General Aviation

Dear friends,
can you share any experience and news in this topic?
It is still very important as the number of pilots using non-EASA but national light aircraft is still growing...

Dear Marcia,
A few years later but hopefully these insights are still helpful.

As a best practice, we initially applied the ORO.FTL framework within our ATO. However, as you and Luca rightly pointed out, it quickly became clear that its relevance is quite limited in this environment. While a line pilot might perform 3 - 4 landings per day, a FI can easily conduct 10 or more in a single training session.

Although ORO.FTL provides a structured framework, it's designed specifically for CAT under an AOC, and the nature of instructional operations within an ATO is quite different. In practice, applying FTL to ATO operations does not bring significant benefits.

To clarify the regulatory picture, we looked into the applicable rules and determined the following:

- For airline crews operating under an AOC, the EASA FTL rules (Regulation (EU) 965/2012) take precedence over national labor laws when it comes to duty and rest time.

- This does not apply to flight instructors working in an ATO, since they are not operating under an AOC. Therefore, FTL rules do not govern their duty time.

- Instead, national labor law applies — covering working hours, rest periods, and employment conditions for instructors.

While EASA regulations like Part-FCL and Part-ORA define the qualifications and oversight requirements for instructors and ATOs, they do not include any provisions on working or rest time.

As a result, any limitations on instructor duty time should come from:
1) Internal company policy,
2) Sector-specific regulations, or
3) Collective labor agreements.

All of which must comply with the respective national labor legislation and may be enforced by local labor authorities.

You mentioned Portugal in your earlier message - and speaking from experience here in Spain, I would expect a similar legal setup applies. It may be worthwhile to check your national labor code or any relevant agreements specific to aviation training.

Hope this is useful for others in the community as well!

However, please note: my post reflects our internal understanding and experience. It does not constitute legal advice, and I advice to refer to consult and conclude with legal or regulatory experts for authoritative guidance.

Best
Keno