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EASA's non-recognition of UK (EASA FCL compliant) theory exam passes and training done before 1/1/2021

That was the Irish Aviation Authority. I asked for confirmation twice (and received the reply I posted above) as well as confirming by phone, they have been told that it is NOT possible to accept the exams unless the applicant is a student pilot. They were extremely clear that it would NOT allow conversion for someone who already has a licence issued. They explained this was discussed in a meeting with EASA when the revised guidance was given to the NAA’s.

In another point, I am not sure I agree that it is only of use if you passed the last ATPL exam 3 years ago. The guidance quite clearly says “provided that those examination completion certificates are still within their validity period in accordance with FCL.025(c)”, FCL.025(c) being the following:

(c) Validity period
(1) The successful completion of the theoretical knowledge examinations will be valid:
(i) for the issue of a light aircraft pilot licence or a private pilot licence, for a period of
24 months;
(ii) for the issue of a commercial pilot licence, instrument rating (IR) or en route
instrument rating (EIR), for a period of 36 months;
(iii) the periods in (i) and (ii) shall be counted from the day when the pilot successfully
completes the theoretical knowledge examination, in accordance with (b)(2).
(2) The completion of the airline transport pilot licence (ATPL) theoretical knowledge
examinations will remain valid for the issue of an ATPL for a period of 7 years from the
last validity date of:
(i) an IR entered in the licence; or
(ii) in the case of helicopters, a helicopter’s type rating entered in that licence.

So by that, I can’t see why my exams for example wouldn’t still be valid according to point (2)(i).

Last Edited by Pirho at 14 Mar 23:51
United Kingdom

Pirho wrote:

it is NOT possible to accept the exams unless the applicant is a student pilot. They were extremely clear that it would NOT allow conversion for someone who already has a licence issued

That sounds so extremely dodgy…

What is the legal definition of “student pilot” anyway? This will be fun…

EDIT: I believe the source of confusion here lies in the word “conversion”. What if you straight-out apply for the EASA licence, using your UK theory, without trying to “convert” anything?

Pirho wrote:

So by that, I can’t see why my exams for example wouldn’t still be valid according to point (2)(i).

Ah yes, I agree. But would the EASA authority only extend that validity if it’s an EASA IR? Or will a non-EASA ICAO (UK CAA) IR also extend the validity of those exams towards an application for an EASA CPL?

Last Edited by Alpha_Floor at 15 Mar 00:15
EDDW, Germany

Alpha_Floor wrote:

EDIT: I believe the source of confusion here lies in the word “conversion”. What if you straight-out apply for the EASA licence, using your UK theory, without trying to “convert” anything?

Yea I understand what you mean – but I am copying the authority’s terminology. By already holding an ICAO licence, it is viewed as a third country conversion. There is no ‘apply from scratch’ option, since a third country conversion isn’t really a conversion in the true sense, as it just grants a licence and doesn’t remove the original one. I agree it seems very dodgy but unfortunately that is what the NAA’s have been briefed by EASA.

Alpha_Floor wrote:

Ah yes, I agree. But would the EASA authority only extend that validity if it’s an EASA IR? Or will a non-EASA ICAO (UK CAA) IR also extend the validity of those exams towards an application for an EASA CPL?

I didn’t consider this, but I think you are right. It all starts to get very messy as the UK had a derogation from EASA to allow ICAO compliant IR’s to count towards exam validity, but I am not sure if EASA ever adopted that body-wide or if it remained a UK only thing. Trying to find anything about it in current EASA docs only finds FCL.625:

(d) If the IR has not been revalidated or renewed in the preceding 7 years, applicants for the IR shall
pass again the IR theoretical knowledge examination and skill test.
(e) Holders of a valid IR on a pilot licence issued by a third country in accordance with Annex 1 to
the Chicago Convention shall be exempted from complying with the requirements in points
(c)(1) and (d) when renewing the IR privileges contained in licences issued in accordance with
this Annex.

Which get’s the gist of it but I am not sure if the stance would be that this is specifically referring to renewing an IR, as opposed to validity of exams specifically, although that’s what it infers.

Once again, a gigantic mess of things that make little sense.

United Kingdom

Pirho wrote:

Once again, a gigantic mess of things that make little sense.

Totally agree, @Pirho, but have you tried Austro Control? IME they’re very pragmatic and efficient. They’re also used to dealing with (ex) UK licenses at ATP level, as a huge number have moved from CAA to them (think EZY). Perhaps worth an email or a call.

@172driver Thanks for the suggestion, I was in contact with them before this latest update and they were unable to help any more than anywhere else, but I have sent a follow up to see if this changes anything.

United Kingdom

I have a question regarding licensing

If a student pilot hold a uk ppl and have completed all ATPL exams (also uk CAA) prior to brexit. Can he or she enroll an EASA approved ATO in a different country than UK and completing cpl/me/ir?

Thanks

[ @ABCD post moved to existing thread ]

ESGT/ESGP, Sweden

And then get issued with a UK CPL/IR – yes

ABCD wrote:

If a student pilot hold a uk ppl and have completed all ATPL exams (also uk CAA) prior to brexit. Can he or she enroll an EASA approved ATO in a different country than UK and completing cpl/me/ir?

Unless that ATO had EASA approval as well, then AFAIK student needs to:
1. Get EASA PPL (two theory exams + skills test).
2. Pass all ATPL exams again with some classroom time under EASA jurisdiction in EASA ATO.
3. Complete CPL/ME/IR under EASA.

EGTR

Unless that ATO had EASA approval

and the rest is true but completely ridiculous

BTW I think point 1. is the “100hr route” so he/she needs 100hrs TT as well.

I reckon most UK FTOs/ATOs must have got EASA approvals sometime mid-2020 or sooner, otherwise anybody depositing ~100k would probably send the hit squad round

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

BTW I think point 1. is the “100hr route” so he/she needs 100hrs TT as well.

Sorry, missed that.

EGTR
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