After the licensing review completed by the CAA in October 2025, revalidating a PPL SEP rating by experience got easier, in one sense, but a little bit
more demanding in another.
Hours required
The old rules were 12 hours flight experience in the second year of validity of the 2 year rating – but bizarrely, none in the first year of validity.
The new requirement is still 12 hours total, but under the new rules these hours can be done over 2 years, which allows more flexibility and the opportunity to spread out the cost of flying. Specifically, the experience requirement over the 2 years is
- 12 hours total time,
- of which 6 hours PiC
- including 12 take offs and landings as sole manipulator of the controls
- a flight with an instructor of at least 1 hour
The new rules stipulate that at least 6 hours (not necessarily PiC) must be flown in the second year of rating validity, but the other requirements can be met at any time during the 2 years.
The biennial instructional flight
As guidance, the CAA have written GM2, AMC1 and AMC3 to FCL.740.A which can be found on their website here. The aim of the flight is to refresh little-practiced exercises, extend skills, and ensure that flying is safe and competent. There is a lengthy menu of potential topics and exercises from which we can choose.
Exercises like stalls, steep turns , a practice forced landing and glide or flapless landings would normally be in the mix, as most pilots don’t practice them regularly. The CAA also expect TEM (threat and error management), the use of an MMD (moving map display) such as SkyDemon and partial power-loss scenarios to be covered. Some of these merit a thorough briefing. At my school, we typically do an hour of ground school before the flight itself, which may extend to more than an hour. The briefing often identifies gaps in knowledge, useful exercises, or indeed things the pilot avoids doing through lack of confidence. That’s all grist for the mill.
Other relevant tests
Previously, it was common practice to accept a pass in e.g. an IR or IMC rating revalidation test, in lieu of the 1 hr SEP instructional flight. It is questionable whether this ever was permitted – the wording in according to the Regulations (FCL.740.A), perhaps badly drafted, suggested that it was not acceptable. To clarify things, the CAA have now stated that the 1 hr instructional flight CAN be combined with an IR or IMCR revalidation test BUT some elements of the SEP instructional flight must be included in that test.
Satisfactory standard
One much debated point is the need to achieve a satisfactory standard – without which the instructor should not sign off the rating revalidation page. In a TrainingCom sent to Instructors and Examiners, available here, the CAA defines ‘satisfactory standard’ as that to be expected during a PPL/LAPL skills test (LST). That has the status of guidance, but the CAA intend to issue further regulatory material as an AMC or GM later in 2026.
You may well ask how the instructional refresher flight differs from a test? In several ways, I think.
- Firstly, a test is, in principle, a single attempt (pass / fail) for a comprehensive set of exercises without input from the examiner. In the training flight, the exercises flown may – if necessary – be briefed beforehand, demo’d by the instructor and practiced by the candidate to achieve a satisfactory standard. Bear in mind, though, that a lot of demo and practice, will exceed the 1 hour minimum, but that’s fine – we can plan for that.
- Secondly, the menu of exercises is not rigid. The flight will invariably comprise some essential safety-related exercises but the content should be tailored to the pilot’s experience, recency and needs. The context of the location may also be relevant. The need to fly accurate headings and altitudes, for example, is paramount in areas close to controlled airspace. Considerations for forced landings and partial power depend on the proximity to airfields and the nature of the landscape being flown over.
- Thirdly, the flight is not necessarily a one-shot event. It is perfectly OK to do more than one flight and work with the pilot to improve his flying, if needed.
- Fourthly, a successful test can be logged as PICUS (P1 under supervision). The biennial instruction flight is always logged as PUT.
And finally…..
The flight with an instructor is not (and never has been) a tick-box exercise. A short jolly to have lunch somewhere with your instructor mate won’t cut it. Think what you would like to cover to get best value for money.
I don’t own an N reg aircraft and I don’t hold an FAA licence, so to me these questions are a bit academic. But people do ask from time to time.
How can I get an FAA licence? There are 2 routes.
In my conversations with students during training and PPL holders during rating re-validation, some interesting myths emerge. So let’s put the record straight on a number of air law and licensing questions.