Category: Official documents

Revalidating an SEP rating by experience

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.

LAPL to PPL

Stop Press: effective  1 October 2025, the UK CAA has changed the crediting rules for holders of NPPL(A), NPPL(M) and LAPL(A) licences who wish to ‘upgrade’ to a PPL.  This blog has been updated with the latest rules.

After Brexit, a UK issued LAPL was no longer recognized outside the UK, even though it was identical to the EASA LAPL.  (There are some exceptions – e.g.  for some specific conditions such as an LAA permit aircraft + LAPL in France). It is unlikely that UK-EASA mutual recognition of so-called sub-ICAO qualifications will happen any time soon, if ever.

Some LAPL holders wanting to fly in EU airspace are asking….can I “upgrade” to a PPL?

The answer is yes, and it’s not that difficult. According to the new rules:

  • there is no mandated training (it was 4 hours, now it’s as required)
  • LAPL PiC hours all count towards the PPL requirement of 10 hrs solo
  • if a LAPL holder has done the qualifying cross country flight (150 nm, 2 intermediate landings) as part of their flying, that counts for the QXC requirement.

Candidates would still need to

  • make an assessment flight at an ATO or DTO
  • do any required training at an ATO / DTO
  • hold a class 2 medical (though that can be replaced by a PMD once the PPL has been achieved)
  • pass the PPL skills test
  • pass the FRTOL practical test if a FRTOL is not already held

What does this mean in practice?

  • check you’ve got a flight which counts as the ‘qualifying cross country’, i.e. 150 nm, 2 intermediate landings, all on one day as PiC (with some proof – e.g. SkyDemon logs or landing fee receipts)
  • read CAA Standards Document 19 which describes the PPL test
  • practice flying to a high standard (see the tolerances in Standards Document 19) – altitude +/- 150 ft or better, heading +/- 10 degrees – the 2 common failings
  • practice steep turns etc, possibly PFL’s and stalls if you feel comfortable doing that solo, or with a safety pilot
  • practice intercepting and tracking a VOR radial. If you’ve no nav radio, you can simulate this using SkyDemon to intercept and track a chosen magenta line using the SkyDemon HSI
  • if necessary, brush up your practical knowledge of air law, met, flight panning (take off perf, M&B), aircraft knowledge ready for the oral part of the skills test

Most of that can be done without paying an instructor!

The training could all be done in a day or two for a competent pilot

  • expect a 1-1.5 hours assessment flight to see which aspects of the pilot’s skills need work, i.e. to define ‘the course’
  • a few hours of ground school to revise key techniques
  • a few hours flying to teach / practice all the skill test manoeuvres and navigation techniques, and un-pick any bad habits
  • a mock skills test (2 hrs)

FAQ’s

Can I hire a freelance instructor to do the training at my home base?

Only if he or she is a DTO, or if his / her ATO approves using an alternative location.

I’ve logged plenty of long cross-countries – will that count as the QXC?

Yes – if it was more than 150 nm with 2 intermediate landings, as PiC throughout, all in one day – with some proof

I’ve done plenty of solo circuits – do they count?

Yes– all solo flying counts

Can I train and test in my own aircraft?

In principle yes. An ATO will want to see the aircraft documents and verify that the aircraft is safe and suitable for the training. They may record it as a temporary addition to their fleet. They may be reluctant if their instructors are not familiar with the aircraft type, or if the instructor seat has limited controls or instruments.

I don’t have a Nav radio. Can I still do the test in my own aircraft?

Maybe. There are several options here:

  • In your own aircraft, demonstrate the radio nav work with a handheld nav radio
  • If the ATO agrees, substitute VOR work with intercepting and tracking a GPS track (magenta line) using the SkyDemon HSI
  • Take a split test. Fly the general handling and circuit work in your own aircraft, and use a suitably equipped (ATO) aircraft for the navigation test
  • Do the entire test in an ATO aircraft.

Can’t I just do the radio nav part of the test in an ATO aircraft, to save cost?

No – the only way in which a test can be split is ALL the general handling circuits and emergencies + ALL the navigation work.

Still interested?

Then talk to your local ATO, DTO or instructor!

Source:

The Consolidated Regulation, Acceptable Means of Compliance and Guidance Material to UK Regulation (EU) No. 1178/2011. The way this regulatory stuff works is a cascade. Everything numbered FCL.2xx refers to PPL

 

LSA’s in Europe (again)

It’s the middle of summer, with travel plans made or indeed already flown.  I’m returning to the question of permits for UK registered factory built LSA’s (i.e. UK Permit aircraft), which cannot be operated freely in EU members states without specific permissions. Below is a list of the permission requirements and processes for different countries:

SWEDEN – apply at  https://www.transportstyrelsen.se/en/Forms/Aviation/Airworthiness/Application-for-permission-to-fly-within-Swedish-airspace-with-foreign-registered-aircraft-which-has-not-an-approved-ICAO-CoA-or-EASA-Permit-to-fly1/

IRELAND – fill out form 138C: https://www.iaa.ie/docs/default-source/publications/forms/airworthiness-application-forms/awsd-f-138c-rev-2.pdf?sfvrsn=c4ab0df3_20  with copies of Certificate of Registration, UK CAA flight permit, permit conditions (form 18B and the Datasheet). Send to  arc@iaa.ie  If o response, contact Ruth Bagnell, Aeronautical Inspector, Tel.: + 353 1 603 1463, Mob: + 353 87 279 8054, Ruth.BAGNELL@iaa.ie . There is no fee and the permit was for 12 months.

FRANCE – Step 1….. Go to https://redevances.dcs.aviation-civile.gouv.fr/index.php/laissez-passer-permit-to-fly.html/ and select “Validation d’un certificat étranger – MTOW < 5,7. create an account and reply to the confirmation email. Then pay 50 euros online. Take a screenshot of the payment page in case the pdf receipt by email gets lost (it takes several hours). Step 2….. Download, complete and save form LP6. Google “France form LP6” to find it. Step 3…. Send form by email to dsac-nav-bf@aviation-civile.gouv.fr , with relevant aircraft documentation –  “Airworthiness document issued by the State of registry, along with the associated validity certificate and/or operating limitations =  UK Permit, the EASA form 18B and the aircraft Datasheet). Include the receipt for payment. The permit arrives in a few working days. Mine was valid until 7 days before permit expiry, so it’s a once per year exercise.

BELGIUM – go to https://mobilit.belgium.be/en/Temporary_permission_to_fly and download the application form. Fee 108 euros.

NETHERLANDS – use form ILT.231 here . When I applied, permission was refused because my aircraft is not one of the categories covered by the tick boxes on the form. The Dutch allow microlights into their airspace and also amateur built aircraft – both on the basis of the ECAC agreement- but not factory built permit aircraft. We have taken this up with the NL branch of AOPA who are addressing it with the Dutch NAA but there has been no progress.

GERMANY – apply here https://www.lba.de/EN/Operations/EntryPermissions/Restricted_Authorisation.html?nn=2099536. No fee, max 180 days. Two working days notice are required.