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 1st of June 2023. The new interpretation will not be applied retroactively. This means that if you are a PPL licence holder with a passed and valid theoretical examination to ATPL, you may have up to the 1st of June 2026 to obtain a CPL licence. However, this requires that the PPL was issued by the Swedish Transport Agency prior to the 10th of March 2023 and that the theoretical ATPL examination was completed prior to this date. Please see how you are affected in the specific cases below. 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.