For some considerations I’m thinking about revalidating my SEP-class rating way before the expiry. I called my CAA and they told me it is not possible to revalidate before the expiry date (and basically moving forward the new expiry date), saying this date cannot be moved. When looking into the EASA access rules I read the regulation differently, so am wondering whether the person I spoke to at the CAA or I am wrong? FCL740 says “If pilots choose to fulfil the revalidation requirements earlier than prescribed in points FCL.740.A (…), the new validity period shall commence from the date of the proficiency check.” What I’m wondering about is their reference to the “proficiency check” – does that only fit to the renewal (proficiency check with examiner) or also to the “revalidation by experience” including the training flight with instructor?
Original part of the regulation:
FCL.740 Validity and renewal of class and type ratings
Regulation (EU) 2024/2076
(a) Validity
(1) The validity period of class and type ratings shall be 1 year, except for single-pilot single-engine class ratings for which the validity period shall be 2 years, unless otherwise determined in the OSD. If pilots choose to fulfil the revalidation requirements earlier than prescribed in points FCL.740.A, FCL.740.H, FCL.740.PL and FCL.740.As, the new validity period shall commence from the date of the proficiency check.
FCL.740.A Revalidation of class and type ratings – aeroplanes
Regulation (EU) 2024/2076
(b) Revalidation of single-pilot single-engine class ratings.
(1) SEP aeroplane class ratings and TMG class ratings. For the revalidation of SEP aeroplane class ratings or TMG class ratings, applicants shall:
(i) within the 3 months preceding the expiry date of the rating, pass a proficiency check in the relevant class in accordance with Appendix 9 to this Part with an examiner; or
(ii) within the 12 months preceding the expiry date of the rating, complete 12 hours of flight time in the relevant class, including the following:
(A) 6 hours as PIC;
(B) 12 take-offs and 12 landings;
(C) refresher training of at least 1 hour of total flight time with and to the satisfaction of a flight instructor (FI) or a class rating instructor (CRI) who shall select those flight exercises that allow the applicant to refresh their competence in safely operating the aircraft and applying normal, abnormal and emergency procedures. (…)
Do you want a new date or not?
Do you have a PPL or LAPL?
When is your expiry date?
I want a new date, and have a PPL. Original expiry is on Dec 15, 2025.
My understanding, and what examiners have been applying in my case, is that it is very possible to revalidate before the deadline, and if one revalidates more than 3 months before the expiry, the new expiration date is:
date of revalidation + last day of month + 2 years.
E.g. for a revalidation between 1 Dec 2024 and 31 Dec 2024 the new expiry is 31 Dec 2026; for a revalidation between 1 January and 31 January 2025 the new expiry date is 31 January 2027, etc.
Marcel wrote:
Original expiry is on Dec 15, 2025
I don’t understand how you ended up with that. Expiry is always end of calendar month, it is official in Part-FCL.
ARA.FCL.215 Validity period
(a) When issuing or renewing a rating or certificate, the competent authority or, in the case of renewal, an examiner specifically authorised by the competent authority, shall extend the validity period until the end of the relevant month.
(b) When revalidating a rating, an instructor or an examiner certificate, the competent authority, or an examiner specifically authorised by the competent authority, shall extend the validity period of the rating or certificate until the end of the relevant month.
Original expiry is on Dec 15, 2025
lionel wrote:
I don’t understand how you ended up with that. Expiry is always end of calendar month, it is official in Part-FCL.
Oha – my mistake! I noted Dec 15, 2025 as a “pre-warning” in my calendar instead of the correct Dec 31 in my licence. Sorry for confusion here.
lionel wrote:
My understanding, and what examiners have been applying in my case, is that it is very possible to revalidate before the deadline
What I’m wondering about is whether that only counts when doing a proficiency check with an examiner, or also when doing the training flight with instructor and sending in the forms to CAA earlier (and maybe a word of explanation to avoid them returning the stuff).
On the other side, and maybe I’m wrong here (?), flying a proficiency check with examiner wouldn’t harm…?
Marcel wrote:
What I’m wondering about is whether that only counts when doing a proficiency check with an examiner, or also when doing the training flight with instructor and sending in the forms to CAA earlier (and maybe a word of explanation to avoid them returning the stuff).
My understanding is that it does not as the relevant paragraph – FCL.740(a) – only mentions early revalidation by proficiency check.
You can do the training flight at any time during the last 12 months of the validity period of the SEP class rating. In theory, you could imagine that if you did the training flight more than 12 months before that date, then the new date would be 12 months from that date but instead the training flight simply won’t count. I think the regulator didn’t foresee that anyone would be interested in that scenario.
