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EASA Permit to Fly - transferring from one register to another

As the title suggests, a flier colleague of mine is looking to purchase an aircraft which was produced and flown on an EASA PtF. This aircraft was latterly certified as an LSA but the aircraft this colleague is looking at cannot be brought up to scratch of the TC without excessive cost – this was recognised hence it has a ‘permanent’ PtF based on 21.A.701(a)15. The aircraft is currently being flown on the Swiss register – HB-WY – but the new owner lives in Germany hence the aircraft would have to be deregistered and then reregistered on another registry as the Swiss do not allow ownership of planes on their register except in circumstances concerning AOCs and similar.

My friend has tried talking to the LBA T4 who basically are hedging their bets as to whether this aircraft can ever be registered in Germany – even though it has the EASA PtF! Depending on who you ask, it theoretically could be registered as an Ultralight (D-Mxxx registration) if he was to change the parachute, remove the autopilot, fit a fixed pitch propeller and limit the weight to 472kg (yeah, sure…). As the MTOW of this aircraft is 600kg, he wants to register it as D-Exxx thus allowing to keep the parachute, propeller and autopilot as it is but the LBA is humming and refusing to give a clear statement.

The question:

what would be the easiest way to allow the aircraft to be flown to Germany, reregister it and keep it flying legally? Does anyone know of a register which would allow an application using a simple transfer of ownership / registry via (eg) EASA Form 18B from HB to another register whilst allowing the owner to live in (e.g.) Germany (ie the French or Dutch registers?)


Last Edited by Steve6443 at 07 Aug 19:42
EDL*, Germany

@mh should know more about the German angle.

Shoreham EGKA, United Kingdom

Really surprising that no other German pilot with a non certified aircraft knows about this. Germany has quite a large non cert community. OTOH registry transfers of these are potentially complicated. One previous thread is here.

Shoreham EGKA, United Kingdom

I think this is different and very special. An EASA permit to fly aircraft is different from the usual national non certified aircraft.


As far as I’ve been able to comprehend, it was intended that EASA permit to Fly aircraft only be on such a permit for 2 years until they were to be certified. But the delays and cock ups around this meant that there are plenty of aircraft on a PtF which cannot be brought up to the TC levels hence they have been given permanent Permits to Fly, albeit with the renewal each year.

So far the task seems to be that my friend needs to deregister the aircraft, apply to EASA for new flight conditions using form 18b and then submit the new datasheet and flight conditions along with any other required documents to the LBA for issuance of a permit….. it will never be listed on the country’s register of aircraft, just be issued a permit to fly which needs to be renewed yearly.

EDL*, Germany

Just thought I’d resurrect this topic…. at the end of last month we finally got the plane back in the air….. talk about a pain in the ass but at least it’s all resolved – here a few of the pitfalls we met. In case anyone has to go through the same procedure, I’ve listed what was needed.

So, the plane was purchased in October 2019 and flown from it’s base in Switzerland back to Germany. Because it was on the Swiss register, there was VAT / import duties to pay. These were resolved in Mannheim. Initially we were going to get the maintenance organisation to handle the transfer from HB to D register; however at the beginning of January, the head of that organisation had still yet to make a start on the registration; worse, he seemed to be even less knowledgable than I was so I decided to continue onwards with the process myself.

First things first was to send off for a revised set of Flight Conditions from EASA. A compliment to them – typically they responded within one or two working days; if something was amiss, then they helped us with the formulation or pointed us in the right direction. Having had the original Flight Conditions from the previous owner helped to fill in the document correctly and by the end of that month, we had the new approved flight conditions; now it was time to tackle the LBA.

Here, working times typically were in the region of 2 weeks. However if I contacted them, they would also respond within one to two days; unfortunately they were less helpful, pointing out what they wanted. For example, they wanted an original proof of transfer of ownership. I thought that the sales contract would suffice. Wrong. It has to be a written document detailing when ownership was transferred. Faxing it to them wasn’t acceptable. The previous owner had to write and send it by post to the LBA….

So, the documents they required were:

  1. EASA Form 21 – this is LBA Form 04T4
  2. EASA Form 18b – this is from the approved Flight Conditions from EASA
  3. copy of the Datasheet – this was received from EASA upon approval of the Flight Conditions
  4. LBA Form 15
  5. Proof of the registration and german flag (*)
  6. Proof of sign in the plane – “this aircraft is not type approved…. bla bla bla….”
  7. Proof of Radio Licence – requested from the Bundesnetzagentur.
  8. Proof of transfer of ownership in original – not the sales contract!
  9. copy of ID
  10. insurance documentation (**)

* The Virus has a very slender tail hence the required height of the registration could not be achieved and an exception had to be granted. More paperwork, internally due to Covid the documents weren’t passed between the person who received the request and the person who needed to approve it. What made this more challenging is that the minimum exceptional height is 15cm. Using a ruler to show they are 15cm height didn’t work because the curvature of the tail made the letters appear smaller. We had to stick a flexible tape measure next to the letters to prove they were the correct height.

** As the plane was flown from Switzerland and we wanted coverage on it’s HB registration, plus the fact that we didn’t have the final registration yet, the insurance was requested for the Plane’s serial number…. this wasn’t acceptable for the LBA, the insurance had to be sent indicating it’s new registration….

Then the LBA requested an extract from the logbook showing that the plane was airworthy. In the meantime, the organisation had received the approvals to carry out the maintenance on the Virus and so they performed the required checks, signed and stuck the ARC sticker into the logbook. A photo was sent to the LBA who then pointed out that an ARC could not be issued for this, that it needed to be removed, instead a statement had to be made stating ‘I hereby certify that an airworthiness review has been performed in accordance with EASA approved Flight Conditions’. So that was done. Finally the long awaited Permit was received.

For the annual renewal of Permit we need to send off the EASA Form 21 (LBA 04T4), a copy of the EASA 18b and LBA Form 15 – hopefully the renewal will be quicker and less stressful….

Below was the first take off with D-EYFF….

Last Edited by Steve6443 at 18 Jun 10:28
EDL*, Germany

Then what’s the point of the EASA PtF ?

Then what’s the point of the EASA PtF ?

I’m not sure I really understand the question??? Whats the point? Well, when my friend was looking for an aircraft, the criteria was:

  1. no UL – to ensure cross border european travels without hinderance
  2. minimum 130knots cruise speed
  3. for two people
  4. modern avionics including a/p
  5. preferably with a chute.

So, one of the few available aircraft to meet those desires was the Pipistrel Virus SW 100. The early versions sold were either UL with an MTOW of 475kg – which for German register meant no A/P – or from around 2010 they could also be bought with an MTOW of 600kg; however, as they weren’t type certified, they were sold with an EASA PtF until such a time that the certification was gained. Ultimately the difference between an SW 100 with 600Kg MTOW and an SW 121 are significant enough that would have required expensive changes to the SW 100 to bring them up to the 121 level; these changes however, are, if not adopted, insufficient to state that the aircraft was no longer safe to fly.

So the Permit allows the plane to continue flying without the expense of the modifications, however with limitations as per the EASA Flight Conditions; the service requirements are essentially the same as the SW 121, but the components aren’t certified. So the Permit could be slightly cheaper, even if the plane needs a permit renewed once yearly.

If the question why that aircraft? Well, my friend now owns a modern, 2 seater aircraft that has a useful load of 260kg, so means full tanks for 4.5 hours endurance plus reserve, two 80kg occupants and 25kg of baggage yet is still under MTOW; it cruises 132knots TAS at FL065 burning 22litres of super plus / hour for a price that was about 50k cheaper than the cheapest SW 121 available…..

If I’ve misunderstood your question, please let me know…..

EDL*, Germany

I must be missing something but this seems revolutionary, in the light of past discussions on the international flying privileges of

  • homebuilt
  • ultralight

which are restricted, although slightly differently between the two above groups, and very differently between different countries in Europe.

Does this mean there is a third category which does away with all the (a) long term parking and (b) overflight limitations?

It sounds like you still can’t do IFR, which is possible to some very small extent in homebuilts.

Shoreham EGKA, United Kingdom

Peter wrote:

I must be missing something but this seems revolutionary, in the light of past discussions on the international flying privileges of

which are restricted, although slightly differently between the two above groups, and very differently between different countries in Europe.

Does this mean there is a third category which does away with all the (a) long term parking and (b) overflight limitations?

It sounds like you still can’t do IFR, which is possible to some very small extent in homebuilts.

Well, the aircraft was factory built so can’t be labelled as homebuilt. Up until type certification of the SW 121, Germans could not register a Virus as anything other than an ultralight – means 475kg MTOW and no A/P; this was the case even though Pipistrel sold the Virus SW 100 in (e.g.) the US as a VLA with 600Kg MTOW, CS Prop. autopilot and cruise speeds of 130 – 140Kts.

The easiest way around this would be to run it using an EASA permit to fly – this allowed the aircraft to be registered as a ‘proper’ (no disrespect meant to UL flyers) aircraft (i.e. in Germany, a D-E instead of a D-M); as it’s Echo registered, there are no restrictions parking it, no restrictions concerning overflying EASA countries – at least I can’t see anything in the Flight Conditions which says it’s only allowed to fly in Germany. What’s interesting is that the Flight Conditions specifically allow ab initio pilot training with it.

Concerning flight categories, yes, it’s limited to Day VFR but there have been some noises about EASA allowing suitably equipped Permit aircraft to be validated for (e.g.) Night VFR – if & when that happens, we’ll see; if it happens, it will likely mean having the plane checked that it’s capable of meeting the requirements and having new Flight Conditions issued ….

As the plane is meant to be used for fun flying, IFR isn’t necessary. But if that were the case, the aircraft only has one radio and one (non certified) GPS installed hence IFR certification would require a significant investment, even if IFR approval could be gained so it’s not a restriction which will be missed….

EDL*, Germany
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