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Aavistus Training · air-law · 010.04

Personnel licensing (ICAO Annex 1 → Part-FCL / Part-MED)

What you'll learn

Annex 1 definitions; relevant parts connected to Part-FCL and Part-Medical: licence structure, ratings, validity, medical certificates, language proficiency.

Regulation — cited to the current EU text

Framework and Definitions

Part-FCL implements ICAO Annex 1 within the EU regulatory system. Core terminology for the entire annex is established in FCL.010 FCL.010@2026-04-30. The abbreviations used throughout the regulation — LAPL, PPL, CPL, ATPL, IR, BIR, ATO, DTO, FSTD and others — are consolidated in the guidance material at GM1 FCL.010@2025-11-25. ICAO Annex 1 source definitions underlying this framework are not covered by the EU corpus (ICAO-framework material).

Licence Structure: One Licence Per Category

A pilot may not hold more than one licence per category of aircraft at any one time FCL.015@2026-04-30. Licences, ratings and certificates are issued by the competent authority upon application accompanied by evidence that the applicant meets the requirements of both Part-FCL and Part-MED; any limitation or extension of privileges must be endorsed in the licence by that authority FCL.015@2026-04-30.

Applications for the issue of a licence, rating or certificate must be submitted no later than 6 months after passing the skill test or assessment of competence FCL.015@2026-04-30.

Ratings and the Exercise of Privileges

The exercise of licence privileges depends on the validity of any ratings contained in the licence and the appropriate medical certificate FCL.040@2026-04-30. A lapsed rating suspends the associated privileges even if the licence itself remains valid.

Theoretical Knowledge: Pass Standards and Validity

All examination papers for a given licence must be taken under the responsibility of one Member State's competent authority FCL.025@2026-04-30. The pass mark for any paper is 75%; no penalty marking applies FCL.025@2026-04-30. Candidates must be recommended by a DTO or ATO before sitting; that recommendation is valid for 12 months FCL.025@2026-04-30.

For applicants for the ATPL, CPL or IR, the requirement to retake the complete set of examination papers is triggered if: one paper is failed within four attempts, or all papers are not passed within six sittings, or all papers are not passed within the 18-month window FCL.025@2026-04-30. For LAPL, PPL, BIR and GPL applicants, the triggers are failing one paper within four attempts, or failing to complete all papers within the 18-month window FCL.025@2026-04-30. In all cases, further training at a DTO or ATO is required before retaking FCL.025@2026-04-30.

Validity of a successfully completed theoretical knowledge examination:

| Licence | Validity of passed exams | |---|---| | LAPL, PPL, GPL | 24 months from successful completion | | CPL, MPL, IR | 36 months from successful completion | | BIR | Unlimited | | ATPL | 7 years from the last validity date of an IR entered in the licence; or, in the case of helicopters, a helicopter type rating entered in that licence |

FCL.025@2026-04-30

Medical Certificates

Part-MED defines three certificate classes, each linked to specific licence privileges MED.A.030@2026-04-30:

| Licence privilege | Minimum medical required | |---|---| | LAPL | LAPL medical certificate | | PPL, GPL | Class 2 | | CPL, MPL, ATPL | Class 1 |

A student pilot must hold the medical certificate required for the relevant licence before flying solo MED.A.030@2026-04-30. A pilot may not hold more than one medical certificate at any one time MED.A.030@2026-04-30.

A class 1 certificate encompasses the privileges and validities of class 2 and LAPL certificates; a class 2 certificate encompasses those of the LAPL certificate AMC1 MED.A.030@2025-11-25.

Additional medical requirements apply: holders of a PPL or LAPL who add a night rating must be colour safe; adding an IR or BIR to a PPL requires pure tone audiometry in accordance with the periodicity and the standard required for class 1 medical certificate holders MED.A.030@2026-04-30.

Language Proficiency

Pilots required to use radio-telephony must hold a language proficiency endorsement — in English or the language used for radio communications — entered in their licence FCL.055@2026-04-30. The minimum acceptable level is operational (Level 4) on the ICAO scale; the rating descriptors for all six levels (pronunciation, structure, vocabulary, fluency, comprehension, interaction) are defined in AMC2 FCL.055@2025-11-25.

Revalidation intervals, unless the pilot has demonstrated expert level (Level 6): - Level 4: every 4 years - Level 5: every 6 years

Level 6 holders are not subject to periodic re-evaluation FCL.055@2026-04-30.

IR holders have an additional specific obligation: demonstrated ability to use English at the appropriate proficiency level, covering R/T in all flight phases, use of technical manuals, pre-flight planning documents, charts and communication with crew FCL.055@2026-04-30 AMC3 FCL.055@2025-11-25. Assessment may be conducted by the competent authority directly or delegated to an approved language testing body AMC1 FCL.055@2025-11-25.

Document Carrying Obligations

A pilot must carry a valid licence and valid medical certificate whenever exercising licence privileges, together with a photo-bearing personal identification document FCL.045@2026-04-30. A pilot or a student pilot must present their flight time records on request to an authorised representative of a competent authority; student pilots must additionally carry authorisation for solo cross-country flights FCL.045@2026-04-30.

Revocation, Suspension and Limitation

The competent authority may limit, suspend or revoke licences, ratings and certificates when a pilot fails to comply with Part-FCL, Part-MED or applicable operational requirements FCL.070@2026-04-30. A pilot whose licence is suspended or revoked must immediately return it to the competent authority FCL.070@2026-04-30.

Your operations manual

This block connects to your school's own Operations Manual (OM-A/B/C/D). In the full product it shows, cited to your manual, how YOUR organisation implements the regulation above — private to your school. (Demo placeholder.)

Real-world context — illustrative only

The cases below are labeled illustrative context, not regulation. They show licensing policy in motion but carry no regulatory authority.

Simulator-heavy licensing proposals to address crew shortages CASE-1: India's regulator has been considering a proposal to create a simulator-heavy pilot licence pathway as a response to a shortage of flight crew. Airlines were asked to comment before a final report to the regulator's head. This illustrates a recurring tension in Annex 1-aligned licensing systems: the extent to which flight simulation training devices can substitute for aircraft time in meeting licence requirements. Under Part-FCL, training completed in FSTDs in accordance with Part-ORO is counted towards experience and revalidation requirements, but the degree of FSTD substitution permitted is bounded by specific provisions for each licence and rating. Regulatory proposals that seek to expand that substitution are a normal part of licence-structure evolution — typically following a rulemaking process rather than informal committee report.

Check your understanding

1. Which trigger for having to retake the complete set of theoretical knowledge examination papers applies to ATPL, CPL and IR applicants but does NOT apply to LAPL, PPL, BIR or GPL applicants?

2. A LAPL holder who wishes to add a night rating must satisfy which specific additional medical requirement?

3. A pilot whose language proficiency has been assessed at ICAO Level 5 must revalidate that endorsement every:

4. An applicant must submit their application for the issue of a licence no later than how long after passing the skill test?

5. How long do successfully completed ATPL theoretical knowledge examinations remain valid?