New interpretation of FCL.025 concerning the validity of ATPL-theory

Due to a new interpretation of FCL.025 in regulation (EU) 1178/2011 that the Swedish Transport Agency has obtained from EASA, it will only be possible to obtain a CPL-licence during the initial 36 months after having completed an ATPL theoretical examination. This in differ from the previous interpretation, where it was sufficient to have a PPL with an IR or type rating (for ATPL(H)VFR) to keep the ATPL-theory valid for a later issue, past the initial 36 months, of a CPL-licence.

The new interpretation will enter into force on the 1^st of June 2023. The new interpretation will not be applied retroactively. This means that if you are a PPL licence holder with a passed ATPL theoretical examination, you will have to obtain a CPL licence by the latest 1^st of June 2026. If you currently are a student with an ongoing theoretical ATPL examination, you will have 36 months to obtain a CPL-licence from the day you pass your ATPL-examination.

The information below describes in detail how the new interpretation will affect PPL licence holders with a valid ATPL-theory. Affected licence holders will receive this information via mail and e-mail.

For students who have commenced but not finished an ATPL-examination:

• ATPL(A):
  Your theoretical examination will remain valid for 36 months from the date you pass your theoretical examination, for the issue of a CPL-licence. The validity period may then be extended further by obtaining an instrument rating within the same 36 month period.
  
  
• ATPL(H):
  Your theoretical examination will remain valid for 36 months from the date you pass your theoretical examination, for the issue of a CPL-licence, and in case of an ATPL(H)IR-examination, an instrument rating. The validity of the theoretical ATPL-examination may then be extended by obtaining a type rating.

Holders of a PPL(A) who have passed an ATPL(A) theoretical examination:

• If you do not hold an instrument rating:
  You have 36 months to obtain an instrument rating from the date you passed your theoretical examination, in order to extend the validity of your theoretical ATPL-examination. You also have until the 1st of June 2026 to obtain a CPL-licence.
  
  
• If you hold an instrument rating:
  With a valid theoretical ATPL examination which has been extended by an instrument rating, you have until the 1st of June 2026 to obtain a CPL-licence.

Holders of a PPL(H)-licence who have passed an ATPL(H)IR theoretical examination:

You have 36 months to obtain an instrument rating, from the date you passed your theoretical examination, in order to extend the validity of your theoretical ATPL-examination. You have until the 1st of June 2026, at the latest, to obtain a CPL-licence.

If you haven’t obtained an instrument rating within 36 months from the date you passed your theoretical examination, but have obtained a type rating, the instrument rating part of the examination will expire. However, you will keep the ATPL(H)VFR theory. The CPL-licence will have to be obtained by the latest of 1st of June 2026.

Holders of a PPL(H)-licence who have passed an ATPL(H)VFR theoretical examination:

• For you without a type rating:
  You have 36 months to obtain a type rating, from the date you passed your theoretical examination. You then have until the 1st of June 2026, at the latest, to take a CPL-licence.
• For you with a type rating:
  With a valid theoretical ATPL examination which has been extended with a type rating, you have until the 1st of June 2026, at the latest, to obtain a CPL-licence.