Published on March 1st, 2022 | by Mark Dwyer0
EASA Pilot Licencing Requirements Changes Coming into Effect 20th June 2022
Pilots holding a pilot licence and associated medical certificate issued by a third country (non-EU country) involved in the non-commercial (VFR, private, etc.) operation of aircraft registered in Ireland are currently permitted to fly in Ireland without any further formality*. The same holds true while flying aircraft registered in non-EU countries where that country permits it e.g. FAA allow holders of a foreign licence to fly privately in the country of issue. However, for pilots residing in the EU, this is due to change from 20th June 2022.
From 20th June 2022, any pilot who resides in the EU must hold an EASA Part FCL licence when flying any aircraft other than those defined in Annex I of the EU Basic Regulation (Regulation (EU) 2018/1139) e.g. gyroplanes, ex-military, homebuilt and certain historic aircraft, and microlight aeroplanes.
Here, we will explore some of the changes and give you links to the relevant legislation. It’s impossible to analyse every scenario but this article should give you the highlights of how these changes will affect you flying legally in Ireland. If you need an EASA Part FCL licence by 20th June 2022, contact an ATO/DTO like FunFly Aerosports (www.funfly.ie).
After 20th June 2022, any pilot resident in the EU, flying an aircraft, wheresoever registered, must hold an EASA Part FCL licence.
This doesn’t apply to Annex I aircraft which are not subject to the EASA Regulations.
Is this likely to be extended?
No, it will not be extended.
Ireland, and some other EU Member States, have been availing of a derogation permitted under Article 12(4) of EU Reg. 1178/2011, which has regularly been extended by the EU whilst awaiting the entry into force of the licencing annex to the EU-USA BASA. As that Annex, and the associated Technical Implementation Procedures – Licensing (TIP-L), are now in force, the EU will not extend the exemption further.
May I fly a N registered aircraft in Ireland on an FAA licence?
A pilot resident in the EU must hold an EASA Part FCL licence to fly in Ireland. There may be additional requirements to meet the FAA’s regulations, but to fly in Ireland legally from 20th June 2022 – you must hold an EASA Part FCL licence. To fly the aircraft outside of Ireland, you must hold an FAA licence also.
A visiting FAA licence holder flying an N registered aircraft does not have to hold an EASA Part FCL licence.
May I fly a G registered aircraft in Ireland on a UK CAA issued licence?
A pilot resident in the EU must hold an EASA Part FCL licence to fly in Ireland. There may be additional requirements to meet the UK CAA’s regulations, but to fly in Ireland legally from 20th June 2022 – you must hold an EASA Part FCL licence. According to the UK CAA website, from 31st Dec 2022, the pilot must also hold a UK CAA pilot licence.
How do I get an EASA Part FCL licence?
It depends on the type of licence you hold today.
FAA licences (PPL)
If you hold an FAA Private Pilot Licence, a bi-lateral agreement between the EU and the USA allows you to be credited for the licence you hold. Since 18th May 2021, there has been a further simplification of the mutual recognition of PPL, instrument rating and multi-engine rating. At the moment this only covers FAA PPL aeroplane licences, but it may be extended in the future to other licences.
The details of how to gain an EASA Part FCL licence based on an FAA licence are contained in the Technical Implementation Procedures – Licensing (TIP-L) – From a high level, to gain a PPL, one needs the following:
- The FAA licence needs to be current in accordance with the applicable FAA regulations when the conversion process is initiated. The pilot won’t be required to surrender the FAA licence, so may hold an EASA and an FAA licence.
- A valid FAA medical must be current and a valid EU medical certificate is required.
- Additional flight training may be required – see TIP-L for details.
- The pilot demonstrates theoretical knowledge, orally, to the examiner before the Skill test.
- English language proficiency. Note: English Proficient endorsement on your licence is deemed to be equal to Level 4. The validity period for ELP level 4 starts from the date of the last documented flight review.
- Skill test in accordance with Regulation (EU) 1178/2011.
Applications to the IAA using this form. Further information is available on the IAA PLAM.031
FunFly Aerosports (www.funfly.ie) is a Declared Training Organisation and can assist with any additional training and skill test requirements a pilot has.
ICAO compliant licence (including UK CAA issued licence)
If you hold an ICAO compliant licence e.g., UK CAA issued licence that you didn’t transfer into the EU before 31st Dec 2020, then, according to the IAA website;
The Authority may convert a licence for the relevant aircraft category into a PPL, a BPL or an SPL, where the original licence is issued in compliance with the requirements of Annex 1 to the Chicago Convention by a third country and the licence is:
(a) an equivalent licence to the licences referred to above; or
(b) a CPL or an ATPL.
You need to choose an ATO or DTO as applicable to obtain further guidance and assistance but the holder of the licence to be converted shall comply with the following minimum requirements for the relevant aircraft category:
- pass a written examination in Air Law and Human Performance;
- pass the PPL, BPL or SPL skill test, as applicable;
- fulfil the requirements for the issue of the relevant class or type rating, in accordance with Subpart H;
- hold a medical certificate, as applicable;
- demonstrate language proficiency in accordance with FCL.055;
- have completed at least 100 hours of flight time as a pilot.
FunFly Aerosports is a Declared Training Organisation and can assist with any additional training and skill test requirements a pilot has. See www.funfly.ie or contact them at email@example.com for further details on your personal licensing situation.
If I previously transferred my IAA issued PPL to another EU Member State, can I get credit for any knowledge or experience?
No, if you previously transferred an IAA-issued JAA or EASA PPL out of Ireland, it may not be revalidated, renewed or resurrected. It effectively ceased to exist when you transferred it. So, you’re starting with whichever licence you hold today. Please contact your Authority for further information on how to convert to an EASA Part-FCL licence.
What if I only visit and fly EU registered aircraft during my visits?
The IAA may validate a licence (ICAO compliant from FAA or UK CAA or any other ICAO state) for a period of up to one year. The requirements regarding the grant of a validation are detailed in Commission Delegated Regulation 2020/723. For a PPL, these requirements are as onerous as getting an EASA Part FCL licence, so a PPL holder shouldn’t even consider applying for a validation.
By way of example, to validate a pilot licence for non-commercial activities without an instrument rating holders shall comply with all the following requirements:
(a) demonstrate knowledge of Air Law and Human Performance;
(b) pass the private pilot licence (‘PPL’) skill test as set out in point FCL.235 of Annex I (Part-FCL) to Regulation (EU) No 1178/2011;
(c) fulfil the relevant requirements of Subpart H of Annex I (Part-FCL) to Regulation (EU) No 1178/2011, for the issuance of a type or class rating as relevant to the privileges of the licence held;
(d) hold at least a Class 2 medical certificate issued in accordance with Annex 1 to the Chicago Convention;
(e) demonstrate language proficiency in accordance with FCL.055 of Annex I (Part-FCL) to Regulation (EU) No 1178/2011;
(f) have a minimum experience of at least 100 hours as pilot in the relevant category of aircraft.
Pilots involved in specific non-commercial tasks may receive a validation for a maximum of 28 days per calendar year which would be less onerous than above, but this is limited to ‘specific non-commercial tasks’. Again, these are very narrow circumstances and probably won’t apply to the majority of pilots.
Any pilot considering a career as a professional pilot should carefully consider their options before applying for a validation. Some airlines rely on validations to allow you to continue flying commercially during a licence transfer process. A validation can only be issued once to a pilot. If you use this to validate your PPL this may prevent you from applying for a validation on a commercial licence in future.
How do I apply to the IAA for an EASA Part FCL Licence?
With June 2022 fast approaching, it is likely that the IAA will be very busy with applications. Longer processing time may apply to your application. As such, it’s important that pilots read the Frequently Asked Questions and application forms or speak to their DTO/ATO to establish the best course of action for them. Sending additional questions to the IAA, which are already answered on their website, will only result in further delays to pilot licence applications.
To apply for an EASA Part FCL PPL when you hold an FAA PPL and are converting under the BASA agreement– the application form is here.
To apply for an EASA Part FCL licence when you hold an ICAO compliant licence – the application form is here.
For further advice, please contact FunFly Aerosports Flying Club at firstname.lastname@example.org or www.funfly.ie
* For pilots visiting Ireland with a U.K. Medical Declaration or a U.K. issued LAPL Medical, please note that these certificates are not ICAO compliant and therefore not valid in Ireland. For pilots flying in Ireland with non-ICAO licences and/or medicals, please see IAA Aeronautical Notice P21 and ensure the associated notification is made.