to be sought. All Class 2 medical certificate holders should revalidate medical examinations in the normal way via their AME.

I fly for an airline, can P33 be used to extend my Airbus or Boeing Type Rating

No. Procedures for extending licences / ratings / certificates for pilots operating for Part-ORO organisations can be found in Aeronautical Notice P30, details should be provided to you by your company.

Where can I find a list of Examiners who can extend my SEP rating validity?

A list of Examiners can found on the IAA website HERE. Only an examiner with the appropriate privileges can conduct the assessment, in that document you’ll find the appropriate examiners in the SEP(Land) section. If you would like me to conduct the assessment, please get in touch at to begin the process.

I hold a National Licence issued by the IAA (i.e. non EASA), does this notice apply?

Yes, the same procedures apply for a national licence holder. However, the list of examiners above can only endorse Part-FCL licences. Please check with the examiner that they can endorse a national licence or contact the IAA Personnel Licensing Office for more details.

There are various other extensions available but they are very specific so I won’t go into detail here. If I haven’t answered your question, please send it to me at and I’ll do my best to answer it.

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About the Author

Mark is an airline pilot flying the Boeing 737 for a major European airline. In addition he is also a Type Rating Instructor, Type Rating Examiner and Base Training Captain on the B737. Outside of commercial flying Mark enjoys flying light aircraft from the smallest 3 Axis microlights up to heavier singles. He is also an instructor and EASA Examiner on single engines and a UK CAA Examiner. He flies the Chipmunk for the Irish Historic Flight Foundation (IHFF). Mark became the Chairman of the National Microlight Association of Ireland (NMAI) in 2013 and has overseen a massive growth in the organisation. In this role he has worked at local and national levels. In 2015, Mark won ‘Upcoming Aviation Professional Award’ at the Aviation Industry Awards sponsored by the IAA. Mark launched this website back in 2002 while always managing the website, he has also been Editor and Deputy Editor of FlyingInIreland Magazine from 2005 to 2015.

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