Pilot Licensing Framework

Pilot licensing is how a State decides who may fly its aircraft and in what role. A national authority tests a person's knowledge, skill, experience and fitness, then issues a licence whose ratings list the aircraft and conditions in which the holder may act as a pilot. The standards behind those decisions are international: every Contracting State of the Chicago Convention licenses its pilots to at least the minimum standards of ICAO Annex 1 (Personnel Licensing), which is what allows an airline pilot trained in one country to fly into dozens of others.

In practice pilots meet the framework through their national or regional rules. In Europe these are EASA's Part-FCL, applied by each Member State's authority; in the United States they are the FAA's certification rules in 14 CFR Part 61. The two systems share Annex 1's structure but differ in vocabulary, training routes and details, which is why air law papers examine both the ICAO baseline and the national rules, and why converting a licence from one system to the other takes real work.

ICAO Annex 1 standards

Article 32 of the Chicago Convention requires the pilot and the other operating crew of every aircraft engaged in international navigation to be provided with certificates of competency and licences issued or rendered valid by the State in which the aircraft is registered. Article 33 obliges other States to recognise those licences, provided they were issued to requirements equal to or above the ICAO minimum standards (see Chicago Convention and ICAO). ICAO itself issues no licences; it sets the Standards and Recommended Practices on which States base theirs, and a State that departs from a Standard must notify ICAO of the difference.

Annex 1 covers flight crew and other aviation personnel, among them air traffic controllers and maintenance engineers. For pilots it covers the student pilot, the private and commercial pilot licences for aeroplanes, airships, helicopters and powered-lift, the airline transport pilot licence for aeroplanes, helicopters and powered-lift, the multi-crew pilot licence for aeroplanes, and the glider and free balloon licences. It defines class, type and instrument ratings, instructor qualifications, and the medical fitness standards that a licence holder must meet. Its minimum ages are 17 for the private licence, 18 for the commercial and 21 for the airline transport licence. Amendment 159, in force from 16 November 1989, made human factors knowledge a mandatory part of professional pilot licensing.

EASA Part-FCL

Part-FCL is Annex I to the Aircrew Regulation, Regulation (EU) No 1178/2011. The same regulation contains Part-MED for medical certification, Part-ORA for training organisations and aeromedical centres, and Part-DTO for declared training organisations. Since 8 April 2020 balloon and sailplane licences have had their own rules, Part-BFCL and Part-SFCL, in separate regulations.

Part-FCL licences are issued by the competent authority of a Member State and are valid throughout the EASA system:

Ratings and certificates sit on the licence: class and type ratings, the instrument rating, additional ratings such as the night rating, and instructor and examiner certificates. Common rules in Subpart A apply to every holder. FCL.025 sets the theoretical knowledge examinations, with a 75 per cent pass mark in each paper; FCL.045 requires the licence, medical certificate and photographic identification to be carried; FCL.055 sets the language proficiency endorsement; and FCL.065 stops a pilot acting as pilot in commercial air transport from age 65. The licence itself does not expire. What lapses are the ratings, the medical and recency, each on its own cycle (see class and type ratings and medical certification).

View full schematic

FAA pilot certificates

The FAA issues a pilot certificate rather than a licence. Part 61 provides student, sport, recreational, private, commercial and airline transport pilot certificates, plus flight instructor certificates, with category, class, type and instrument ratings entered on them. A type rating is required for aircraft over 12,500 lb maximum take-off weight and for any turbojet-powered aeroplane. Minimum ages are 17 for the private certificate (16 for glider and balloon ratings), 18 for the commercial and 23 for the airline transport pilot certificate, or 21 for the restricted ATP.

Like an EASA licence, an FAA certificate does not expire. Its privileges depend on a medical certificate under Part 67, or BasicMed for some private flying, on a flight review every 24 calendar months under 61.56, and on recent experience for carrying passengers and flying under IFR. A pilot carries the certificate, the medical and government-issued photo identification. The licences themselves are detailed in student, private and recreational pilot licences and commercial and airline transport pilot licences.

Part 61 vs Part 141 training

US pilots reach the same certificate by two training routes. The nearest European parallel is the choice between integrated and modular courses, but in Europe professional courses of both kinds are run by ATOs:

Part 61 vs. Part 141 is therefore a trade between flexibility and structure, and in Part 141 the structure earns lower minimum hours. The practical test and the certificate are the same. Part 142 certificates training centres that deliver most of their training in simulators, typically for type ratings.

Approved and declared training organisations

In Europe every course for a professional licence, the instrument rating or a type rating must be delivered by an Approved Training Organisation (ATO), approved by its competent authority under Part-ORA. An ATO has a head of training and a management system, and it runs integrated courses, which take a student with little or no experience to a CPL or ATPL in one programme, or modular courses taken in stages. The training organisation recommends the candidate for the theoretical knowledge examinations, and the recommendation is valid for 12 months. For the professional licences and the instrument rating, all papers must be passed within 18 months of the end of the calendar month of the first attempt, in no more than six sittings, with no more than four attempts at any one paper.

A Declared Training Organisation (DTO), introduced by Regulation (EU) 2018/1119, does not need approval: it declares its activity to the competent authority and is then overseen by it. DTOs may train for the leisure licences, such as the LAPL and PPL, and associated ratings such as the night rating. Professional training, including the CPL, MPL, ATPL theory, the instrument rating and type ratings, remains with ATOs.

Foreign licence validation

A licence is valid first of all for aircraft registered in the State, or for Part-FCL the group of States, that issued it. To fly an aircraft registered elsewhere, a pilot usually needs that State's own licence, or a validation of the foreign one. The FAA, for example, allows a US-registered aircraft to be flown within a foreign country on a licence issued by that country (14 CFR 61.3).

In the EU, acceptance of third-country licences is governed by Delegated Regulation (EU) 2020/723, which took over the former Article 8 and Annex III of Regulation (EU) No 1178/2011. It provides two routes: validation, a limited acceptance of the foreign licence under conditions, and conversion, the issue of a Part-FCL licence with credit for the foreign one. Converting an FAA licence for professional use typically means an EASA medical, the EASA theoretical examinations and a skill test.

In the United States, 14 CFR 61.75 allows the holder of a licence at private level or higher from an ICAO Contracting State to be issued a foreign-based pilot certificate: a US private pilot certificate issued on the basis of the foreign licence, without a knowledge or practical test. The FAA first verifies the licence with the issuing authority. The certificate carries private privileges only, even for an ATPL holder; it is valid only while the foreign licence is in the pilot's possession or readily accessible in the aircraft; and an instrument rating held on the foreign licence can be added by passing the Instrument Rating Foreign Pilot knowledge test. Flying for hire needs a full FAA certificate.

Language proficiency requirements

Since 5 March 2008, ICAO language proficiency requirements have applied to pilots of aeroplanes, airships, helicopters and powered-lift, to air traffic controllers and to aeronautical station operators. They must be able to speak and understand the language used for radiotelephony communications to at least Operational Level 4, and the level is endorsed on the licence. Holders below Expert Level 6 are formally re-evaluated at intervals.

• EASA. Under FCL.055, a pilot required to use the radiotelephone needs a language proficiency endorsement in English or in the language used for the flight's radio communications, at Level 4 or above. Instrument rating holders must also have demonstrated the ability to use English. Level 4 is re-evaluated every four years, Level 5 every six, and Level 6 needs no further evaluation.
• FAA. English language proficiency (ELP) is a condition of each pilot certificate: applicants must be able to read, speak, write and understand English. The FAA applies the ICAO Level 4 standard and marks certificates "English Proficient", with guidance in AC 60-28B.

ICAO proficiency levels

The ICAO rating scale, explained in Doc 9835, has six levels and six skills: pronunciation, structure, vocabulary, fluency, comprehension and interactions. A candidate's level is the lowest score in any of the six skills, not an average.

Only Levels 4 to 6 permit operational use of the radio. The language proficiency endorsement (ICAO Levels 4 to 6) is therefore as much a part of a working licence as its ratings, and for a pilot who must use the radio, an expired Level 4 endorsement is as grounding as an expired medical. How the language is used in practice is covered in aeronautical telecommunication services and flight deck communication.

Library articles are written for study and exam preparation. They do not replace your aircraft's approved documentation, your operator's procedures or the regulations themselves.