The CS-FSTD(A) - issue 2 was published on 3rd May 2018. When does the applicant/operator need to comply with issue 2?
Article 2 of the ED Decision 2018/006/R) states:
“This decision shall enter into force on the day following that of its publication in the Official Publication of EASA.”, which is the 4th of May 2018.
It means that the decision has been adopted and published - thus producing legal effects -, but is not necessarily mandatory on the date of entry into force. From that date on you may use Issue 2 for the qualification of a device, however, the use of the initial issue of CS-FSTD(A) is still possible.
The date when CS-FSTD(A) issue 2 becomes mandatory is the date of applicability of the ED decision. This date will be the “applicability date of the related Commission Regulation (which has been prepared based on EASA Opinion No 06/2017) that introduces new requirements on loss of control prevention and recovery training (UPRT) into Commission Regulation EU 1178/2011”.
The publication of this Commission Regulation is still pending but is expected for April 2019 (unless the date is further extended due to delays with the regulation).
From this date, any application for initial FSTD qualifications (letter of application) shall be against CS-FSTD(A) issue 2, in accordance with ORA.FSTD.210 (a)(1):
“The qualification basis for the issuance of an FSTD qualification certificate shall consist of: (1) the applicable Certification Specifications established by the Agency that are effective on the date of the application for the initial qualification;”