NPA 2024-08

Dokumendiregister	Transpordiamet
Viit	1.8-5/25/212-1
Registreeritud	06.01.2025
Sünkroonitud	07.01.2025
Liik	Sissetulev kiri
Funktsioon	1.8 Rahvusvahelise koostöö korraldamine
Sari	1.8-5 Rahvusvaheline kirjavahetus lennundusohutuse küsimustes: ECAC, ICAO, EASA, Eurocontrol, State Letterid
Toimik	1.8-5/2025
Juurdepääsupiirang	Avalik
Juurdepääsupiirang
Adressaat	Euroopa Lennundusohutusamet
Saabumis/saatmisviis	Euroopa Lennundusohutusamet
Vastutaja	Mari Toodu (Users, Tugiteenuste teenistus, Õigusosakond)
Originaal	Ava uues aknas

Dokument on kokkuvõtte tegemiseks liiga mahukas (703469 tm).

Failid

npa_2024-08_a.pdf

npa_2024-08_b.pdf

npa_2024-08_c.pdf

npa_2024-08_d.pdf

npa_2024-08_e.pdf

npa_2024-08_f.pdf

npa_2024-08_a.pdf

European Union Aviation Safety Agency

Notice of Proposed Amendment 2024-08 (A) in accordance with Article 6(1) of MB Decision 01-2022

TE.RPRO.00034-013 © European Union Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 1 of 37

An agency of the European Union

Enabling electronic personnel licensing in Europe RMT.0737

EXECUTIVE SUMMARY

The purpose of this rulemaking activity is to establish the requirements for the introduction and implementation of personnel licences in electronic format (electronic personnel licences (EPLs)) within the EU regulatory framework. The objectives are to:

1. enable the issuance, display, validation, and verification of EU EPLs on self-contained mobile electronic visual display devices, in addition to the traditional physical format (e.g. paper or plastic cards). EPLs will be optional, but national competent authorities (NCAs) shall recognise personnel licences issued in electronic format not only by other EU Member States (MSs) but also by all ICAO Contracting States;

2. ensure the security, confidentiality, data protection, integrity, authentication and accessibility of EPLs;

3. ensure the interoperability of electronic personnel licence systems (EPLSYS) used by different NCAs and stakeholders;

4. incorporate ICAO Annex 1 Standards and Recommended Practices (SARPs) related to implementing an EPLSYS into the relevant EU aviation regulations.

To enable the introduction of personnel licences issued in electronic format and the EPLSYS, amendments are proposed to several regulations. The main topics addressed through the new or amended requirements and associated AMC and GM include:

— new definitions related to the introduction of EPLs;

— new authority requirements on the establishment of EPLSYS enabling authorities to generate, manage and verify such licences;

— new technical specifications for the issuance of EPLs and the establishment of an EPLSYS, based on the ISO/IEC 18013- 5:2021 International Standard and ICAO Doc 10190;

— new EASA Forms for EPLs;

— transitional measures related to the inclusion of medical certificate information in EPLs (for pilot and air traffic controller licences only), allowing authorities to start issuing EPLs while continuing to issue medical certificates in the traditional physical (paper) format;

— provisions permitting EPLs to include information on national privileges outside the scope of EU regulations (e.g. related to ‘Annex I aircraft’), issued in accordance with national legislation and valid only within the territory of the issuing MS;

— simplifications with regard to the current ICAO EPL format, removing the need to include the photograph of the holder, the script signature of the holder (except in the maintenance domain), and the seal or stamp of the issuing authority.

REGULATION(S) TO BE AMENDED — Commission Regulation (EU) No 1178/2011 (aircrew); — Commission Regulation (EU) 2015/340 (air traffic controllers’

licences and certificates); — Commission Regulation (EU) No 1321/2014 (continuing

airworthiness); — Commission Regulation (EU) No 2018/1976 (sailplanes); — Commission Regulation (EU) No 2018/395 (balloons).

ED DECISION(S) TO BE AMENDED ED Decisions that issue the acceptable means of compliance (AMC) and guidance material (GM) to support the application of those Regulations

AFFECTED STAKEHOLDERS

NCAs, holders of a pilot licence, holders of an air traffic controller licence, holders of an aircraft maintenance licence; instructors;

examiners; training organisations; aircraft operators; maintenance organisations; aero-medical examiners and aero-medical centres.

WORKING METHODS

Development Impact assessment(s) Consultation

By EASA with external support Light Public – NPA

RELATED DOCUMENTS / INFORMATION ToR RMT.0737, issued on 20.9.2022

PLANNING MILESTONES: Refer to the latest edition of EPAS Volume II.

European Union Aviation Safety Agency NPA 2024-08 (A)

Table of contents

An agency of the European Union

Table of contents

1. About this NPA ........................................................................................................................ 3

1.1. How this regulatory material was developed .......................................................................... 3 1.2. How to comment on this NPA .................................................................................................. 3 1.3. The next steps .......................................................................................................................... 3

2. In summary — why and what ................................................................................................... 5

2.1. Why we need to act — issue/rationale .................................................................................... 5 2.2. Description of the issue ............................................................................................................ 5 2.3. Assessment of the issue ........................................................................................................... 5 2.4. Who is affected by the issue .................................................................................................... 5 2.5. How could the issue evolve ...................................................................................................... 6 2.6. What we want to achieve — objectives ................................................................................... 6 2.7. How we want to achieve it — overview of the proposed amendments .................................. 7

2.7.1. Amendments applicable to all domains within the RMT scope ........................................ 8 2.7.2. Specific proposed amendments to the existing requirements of Commission Regulation (EU) 1178/2011 (aircrew) .............................................................................................................. 14 2.7.3. Specific proposed amendments to existing requirements of Commission Regulation (EU) 2015/340 (ATCO) ................................................................................................................... 15 2.7.4. Specific proposed amendments to existing requirements of Part-66 (Annex III to Commission Regulation (EU) No 1321/2014 (continuing airworthiness)) .................................... 17

3. What are the expected benefits and drawbacks of the proposed regulatory material ............ 22

4. Proposed regulatory material ................................................................................................. 25

5. Monitoring and evaluation ..................................................................................................... 26

6. Proposed actions to support implementation ........................................................................ 27

7. References ............................................................................................................................. 28

Appendix 1 — Details on the impact assessment .......................................................................... 29

1. Overview of the analysed options .......................................................................................... 29 2. Assessment of the options ..................................................................................................... 30 3. Conclusion .............................................................................................................................. 36

Appendix 2 — Quality of the NPA ................................................................................................. 37

1. The regulatory proposal is of technically good/high quality .................................................. 37 2. The text is clear, readable, and understandable .................................................................... 37 3. The regulatory proposal is well substantiated ....................................................................... 37 4. The regulatory proposal is fit for purpose (achieving the objectives set) .............................. 37 5. The regulatory proposal is proportionate to the size of the issue ......................................... 37 6. The regulatory proposal applies the ‘better regulation’ principles ....................................... 37 7. Any other comments on the quality of this document (please specify) ................................ 37

European Union Aviation Safety Agency NPA 2024-08 (A)

1. About this NPA

An agency of the European Union

1. About this NPA

1.1. How this regulatory material was developed

The European Union Aviation Safety Agency (EASA) developed this Notice of Proposed Amendment

(NPA) in line with Regulation (EU) 2018/11391 (the ‘Basic Regulation’) and the Rulemaking Procedure2,

in the context of Rulemaking Task (RMT).0737. This task is included in Volume II of the European Plan

for Aviation Safety (EPAS) for 2023-20253 and its scope and overall timescales are defined in the

related Terms of Reference (ToR)4.

This regulatory proposal was developed by EASA with the support of rulemaking group (RMG).0737.

1.2. How to comment on this NPA

The NPA is hereby submitted to all interested parties for consultation in accordance with Article 115

of the Basic Regulation, and Article 6(1) of the Rulemaking Procedure.

Please submit your comments using exclusively the dedicated Comment-Response Tool (CRT)

available at https://hub.easa.europa.eu/crt/5.

The deadline for the submission of comments is 19 March 2025.

1.3. The next steps

Following the consultation of the draft regulatory material, EASA will review with the support of

RMG.0737 all the comments received and will duly consider them in the subsequent phases of this

rulemaking activity.

Considering the above, EASA may issue an Opinion proposing amendments to the following

Regulations:

(a) Commission Regulation (EU) No 1178/20116 (aircrew);

1 Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common rules in the field of

civil aviation and establishing a European Union Aviation Safety Agency, and amending Regulations (EC) No 2111/2005, (EC) No 1008/2008, (EU) No 996/2010, (EU) No 376/2014 and Directives 2014/30/EU and 2014/53/EU of the European Parliament and of the Council, and repealing Regulations (EC) No 552/2004 and (EC) No 216/2008 of the European Parliament and of the Council and Council Regulation (EEC) No 3922/91 (OJ L 212, 22.8.2018, p. 1) (http://data.europa.eu/eli/reg/2018/1139/oj).

2 EASA is bound to follow a structured rulemaking process as required by Article 115(1) of Regulation (EU) 2018/1139. Such a process has been adopted by the EASA Management Board (MB) and is referred to as the ‘Rulemaking Procedure’. See MB Decision No 01-2022 of 2 May 2022 on the procedure to be applied by EASA for the issuing of opinions, certification specifications and other detailed specifications, acceptable means of compliance and guidance material ('Rulemaking Procedure'), and repealing Management Board Decision No 18-2015 (EASA MB Decision No 01-2022 on the Rulemaking Procedure, repealing MB Decision 18-2015 (by written procedure) | EASA (europa.eu)).

3 European Plan for Aviation Safety (EPAS) 2023-2025 | EASA (europa.eu) 4 ToR RMT.0737 - Enabling electronic personnel licensing in Europe | EASA (europa.eu) 5 In case of technical problems, please send an email with a short description at [email protected]. 6 Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and administrative

procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 311, 25.11.2011, p. 1) (http://data.europa.eu/eli/reg/2011/1178/oj).

European Union Aviation Safety Agency NPA 2024-08 (A)

1. About this NPA

An agency of the European Union

(b) Commission Regulation (EU) 2015/3407 (air traffic controllers’ licences and certificates);

(d) Commission Implementing Regulation (EU) 2018/19769 (sailplanes);

(e) Commission Regulation (EU) 2018/39510 (balloons).

The Opinion will be submitted to the European Commission which shall consider its content and

decide whether to issue amendments to the related Regulations.

When issuing the Opinion EASA will also provide feedback to the commentators and information to

the public on who engaged in the process and/or provided comments during the consultation of the

draft regulatory material, which comments were received, how such engagement and/or consultation

was used in rulemaking, and how the comments were considered. Further to the issuing of the

Opinion, EASA will issue Decisions with associated AMC and GM to support the application of the

above-mentioned Regulations.

7 Commission Regulation (EU) 2015/340 of 20 February 2015 laying down technical requirements and administrative

procedures relating to air traffic controllers' licences and certificates pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council, amending Commission Implementing Regulation (EU) No 923/2012 and repealing Commission Regulation (EU) No 805/2011 (OJ L 63, 6.3.2015, p. 1) (http://data.europa.eu/eli/reg/2015/340/oj)

8 Commission Regulation (EU) No 1321/2014 of 26 November 2014 on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these tasks (OJ L 362, 17.12.2014, p. 1) (http://data.europa.eu/eli/reg/2014/1321/oj).

9 Commission Implementing Regulation (EU) 2018/1976 of 14 December 2018 laying down detailed rules for the operation of sailplanes pursuant to Regulation (EU) 2018/1139 of the European Parliament and of the Council (OJ L 326, 20.12.2018, p. 64) (http://data.europa.eu/eli/reg_impl/2018/1976/oj).

10 Commission Regulation (EU) 2018/395 of 13 March 2018 laying down detailed rules for the operation of balloons pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 71, 14.3.2018, p. 10) (http://data.europa.eu/eli/reg/2018/395/oj).

European Union Aviation Safety Agency NPA 2024-08 (A)

2. In summary — why and what

An agency of the European Union

2. In summary — why and what

2.1. Why we need to act — issue/rationale

Having regard to the adopted Amendment 178 to ICAO Annex 1 regarding the introduction of the

electronic personnel licence11, EASA needs to act to transpose these ICAO requirements into the EU

regulatory framework. Failing to do so may lead to difference with the ICAO SARPs and even difficulty

in accepting personnel licences issued in electronic format by other ICAO Contracting States in the EU.

The latter is due to the fact that the ICAO Annex 1 amendments set up an obligation for all ICAO

Contracting States to accept personnel licences issued in electronic format issued by other Contracting

States, although the issuance of personnel licences in electronic format remains a free choice. In order

to ensure transposition of ICAO standards and to promote level playing field across EU MSs, EASA

decided to take a regulatory action through RMT.0737.

2.2. Description of the issue

At present, the EU regulatory framework does not address the issuance and management of personnel

licences issued in electronic format. However, ICAO through the adoption of Amendment 178 to

Annex 1 has introduced provisions allowing ICAO Contracting States to introduce personnel licences

issued in electronic format and ensuring their recognition amongst all ICAO Contracting States.

2.3. Assessment of the issue

Amendment 178 to ICAO Annex 1 refers to the introduction of personnel licences issued in electronic

format. In the EU regulatory framework, personnel licences are regulated in three domains: aircrew

for pilot licences, continuing airworthiness for aircraft maintenance licences, and ATCO for (student)

air traffic controller licences.

Currently no EU MS issues personnel licences in electronic format in the aircrew domain, even though

there is a strong interest from some EU MSs, having regard to the pace of their digitalisation.

In the continuing airworthiness and ATCO domains, there are some individual initiatives from EU MSs

to issue personnel licences in electronic format in addition to the licence issued in physical format, but

they do not follow common standards. If not addressed in the future, the current situation may lead

to significant differences and a global lack of interoperability.

Considering the digitalisation and automation in the aviation, as well as interest of EU MSs to

introduce personnel licences issued in electronic format, as is the case in other transport domains (e.g.

electronic driving licences), there is a clear need for an EU regulatory framework which will enable

proper issuance and oversight of the personnel licences issued in electronic format by the EU MS

competent authorities.

2.4. Who is affected by the issue

Stakeholders affected are the NCAs of the EU MSs, holders of a pilot licence, holders of an ATCO

licence, holders of an aircraft maintenance licence, instructors, examiners, training organisations,

11 While ICAO Annex 1 uses the term ‘electronic personnel license’ (EPL), this NPA uses the term ‘personnel licence issued

in electronic format’.

European Union Aviation Safety Agency NPA 2024-08 (A)

2. In summary — why and what

An agency of the European Union

aircraft operators, maintenance organisations, aero-medical examiners and aero-medical centres. The

stakeholders would be not equally affected. As the decision to introduce personnel licences issued in

electronic format is voluntary, the affected stakeholders would be mainly those of the EU MSs where

personnel licences will be issued in electronic format. Nevertheless, all other EU MSs have an

obligation to accept personnel licences issued in electronic format. Consequently, these EU MSs would

be affected, even though they have not (yet) issued personnel licences issued in electronic format.

2.5. How could the issue evolve

A lack of regulatory action to introduce licences issued in electronic format may result in:

— difference of the EU regulatory framework from ICAO Annex 1 SARPs as regards the personnel

licences issued in electronic format;

— difficulty for the RAMP inspectors to verify (third-country) personnel licences issued in

electronic format due to the lack of harmonised requirements regulating the issuance and

validation of the personnel licences issued in electronic format.

In addition to the above, if an EU MS decides to develop its own tools for issuing personnel licences

issued in electronic format (due to the lack of common EU requirements), this may lead to

proliferation/divergence of different tools. Consequently, it might result in lack of standardisation of

the personnel licences issued in electronic format across EU, and put at risk the interoperability

between the IT systems developed by different EU MSs.

2.6. What we want to achieve — objectives

The overall objectives of the EASA system are defined in Article 1 of the Basic Regulation. The

introduction of personnel licences issued in electronic format is a strategic priority outlined in the

EPAS, in line with the growing digitalisation of EU public services. It aligns with the EU strategy aimed

at modernising the administration of personnel licences, fostering interoperability of cross-border

systems among licensing authorities to facilitate the movement of aviation personnel, and enabling

digital interactions between licensing authorities and aviation personnel to enhance service quality.

Besides, personnel licences issued in electronic format contribute to the prevention of licence fraud

and forgery via enhanced security means to authenticate and control access to licences. Furthermore,

this regulatory proposal aims at introducing personnel licences issued in electronic format in the EU

regulatory framework, following the adoption of Amendment 178 to ICAO Annex 1 Personnel

Licensing.

The specific objectives of this proposal are to develop and establish the requirements for introducing

personnel licences issued in electronic format within the EU regulatory framework to:

(a) allow the issuance, display, validation and verification of EU personnel licences issued in

electronic format on self-contained mobile electronic visual display devices, as an alternative to

licences issued in physical format (licences printed on paper or other suitable materials,

including plastic cards). Personnel licences issued in electronic format will be an option available

to an EU MS to adopt in lieu of a licence issued in physical format, but EU MSs shall recognise

personnel licences issued in electronic format issued by all other ICAO Contracting States;

(b) ensure the security, confidentiality, data protection, integrity, authentication and accessibility

of personnel licences issued in electronic format; and

European Union Aviation Safety Agency NPA 2024-08 (A)

2. In summary — why and what

An agency of the European Union

different NCAs and relevant stakeholders.

This RMT sets the stage for a competitive European market for digital solutions while granting

flexibility to EU MSs, allowing them to develop their own IT systems and tools to facilitate the

introduction of licences in electronic format.

Furthermore, EASA needs to embrace this topic by enabling personnel licences issued in electronic

format in three domains. Instead of having three different rulemaking tasks for each domain, EASA

considers that the issue can be addressed by applying a total system approach and initiating a single

RMT which encompasses the common standards for issuance and oversight of personnel licences

issued in electronic format across the three domains.

2.7. How we want to achieve it — overview of the proposed amendments

To achieve the aforementioned objectives, EASA shall undertake the following:

(a) Establish a standardised EASA form for personnel licences issued in electronic format, following

the ICAO Annex 1 SARPs. This EASA form will address the specific needs of the aviation sectors

within the scope of this RMT, including flight crew licences, ATCO licences, and aircraft

maintenance licences. The implementation of this EASA form will promote full recognition and

standardisation of personnel licences issued in electronic format among all EU MSs and aims to

encourage comprehensive acknowledgment and standardisation of EU personnel licences

issued in electronic format globally across ICAO Contracting States.

(b) Set requirements, functionalities and performance standards for the IT systems and related

infrastructure (EPLSYS) used for issuing, displaying and verifying personnel licences issued in

electronic format securely, accessibly, and in an interoperable way, while ensuring

confidentiality and data protection. These requirements should address how the EPLSYS

interacts with the existing national personnel licence systems (LICSYS) of EU MSs, including their

examiners and training organisations. Common standards for information security, access rights

and methods for verifying personnel licences issued in electronic format authenticity should be

outlined, enabling consistent implementation of the EPLSYS across all EU MSs.

amending, renewing and overseeing personnel licences issued in electronic format.

(d) Develop domain-specific requirements for the implementation of the EPLSYS in various

personnel licensing domains (such as flight crew licences, ATCO licences, aircraft maintenance

licences), as needed.

(e) Permit each EU MS to develop IT systems and tools, based on the EASA form, for issuing

personnel licences in electronic format under their oversight. These systems and tools should

conform to common EU standards and specifications, promoting standardised and uniform

implementation of the EPLSYS across EU MSs. This approach will ensure interoperability of the

EPLSYS across different IT systems.

The following domain-specific regulations are proposed to be amended to make the introduction of

the licences issued in electronic format and the EPLSYS possible in the three domains:

European Union Aviation Safety Agency NPA 2024-08 (A)

2. In summary — why and what

An agency of the European Union

Aircrew:

(a) Commission Regulation (EU) No 1178/2011 (aircrew);

(b) Commission Implementing Regulation (EU) 2018/1976 (sailplanes);

ATCO:

(d) Commission Regulation (EU) 2015/340 (air traffic controllers’ licences and certificates);

Continuing airworthiness:

(e) Commission Regulation (EU) No 1321/2014 (continuing airworthiness).

2.7.1. Amendments applicable to all domains within the RMT scope

2.7.1.1. Introduction of the personnel licence in electronic format

This NPA proposes to introduce the possibility to issue personnel licences in electronic format, as an

alternative to the traditional issuance of licences in physical format (paper, plastic card). This is in line

with ICAO Annex 1 Chapter 5.1.1, which now gives the possibility to issue personnel licences in physical

format (hard copy) or to issue personnel licences in electronic format.

In line with the amended ICAO provisions, personnel licences will therefore have to conform to one

of the following specifications:

(a) licences issued on first quality paper or other suitable material, including plastic cards; or

(b) personnel licences issued in electronic format on self-contained mobile visual electronic display

devices.

2.7.1.2. New definitions regarding the introduction of the personnel licence in electronic format

This NPA proposes to include new definitions in each domain-specific regulation (Commission

Regulation (EU) No 1178/2011 (aircrew); Commission Regulation (EU) 2015/340 (ATCO) and

Commission Regulation (EU) No 1321/2014 (continuing airworthiness)): two new definitions regarding

the licence issued in physical format and the licence issued in electronic format, one new definition

regarding the electronic personnel licence system (EPLSYS), and one new definition regarding the

device on which the licence issued in electronic format is displayed.

This self-contained mobile electronic visual display device is normally a small portable device that can

easily be carried by a single individual. This device is designed to operate, transmit and receive

information without a wired connection and possesses local, non-removable or removable data

storage. The device includes a self-contained power source, display, and a means for the holder of the

portable computing device to interact with it.

This NPA also proposes to include a new definition regarding the licence in general (for all three

domain-specific regulations) and regarding the medical certificate (for the Aircrew Regulation and

ATCO Regulation). These new definitions are applicable for both the licence and medical certificate

issued in either electronic or physical format.

European Union Aviation Safety Agency NPA 2024-08 (A)

2. In summary — why and what

An agency of the European Union

2.7.1.3. New EASA Forms for the personnel licences issued in electronic format

EASA will introduce three new EASA Forms for the personnel licences issued in electronic format (one

for each domain within the scope of this RMT) which will be part of the already existing Appendices

to each domain-specific regulation:

Aircrew: EASA Form 155 is the new format for a licence issued in electronic format; EASA Form 141 is

the already existing form for a licence issued in physical format.

ATCO: EASA Form 156 is the new format for a licence issued in electronic format; EASA Form 152 is

the already existing form for a licence issued in physical format.

Continuing airworthiness: EASA Form 206 is the new format for a licence issued in electronic format.

EASA Form 26 is the already existing form for a licence issued in physical format.

To transpose the ICAO standard requiring the competent authority to only issue each licence in one

of the two formats (physical or electronic), this NPA proposes to include in the Appendices of each

domain-specific regulation (where both electronic and physical formats are included) a requirement

that the competent authority shall issue a licence in only one of the two possible formats — physical

or electronic.

2.7.1.4. EASA Forms for the licence issued in electronic format: differences v the ICAO Common

Form

This NPA proposes to introduce the Common Form of the Electronic Personnel Licence as introduced

in ICAO Annex 1, Appendix 4. However, it proposes that certain items in the EASA Forms (EASA Forms

155, 156 and 206) differ, for the reasons explained below:

a. Item IVa: Photograph of holder

ICAO Annex 1, Appendix 4 (Common Form of the Electronic Personnel Licence) requires in item IVa a

photograph of the holder. This new requirement has no equivalent in ICAO Annex 1 for the traditional

licence issued in physical format.

Therefore, within the EU MSs, the aircrew licences, the aircraft maintenance licences and the (student)

ATCO licences issued in physical format do not contain a photograph of the holder. This means that

issuing competent authorities lack this information in their licence systems. While adding a

photograph to a licence issued in electronic format is technically feasible, it introduces certain

challenges:

(a) While a photograph aids in identifying the licence holder, many ICAO Contracting States do not

view a licence as a valid identification document.

(b) With the increasing digitalisation of issuing competent authorities, online procedures are

common for licence applications. If a licence holder submits a photograph online, the

competent authority cannot guarantee its accuracy or authenticity. Requiring in-person

applications would be inconvenient for both competent authorities and licence holders.

challenging for licence holders to ensure compliance.

European Union Aviation Safety Agency NPA 2024-08 (A)

2. In summary — why and what

An agency of the European Union

With this NPA, the proposal is to not transpose this ICAO standard, and therefore not to include the

photograph of the holder in aircrew licences, aircraft maintenance licences and (student) ATCO

licences issued in electronic format.

b. Item V: Address of holder

ICAO Annex 1, Appendix 4 (Common Form of the Electronic Personnel Licence) requires in item V the

address of the holder if desired by State. This requirement is equivalent to the one in ICAO Annex 1

for the traditional licence issued in physical format in Chapter 5.2.1, item V. In both formats, such

information is optional.

Today, within the EU MSs, the address of the holder is required to be included in the aircraft

maintenance licence by Appendix VI to Annex III (Part-66) to Commission Regulation (EU) No

1321/2014 and to be included in the aircrew licence by Appendix I to Annex VI (Part-ARA) to

Commission Regulation (EU) No 1178/2011. The address of the holder of the (student) ATCO is

optional in Appendix 1 to Annex II to Commission Regulation (EU) 2015/340.

With this NPA, the proposal is:

(a) to remove the address of the holder of:

— an aircraft maintenance licence issued in physical format;

— a (student) ATCO licence issued in physical format, and

(b) to make the address of the holder an optional piece of information for an aircrew licence issued

in physical format.

The proposal under point (a) is based on assessment and evidence that the loss or theft of the holder’s

licence may result in undesired divulgation of private information, which could be used for ill-

intentioned purposes. Additionally, applicants for an aircraft maintenance licence or changes to their

licences are still required to provide an application form (EASA Form 19) which includes the address

of the applicant (refer to Appendix V to Part-66). Therefore, the competent authority issuing licences

will still collect and possess this information.

c. Item VII: Script signature of holder

ICAO Annex 1, Appendix 4 (Common Form of the Electronic Personnel Licence) requires in item VII the

script signature of the holder. This requirement is equivalent to the one in ICAO Annex 1 for the

traditional licence issued in physical format in Chapter 5.2.1, item VII.

The script signature of the licence holder has traditionally been added after the competent authority

completes the licence issuance procedure. Typically, licences issued in physical format are delivered

to holders by mail, allowing them to sign the licence in physical format upon receipt.

Introducing a requirement for competent authorities to verify the holder’s script signature before

issuing the licence in electronic format, especially in online procedures, seems impractical. Several

issues arise, such as:

(a) Scanned script signatures attached to online applications cannot be verified, making it

challenging for competent authorities to ensure script signature authenticity.

(b) In many countries, a scanned script signature lacks the automatic presumption of legal validity.

European Union Aviation Safety Agency NPA 2024-08 (A)

2. In summary — why and what

An agency of the European Union

(d) Electronic signatures are widely available, and their use is increasing.

(e) Concatenated signing steps (authority, holder) may complicate the issuance of licences.

The electronic signature of the officer issuing the licence, as required in item X of ICAO Annex 1,

Appendix 4 (Common Form of the Electronic Personnel Licence) secures and guarantees the

authenticity and integrity of licence data, excluding the holder’s script signature. According to ICAO

Annex 1, Chapter 5.3.1.3, the electronic signature of the issuing officer is required to conform to

recognised standards and have an appropriate level of security. In the European context, the

recognised standard would be provided by Regulation (EU) No 910/201412 (eIDAS Regulation) and the

appropriate level of security will be at least that of an advanced electronic signature.

Considering all the above, this NPA proposes to not transpose this ICAO standard for the aircrew

licence and (student) ATCO licence issued in electronic format, which means that the script signature

of the holder is not included in their licences.

In the case of aircraft maintenance licences issued in electronic format, the script signature of the

licence holder can be used for comparison with the signature that the licence holder has affixed on

maintenance release documents, including the EASA Form 1 for components and the aircraft

certificate of release to service (CRS). This ensures traceability on the maintenance performed and the

use of privileges granted with the issuance of an aircraft maintenance licence.

Today, this capability is already ensured by the presence of the holder’s script signature on licences

issued in physical format; hence the intention to maintain it for licences issued in electronic format.

Future evolutions on this matter will rely on the use, by all stakeholders, of electronic signatures for

maintenance release documents.

With this NPA it is also proposed that the script signature of the holder of the (student) ATCO on their

licence in physical format is not needed anymore, and to delete this requirement under item V of

Appendix 1 to Annex II to Commission Regulation (EU) No 2015/340. This is done both to keep

consistency between licences issued in electronic format and in physical format, but also because a

script signature in a physical licence is not deemed necessary. With the added requirement for ATCOs

to be able to show a photographic-ID when requested, the ID will contain the required features for

identification of the individual. The licence itself is not suitable for this and therefore it is considered

sufficient to be able to confirm that the personal data of the licence matches the ID, and the ID is then

matched to the ATCO presenting the documents.

d. Item XI a: Seal or stamp of authority issuing the licence

ICAO Annex 1, Appendix 4 (Common Form of the Electronic Personnel Licence) requires in item XIa

the seal or stamp of the authority issuing the licence.

The seal or stamp of the competent authority is deemed an additional security feature in licences

issued in physical format, but it adds no extra functionality to licences in electronic format. The

presence of such seal or stamp of the competent authority does not bring value for identifying the

12 Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification

and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC (OJ L 257, 28.8.2014, p. 73) (http://data.europa.eu/eli/reg/2014/910/oj).

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competent authority issuing the licence and proving the authenticity of the licence issued in electronic

format. The electronic signature of the officer issuing the licence already serves this purpose.

With this NPA, the proposal is to not transpose this ICAO standard, and therefore not to include the

seal or stamp of the authority issuing the licence in the aircrew licence, aircraft maintenance licence

and (student) ATCO licence issued in electronic format.

2.7.1.5 New authority requirements regarding the introduction of the licence issued in electronic

format

New authority requirements in each domain-specific regulation are proposed to be added regarding

the licences issued in electronic format and the establishment of an electronic personnel licence

system (EPLSYS). These new authority requirements follow the structure of the requirements of

Chapter 5 (Specifications for Personnel Licences) in ICAO Annex 1.

Because each domain-specific regulation has its own regulatory structure, this NPA proposes to have

the same new requirements placed in the appropriate parts of each regulation.

These new authority requirements are to be found in:

(a) Commission Regulation (EU) No 1178/2011 (aircrew): point ARA.FCL.130;

(b) Commission Regulation (EU) 2015/340 (ATCO): point ATCO.AR.D.002;

(Part-66).

These requirements contain the following:

The competent authority having issued a licence in electronic format shall ensure that all other

competent authorities are able to determine the licence, rating or certificate privileges and validity;

The authenticity, validity and content of a licence issued in electronic format shall be electronically

verifiable:

(a) online when an internet connection is available; or

(b) offline when no internet connection is available through a means that imposes no undue burden

on the competent authorities verifying the licence.

In the context of issuing licences in electronic format, the competent authority shall establish

procedures for the establishment and operation of an EPLSYS.

The EPLSYS shall ensure interoperability, security, confidentiality, data protection, authentication and

accessibility of the licence issued in electronic format.

Personnel licences issued in electronic format shall:

(a) be displayed on self-contained mobile electronic visual display devices;

(b) replicate the information contained in the competent authority electronic personnel licence

system records.

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2.7.1.6 Technical specifications for the licence issued in electronic format

The issuance of licences in electronic format requires a supporting EPLSYS that allows the generation,

display and verification of the licence. ICAO is developing the technical specifications of a generic

EPLSYS, which are based on the ISO/IEC 18013-5:2021 International Standard (ISO 18013-5). Once

finalised, they will be issued as ICAO Doc 10190 ‘EPL technical specifications for implementation and

verification’ (hereafter: ICAO Doc 10190).

This NPA proposes to introduce an AMC (EPLSYS AMC) to the applicable EU Regulations, in which ISO

18013-5 and ICAO Doc 10190 are referenced. An EPLSYS should be trustworthy and globally

interoperable across licensing competent authorities, not only within the EU MSs but within all ICAO

Contracting States. The EPLSYS should also ensure the security and accuracy of information by meeting

the technical specifications for the establishment and operation of an EPLSYS. Additionally, it should

safeguard the privacy of the licence holder.

Besides the above, the specifications for the implementation of an EPLSYS must provide flexibility to

support competent authorities in the selection of architectures that best meet their needs. Most

licensing competent authorities already make use of IT tools and applications to manage and issue the

licences in physical format, i.e. a licence system (LICSYS) based on different architectures and

technological solutions. Consequently, the EPLSYS specifications must allow the EPLSYS to be

independent from any specific architecture or technical solution, making its implementation possible

in the context of any existing LICSYS.

The proposed EPLSYS AMC is the same for aircrew licences, (student) ATCO licences and aircraft

maintenance licences issued in electronic format.

As each domain-specific regulation has its own regulatory structure, this NPA proposes to have such

AMC placed in different parts of the regulations. This AMC is linked to the following requirements:

(a) Commission Regulation (EU) No 1178/2011 (aircrew): point ARA.FCL.130;

(b) Commission Regulation (EU) 2015/340 (ATCO): point ATCO.AR.D.002;

(Part-66).

The technical specifications included in the proposed EPLSYS AMC are aligned with the draft ICAO Doc

10190. However, in some cases this AMC introduces certain differences when a slightly different

solution is considered to have benefits. These cases are clearly identified in this AMC; for example,

the namespace has been changed from ‘int.icao.epl…’ to ‘int.easa.epl…’ to identify the namespaces

that are not in line with the draft ICAO Doc 10190. EASA is working with ICAO to achieve full alignment

between the two documents before they become applicable.

Finally, licences in electronic format will be subject to verification by inspectors from verifying

competent authorities other than the issuing competent authority, so inspectors not affiliated with

the issuing competent authority must be able to securely access and authenticate the licence in

electronic format. According to ICAO Annex 1, ICAO Contracting States can decide whether to

implement an EPLSYS or not, but they are obliged to accept licences issued in electronic format issued

by other States. At the same time, if a State decides to implement an EPLSYS, it will have to be

implemented in such a manner that it provides all the necessary means for other States to verify its

licences issued in electronic format.

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2.7.1.7 Transitional measures regarding the inclusion of the information of the medical certificate

in licences issued in electronic format (pilot licence and (student) ATCO licence only)

Section 5.3.6. of ICAO Annex 1 states that the electronic personnel licence ‘shall include, when

applicable, the current medical assessment with class, expiry date, and any medical limitations

deemed relevant by the Licencing Authority’.

Today, in the EU system the licence and the medical certificate are two separate types of documents

with significantly different processes and IT systems. Being mindful of the complexity associated with

the migration to an integrated system, the NPA proposes that competent authorities be allowed a

transition period of up to 10 years from the date of entry into force of this Regulation to include the

medical information in the licence issued in electronic format. During such transition period, the

medical certificate may remain in physical format in accordance with Part-MED and Part ATCO.MED.

A new Subtask 2 of RMT.0737 is considered by EASA in order to introduce the medical certificate

issued in electronic format into the licence issued in electronic format well in time before the end of

the transition period of 10 years.

2.7.2. Specific proposed amendments to the existing requirements of Commission Regulation (EU)

1178/2011 (aircrew)

a. Point ARA.FCL.200 Procedure for issue, revalidation or renewal of a licence, rating or

certificate

These requirements were originally written for the licence issued in physical format. This NPA

proposes different requirements for the licence issued in electronic format, as follows:

New points (d), (e), (g) and (h)

In the context of licences issued in electronic format, interactions between the parties involved should

be fully digital and paper processes should be largely eliminated. Processes should be faster and must

not be slower than today’s processes. Digital communication channels should be created and utilised.

Communication and data transfer should take place in real time wherever possible. Access rights for

the corresponding IT systems must therefore be specifically defined and regulated for each use case

(such as revalidation / renewal and the corresponding transmission of documentation).

To make communication and data transfer possible in real time, the new requirements state that

competent authorities shall develop appropriate procedures to grant examiners or evidence-based

training (EBT) managers access to the licensing system of the pilot’s competent authority for the

revalidation and renewal of a rating or certificate on a licence issued in electronic format (point (d))

and issuance of an additional rating or certificate on a licence issued in electronic format (point (e)).

The competent authorities shall also develop appropriate procedures to grant authorised personnel

access to the licensing system of the pilot’s competent authority to enter the new validity date of the

SEP or TMG class rating (point (g)) and the SE piston or turbine helicopter type rating (point (h)).

b. Addition of the new point ARA.FCL.221 Procedure for the update of a pilot licence issued in

electronic format

Point ARA.FCL.220 defines the requirements regarding the procedure for the re-issue of a pilot licence.

These requirements were originally written for the licence issued in physical format.

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To make clear that the procedure for the licence issued in electronic format is different, this NPA

proposes to introduce the new point ARA.FCL.221.

In conjunction with point ARA.FCL.220, this new point ensures that suitable update procedures apply

for licences in electronic format.

2.7.3. Specific proposed amendments to existing requirements of Commission Regulation (EU)

2015/340 (ATCO)

a. Adaptation of the licence definition

According to its definition, licence is a document issued and endorsed in accordance with the

provisions of Commission Regulation (EU) 2015/340. However, with the adoption of the licence issued

in electronic format, the current definition was adapted to suit both formats.

b. Addition of a requirement to carry a personal identification document (new point

ATCO.A.015A)

Today holders of pilot licences or aircraft maintenance licences are required to carry a personal

identification document while exercising the privileges of their licence. For the (student) ATCO there

has been no such requirement. This means that an inspector is not able to confirm that the individual

that presents a licence is in fact the holder of said licence.

To streamline the domains and to rectify this issue, a new provision has been added which requires

(student) ATCOs to carry the licence, the medical certificate and a personal identification document,

while they exercise the privileges of the licence. This provision is based on point FCL.045 of

Commission Regulation (EU) No 1178/2011 (aircrew) and written to be as aligned as much as possible

with the other domains.

c. Amendment to point ATCO.A.020 Revocation and suspension of licences, ratings and

endorsements

The text was amended to reflect that for all licences (issued in either physical or electronic format) the

procedures established for revocation are provided in ATCO.AR.D.005, and the other requirements

are only applicable to the licences issued in physical format.

d. Amendment to point ATCO.AR.D.001 Procedure for the issue, revalidation and renewal of

licences, ratings, endorsements and authorisations

These requirements were originally written for licence issued in physical format; the amendment

clarifies that only one licence format may be used (physical or electronic).

Furthermore, the new AMC2 ATCO.AR.D.001(a)(2) is added to facilitate the use of a temporary

procedure, allowing a controller to exercise a unit endorsement once it has been revalidated or

renewed, but before the electronic licence has been updated.

e. Addition of the new point ATCO.AR.D.002 Licence issued in electronic format and

establishment of an electronic personnel licence system

This new point regulates the establishment of an electronic personnel licence system, which includes

requirements on the issuance of a licence issued in electronic format as well as the ability to validate

such a licence issued in electronic format.

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Requirements on system access for other entities

The proposed amendments to Commission Regulation (EU) No 1178/2011 (aircrew) in points

ARA.FCL.130 (i) – (j) and to Commission Regulation (EU) No 1321/2014 (continuing airworthiness) in

point 66.B.25 contain requirements for granting access to the licensing system for several entities; for

example, training organisations, examiners or other authorities. These requirements are not included

in the ATCO Regulation. While holders of a pilot licence or an aircraft maintenance licence are highly

mobile, this is not the case for ATCOs, and an ATCO wishing to obtain a unit endorsement in a new MS

must change the competent authority of their licence. This means that a licence interaction between,

for example, an examiner and a licence holder holding licences from different competent authorities

is extremely rare.

Adding requirements on data access increases the work required to implement an electronic

personnel licence system (EPLSYS) for ATCO licences issued in electronic format, and as these

requirements are not considered essential, they are not replicated in the ATCO Regulation. Should a

competent authority wish to establish access for, for example, training organisations or air navigation

service providers (ANSPs), they may still do so.

f. Provisions to allow temporary exercise of the privileges before the licence issued in electronic

format can be updated

AMC1 ATCO.AR.D.001(a) allows the competent authority to develop a procedure to enable a licence

holder to exercise the privileges of the licence before the licence has been issued. The proposed

amendments include an additional AMC (AMC1 ATCO.AR.D.001(a)(2)) to allow a similar provision to

apply when a licence issued in electronic format is used and a unit endorsement is issued, renewed or

revalidated. This is to allow the controller to exercise the privileges of the unit endorsement after the

controller has completed the last assessment but before the authority has updated the licence issued

in electronic format.

This is required as an assessor revalidating or renewing a unit endorsement can no longer enter the

new endorsement into the licence, creating a lag between the assessor completing the assessment

and the competent authority being able to update the licence issued in electronic format. Therefore,

competent authorities are given the option to develop a procedure which would allow the ATCO to

exercise the privileges of the unit endorsement, pending the update of the licence issued in electronic

format.

g. Removing the option for additional variable field XIV from the ATCO licence format(s)

In fields XIII and XIV of the licence format for the (student) ATCO issued in electronic format there is

an option to enter ‘additional licensing information’. The rulemaking group did not identify any need

for such ‘additional information’.

Today, field XIV is sometimes used to enter the date of birth. This information is available on the

application form for the issue, revalidation or renewal within the competent authority, but there is no

requirement to insert this in the licence.

Since there has been no identified need for its use, it is proposed to remove field XIV. Field XIII can still

be used by the competent authority for additional input necessary for the (student) ATCOs, e.g.

radiotelephony certificate, etc. A removal would reduce the information that is printed on the licence

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and produce a more uniform licence format throughout the MSs. It would also reduce administrative

complexity.

Field XIV is listed as ‘reserved’, to highlight that this data field will be empty. The intention is that this

field shall not be displayed on the licence issued in electronic format; it will only be existing in the

database in the event that a foreign (non-EU) licence issued in electronic format is audited and

provides data for this field.

h. Moving the language proficiency endorsement in the licence format(s) for the (student) ATCO

licence

In the (student) ATCO licence the language proficiency endorsement is listed in field XIII, while all other

endorsements are listed in item XIIb. In the pilot licence, language proficiency endorsements are listed

in field XIII.

In February 2023 the EASA Committee, when discussing EASA Opinion No 06/2022 (the result of which

was Commission Regulation (EU) 2023/893), proposed to change the location of language proficiency

endorsement from item XIII to item XIIb. The decision taken was that this change will be proposed in

the context of the rulemaking activities for electronic personnel licences. In line with the above, it is

proposed to move the language proficiency endorsement from field XIII to field XIIb, in both the

licence issued in physical format and licence issued in electronic format. There are no changes to the

endorsement itself or how this is presented in the licence; the information is simply moved from one

field to another.

2.7.4. Specific proposed amendments to existing requirements of Part-66 (Annex III to Commission

Regulation (EU) No 1321/2014 (continuing airworthiness))

a. Point 66.A.10

Point 66.A.10 is proposed to be amended to clarify the actions to be taken depending on what the

application is made for (i.e. issuance of a new licence, change to a licence or validity renewal of a

licence issued in physical format).

The proposed requirements also refer only to Appendix V as regards the information which needs to

be provided by the applicant (including EASA Form 19).

Additionally, the provision allowing maintenance organisations (approved in accordance with Part-

145 or Part-CAO) to provide application documentation on behalf of the applicant is proposed to be

moved from point 66.A.40(b) and extended to all types of applications.

b. Points 66.A.40 and 66.B.120

Point 66.B.120 are proposed to be amended to apply only to licences issued in physical format.

As set out in point 66.A.40(a), the current process to renew the validity of aircraft maintenance

licences aims at verifying, every 5 years, that the records of the competent authority correspond to

what is written on the licence. This is to ensure that the licence holder does not use a licence

containing information that was not added by the competent authority.

However, the licences issued in electronic format, when updated by the holder, reflect the records of

the competent authority (as part of its licensing system).

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The information included in those records is supposed to be always accessible to the competent

authority and that it cannot be manipulated by an external entity without the authority being aware

or having granted an authorisation.

Therefore, the validity of licences issued in electronic format cannot not expire based on the reason

currently laid down in point 66.A.40(a).

Additionally, point 66.A.40 is proposed to be amended for clarity purposes (with point (c)(2) proposed

to be amended to reflect the specificity of licences issued in electronic format but still applying to

licences issued in physical format).

AMC1 66.A.40(c) is proposed to be added to complement point (c) and advise the holder on how to

ensure that the content of the licence is correct and that they have signed their licence or the script

signature inserted is correct.

c. Point 66.A.55

Point 66.A.55(a)(2) is proposed to be added to reflect a requirement already set out in Section VIII of

the aircraft maintenance licence in physical format (i.e. in EASA Form 26: ‘This licence shall be signed

by the holder and be accompanied by an identity document containing a photograph of the licence

holder.’).

Point 66.A.55(b) is proposed to be added to require the licence holder to report the loss of his or her

licence in physical format or of the device on which his or her licence was issued in electronic format.

Point 66.A.55(c) is proposed to be added to ensure that aircraft maintenance licence holders whose

licence in physical format has been limited, suspended, or revoked return their licence to the

competent authority that issued the licence.

Point 8 of Appendix VI to Part-66 is proposed to be moved to the new point 66.A.55(d) to concentrate

the requirements addressed to licence holders under Section A of Part-66.

d. Point 66.B.105

Today, pursuant to point 66.B.105(a)(i) of Annex III (Part-66) to Regulation (EU) No 1321/2014, a

maintenance organisation approved in accordance with Annex II (Part-145) or Annex Vd (Part-CAO)

may prepare aircraft maintenance licences on behalf of the competent authority when the competent

authority has authorised the organisation to do so.

The licence prepared is then to be provided to the competent authority for issuance to the applicant

as specified in point 66.B.105(c).

With this NPA, point 66.B.105 is proposed to be entirely deleted since:

— Point 66.B.105(a)(i) is proposed to be deleted, and, therefore, the possibility for maintenance

organisations to prepare aircraft maintenance licences is withdrawn from the Regulation.

This proposal is due to the introduction of licences issued in electronic format, whose nature

will trigger new concerns if such provision remains.

If maintenance organisations were authorised to prepare licences in electronic format, it would

require them to access the issuing authority’s server to enter information relevant to the

applicant.

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In such cases, giving access in writing to maintenance organisations could create information

security risks (e.g. leakage of information, potential system vulnerabilities, others).

For consistency purposes, this possibility is also proposed to be removed for licences issued in

physical format.

Additionally, EASA has requested and received feedback from the MSs (through the RMG and

through meetings with the Advisory Bodies) on whether this provision was used in their national

context.

All replying competent authorities indicated that they do not use this provision, hence have not

given authorisation to maintenance organisations to prepare licences on their behalf.

This information leads to believing that there should be no to low impact on maintenance

organisations, pending the comments that will be received during the consultation.

— Point 66.B.105(a)(ii) is proposed to be deleted, and, therefore, the explicit statement that

maintenance organisations approved in accordance with Annex II (Part-145) or Annex Vd (Part-

CAO) may issue recommendations on licence-related applications.

This proposal is due to the fact that Part-66 does not require any action from the competent

authority when such recommendations are received, and thus does not ensure that the

associated applications will be processed faster or in a different manner.

Additionally, it has been observed with a few competent authorities that this provision is not

used and that application documentation remains thoroughly reviewed even when a

recommendation was issued by a maintenance organisation.

Therefore, this provision is deemed ineffective and limited, and its deletion is proposed for

simplification purposes with seemingly no to low impact, pending the comments that will be

received during the consultation.

All related provisions are proposed to be deleted from Appendix V to Part-66 (EASA Form 19),

Appendix VI to Part-66 (points 6 and 7), Part-145, Part-CAO, as well as AMC 66.B.105.

e. Points 66.B.110(a), 66.B.115(a) and 66.B.120(a)

Points 66.B.110(a), 66.B.115(a) and 66.B.120(a) are proposed to be amended for clarity purposes and

to remove the notion of ‘issuance of the licence’ where applicable when the intended meaning is

rather:

— the production of a new licence in physical format with updated information to replace an

existing licence; or

— the amendment of a licence in electronic format with updated information.

The reason is that the word ‘reissue’ might be confused with the meaning intended in point 66.B.100

which is to render a new licence valid (with a new licence holder number, as referred to in point 1.4

of Appendix VI to Part-66) after the applicant has met the applicable requirements and provided his

or her application in accordance with Appendix V to Part-66.

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f. Point 66.B.500

Point 66.B.500(a)(9) is proposed to be added to require authorities to act upon licences whose content

has not been issued or amended by them (in such case, the wording remains generic and includes

licences issued in electronic format, should they also be subject to such risks).

This new proposed point is combined with the new proposed point 66.A.55(d) (moved from point 8 of

Appendix VI to Part-66).

Point 66.B.500(b) is proposed to be added, along with the associated AMC, to require competent

authorities to establish and implement a procedure for the revocation, suspension or limitation of

valid aircraft maintenance licences issued in electronic format.

Point 66.B.500(c) is proposed to be added to require actions from the competent authority once the

licence holder has reported the loss or theft of their current licence issued in physical format or of the

self-contained mobile electronic visual display device on which their licence was issued.

Those amendments will mitigate the risk of someone using a licence while it has been stolen, limited,

suspended, or revoked.

This new proposed point is combined with the new proposed point 66.A.55(b).

g. Appendix V to Part-66

Appendix V to Part-66 is proposed to be amended as follows:

— Point (a) of Appendix V is proposed to clearly account for any application format and thus not

restrict EASA Form 19 to physical documentation.

Part of the current content of point 66.A.10(a) is also proposed to be moved to point (a) of

Appendix V.

— The requirement to provide supporting documentation with any application is proposed to be

moved from point 66.A.10 to point (b) of Appendix V.

— EASA Form 19 is proposed to be amended for wording improvement and to account for licences

issued in electronic format, including a new field for the signature of the applicant, allowing the

signature to be reused for the issuance of the licence (in Section VII of EASA Form 206).

AMC1 Appendix V to Part-66 is proposed to be added to list some of the possibilities regarding the

means that an applicant can use to send an application related to the aircraft maintenance licence.

AMC1 Point 3.3 of Appendix VI to Part-66 is proposed to be added to completement Appendix V

regarding how the competent authority should acquire the script signature of the applicant before

issuing a licence in electronic format.

h. Points 2, 3, 5, 11 and 14 of Appendix VI to Part-66

Points 2, 3, 5, 11 and 14 of Appendix VI are proposed to be amended or deleted to reflect that aircraft

maintenance licences issued in physical format may not be issued only on paper but also using other

suitable material such as plastic cards (refer to the definition added with point (v) of Article 2) and to

remove obsolete provisions.

The proposed amendments aim to keep the same intent but make the wording more generic to

account for all possibilities.

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Where relevant, the previous requirements, worded as possible actions for competent authorities,

are proposed to be changed into acceptable means of compliance (AMC).

i. Information on the ‘place of birth’ in EASA Form 26 in Appendix VI to Part-66

Today, the information on the place of birth of the holder is required to be included in the aircraft

maintenance licence by Appendix VI to Annex III (Part-66) to Regulation (EU) No 1321/2014.

This is an additional requirement to those of point 5.2.1 of ICAO Annex 1 on personnel licensing.

With this NPA, the place of birth of the holder is proposed to be removed from aircraft maintenance

licences that will be issued in either physical or electronic format.

This proposal is due to the introduction of licences issued in electronic format, whose mandatory

content will be based on the provisions of ICAO Annex 1, Appendix 4 (Common Form of the Electronic

Personnel Licence).

The ICAO Common Form does not include a field for the place of birth of the licence holder, therefore,

maintaining this information in licences in electronic format would require the addition of a new data

field and set.

Such addition would cause compatibility issues when third-country reading devices and applications,

pre-programmed for the number of data fields given by ICAO, would not be able to read aircraft

maintenance licences issued by MSs.

Moreover, the reading devices of each MS would require a different set-up depending on whether

they would be used for the inspection of aircraft maintenance licences or other types of licences which

do not contain the place of birth of the holder (e.g. ATCO licences, flight crew licences).

For consistency purposes, the removal of the place of birth from licences in electronic format is also

proposed to be applied to licences in physical format.

Nevertheless, knowing the place of birth of the licence holder might be useful for the competent

authority to identify them in specific situations. This information will still be collected by the

competent authority at the time of application for a licence, changes to it, or validity renewal for

licences in physical format (through EASA Form 19, refer to Appendix V to Part-66).

As regards the proposal to delete the address of the holder from aircraft maintenance licences, please

refer to point b. of Section 2.7.1.4.

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3. What are the expected benefits and drawbacks of the proposed regulatory material

An agency of the European Union

3. What are the expected benefits and drawbacks of the proposed

regulatory material

Before the publication of ToR RMT.0737, an impact assessment (IA) was performed to define the best

regulatory approach to address the issues defined in Section 2.2. The results of this IA were presented

and discussed with the Advisory Bodies (MAB and SAB) in May-June 2022. Based on the feedback

provided, EASA concluded that the MSs are supportive of RMT.0737 with the objectives and the scope

presented in Sections 2.6 and 2.7 respectively.

This IA was performed using the experience gained in developing the dLAP13 project, cost-benefit

analysis conducted to assess the initial and recurrent costs for building an IT platform for

implementation of the EPL, and feedback from the Advisory Bodies.

Below is an extract of the regulatory options which were considered and analysed. A full overview of

all analysed options and their assessment is presented in Appendix 1.

Table 1: Analysed options

No Title Description

Option 0

No regulatory change

MSs continue issuing only paper version of licences. Issues remain at stake.

Option 1

Transposition of ICAO Annex 1 EPL into three personnel licence domains (pilot licence, Part-66 licence, ATCO licence) and establishment of common standards for EPL implementation.

In RMT.0737 EASA develops: a. a definition for a common single EU EPL, based on the proposed

ICAO Annex 1 amendments; b. common standards for the security, confidentiality, integrity,

authentication, accessibility of an EPL and common standards for the EPL to enable the functions of EPL issuance and oversight.

Regulating a common approach to the EPL in line with ICAO Annex 1 across the three affected domains and applying common principles to ensure confidentiality, integrity, authentication, accessibility and security of the licences. The EPL will be optional (supplementary to the paper pilot licence),, and the MSs could decide whether to apply the EPL or not. MSs under their own sovereignty develop and manage an IT EPL tool / infrastructure which would allow and ensure: a. issuance/amendment of an EPL format (e.g. via e-signature, seal,

etc); b. display in an electronic format (via QR code, available on a mobile

device); c. verification of the confidentially, integrity, authenticity, availability

and non-repudiation of an EPL. The requirements which the MSs need to comply with when developing such IT system would be part of RMT.0737.

13 In 2017, EASA initiated a project to digitalisation of pilot licences by launching a partnership Proof of Concept between

EASA and six national competent authorities (NCAs) for digital Licences for EU Aviation Pilots (dLAP).

European Union Aviation Safety Agency NPA 2024-08 (A)

3. What are the expected benefits and drawbacks of the proposed regulatory material

An agency of the European Union

Under this option, EASA will not intervene at the level of development and implementation of the IT system.

The benefits and drawbacks of these options are presented in the table below. Table 2: Summary of the benefits and costs of the analysed options

Criteria Option 0 No regulatory change

Option 1 Transposition of ICAO Annex 1 EPL into the three affected domains and introduction of common standards for EPL implementation

Safety No impact Enhance safety as potential fraud can be minimised, and changes to the electronic personnel licences can be reflected in a timelier manner.

Social No impact No impact

Environmental No impact Overall positive impact due to the move from a paper to electronic document. No quantitative assessment is performed.

Economic Lack of digital interaction between licensing authority and EPL holders, leading to inefficiencies

Benefits:

• Flexibility for the MSs to decide, based on their budget, resources, maturity and interest in the digitalisation, the pace of development/ implementation of an IT EPL system, as the implementation of the EPL is optional. Furthermore, the impact can vary depending on the size and complexity of the aeronautical community that will be affected in the MS. The MSs have full autonomy to decide whether they will implement the EPL to all personnel, to a certain group (e.g. private pilot, commercial pilot, airline transport pilot, etc.) or to individual applicants.

• Enhanced efficiency by reducing the overall time required to issue a licence and by providing real-time authenticity verification.

• The common standards for the IT system for EPL implementation would ensure interoperability of the EPL.

• Facilitate standardisation and uniform presentation of the EPL across MSs due to the common standards applicable to all MSs.

• For EASA — one single RMT to introduce the EPL, instead of three individual tasks. One RMT would ensure a holistic and coordinated approach in developing changes for all domains in a coordinated and structured way. Risks related to the divergence in transposing ICAO Annex 1 amendments to the

EPL would be minimised.

• Potential economy of scale for the NCAs to commission an IT EPL tool for the EPL (e.g. price of the seal, the qualified or advanced signatures).

• By transposing the ICAO SARPs and its guidance, ramp inspectors would be faced with fewer differences between personnel licences issued in electronic format, which facilitates quick verification of personnel holding a valid licence for the type of aircraft they operate during ramp inspections performed on either MS carriers or third-party carriers.

European Union Aviation Safety Agency NPA 2024-08 (A)

3. What are the expected benefits and drawbacks of the proposed regulatory material

An agency of the European Union

Disadvantages:

• The verification mechanism for electronic personnel licences will have minimal impact. MSs will need an electronic device if they wish to use electronic authenticity verification systems for an electronic personnel licence; otherwise, they will be able to use traditional means of verification.

Note: The costs for the development of the EPL IT system and its deployment depend on how the MS envisages to implement the EPL. Therefore, an assessment of such costs could not be provided.

Based on the above, it is concluded that the best regulatory option for RMT.0737 is Option 1

(introduction of the EPL across several domains (aircrew, ATCO, Part-66 maintenance) and

development of common standards for security, authentication, accessibility and interoperability of

an electronic pilot licence) to ensure a standardised approach to the issuance and oversight of the

EPL. The implementation of the EPL is left to the MSs to develop an IT tool for the EPL (based on their

interest/budget, etc), respecting the EU standards, subject to RMT.0737. This proposal is aimed at

introducing the EPL in a harmonised way to ensure total system approach. EASA’s role as a regulator

will involve setting robust (technical) requirements, through RMT.0737, for EPL display and

verification, while allowing market providers to develop IT solutions in accordance with common

(technical) standards.

European Union Aviation Safety Agency NPA 2024-08 (A)

4. Proposed regulatory material

An agency of the European Union

4. Proposed regulatory material

Please refer to:

— NPA 2024-08 (B) ‘Proposed amendments to Commission Regulation (EU) No 1178/2011’

(aircrew)

— NPA 2024-08 (C) ‘Proposed amendments to Commission Regulation (EU) 2015/340’ (air traffic

controllers’ licences and certificates)

— NPA 2024-08 (D) ‘Proposed amendments to Commission Regulation (EU) No 1321/2014’

(continuing airworthiness)

— NPA 2024-08 (E) ‘Proposed amendments to Commission Regulation (EU) 2018/1976’

(sailplanes)

— NPA 2024-08 (F) ‘Proposed amendments to Commission Regulation (EU) 2018/395’ (balloons)

European Union Aviation Safety Agency NPA 2024-08 (A)

5. Monitoring and evaluation

An agency of the European Union

5. Monitoring and evaluation

EASA will monitor the proposed regulatory material by following closely how many EU MSs have

decided to deploy personnel licences issued in electronic format in the three affected domains, and

what issues they face during and after the implementation. Furthermore, EASA will monitor through

the RAMP inspections how EU MSs validate personnel licences issued in electronic format from third

countries and what questions/issues they may face. As the information of such monitoring is mainly

of qualitative nature, no monitoring indicators are proposed at this stage. Feedback from the

implementation, as well as questions/issues, will be captured and discussed at regular meetings with

Advisory Bodies, RAMP meetings, etc.

The decision whether an evaluation will be necessary will be taken based also on the monitoring

results.

European Union Aviation Safety Agency NPA 2024-08 (A)

6. Proposed actions to support implementation

An agency of the European Union

6. Proposed actions to support implementation

EASA intends to provide focused communications for Advisory Body (AB) meetings (Technical Bodies

(TeBs) and Technical Committees (TECs)), after the amending Regulations and the associated AMC and

GM are published.

European Union Aviation Safety Agency NPA 2024-08 (A)

7. References

An agency of the European Union

7. References

— State letter AN 12/1.1.25-20/112, 23 December 2020, Proposals for the amendment of Annex

1 regarding implementing an electronic personnel licensing system with the objective to

improving efficiency

— ICAO Annex I – Personnel licensing

— ICAO Doc 9303 – Machine Readable Travel Documents

— ICAO Doc 9379 – Manual of procedures for establishment and management of a State’s

personnel licensing system

— ICAO Doc 10190 – EPL technical specifications for implementation and verification

European Union Aviation Safety Agency NPA 2024-08 (A)

Appendix 1 — Details on the impact assessment

An agency of the European Union

Appendix 1 — Details on the impact assessment

Before starting the RMT, an impact assessment was performed to identify different options for

implementation of the personnel licences in electronic format. The assessment provides answers to

two questions:

1. How could the personnel licences in electronic format be developed/implemented, considering

the experience gained during the dLAP project14?

2. What are the benefits and drawbacks of extending the scope of RMT.0737, initially planned only

for pilot licences to personnel licences in other domains (ATCO, maintenance)?

This is an overview of all analysed options for regulating personnel licences in electronic format

following the total system approach, providing answers to these questions.

The current analysis studied options for implementation of personnel licences in electronic format,

considering various perspectives (compliance with the Basic Regulation and EASA remit, technical and

legal/procurement aspects, political will, etc.). These aspects, especially on legal compliance with the

Basic Regulation, are deemed essential for decision-making. Therefore, the initial analysis uses these

criteria to filter options which are eligible for further analysis.

1. Overview of the analysed options

Option 0 is the baseline scenario. It is the ‘do nothing’ option which implies no change to the

regulatory framework.

Option 1.1 proposes the introduction of EU personnel licences in electronic format in the EU

regulatory framework. EU MSs develop and manage IT tool(s) for EPL implementation.

Option 1.2 envisages the introduction of EU pilot licences in electronic format in the EU regulatory

framework and the development of common requirements for the security of pilot licences in

electronic format. EU MSs develop and manage IT tool(s) for EPL implementation.

Option 1.3 proposes the transposition of ICAO Annex 1 SARPs into the EU regulatory framework

(without common requirements for the security of personnel licences in electronic format).

Option 1.4 proposes the transposition of ICAO Annex 1 SARPs into the EU regulatory framework. EASA

develops and manages one mandatory system for all EU MSs (‘one EU system for all’)

Option 1.5 proposes the development and management of an IT electronic personnel licence system

by EASA, and EU MSs are invited to join the system on a voluntary basis.

14 In 2017, EASA initiated a project on the digitalisation of pilot licences by launching a partnership Proof of Concept

between EASA and six NCAs for digital Licences for EU Aviation Pilots (dLAP).

European Union Aviation Safety Agency NPA 2024-08 (A)

Appendix 1 — Details on the impact assessment

An agency of the European Union

2. Assessment of the options15

Table 1: Options for the development and implementation of an electronic pilot licence

Option Title Description Means of implementation

Advantages Disadvantages Retained

Option 0 No regulatory change

MS continue issuing only paper version of the EPL. Issues remain at stake.

- Lack of digital interaction between licensing authority and EPL holders, leading to inefficiencies

Option 1.1

Transposition of ICAO Annex 1 EPL into three personnel licence domains (pilot licence, Part-66 licence, ATCO licence) and establishment of common standards for EPL implementation

In RMT.0737 EASA develops: a. a definition for a common single EU EPL,

based on the proposed ICAO Annex 1 amendments;

b. common standards for the security, confidentiality, integrity, authentication, accessibility of an EPL and common standards for the EPL to enable the functions of EPL issuance and oversight.

Regulating a common approach to the EPL in line with ICAO Annex 1 across the three affected domains and applying common principles to ensure confidentiality, integrity, authentication, accessibility and security of the licences. The EPL will be optional, and the MSs could decide whether to apply the EPL or not. MSs under their own sovereignty develop and manage an IT EPL tool / infrastructure which would allow and ensure: a. issuance/amendment of an EPL format

(e.g. via e-signature, seal, etc.); b. display in an electronic format (via QR

code, available on a mobile device);

Amendment to Commission Regulation (EU) No 1178/2011 (aircrew); Commission Regulation (EU) 2015/340 (air traffic controllers’ licences and certificates); Commission Regulation (EU) No 1321/2014 (continuing airworthiness); Commission Regulation (EU) 2018/1976 (sailplanes); Commission Regulation (EU) 2018/395

• Flexibility for the MSs to decide, based on their budget, resources, maturity, and interest in the digitalisation the pace of the development / implementation of an IT EPL system, as the implementation of the EPL is optional. Furthermore, the impact can vary depending on the size and complexity of the aeronautical community that will be affected in the MS. The MSs have full autonomy to decide whether they will implement the EPL to all personnel, to a certain group (e.g. private pilot, commercial pilot, airline transport pilot, etc.) or to individual applicants.

• Enhanced efficiency by reducing the overall time required to issue a licence and by providing real-time authenticity verification.

The verification mechanism for electronic personnel licences will have minimal impact. MSs will need an electronic device if they wish to use electronic authenticity verification systems for an electronic personnel licence; otherwise, they will be able to use traditional means of verification. Note: The costs for the development of the EPL IT system and its deployment depend on the how an MS envisages the EPL implementation. Therefore, an assessment of such costs could not be provided.

Yes, due to the positive impact and limited adverse effects

15 For the assessment, the abbreviation EPL (electronic personnel licence) is used which is the same as the use of the term ‘ personnel licence issued in electronic format’ throughout the NPA.

European Union Aviation Safety Agency NPA 2024-08 (A)

Appendix 1 — Details on the impact assessment

An agency of the European Union

Option Title Description Means of implementation

Advantages Disadvantages Retained

c. verification of the confidentially, integrity, authenticity, availability and non- repudiation of an EPL.

The requirements which the MSs need to comply with when developing such IT system would be part of RMT.0737. The EPL will be optional (supplementary to the paper pilot licence) and the MS could decide

whether to apply the EPL or not. Under this option, EASA will not intervene at the level of development and implementation of the IT system.

(balloons), and to the associated AMC and GM to support the application of those Regulations.

• The common standards for the IT system for EPL implementation would ensure interoperability of the EPL.

• Facilitate standardisation and uniform presentation of the EPL across MSs due to the common standards applicable to all MSs.

• Failing to integrate the other domains within the RMT.0737 may result in additional resources at a later stage for EASA to transpose ICAO Annex 1 amendments into the relevant domains.

• Potential economy of scale for the NCAs to commission an IT

EPL tool for the EPL (e.g. price of the seal, the qualified or advanced signatures).

• No dependency on REPIF timelines and quick implementation possible by MS

European Union Aviation Safety Agency NPA 2024-08 (A)

Appendix 1 — Details on the impact assessment

An agency of the European Union

Option Title Description Means of implementation

Advantages Disadvantages Retained

• Full compliance with the current Basic Regulation.

Option 1.2

Introduction of EU electronic pilot licences in the EU regulatory framework and development of common requirements for the security of pilot licences in electronic format. MSs develop and manage IT tool(s) for EPL implementation

Same as for Option 1.1 but limited only to pilot licences.

Amendment to the Aircrew Regulation and the associated AMC and GM

• Same benefits as above but limited only for pilot licences.

There is still the necessity to transpose ICAO Annex 1 standards to the other domains: maintenance licences and ATCO licences. It is not worth initiating a RMT only for one domain, whereas there are others also affected and for which transposition of the ICAO standards is still necessary. Disproportionate one-off costs for the MSs depending on the population of affected personnel licences

No, due to the limited benefits compared to Option 1.1

Option 1.3

Transposition of ICAO Annex 1 EPL into the EU regulatory framework (without common requirements for security of personnel licences in electronic format)

In RMT.0737 EASA develops a regulatory framework on a common and unique EU EPL format (based on the ICAO Annex 1 EPL format). Apart from the pure transposition of the ICAO standards, this option envisages that the MSs would be left to decide themselves how to implement the EPL in their national context. Therefore, the option would open the possibility for a variety of solutions for EPL implementation which could hamper the

Changes in the Aircrew Regulation, the ATCO Regulation and the Continuing airworthiness Regulation and the associated AMC and GM

Small resources from EASA to develop the changes in the Aircrew Regulation (EU) No 1178/2011.

Proliferation of different tools/divergence which may have an adverse effect on the standardisation of the EPL. Very high risk/lack of interoperability between the IT systems for EPL implementation

No, due to the drawbacks

European Union Aviation Safety Agency NPA 2024-08 (A)

Appendix 1 — Details on the impact assessment

An agency of the European Union

Option Title Description Means of implementation

Advantages Disadvantages Retained

standardised and uniform administration of the EPL by the MSs and cause interoperability issues.

Option 1.4

Transposition of ICAO Annex 1 SARPs into the EU regulatory framework. EASA develops and manages one mandatory system for all MSs (‘one EU-system for all’)

In this option, in addition to the transposition of the forthcoming ICAO Annex 1 changes, EASA would develop and manage (procured to a third party) an IT EPL tool which enables an electronic format of the EPL as a single system for all MSs. This tool will be unique and central for all MSs. The NCAs would need to integrate this tool into their licensing system to ensure interoperability. It would be possible for MSs to continue issuing a paper licence and/or an EPL. If a MS decides to issue an EPL, this would be possible only through the central single system, established and managed by EASA. The EPL will be supplementary to the paper pilot licence. In this option, EASA will take the responsibility for:

• the issuance of the EPL according to the EU EPL format;

• guaranteeing authenticity and security of all EPLs which will be issued via the EU single IT system. EASA will provide a unique EU EPL verification system (QR code) and consequently the issuance/verification of an EPL.

• maintaining the authenticity of the EPL and taking any responsibility in case of fraud in the EPL, malfunction

Changes in the Basic Regulation (TBC with MS/EC) to give mandate to EASA to develop/ manage an IT EPL system. Standards for the IT system for managing the EPL and further clarify responsibilities for EASA to manage the system, access of third parties, etc.

1 IT tool instead of several which will save resources in development/maintenance and might be easily interoperable with other systems. In financial terms, the costs for development of the REPIF could be lower comparing to other options: One-off cost ca 740 K EUR Recurrent costs ca 132 K EUR/year. Facilitate standardisation and uniform presentation of the EPL across MSs (however this benefit is relevant also for other options.)

No remit from the Basic Regulation for EASA to perform the assigned task. Unclear interest from all MSs to give a mandate to EASA for such task. No earmark funds yet to develop/host the IT tool. High liability and reputational risk if the information in EU IT EPL system is not updated/secure, etc. Limited internal competency in developing/hosting such tool. Reliance on the REPIF could delay the EPL project and delivered solution for the MS

No due to the shortcomings explained

European Union Aviation Safety Agency NPA 2024-08 (A)

Appendix 1 — Details on the impact assessment

An agency of the European Union

Option Title Description Means of implementation

Advantages Disadvantages Retained

of an IT system, hampering the completeness/correctness when displaying the EPL, etc.

It is not in the remit of EASA (Articles 62, 72 and 75 of the Basic Regulation) to perform such a task. Such a responsibility may be granted to EASA either: — through an amendment to the Basic

Regulation (subject to discussion with the European Commission and MSs); or

— transferred to EASA by MSs (subject to discussion with MSs and the European Commission).

If there is no interest from the European Commission/MSs to amend the Basic Regulation or transfer responsibilities on verification, this option is legally not feasible and may be discarded.

Discarded option and reasoning

Option Title Description Rationale for discarding

Option 1.5

EASA develops and manages an IT EPL system and MSs are invited to join the system on a voluntary basis

In this option, EASA develops and manages a central IT system

for the EPL. It could be an additional layer to that provided by Article 74 of the Basic Regulation regarding the REPIF. MSs on a voluntary basis conclude an agreement with EASA to procure to a third party the development/maintenance of a common EU IT system. The system would allow presentation of an EPL in a mobile device. EASA acts as a private actor to develop and host such system. In addition, it would be responsible for confidential, authenticated,

1. No clear remit in the Basic Regulation for EASA to perform the assigned task of

hosting an IT system for the EPL. 2. Unclear commitment/unclear number of MSs that are willing to join on a

voluntary basis the EU IT system for the EPL. 3. Risk of non-compliance with EU competition and state aid rules: EASA will act as

a private actor; therefore special attention needs to be paid to the funding of the tool and the price asked to MSs for the ‘service’. In addition, the risk of imposing technical entry barriers needs to be considered.

4. Centralising a small amount of data from MSs on a voluntary basis has no advantage for EASA.

European Union Aviation Safety Agency NPA 2024-08 (A)

Appendix 1 — Details on the impact assessment

An agency of the European Union

updated, complete and valid replication of information from the EPL. In this option, due to the voluntary nature of the agreement between EASA and MSs, there might be several MSs that wish to join the EU IT EPL system and some others that wish to have their own national IT system/platform and even some that would not have EPLs at all.

5. Evidence from the current practice in implementing the dLAP Proof of concept shows that not all MSs have interest in joining the system, which hampers the benefit of the option.

6. No earmark funds to develop/host the IT tool. 7. No (clear) benefit for EASA to develop/host this tool. 8. High political exposure and reputational risk if the information in the EU IT EPL

system is not updated/secure, etc. 9. Risk that the centralisation of tool (versus decentralised development by MSs)

may slow down the process of digitalisation. 10. Risk of proliferation of different IT tools, as some MSs may decide to join the EU

IT EPL system and others not.

European Union Aviation Safety Agency NPA 2024-08(A)

Appendix 1 — Details on the impact assessment

An agency of the European Union

3. Conclusion

The optimal option for implementing RMT.0737, addressing the key questions, is determined to be

Option 1.1. This proposal aims to introduce personnel licences issued in electronic format in a

harmonised and coordinated manner across aviation personnel domains. EASA’s role as a regulator

will involve setting robust (technical) requirements through RMT.0737 for EPL display and verification,

while allowing market providers to develop IT solutions in accordance with common (technical)

standards. The lack of an integrated approach in transposing ICAO Annex 1 amendments could result

in certain domains relevant to personnel licences falling behind in terms of compliance and

interoperability. The implementation of the selected option would ensure transposition of the EPL

standards of ICAO Annex 1 into the EU regulatory framework, promote cross-border licensing

interoperability, facilitate personnel and business mobility, and enhance digital interactions in line

with the broader EU strategy for digital public interoperability.

European Union Aviation Safety Agency NPA 2024-08 (A)

Appendix 2 — Quality of the NPA

An agency of the European Union

Appendix 2 — Quality of the NPA

To continuously improve the quality of its documents, EASA welcomes your feedback on the quality

of this document regarding the following aspects:

Please provide your feedback on the quality of this document as part of the other comments you have

on this NPA. We invite you to also provide a brief justification, especially when you disagree or strongly

disagree, so that we consider this for improvement. Your comments will be considered for internal

quality assurance and management purposes only and will not be published (e.g. as part of the CRD).

1. The regulatory proposal is of technically good/high quality

Please choose one of the options

Fully agree / Agree / Neutral / Disagree / Strongly disagree

2. The text is clear, readable, and understandable

Please choose one of the options

Fully agree / Agree / Neutral / Disagree / Strongly disagree

3. The regulatory proposal is well substantiated

Please choose one of the options

Fully agree / Agree / Neutral / Disagree / Strongly disagree

4. The regulatory proposal is fit for purpose (achieving the objectives set)

Please choose one of the options

Fully agree / Agree / Neutral / Disagree / Strongly disagree

5. The regulatory proposal is proportionate to the size of the issue

Please choose one of the options

Fully agree / Agree / Neutral / Disagree / Strongly disagree

6. The regulatory proposal applies the ‘better regulation’ principles[1]

Please choose one of the options

Fully agree / Agree / Neutral / Disagree / Strongly disagree

7. Any other comments on the quality of this document (please specify)

[1] For information and guidance, see:

− https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and- how_en

− https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and- how/better-regulation-guidelines-and-toolbox_en

npa_2024-08_b.pdf

European Union Aviation Safety Agency

Notice of Proposed Amendment 2024-08 (B) in accordance with Article 6(1) of MB Decision 01-2022

An agency of the European Union

Proposed amendments to Commission Regulation (EU)

No 1178/2011 (aircrew)

European Union Aviation Safety Agency NPA 2024-08 (B)

Table of contents

An agency of the European Union

Table of contents

Proposed regulatory material ......................................................................................................... 4

Commission Regulation (EU) No 1178/2011 (Aircrew) .................................................................... 4

Article 1 — Subject matter .................................................................................................................. 4 Article 2 — Definitions ......................................................................................................................... 4 Article 13 – Transitional measures regarding the inclusion of the information .................................. 5

ANNEX I (Part-FCL) ......................................................................................................................... 6

FCL.045 Obligation to carry and present documents ...................................................................... 6 FCL.070 Revocation, suspension and limitation of licences, ratings and certificates ...................... 6

AMC1 to Appendix 10 Revalidation and renewal of type ratings, and revalidation and renewal of IRs when combined with the revalidation or renewal of type ratings – EBT practical assessment .............................................. 6 GM1 to Appendix 10 — Revalidation and renewal of type ratings, and revalidation and renewal of IRs when combined with the revalidation or renewal of type ratings – EBT practical assessment .............................................. 7

ANNEX IV (Part-MED) ..................................................................................................................... 7

MED.A.046 Suspension or revocation of medical certificates ......................................................... 7

ANNEX VI (Part-ARA) ...................................................................................................................... 8

AMC1 ARA.GEN.210 Changes in the management system ........................................................................................... 8 ARA.GEN.360 Change of competent authority ................................................................................ 8 ARA.FCL.130 Licences issued in electronic format and establishment of an electronic personnel licence system .................................................................................................................................. 8

AMC1 ARA.FCL.130 Licences issued in electronic format and establishment of an electronic personnel licence system ......................................................................................................................................................................... 10

1. DEFINITIONS .................................................................................................................................................. 10 2. ABBREVIATIONS ............................................................................................................................................. 10 3. PRIOR TO IMPLEMENTATION ......................................................................................................................... 11

3.1. Licensing system and electronic personnel licence system................................................................... 11 3.2. The data set for the licence issued in electronic format (EPLDS) .......................................................... 12 3.3. The term ‘licence’ and life cycles .......................................................................................................... 13 3.4. Verification of the authenticity and validity of a licence issued in electronic format ........................... 18

4. EPLSYS ............................................................................................................................................................ 19 4.1. EPLSYS introduction .............................................................................................................................. 19 4.2. Data exchange phases ........................................................................................................................... 20 4.3. Chain of trust ......................................................................................................................................... 31 4.4. EPLAPP .................................................................................................................................................. 31 4.5. EPLRAP .................................................................................................................................................. 37

5. DATA MODEL ................................................................................................................................................. 40 5.1. EPLDS .................................................................................................................................................... 40 5.2. EPLDM ................................................................................................................................................... 41

6. IMPACT OF THE IMPLEMENTATION OF AN EPLSYS ........................................................................................ 55 6.1. Impact on the LICSYS when implementing an EPLSYS ........................................................................... 55 6.2. Impact on the issuing authority’s procedures when implementing an EPLSYS ..................................... 57

AMC1 ARA.FCL.130(h) Licences issued in electronic format and establishment of an electronic personnel licence system ......................................................................................................................................................................... 57

ARA.FCL.200 Procedure for issue, revalidation or renewal of a licence, rating or certificate ....... 59 GM1 ARA.FCL.200(d) Procedure for issue, revalidation or renewal of a licence, rating or certificate ........................ 60 AMC1 ARA.FCL.215(d) Validity period ......................................................................................................................... 61 GM1 ARA.FCL.215(d) Validity period .......................................................................................................................... 61

ARA.FCL.220 Procedure for the re-issue of a pilot licence issued in physical format .................... 61 ARA.FCL.221 Procedure for the update of a pilot licence issued in electronic format .................. 62

APPENDICES TO ANNEX VI ................................................................................................................. 63 Appendix I to ANNEX VI (Part-ARA) — Flight crew licence — EASA Forms 141 and 155 .............. 63

European Union Aviation Safety Agency NPA 2024-08 (B)

Table of contents

An agency of the European Union

1. General requirements for the flight crew licence .................................................................................................. 63 2. Requirements for the flight crew licence issued in physical format ..................................................................... 63 3. Requirements for the flight crew licence issued in electronic format .................................................................. 68 AMC1 Point 1.2 of Appendix I to Annex VI (Part-ARA) — Flight crew licence — EASA Forms 141 and 155 ................ 72 AMC1 Point 3.1 of Appendix I to Annex VI (Part-ARA) — Flight crew licence — EASA Forms 141 and 155 ................ 73

1. RATING ENDORSEMENT IN FLIGHT CREW LICENCES ISSUED IN ELECTRONIC FORMAT ......... 73 2. ARCHETYPES ............................................................................................................................ 74

2.1. Archetypes for aeroplane and helicopter licences .......................................................... 74 2.2. Archetypes for sailplane licences .................................................................................... 74 2.3. Archetypes for balloon licences ...................................................................................... 74 3.1. Aircraft category taxonomy ............................................................................................. 75 3.2. Aeroplane licences ........................................................................................................... 75 3.2.1. Title taxonomy ................................................................................................................. 75 3.2.2. Rating taxonomy .............................................................................................................. 75 3.2.3. Endorsement methodology ............................................................................................. 79 3.3. Helicopter licences .......................................................................................................... 84 3.3.1. Title taxonomy ................................................................................................................. 84 3.3.2. Rating taxonomy .............................................................................................................. 84 3.3.3. Endorsement methodology ............................................................................................. 86 3.4. Sailplane licences ............................................................................................................. 90 3.4.1. Title taxonomy ................................................................................................................. 90 3.4.2. Rating taxonomy .............................................................................................................. 90 3.4.3. Endorsement methodology ............................................................................................. 92 3.5. Balloon licences ............................................................................................................... 94 3.5.1. Title taxonomy ................................................................................................................. 94 3.5.2. Rating taxonomy .............................................................................................................. 94 3.5.3. Endorsement methodology ............................................................................................. 96

GM1 Point 3.1 of Appendix I to Annex VI (Part-ARA) — Flight crew licence — EASA Forms 141 and 155 .................. 98 AMC1 Point 3.2 of Appendix I to Annex VI (Part-ARA) — Flight crew licence — EASA Forms 141 and 155 .............. 103 GM1 Point 3.4 of Appendix I to Annex VI (Part-ARA) — Flight crew licence — EASA Forms 141 and 155 ................ 103 GM1 Point 3.6 Appendix I to Annex VI (Part-ARA) — Flight crew licence — EASA Forms 141 and 155 ................. Error! Bookmark not defined.

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

Proposed regulatory material

The text of the amendment is arranged to show deleted, new or amended, and unchanged text as

follows:

— deleted text is struck through;

— new or amended text is highlighted in blue;

— an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.

Where necessary, the rationale is provided in blue italics.

Commission Regulation (EU) No 1178/2011 (Aircrew) Commission Regulation (EU) No 1178/2011 is amended as follows:

COMMISSION REGULATION (EU) No 1178/2011 of 3 November 2011

laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council

Article 1 — Subject matter 1. This Regulation lays down detailed rules for: [...] 2. Articles 11b, and 11c and 13 of this Regulation as well as Annex IV (Part-MED), Annex VI (Part-ARA), Annex VII (Part-ORA) and Annex VIII (Part-DTO) to this Regulation shall apply to pilot licences for balloons and sailplanes.

Article 2 — Definitions For the purposes of this Regulation, the following definitions shall apply:

[…]

(26) ‘licence’ means a document issued in physical or electronic format and endorsed in accordance

with this Regulation and entitling its lawful holder to exercise the privileges of the associated

ratings and certificates contained therein;

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(27) ‘licence issued in electronic format’ means a licence issued on a self-contained mobile electronic

visual display device. A licence issued in electronic format may be referred to as an ‘electronic

personnel licence’;

(28) ‘licence issued in physical format’ means a licence issued on paper or other suitable material,

including plastic cards;

(29) ‘electronic personnel licence system’ means an integrated system comprised of the computer

hardware, network and communication facilities, computer software, validated data, users and

associated regulatory framework to enable the issuance of licences in electronic format and the

conduct of verification activities;

(30) ‘self-contained mobile electronic visual display device’ means a device such as a mobile phone,

tablet or other mobile device that enables the generation and verification of the authenticity

and validity of a licence issued in electronic format;

(31) ‘medical certificate’ means a document issued in either physical format or electronic format

containing the items specified in point ARA.MED.130 of Annex VI (Part-ARA), confirming

compliance with the medical requirements in Annex IV (Part-MED).

Article 13 – Transitional measures regarding the inclusion of the information regarding the medical certificate in licences issued in electronic format

By way of derogation from point ARA.FCL.130(g) of Annex VI (Part-ARA), Member States may decide

to not include in a licence issued in electronic format the mandatory information regarding the medical

certificate of the licence holder as required in Appendix I to Annex VI (Part-ARA) until [date of entry

into force/applicability date + 10 years]. In that case, the holder of a licence issued in electronic format

shall hold a medical certificate issued in a physical format in accordance with Annex IV (Part-MED).

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ANNEX I (Part-FCL)

FCL.045 Obligation to carry and present documents […]

(f) The holder of the flight crew licence issued in electronic format shall report to the competent

authority that issued his or her licence the loss or theft of the self-contained mobile electronic

visual display device on which the licence was generated.

FCL.070 Revocation, suspension and limitation of licences, ratings and certificates

[…]

(b) When the pilots haves his/her their licence or certificate limited, suspended or revoked, they

he/she shall in the case of a licence or certificate issued in physical format immediately return

the this licence or certificate to the competent authority.

[…]

AMC1 to Appendix 10 Revalidation and renewal of type ratings, and revalidation and renewal of IRs when combined with the revalidation or renewal of type ratings – EBT practical assessment

[…]

Appendix 10 to another person to endorse the licence of the applicant, the following should

apply:

(1) the person signing endorsing the licence should be nominated,

(2) the person signing endorsing the licence should hold or have held an instructor

certificate,

(3) the approved procedure for delegation of signature should include procedures to prevent

the person who received the delegation from signing the licence when the EBT

programme applicable to the validity period has not been completed.

[…]

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GM1 to Appendix 10 — Revalidation and renewal of type ratings, and revalidation and renewal of IRs when combined with the revalidation or renewal of type ratings – EBT practical assessment […]

to Appendix 10 point (c), the EBT manager may nominate the EBT instructor who completed the

EBT module as the person to whom the signature endorsement of the examiner is delegated. A

stamp or electronic signature may exclusively be given from the EBT manager to the EBT

instructor, in order to document the delegation in a transparent and secure manner. Following

that process, EBT instructors on behalf of the EBT manager can endorse an applicant’s licence.

[…]

ANNEX IV (Part-MED)

MED.A.046 Suspension or revocation of medical certificates

(a) A medical certificate may be suspended or revoked by the licensing authority.

(b) Upon suspension of the medical certificate issued in physical format, the holder shall return the

this medical certificate to the licensing authority on request of that authority.

immediately return the this medical certificate to the licensing authority.

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ANNEX VI (Part-ARA)

AMC1 ARA.GEN.210 Changes in the management system COMPREHENSIVE RISK ASSESSMENT — ELECTRONIC PERSONNEL LICENCE SYSTEM

(a) The establishment and operation of an electronic personnel licence system will inherently

introduce new risks within the management system (either safety management system,

information security management system, protection of personnel data or the integrated

management system). To address such new risks, the introduction of an electronic personnel

licence system should entail a comprehensive risk assessment, and the risks identified should be

adequately mitigated in each phase of the project.

(b) Such risk assessment should be an integral part of the competent authority’s process for the

management of changes.

ARA.GEN.360 Change of competent authority MC1 to Appendix 10 Re […]

certificate provided that it has received and processed all documents specified in point (a). Upon

the reissuance of the licence and medical certificate, the receiving competent authority shall

immediately request the licence holder to surrender to it the licence issued by the transferring

competent authority and the associated medical certificate, if issued in physical format.

(d) The receiving competent authority shall immediately notify the transferring competent

authority once it has reissued the licence and medical certificate to the licence holder and the

licence holder has surrendered the licence and medical certificate pursuant to point (c). Until

such a notification is received, the transferring competent authority remains responsible for the

licence and the medical certificate originally issued to that licence holder.

(e) In the case of a transfer of a licence issued in electronic format, the receiving competent

authority and the transferring competent authority shall coordinate the revocation and reissue.

ARA.FCL.130 Licences issued in electronic format and establishment of an electronic personnel licence system

(a) The competent authority may decide to issue licences in electronic format to all licensed groups

of personnel, certain groups of personnel or certain individuals. For the same type of licence,

the same individual licence holder cannot hold both a licence issued in physical format and a

licence issued in electronic format.

(b) By way of derogation from point (a), the pilot is entitled to have a licence issued in electronic

format together with a document in physical format, issued in accordance with point

ARA.FCL.215, allowing the licence holder to exercise the privileges of the licence for a maximum

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period of 8 weeks after successful completion of the applicable examination(s), pending the

endorsement of the licence issued in electronic format.

authorised personnel can verify the authenticity and validity of the licence and are able to

determine its privileges and validity.

(d) The authenticity, validity and content of a licence issued in electronic format shall be

electronically verifiable:

(1) online when an internet connection is available; or

(2) offline when no internet connection is available through a means that imposes no undue

burden on the authorised personnel verifying the authenticity and validity of the licence.

(e) When the competent authority issues licences in electronic format, it shall establish and

implement procedures for the establishment and operation of an electronic personnel licence

system.

(f) The electronic personnel licence system shall ensure interoperability, security, confidentiality,

data protection, authentication and accessibility of the licences issued in electronic format.

(g) A licence issued in electronic format shall include the current information on the medical

certificate with class, expiry date and any medical information deemed relevant by the

competent authority in accordance with Part-MED.

(h) The competent authority shall develop and apply an administrative procedure for the update of

the licence issued in electronic format, including its limitation, suspension or revocation.

(i) The competent authority shall, upon request, grant to other competent authorities, aircraft

operators established in the Union, training organisations established in the Union and

instructors and examiners subject to this Regulation read-only access in real time to the personal

or licensing data as defined in Appendix I to this Part, if the requesting competent authority,

aircraft operator, training organisation, instructor or examiner can provide evidence to the

competent authority concerned that it needs such access to fulfil a legal obligation regarding a

specific holder of a licence issued in electronic format. That access shall be granted only as

regards the personal or licensing data of the licence holder identified in that request.

(j) When holders of a licence issued in electronic format have reported the loss or theft of the self-

contained mobile electronic visual display device on which their licence was issued, the

competent authority shall invalidate this licence and generate a new licence on another device

declared by the holder and to which they have access.

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AMC1 ARA.FCL.130 Licences issued in electronic format and establishment of an electronic personnel licence system

ELECTRONIC PERSONNEL LICENCE SYSTEM

1. DEFINITIONS

The following definitions apply to this Acceptable Means of Compliance.

‘Issuing authority’ means a competent authority with competence to issue licences, including licensing

authorities from third countries.

‘Mdoc’ means a document or application that resides on a self-contained mobile electronic visual

display device or requires such a device as part of the process to gain access to the document or

application.

‘Verifying authority’ means a competent authority with competence to verify the validity and

authenticity of licences, including authorities from third countries with competence to verify the

validity and authenticity of licences.

2. ABBREVIATIONS

API application programming interface

CSR certificate-signing request

EPL electronic personnel licence

EPLAPP application for a licence issued in electronic format

EPLDM electronic personnel licence data model

EPLDS data set for the licence issued in electronic format

EPLHD electronic personnel licence holder device

EPLRAP reading application for licences issued in electronic format

EPLRD electronic personnel licence reading device

EPLSYS electronic personnel licence system

FCL flight crew licence

HDPKIC holder device public key infrastructure certificate

IAPKIC issuing authority public key infrastructure certificate

IAS issuing authority server

JWT Java web token

LICSYS licensing system

MSO mobile security object

PKI public key infrastructure

RDPKIC reading device public key infrastructure certificate

TLS transport layer security

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URL uniform resource locator

3. PRIOR TO IMPLEMENTATION

Once an issuing competent authority has decided that one or several types of licence will be issued in

electronic format, it should decide on one of the following options:

(a) All the licences of that type will always be issued in electronic format.

(b) The two formats of the licence will be maintained (both physical format and electronic format).

format will be issued just for certain groups of personnel or specific individuals.

3.1. Licensing system and electronic personnel licence system

The licensing system (LICSYS) used by an issuing authority is not the electronic personnel licence

system (EPLSYS). The LICSYS and the EPLSYS are independent systems that share the source where the

information is stored: the issuing authority server (IAS) — see Figure 1.

Figure 1 — LICSYS and EPLSYS schema

(a) The LICSYS provides the tools that allow an issuing authority to manage the licence information

in accordance with its procedures for issuing, updating and invalidating the licence data. Only

data that has been validated in the national LICSYS and stored as valid licence information can

be used by the EPLSYS.

(b) The LICSYSs used by different issuing authorities might be different one from another: maybe

some issuing authorities use an existing market solution, and others have developed their own

LICSYS in accordance with their needs. Each LICSYS should work in accordance with the

requirements of the regulatory framework that applies to the issuing authority (such as EU

regulations, national regulations and national procedures established for the issuance, renewal,

revalidation, suspension and revocation of a licence).

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of an issuing authority are converted to an mdoc and are transferred to the holder device

(EPLHD).

(d) The EPLSYS also provides the method by which external parties (inspectors or other parties, who

will be generally called ‘verifiers’) can get the licence information on an electronic personnel

licence reading device (EPLRD) and proceed with the verification the authenticity and validity of

the of the licence issued in electronic format. Both the EPLHD and the EPLRD will need the

installation of software that can process the licence information..

3.2. The data set for the licence issued in electronic format (EPLDS)

(a) Each type of licence issued in electronic format has a specific set of data defined in the

Appendices to each applicable Regulation, such as Commission Regulation (EU) No 1178/2011

(aircrew).

(b) In contrast to licences issued in physical format, licences issued in electronic format share a

common structure, a common data set of information that is the same for all types of licences.

This common structure has been included in the affected regulations, and in this AMC it will be

referred to as the data set for the licence issued in electronic format (EPLDS).

medical certificate information of the licence holder, if applicable, as certain types of licence

might not require a medical certificate) — see Figure 2.

(d) Generally, the EPLDS is composed of two subsets of data: a subset related to the licence data

issued in physical format and a subset related to the medical certificate — see Table 1. This

creates unavoidable differences between the licence issued in physical format and the licence

issued in electronic format.

Figure 2 — Data sources for the licence issued in electronic format

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(e) Some licences issued in physical format allow the endorsement of rating revalidations by writing

them down on the licence issued in physical format. The revalidation information is handwritten

and signed by an examiner. Therefore, revalidations, even though they are part of the licence

issued in physical format, are validated by a person in a different role: the examiner instead of

the officer who signs the issuance of the licence. This creates a third source of licence

information of licences issued in electronic format — see Figure 3.

3.3. The term ‘licence’ and life cycles

(a) A licence issued in electronic format should be seen as a representation of the licence

information of the licence issued in physical format and the medical certificate at a particular

moment in time. It will remain valid as long as the licence issued in physical format and the

medical certificate remain the same, but the moment one of these subsets of data varies, this

representation is no longer valid, and another licence issued in electronic format supersedes the

existing licence issued in electronic format. Therefore, licences issued in electronic format

should be considered something that works in a similar way to how medical certificates do. The

invalidation of a licence issued in electronic format does not equal the invalidation of a licence

issued in physical format or the invalidation of a medical certificate; it only means that the

information in that representation is no longer accurate.

(b) Both the licence issued in physical format and the licence issued in electronic format grant the

licence holder the right to make use of the privileges given by them, and it makes no difference

having one format or the other, but technically they are not the same because of the

particularities of the licence issued in electronic format.

3.3.1. Issuance of a licence

Referring to licences (either licences issued in electronic format or licences issued in physical format),

the issuance could be considered as the process by which the data of the document is validated by the

Table 1 — Information data set for each type of document

Figure 3 — Revalidations as a third data source

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issuing authority and the outcome is a valid licence being delivered to the licence holder. This process

contains two important actions:

(a) generation of the licence: action by which the licence data is inserted into a document

(independently of the format of the document, electronic or not);

(b) validation of data: action by which the licence data at a specific moment in time is rendered

valid by a signature that comes from the competent authority.

3.3.1.1. Physical licence issuance process

When using licences issued in physical format, a simplification of the issuance process should be as

shown in Figure 4:

Figure 4 — Physical licence issuance process

(a) A licence applicant (or holder, if a previous licence has already been issued), fills out a licence

application and submits it to the issuing authority.

(b) The issuing authority officers process the application following the established procedures.

(d) The licence information is validated by an issuing authority officer’s signature.

(e) The licence is given to the applicant, who becomes a licence holder.

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3.3.1.2. Issuance process of the licence issued in electronic format

With an EPLSYS, the issuance process of a licence issued in electronic format would be as shown in

Figure 5:

Figure 5 — Issuance process of the licence issued in electronic format

(a) A licence applicant (or holder, if a previous licence has already been issued) completes a licence

application and submits it to the issuing authority.

(b) The issuing authority officers process the application following the established procedures.

signed digitally by an officer of the issuing authority.

(d) Since the medical information is included in the licence issued in electronic format, it needs to

be available in the IAS. If it is not, it will be registered and validated by the medical assessor.

(e) Once validated, the licence data and the medical data set are stored in the IAS.

(f) The licence holder needs to install the application for the licence issued in electronic format

(EPLAPP) on the EPLHD and send a request for the generation of a licence issued in electronic

format to this specific device.

(g) The licence issued in electronic format is generated by the IAS and sent to the EPLHD.

(h) Once the licence issued in electronic format is received in the EPLHD, it is stored in the EPLAPP.

3.3.1.3. Comparison of issuance processes

If the processes of issuance of the licence issued in physical format and of issuance of the licence issued

in electronic format are compared (see Figure 6), depending on the format of the licence, there are

significant differences that affect the concept of issuance:

Figure 6 — Comparison of issuance processes

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(a) Difference in the number of documents: The primary and most obvious difference is that,

outside the electronic world, two separate documents exist for some licences: for example, with

a flight crew licence, there are the licence issued in electronic format and the medical certificate.

Revalidations are considered part of the licence data set, although they might have a different

validator. With licences issued in electronic format, only one document exists, and parts of its

information are validated by people in different roles.

(b) Updating licence information: The licence information of the licence issued in electronic format

can be updated in response to changes in the licence issued in physical format data set or in the

medical certificate data set. Every time that there is a change, a new licence issued in electronic

format must be generated, so that the information it contains is valid and up to date. This entails

that in a licence issued in electronic format will be generated and delivered more frequently

than in a licence issued in physical format.

is generated (printed) and then validated by the officer’s signature (handwritten) whereas in an

EPLSYS the licence data of the licence issued in electronic format must first be validated by an

officer in the LICSYS (by an electronic signature) and then the mdoc is generated and finally

electronically signed by the issuing authority. Note that the signature of the mdoc is intended to

protect the mdoc information, not to validate the data it contains.

(d) Method of licence generation: A licence issued in physical format is generated when the issuing

authority decides to do so, by printing it, whereas with an EPLSYS the data verified by the issuing

authority is made available for generation of the licence in electronic format once the licence

holder sends a request from the EPLHD.

(e) The licence holder is in charge of generating the information on the licence issued in electronic

format: The licence issued in electronic format is linked to a specific self-contained mobile

electronic visual display device. When the licence in electronic format is generated, it contains

information about the device where it will be contained; therefore, the licence holder must have

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provided the information about the device prior to the generation of the licence in electronic

format, meaning that it is the licence holder who initiates the generation of the licence in

electronic format.

3.3.2. Suspension and revocation of a licence

(a) When a licence is generated in electronic format, the issuing authority should also generate a

public key infrastructure (PKI) certificate that represents the issuing authority, the issuing

authority PKI certificate (IAPKIC), and the licence issued in electronic format is signed with this

certificate. Further details of this process are provided in Section 4.2.1, but for now it should

suffice to be aware that the EPLDS of each licence issued in electronic format will be signed with

a unique IAPKIC that is specific for each licence issued in electronic format.

(b) A licence issued in electronic format should be considered a representation that reflects the

licence data set information and the medical data set information at a specific moment in time.

If any of this information changes, then the licence issued in electronic format must be

invalidated and a new licence in electronic format generated. The invalidation of a licence issued

in electronic format takes place by revoking the IAPKIC used to sign the EPLDS, but this

revocation of the IAPKIC must not be confused with the administrative act of revocation of a

licence or the revocation of a medical certificate, which would take away the privileges of the

licence holder. Therefore, in order to avoid confusion, the revocation of an IAPKIC will be

referred to in this AMC as ‘invalidation’, and the outcome is that the licence in electronic format

signed with this IAPKIC is invalidated.

format, and no further generations of the licence are possible. This presents a completely

different situation.

(d) The electronic personnel licence data model (EPLDM) does not include the status of the licence,

so there is no way to indicate whether a licence issued in electronic format is valid, suspended

or revoked. A licence issued in electronic format provides only valid and up-to-date information.

(e) If a licence is suspended by an administrative act, the existing IAPKIC used to sign the licence

issued in electronic format shall be revoked and a new licence in electronic format generated

without information, or with only the medical information if it was valid. In an EPLSYS as defined

by ICAO, the difference between the revocation and the suspension would be noted because:

(1) In the case of revocation, no licence issued in electronic format exists and no new licence

issued in electronic format can be generated.

(2) In the case of suspension, the licence in electronic format can be generated, but it is

empty (no valid data is available), and new licences in electronic format can be generated.

When the suspension ends, a further generation of the licence in electronic format would

recover all the valid licence data.

(f) The revocation of a medical certificate will not revoke the licence data set; therefore, the

existing IAPKIC used to sign the licence issued in electronic format is revoked and a new licence

in electronic format without medical information is generated. In this case, there would be no

difference between the revocation or suspension of a medical certificate; the medical

information would not be displayed in the licence issued in electronic format just the same.

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3.4. Verification of the authenticity and validity of a licence issued in electronic format

(a) The verification of the authenticity and validity of a licence issued in electronic format consists

in verifying that the IAPKIC is still valid. When a licence issued in electronic format is invalidated,

so is the IAPKIC, and the IAPKIC is added to a certificate revocation list in the IAS. This means

that each licence issued in electronic format has a unique IAPKIC that is specific for each licence

issued in electronic format, and its validity is checked, verifying whether the IAPKIC is still valid.

(b) It is important to be aware that the verification of the authenticity and validity of a licence issued

in electronic format ensures that the information in the EPLDS has not been tampered with and

it remains as provided by the issuing authority. The verification process of the EPLSYS does not

check whether the ratings are still valid (it is possible that some ratings have an expiry date in

the past and the licence issued in electronic format is still valid). Therefore, verifiers will need to

look at the information provided and analyse whether the holder has the appropriate privileges

to perform whatever task the holder is performing, just as done with a licence issued in physical

format.

verifies that:

(1) the licence issued in electronic format is still valid (the IAPKIC with which it was signed is

not revoked); and

(2) the licence information of the licence issued in electronic format is as provided by the

issuing authority.

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4. EPLSYS

4.1. EPLSYS introduction

(a) An EPLSYS is an integrated system comprised of computer hardware, network and

communication facilities, computer software, validated data, users, and rules and regulations to

enable the issuance of licences in electronic format and the conduct of oversight activities.

Figure 7 — EPLSYS interfaces

Error! Reference source not found. represents the three interfaces of the EPLSYS, accordance to ISO 18013-5, which are:

1. interface between the issuing authority and the licence holder;

2. interface between the licence holder and the licence verifier;

3. interface between the licence verifier and the competent authority.

ISO 18013-5 applies to interfaces 2 and 3 and considers interface 1 (the link between the

competent authority’s server and the licence holder) specific to each state.

(b) EPLSYS implementation requires that the issuing authority should develop an application for the

licence holder: the EPLAPP. This application should be installed in the EPLHD and should allow

the licence holder to connect with the IAS, receive and store the licence issued in electronic

format (interface 1) and allow the verification of the validity and authenticity of the licence by a

licence verifier that may use an EPLRD. This verification is done through interface 2 (offline

through a data exchange between devices) or interface 3 (online through a connection with the

IAS).

licences issued in electronic format. This means that it is up to the competent authority to decide

whether or not it is necessary to provide the licence verifiers with a tool for the verification of

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the validity and authenticity of the licences issued in electronic format. This verification tool

consists of a second application that can be installed in an EPLRD, which allows engagement

with the EPLHD, can understand the information received from the EPLHD and permits

verification, both offline (interface 2) and online (interface 3). This application will be called the

reading application for licences issued in electronic format (EPLRAP).

(d) The implementation of an EPLSYS does not require the implementing competent authority to

develop the EPLRAP, but it does require the development of the verification tools necessary for

other verifying authorities to verify the validity and authenticity of the licences issued in

electronic format by the implementing competent authority. This means that the licences in

electronic format generated by the implementing competent authority should be able to be

verified by EPLRAPs of other verifying authorities both offline (interface 2) and online

(interface 3). The implementing competent authority may choose not to develop an EPLRAP, but

it needs to provide just the same the possibility for other states to verify its licences issued in

electronic format through device engagement and by connection to the IAS.

(e) If a competent authority does not develop an EPLRAP, there can only be a visual inspection of

licences issued in electronic format. Verification using the EPLRAP provides extra measures of

security that make it very difficult to tamper with the licence information of a licence issued in

electronic format.

(f) It is important that verifying authorities be aware that they will have to verify licences in

electronic format even if they do not implement them. Therefore, they might need an EPLRAP

even though they do not issue licences in electronic format.

(g) The EPLHD and EPLRD where the EPLSYS applications will be installed should provide for the

information security requirements.

4.2. Data exchange phases

There are the following phases of data exchange: licence issuance, initialisation, device engagement

and data retrieval — see Figure 8.

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Figure 8 — Data exchange phases

— Phase 0 — Licence issuance: This interaction is between the EPLHD and the IAS. In this phase a

licence in electronic format is generated and stored in the EPLHD.

— Phase 1 — Initialisation: The licence holder initiates the EPLHD for licence verification. This

phase is always initiated by the licence holder. A QR code that contains the information required

to set up and secure phases 2 and 3 is generated. The EPLHD gets ready for phase 2.

— Phase 2 — Device engagement: The EPLRD reads the QR code generated in phase 1 on the

EPLHD, and a message is transferred from the EPLHD to the EPLRD.

— Phase 3 — Data retrieval: The licence verifier selects the data retrieval mode and asks the

licence holder for consent to access the licence data of the licence issued in electronic format.

If consent is granted, this interaction depends on the methodology of the data retrieval: it can

be either between the EPLHD and the EPLRD or between the EPLRD and the IAS. The licence

information of the licence issued in electronic format is obtained in the EPLRD and verified.

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4.2.1. Phase 0: Licence generation

Figure 9 — Data validation

(a) Prior to the generation of the licence issued in electronic format, as explained in Section 3.3.1.2,

the data has been validated in the LICSYS and properly stored in the IAS — see Figure 9. At this

point, no generation of a licence in electronic format has occurred.

(b) The licence holder should have the EPLAPP installed on the EPLHD, and the EPLAPP must be

initialised (see Section 4.4.2). The reader should note that the initialisation of the EPLAPP is not

the same as the initialisation of ‘phase 1: device engagement’ when exchanging data.

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4.2.1.1. The mdoc of a licence issued in electronic format

(a) A licence issued in electronic format should follow the specification of an mdoc — see Figure 10.

Figure 10 — Mdoc data model

(b) The doctype and namespace are used to encapsulate the document type and the space in which

the data elements are defined.

1 represents the version of the document type. The licence issued in electronic format has a

specific data model that might change with time; should this happen, the doctype version will

change. The EPLAPP should be ready to work and be updated with new versions of the EPLDM.

(d) Each namespace of the licence issued in electronic format, as defined in ICAO Doc 10190, is

related to one of the groups of information of the common form defined in ICAO Annex 1

(Appendix 4) and contains a list of data items in accordance with the licence or the medical

certificate data.

4.2.1.2. Step 1: Device enrolment with the competent authority

To initiate the generation of a licence issued in electronic format, the EPLAPP must enrol the EPLHD

with the issuing authority through an interface provided by the issuing authority. This enrolment is

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done creating a PKI certificate-signing request (CSR) in the EPLHD and sending it to the IAS, as shown

in Figure 11:

Figure 11 — Step 1 of licence issuance in electronic format

(a) The EPLAPP generates a public/private key pair for the EPLHD, to be used only for this specific

licence issued in electronic format.

(b) The public key generated in (a) is included in a CSR.

(d) The IAS issues and signs the holder device PKI certificate (HDPKIC). The HDPKIC represents the

EPLHD identity and will allow the licence issued in electronic format to be linked to the EPLHD

where the key pair was generated. This avoids the possibility that the licence issued in electronic

format can be cloned in another EPLHD.

(e) The HDPKIC is stored with the licence holder’s record in the IAS.

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4.2.1.3. Step 2: Mobile security object generation

Figure 12 — Step 2 of licence issuance in electronic format

(a) The EPLSYS in the IAS should search for any already existing licence of the same type issued in

electronic format for the holder (for example, a licence in electronic format was generated in

another EPLHD) — see Figure 12. If so, the existing licence in electronic format should be

invalidated before the new licence in electronic format is generated.

(b) The licence data set and the medical data set are obtained from where they are stored in the

IAS. The information must be processed as it is organised in the valid data model, putting every

piece of information in the corresponding namespace and data item. The EPLDS is obtained.

(d) ISO 18013-5 requires the use of two public/private key pairs in the mdoc: one for the EPLHD

(generated in step 1) and another one for the issuing authority. The authorities must generate

a unique key pair for each individual licence issued in electronic format.

(e) The IAPKIC, which is a PKI certificate containing the issuing authority public key, is generated,

and it is signed by the issuing authority.

(f) The MSO is signed with the private key of the IAPKIC.

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4.2.1.4. Step 3: Delivery of the licence issued in electronic format

(a) The mdoc is generated, including the IAPKIC, the information about the EPLDS and the MSO. The

mdoc is returned to the EPLHD — see Figure 13. The licence issued in electronic format is stored

in the EPLAPP and ready to be displayed and verified.

(b) The EPLAPP may encrypt the mdoc information using the HDPKIC, so the privacy of the licence

holder is protected.

4.2.2. Phase 1: Initialisation

(a) The initialisation consists of preparing the EPLHD for the next phase (device engagement). The

EPLSYS shall admit initialisation only using a QR code.

(b) The QR code contains the ‘engagement message’, which should follow the structure defined in

Section 8.2.1.1 of ISO 180136-5 and contains information such as device retrieval technologies

(offline retrieval); server retrieval technologies (online retrieval); server retrieval token; and

protocol info.

code. Once it is generated, the EPLHD should open the connections to allow the request from

an EPLRD — see Figure 14.

4.2.3. Phase 2: Device engagement

(a) The verification of the authenticity and validity of the licences issued in electronic format is done

using wireless short-range peer-to-peer communication between the EPLHD and the EPLRD. The

devices exchange information in two phases, the device engagement being the first one of them

— see Figure 15. This phase determines the technical characteristics for the later retrieval phase:

(1) The EPLRD, using the EPLRAP, reads the code generated in the EPLAPP.

(2) The EPLRD opens the communications to start the next phase.

Figure 14 — Phase 1: Initialisation

Figure 13 — Step 3 of the generation of the licence issued in electronic format

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(b) During this phase, the engagement message is transferred from the EPLHD to the EPLRD by

means of a QR code containing the information required to set up and secure the data retrieval.

The information exchanged includes the capabilities of the EPLHD for the subsequent data

retrieval (technologies usable: Bluetooth low energy, Wi-Fi aware (optional) and online) and

parameters for a session initiation (cipher suites, keys). The message contains the security

information used to initiate device retrieval and the token used to initiate server retrieval.

Following transfer of the device engagement message, the information contained in the

message is used to hand off the retrieval of the licence issued in electronic format to a separate

channel (phase 3).

a certain time (not less than 30 seconds is recommended). The EPLHD may terminate the

engagement and the data retrieval at any time.

4.2.4. Phase 3: Data retrieval

4.2.4.1. Step 1: Data retrieval request

Figure 16 — Phase 3, step 1: Data retrieval request

(a) Once the devices are engaged, the verifier will generate in the EPLRAP a data retrieval request

(see Figure 16), whereby the licence verifier notifies the holder of the licence which information

from the EPLDS is to be retrieved and which retrieval method will be used.

(b) The data retrieval request is received by the EPLHD, and the EPLAPP will proceed to verify the

validity of the data retrieval request.

authorise the data retrieval or refuse it.

(d) When the licence holder receives a data retrieval request from a verifier, the EPLAPP must carry

out a few verification steps to assess whether the data retrieval request is valid, as follows:

(1) The EPLAPP gets the RDPKIC from the data retrieval request.

Figure 15 — Phase 2: Device engagement

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(2) The EPLAPP verifies that the RDPKIC is not expired and that it is signed with the verifier’s

IAPKIC.

(3) The EPLAPP verifies that the RDPKIC is not included in the PKI certificate revocation list of

the verifier’s authority (it would be so in case of a security key compromise, for instance).

(4) The EPLAPP verifies that the verifier’s IAPKIC is included in the trust list by following the

steps described in Section 11.1.12 of ICAO Doc 10190.

(e) If any of these checks fail, an appropriate error indication is displayed in the EPLAPP, and the

communication session should be terminated.

(f) If the validation of the data retrieval request is successful, the licence holder can proceed with

the authorisation of data retrieval.

4.2.4.2. Step 2: Data retrieval

(a) The data retrieval methods available (see Figure 17) should be:

(1) device retrieval: the licence issued in electronic format is transferred from the EPLHD to

the EPLRD (offline);

(2) server retrieval: the licence issued in electronic format is transferred from the IAS to the

EPLRD (online).

(b) It is recommended that the first attempt at data retrieval be the device retrieval option and, if

unsuccessful, only then is the server retrieval attempted.

request for data elements and the EPLAPP (or IAS) responds with the requested data. The

retrieval of data works in a session, and only those elements of the EPLDS that are requested by

the verifier are transmitted once the licence holder has approved the request.

(d) Licences issued in electronic format may have additional data elements that can be defined by

each issuing authority, and they might not be interoperable with reading devices from other

states. If the EPLHD cannot recognise a requested data element, it will be ignored and the EPLRD

might inform the licence verifier about the data elements that will not be returned.

(e) The data retrieval differs depending on the data retrieval option the licence verifier specifies in

the data retrieval request.

Figure 17 — Phase 3, step 2: Data retrieval

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4.2.4.2.1. Device data retrieval

Figure 18 — Phase 3, step 2: Device data retrieval

(a) Once the data retrieval request is authorised by the licence holder, the licence issued in

electronic format is transferred from the EPLHD to the EPLRD — see Figure 18.

(b) When an EPLRD receives the licence issued in electronic format from an EPLHD, the EPLRAP

verifies that:

(1) the IssuerSigned element contains the MSO;

(2) the MSO is signed by a non-expired IAPKIC and that the IAPKIC is included in the trust list

following the steps of Section 11.1.1.2 of ICAO Doc 10190;

(3) the DeviceSigned element contains the HDPKIC;

(4) the HDPKIC is not included in the PKI certificate revocation list of the issuing authority.

information exchange should be terminated.

(d) The data elements of the licence issued in electronic format should be returned in the

namespaces of the EPLDM defined in ICAO Doc 10190. The elements of the MSO should always

be returned as IssuerSigned elements; if they were returned in the DeviceSigned data, the

licence issued in electronic format should be considered invalid.

(e) The elements of the licence issued in electronic format should be verified to conform to the

encoding format and maximum size as defined in ICAO Doc 10190.

(f) In order to ensure the integrity of the data value for each data element, the reader application

should calculate the message digest for each data value using the digest algorithm specified in

the MSO. The structure of the MSO is described in Section 9.1.2.4 ‘Signing method and structure

for MSO’ in ISO 18013-5.

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4.2.4.2.2. Server retrieval

Figure 19 — Phase 3, step 2: Server data retrieval

(a) The licence information of the licence issued in electronic format is transferred from the IAS to

the EPLRD.

(b) Section 6.3.2.5 of ISO 18013-5 contemplates two server retrieval options: web application

programming interface (API) and OpenID Connect. ICAO Doc 10190 limits the options to web

API. Therefore, both the EPLHD and the EPLRD must support web API retrieval, the structure of

which is defined in Section 8.2.1.2 of ISO 18013-5. It includes three fields:

(1) Version, currently 1;

(2) Issuer uniform resource locator (URL), as defined in Section 8.3.3.2.1 of ISO 18013-5;

(3) Server retrieval token.

a well-designed server retrieval token. The token and a universal resource identifier (URI) for

accessing the issuing authority’s EPLSYS are sent from the EPLHD to the EPLRD — see Figure 19.

The EPLRD will use the token in response to the server retrieval request and does not need to

verify or understand it, but the issuing authority receiving the request should perform validation

of the authenticity and integrity of it. Each competent authority will be able to determine the

format of the server retrieval token; however, they should:

(1) be of a short duration;

(2) be used only once (single use);

(3) uniquely identify the licence holder;

(4) include consent for release of specific elements of the licence issued in electronic format;

(5) include digital device signature authenticating the licence holder.

(d) ISO 18013-5 supports transfer of the server retrieval token during both device engagement and

data retrieval, but ICAO Doc 10190 specifies that the server retrieval token must be sent in the

device engagement phase and not in the data retrieval phase.

(e) The EPLRD obtains the issuer URL contained in the device engagement message, to establish a

connection with the competent authority. The EPLRAP should verify the URL against the

distinguished name field in the IAPKIC in the ICAO master trust list, to ensure that the URL is not

spoofed. The communications between the EPLRD and the IAS should be secured using transport

layer security (TLS) with mutual authentication.

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(f) The issuing authority should validate the TLS PKI certificate presented by the EPLRD, and the

EPLRD should validate the TLS PKI certificate presented by the issuing authority.

(g) The token provides authorisation from the licence holders for the licence verifiers to access

licence data issued in electronic format. A valid token is required for server retrieval. If the

validation of the token fails, the competent authority should not return licence data issued in

electronic format to the EPLRD.

(h) The issuing competent authority should verify that the fields that are requested by the reader

have been approved for disclosure by the holder.

(i) The server response for Web API is described in Section 8.3.2.2.2.2 of ISO 18013-5, and it

includes three fields:

(1) Version: always 1 as defined by ISO 18013-5;

(2) Documents: it will contain the licence issued in electronic format as a Java web token

(JWT);

(3) DocumentErrors: The EPLRAP should process error codes contained here.

(j) The Java simple object notation (JSON) web signature should be protected using a Java simple

object notation (JSON) web signature as specified in ISO 18013-5 Section 9.2.2. The EPLRD

should validate the JWS as described in ISO 18013-5 Section 9.3.2.

4.3. Chain of trust

(a) Both the EPLAPP and EPLRAP should download the latest EPL master trust list from ICAO to the

device where they have been installed, and should check the electronic signature of the trust

list to ensure its integrity.

(b) Each IAPKIC in the trust list will contain the URL distribution point value that points to the licence

holder’s and verifier’s PKI certificate revocation lists for that state. These lists should be

downloaded every 24 hours to the EPLHDs and EPLRDs to ensure that the revocation list is up to

date and available for the verification process.

Doc 10190 are followed.

4.4. EPLAPP

The EPLAPP will be installed in the EPLHD and will allow an appropriate way to identify the licence

holder, generate and store one or several licences issued in electronic format, and synchronise the

existing licences information issued in electronic format in the application. It will also have some

functionalities that allow the licence holder to generate a one-time QR code that will allow

engagement with an EPLRD and the retrieval of licence data of the licences issued in electronic format.

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4.4.1. Downloading and installing the EPLAPP

(a) Each issuing authority will need to publish its national EPLAPP for at least Android and iOS

systems — see Figure 20.

(b) Once downloaded, the application will be installed like any market application for those

operating systems.

4.4.2. Initialising the EPLAPP

Figure 21 — EPLAPP initialisation

(a) Any instance of an EPLAPP installed on a new device will need to follow an initialisation process

— see Figure 21. The purpose of this process is to ensure the proper identification of the licence

holder and to link the new EPLHD to the licence holder. The process of initialisation requires an

internet connection to be available.

(b) The first time the licence holder signs in to an instance of an EPLAPP installed on a specific

EPLHD, the licence holder needs to be properly identified. If the licence holder is in possession

Figure 20 — EPLAPP operating systems

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of a digital certificate that already provides a digital identity, it can be used to log in to the

EPLAPP.

themselves to the issuing authority, which, once the licence holder has been properly identified,

will create the digital identity of the licence holder and provide credentials to log in to the

EPLAPP.

(d) Issuing authorities could also consider the use of an approved vetting and proofing process that

can create digital credentials for the licence holder. This process can be established using a

method such as two-factor authentication using a username and password followed by a one-

time token.

(e) All issuing authorities will need to prepare the EPLAPP to identify the licence holder using the

EU Digital Identity Wallet of the holder and use it as the digital identity of the licence holder.

(f) Once the licence holder has logged in, the EPLAPP will verify the holder digital identity in the IAS

and link the instance of the EPLAPP to the licence holder.

(g) The EPLAPP will send a confirmation that the initialisation process has successfully finalised. In

the event of a failure, it will send a notification of any error that has occurred.

Once the initialisation process has successfully finalised, the EPLAPP will be available for use.

Otherwise, the EPLAPP will have all its functionalities blocked and no information will be able to

be seen or managed in the application.

4.4.3. Actions on the licence issued in electronic format

The EPLAPP needs to provide the licence holder with several actions to perform on the licence issued

in electronic format, such as:

(a) View licence issued in electronic format: The licence issued in electronic format has been

downloaded into a device and is ready to be used. Pressing the button leads the holder to view

the licence issued in electronic format.

(b) View licence issued in electronic format in accordance with ICAO format: The information in the

licence issued in electronic format should always be available in English. However, Member

States can use up to eight additional national languages.

(1) The EPLDM described in ICAO Doc 10190 allows the issuing authority to specify national

privileges for the licence issued in electronic format. These national privileges might not

follow a standardised taxonomy, might have very particular characteristics, might make

no sense outside the issuing state or might not be available in English, since the authority

is not obliged to translate them. Therefore, it could happen that an EPLRD from another

state is not able to read or process the information about the national ratings.

(2) For these reasons, the EPLAPP needs to provide a standardised display of the licence

issued in electronic format (that is, in English and lacking national privileges should they

not be understood by EPLRDs from other states), which is considered the ICAO format

and is compliant with ICAO specifications. Therefore, the EPLAPP must provide for each

type of licence the possibility of displaying the licence issued in electronic format in this

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ICAO format. The button in the EPLAPP that allows the generation of this format is

required to have the ICAO logo.

available as a licence issued in electronic format, but the licence issued in electronic format has

never been generated yet. Pressing this button will start the licence generation as described in

phase 0 (see Section 4.2.1).

(d) Update licence issued in electronic format: The licence issued in electronic format has been

downloaded to an EPLHD, but the EPLAPP detects that there have been changes in the EPLDS,

so the generation of a new licence in electronic format is required. The EPLAPP needs to indicate

to the licence holder that a new licence issued in electronic format should be generated.

It is important that the licence holder manually initiate the generation of the new licence in

electronic format, because it will be in the process of generation that the former licence issued

in electronic format will be invalidated. It could cause problems, especially for aircrew licences,

because if this licence were invalidated without the knowledge of the licence holder, and there

were a process of verification, the licence holder would not know that the stored new licence

issued in electronic format was no longer valid and might be in a situation where there would

be no option to update it. Therefore, the former licence in electronic format should be valid until

the new licence in electronic format is generated.

(e) Transfer licence issued in electronic format: The licence issued in electronic format has been

downloaded to another device. The licence holder can decide to transfer the licence to this

device, which will invalidate the licence issued in electronic format in the first device and

generate a new licence in electronic format in the current device.

4.4.4. Availability of the licence issued in electronic format

(a) There might be cases where the licence holder will not be able to request the generation of the

licence in electronic format in the EPLAPP. In these cases, an indication of ‘EPL not available’

should be shown to the licence holder.

(b) The message ‘EPL not available’ could be due to any of the following situations:

(1) The competent authority has decided not to use the electronic format for this particular

type of licence.

(2) The licence holder does not possess that type of licence.

(3) The licence holder possesses that type of licence, but the licence holder possesses a

physical version of the licence, so the licence in electronic format cannot be generated.

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4.4.5. List of licences

(a) This section contains a proposal for competent authorities about how the EPLAPP home page

could work, but Member States may decide on a different solution that best suits their purposes.

(b) Error! Reference source not found.’ proposes that the home page of EPLAPP contain the

identification data of the licence holder and a list of all the licences the licence holder has. Each

licence issued in electronic format is an independent entity, which might have been issued

subject to a different regulation, but, if the licence holder has five different licences, it will be

costly for the issuing authority to develop and maintain one independent EPLAPP for each type

of licence. The list of licences in this example allows all the types of licences to be listed in a

single application, and each type of licence has an associated action that depends on the status

of the licence.

Figure 22 — EPLAPP home page

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a single EPLAPP.

(d) Every time the list is loaded, there will be a synchronisation of the licence information of each

type of licence, so the synchronisation date of each type of licence should be updated.

(e) When developing the EPLAPP, it should be taken into consideration that the application must

be able to function properly offline. If the EPLHD is online, the list of licences and available

actions can be synchronised as appropriate. If the EPLHD is not online, only the licences issued

in electronic format stored on this specific device will be listed.

4.4.6. Accessing a licence issued in electronic format

When a licence issued in electronic format is stored in an instance of the EPLAPP, the action ‘View EPL’

will be available. Pressing the button will lead to the licence information of the licence issued in

electronic format and the actions that can be taken on that specific licence issued in electronic format,

such as:

(a) Manual synchronisation: This action will not be available in offline mode. When selected, the

EPLAPP will look for any changes in the licence issued in electronic format and update the date

of last synchronisation. If necessary, the licence information of the licence issued in electronic

format will be updated by the generation of a new licence in electronic format.

(b) Deactivate the licence issued in electronic format: This action will allow the holder of the licence

issued in electronic format to deactivate it in the instance of the EPLAPP on which it is stored.

Therefore, the licence issued in electronic format will be invalidated.

When the licence holder decides to erase the licence issued in electronic format from an

instance of EPLAPP, such deletion:

(1) should delete all information, including log information, and any metadata that could

impart information about the erased licence in electronic format;

(2) should not require approval by the issuing authority;

(3) should be available to a licence holder via a request from the issuing authority.

Issuing authorities should consider making it possible to delete a licence in electronic format

from an EPLHD remotely, for security reasons (such as the EPLHD being stolen).

generate the QR that will allow the device engagement with the EPLRD. This action will allow

the generation of the QR code.

4.4.7. Background with moving image

As a security measure, licences issued in electronic format should have security features such as a

moving image that allow the verifiers to be certain they are not viewing a static image.

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4.4.8. Audit log

The EPLAPP should be capable of maintaining an audit log. The licence holder should be able to decide

whether to make use of this log or not. The audit log and related settings should be accessible only to

the licence holder.

The audit log will keep a record of all the transactions concerning the licence issued in electronic format

(sharing licence information of the licence holder with a verifier for the licence issued in electronic

format) and communication actions between the EPLHD and the competent authority.

4.5. EPLRAP

(a) The EPLRAP will be installed on the EPLRD and will allow the staff of competent authorities to

retrieve data from a licence issued in electronic format (or directly from an IAS) and proceed

with the necessary verification of the data, such as the validity of the signature and the validity

of the EPLDM that has been retrieved.

(b) Member States that decide to develop an EPLRAP should follow the specifications of this AMC.

on the personal devices of the verifying authority staff. The competent authorities should

provide their staff with the tools required to fulfil their tasks.

4.5.1. EPLRAP functional requirements

The EPLRAP shall include at least the following functional requirements:

(a) It needs to be able to request, receive and verify the integrity and authenticity of a licence issued

in electronic format whether online connectivity is present or not for either the EPLHD or the

EPLRD.

(b) A user of EPLRAP not associated with the issuing authority needs to be able to verify the integrity

and authenticity of a licence issued in electronic format.

issued in electronic format and the licence holder.

(d) The interface between the licence issued in electronic format and the EPLRAP needs to support

the selective release of the licence data issued in electronic format to the reader.

4.5.2. Downloading and installing EPLRAP

(a) Each verifying authority can decide to develop its own EPLRAP in any operating system that best

suits the authority’s purposes. Unlike the EPLAPP, the verification application will be developed

to be used only by the verifying authority’s staff. Therefore, it can be developed in accordance

with the verifying authority’s requirements provided it complies with the specifications of this

AMC.

(b) The ability to download the application should not be publicly available. The verifying authority

can install the EPLRAP on the devices of the staff who need to perform verification of the licence

issued in electronic format.

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4.5.3. Reading licence issued in electronic format with EPLRAP

(a) The home page of the EPLRAP will have the user’s basic information — see Figure 23. It does not

need to have personal data; the officer/inspector number or any other type of identification the

authority considers necessary should be enough.

(b) Under the person’s details, there should be an ‘Engage’ button that will activate the EPLRD

camera to read the QR code generated in the EPLAPP. Once the code is read, the EPLRAP will

manage the information from the QR code and proceed with the device engagement (see

Section 4.2.3).

the data to be retrieved from the licence issued in electronic format. By default, the EPLRAP will

have the following requests available:

Figure 23 — EPLRAP home page

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(1) Inspection data retrieval: This request will contain the minimum data set necessary to

proceed with a ramp inspection, as defined by ICAO.

(2) Full licence data retrieval: This request will contain all the licence information of the

licence issued in electronic format.

(3) Customised data retrieval: This option will allow the licence verifier to choose which items

of the licence issued in electronic format to request to be retrieved from the licence issued

in electronic format.

(d) Once the set of data to be requested has been selected, the licence verifier needs to indicate

the data retrieval mode (device retrieval or server retrieval).

(e) With the selections defined, the EPLRAP will generate the data retrieval request and send it to

the EPLHD. Only if the licence holder authorises the data retrieval will the licence information of

the licence issued in electronic format be retrievable.

(f) The EPLRAP should display the licence information of the licence issued in electronic format in

accordance with the data dissemination option authorised by the licence holder.

4.5.4. Data retention

(a) The information should be kept only during the time necessary for the inspection and

accident/incident processes and be removed within 24 hours from the end of the verification

process. Appendix D to ICAO Doc 10190 specifies the policy on data retention in EPLRDs.

(b) If a verifying authority requires to keep data from the licence issued in electronic format, the

licence holder, who will be properly informed, should be notified and agree in writing.

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5. DATA MODEL

5.1. EPLDS

(a) All types of licences issued in electronic format should be compliant with the common EPLDS

that has been defined in the applicable Regulation. Table 2 lists how the licence data of the

licence issued in electronic format is structured, and has the following structure:

— Section: Defines a portion of a licence that contains specific data units that have a logical

relation with each other

— Data unit: Piece of licence data of the licence issued in electronic format that defines

specific information.

(b) However, not all the data units of the EPLDS are included in the MSO signed by the IAPKIC. In

the column ‘MSO’, those data units to be included in the MSO are specified. In addition, the

column ‘Presence’ determines which data units are mandatory (M), which ones are optional (O)

and which ones are mandatory as long as they are applicable (M*). For example, medical

limitations are mandatory if there are any, but are not mandatory if there are none or if a certain

type of licence does not require to have medical information associated with it.

Table 2 — EPLDS Section Data unit Data unit description MSO Presence

General I Name of state Yes M

II Title of licence Yes M

III Serial number of licence Yes M

Personnel information

IVa Photograph of holder Yes M

IVb Name of holder in full Yes M

IVc Date of birth Yes M

V Address of holder Yes M

VI Nationality of holder Yes M

VII Script signature of holder No M*

Issuing authority

VIII Authority and conditions under which the licence is issued

Yes M

IX Certification concerning validity and authorisation for holder to exercise privileges appropriate to the licence

Yes M

X Electronic signature of officer issuing the licence and the date and time of issue

XIa Seal or stamp of authority issuing the licence Yes M

XIb Date and time of last synchronisation with the server of the national competent authority

XIc Machine-readable code to retrieve authentication data

Rating XII Ratings Yes M

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Remarks XIII Remarks, i.e. special endorsements relating to limitations and endorsements on privileges, including endorsement of language proficiency, and other information required pursuant to Article 39 of the Chicago Convention

Yes M*

XIV Any other details desired by the state issuing the licence

Yes M*

Medical assessment

XVa Class (1, 2 or 3) Yes M*

XVb Expiry date Yes M*

XVc Special medical limitations Yes M*

XVd Other information associated with the medical assessment as determined by the medical authority

Yes M*

Additional supplementary information

XVIa Other information associated with the licence Yes M*

XVIb Other information associated with the licence Yes M*

XVIc Other information associated with the licence Yes M*

5.2. EPLDM

(a) The data model needs to be followed in order to guarantee the interoperability of licences issued

in electronic format around the world.

(b) The licence issued in electronic format will consist of an mdoc that is divided into several

namespaces, each one related to one of the sections of the EPLDS and composed of several

items that provide the licene information.

version of the licence issued in electronic format. It is expected that the licence issued in

electronic format will be subject to changes due to amendments and new requirements that

may apply in the future. In the first version of the doctype, X = 1, and it will be increased with

future versions. Each namespace is directly related to a section of the EPLDS.

(d) Table 3 provides the namespaces.

Table 3 — Namespaces of the licence issued in electronic format

Namespace EPLDS section Data units

int.icao.epl.general.1 General Name of state, title of licence, serial

number of licence

int.icao.epl.personnel.1 Personnel information Photograph of holder, name of holder,

date of birth, address of holder,

nationality of holder, script signature of

holder

int.icao.epl.authority.1 Issuing authority Name of authority, conditions under

which the licence is issued, certification

concerning validity and authorisation for

holder to exercise privileges, signature of

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the officer issuing the licence, seal of the

authority, date and time of last

synchronisation, machine-readable code

to retrieve authentication data

int.icao.epl.ratings.1 Ratings List of ratings of the licence

int.icao.epl.remarks.1 Remarks List of remarks

int.icao.epl.medical.1 Medical assessment Medical certificate class, expiry date,

medical limitations

int.icao.epl.additional.1 Additional supplementary

information

Any other relevant licence information

related to the licence

(e) The following sections of this AMC define how the information in each data unit should be

formalised in the EPLDM. A single data unit may be composed of one or more items; for example,

some data units have one item with the information in English and another item with the

information in national languages other than English, so the EPLDM can provide the means to

use up to eight languages in addition to English. All the information from the EPLDM in English

conforms to what is called the ICAO version, which is the one expected to be used by states

other than the issuing state.

(f) Each item will be determined by the following components:

(1) Its own identifier, which makes it possible to uniquely identify the item and allows a

verifier to select which items will be included in either the device retrieval request or the

server retrieval request as specified in Section 4.2.4.

(2) An encoding format that defines how the item is encoded. The concise data definition

language as defined in RFC 8610 is used where possible, and ISO 180136-5 Section 7.2.1

provides encoding formats for data retrieval for concise binary object representation and

Java simple object notation.

(3) A maximum size, which limits the size an item can have.

These components will be specified in the following subchapters of this AMC.

5.2.1. Namespace int.easa.epl.general.1

The namespace int.icao.epl.general.1 includes elements I, II and III of the EPLDS. This namespace has

been adapted into int.easa.epl.general.1 so that it allows the introduction of several titles in a licence

issued in electronic format, in contrast to int.icao.epl.general.1, which permits the incorporation of

only one title.

5.2.1.1. Data unit I — name of state

The ‘name of state’ data unit provides the name of the issuing state. It is composed of the items in

Tables 4–6.

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Table 4 — state_fullname.english

Identifier state_fullname.english Presence M

Description Full name of state. Expressed in English. UTF-8-encoded basic Latin characters

Encoding format tstr Maximum size 128 B

Table 5 — state_fullname.national

Identifier state_fullname.national Presence O

Description Full name of state. Expressed in national language. ITF-8-encoded full Unicode

character set

Encoding format [*NationalStateName]

NationalStateName = {

language : tstr

state_fullname : tstr

}

Maximum size Array length: 8

Language: 3 B

state_fullname: 512 B

Table 6 — state_countrycode Identifier state_countrycode Presence M

Description 2-letter code of the issuing state as defined in ICAO Doc 9303 Part 3

Encoding format tstr Maximum size 2 B

5.2.1.2. Data unit II — title of licence

List of titles linked to the licence, when applicable. This data unit is composed of the items in Tables 7

and 8.

Table 7 — title.english Identifier title.english Presence M

Description Title or titles of the licence, as defined in each regulation. Expressed in English. UTF-8-

encoded Latin characters

Encoding format [*EnglishLicenceTitle]

EnglishLicenceTitle = {

title : tstr

titleissuance: full-date

}

Maximum size Array length: 5

title: 1 024 B

titleissuance: 64 B

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Table 8 — title.national Identifier title.national Presence O

Description Title or titles of licence, as defined in each regulation. Expressed in national language.

UTF-8-encoded full Unicode character set

Encoding format [*NationalLicenceTitle]

NationalLicenceTitle = {

language : tstr

languagetitle: [*LanguageTitle]

}

Languagetitle = {

title : tstr

titleissuance: full-date

}

Maximum size Array length: 8

language: 3 B

languagetitle:

Array length: 5

title: 1 024 B

titleissuance: 64 B

5.2.1.3. Data unit III — serial number of the licence

This gives the serial number of the licence as defined by each applicable regulation. It is composed of

the items in Tables 9 and 10.

Table 9 — serial_number.english Identifier Serial_number.english Presence M

Description Serial number of the licence. UTF-8-encoded basic Latin characters

Encoding format tstr Maximum size 128 B

Table 10 — serial_number.national Identifier serial_number.national Presence O

Description Serial number of the licence. Expressed in national language. UTF-8-encoded full

Unicode character set

Encoding format [*NationalSerialNumber]

NationalSerialNumber = {

language : tstr

serial_number : tstr

Maximum size Array length: 8

Language: 3 B

Serial_number: 128 B

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}

5.2.2. Namespace int.easa.epl.personnel.1

The namespace int.icao.epl.general.1 includes data units IVa, IVb, IVc, V and VI of the EPLDS. This

namespace has been adapted because, unlike int.icao.epl.general.1, it does not include either the

picture (IVa) or the address (V) of the holder of the licence in electronic format.

The signature of the holder of the licence in electronic format (VII) is included in the personnel section

of the EPLDS but is not included in the MSO; therefore, it is not included in the EPLDM.

5.2.2.1. Data unit IVb — name of the holder of the licence in electronic format

The ‘name of holder in full’ data unit provides the name of the licence holder. It is composed of the

items in Tables 11–14.

Table 11 — name.latin.primary Identifier name.latin.primary Presence M

Description Primary name of the holder of the licence issued in electronic format. UTF-8-encoded

basic Latin characters

Restrictions and recommendations are defined in ICAO Doc 9303 Part 3.

If the national characters are not Latin-based, a transcription or transliteration into

Latin characters shall be provided.

Encoding format tstr Maximum size 512 B

Table 12 — name.latin.secondary Identifier name.latin.secondary Presence M

Description Secondary name of the holder of the licence issued in electronic format. UTF-8-

encoded basic Latin characters.

Restrictions and recommendations are defined in ICAO Doc 9303 Part 3.

If the national characters are not Latin-based, a transcription or transliteration into

Latin characters shall be provided.

Encoding format tstr Maximum size 512 B

Table 13 — name.national.primary Identifier name.national.primary Presence O

Description Primary name of the holder of the licence issued in electronic format. UTF-8-encoded

full Unicode character set

Encoding format [*NationalNamePrimary]

Maximum size Array length: 8

Language: 3 B

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NationalNamePrimary = {

language : tstr

primary_name: tstr

}

primary_name: 1 024 B

Table 14 — name.national.secondary Identifier name.national.secondary Presence O

Description Secondary name of the holder of the licence issued in electronic format. UTF-8-encoded

full Unicode character set

Encoding format [*NationaNameSecondary]

NationalNameSecondary= {

language : tstr

secondary_name : tstr

}

Maximum size Array length: 8

Language: 3 B

secondary_name:

1 024 B

5.2.2.2. Data unit IVc — date of birth

Table 15 — dob Identifier dob Presence M

Description Year, month and day on which the holder of the licence issued in electronic format was

born

Encoding format Full-date Maximum size 10 B

5.2.2.3. Data unit VI – nationality of holder

Table 16 — nationality.english Identifier nationality.english Presence M

Description Nationality of the holder of the licence issued in electronic format. Expressed in English.

UTF-8-encoded Latin characters

Encoding format tstr Maximum size 64 B

Table 17 – nationality.national Identifier nationality.national Presence O

Description Nationality of the holder of the licence issued in electronic format. Expressed in

national language. UTF-8-encoded full Unicode character set

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Encoding format [*NationalNationality]

NationalNationality = {

language : tstr

nationality : tstr

}

Maximum size Array length: 8

Language: 3 B

nationality: 256 B

Table 18 — nationality.countrycode Identifier nationality.countrycode Presence O

Description Nationality of the holder of the licence issued in electronic format as 2-letter code as

defined in ICAO Doc 9303 Part 3

Encoding format tstr Maximum size 2 B

5.2.3. Namespace int.easa.epl.authority.1

5.2.3.1. Data unit VIII — authority and conditions under which the licence is issued

Table 19 — licensing.authority.latin Identifier licensing.authority.latin Presence M

Description Name of the licensing authority. Expressed in English. UTF-8-encoded Latin characters.

Translation to English is recommended

Encoding format tstr Maximum size 256 B

Table 20 — licensing.authority.national Identifier licensing.authority.national Presence O

Description Name of the licensing authority. Expressed in national language(s). UTF-8 encoded

using full Unicode character set

Encoding format [*NationalLicensingAuthority]

NationalLicensingAuthority = {

language : tstr

licensing_authority : tstr

}

Maximum size Array length: 8

Language: 3 B

Licensing_authority:

512 B

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Table 21 — licensing.conditions.english Identifier licensing.conditions.english Presence M

Description Conditions under which the licence is issued. Expressed in English. UTF-8-encoded Latin

characters. Translation to English is recommended.

Encoding format tstr Maximum size 256 B

Table 22 — licensing.authority.national Identifier licensing.authority.national Presence M

Description Name of the licensing authority in the national language/working language of the

licensing authority, UTF-8 encoded using full Unicode character set

Encoding format [*NationalLicensingAuthority]

NationalLicensingAuthority = {

language : tstr

licensing_authority : tstr

}

Maximum size Array length: 8

Language: 3 B

Licensing_conditions:

512 B

5.2.3.2. Data unit IX — certification concerning validity and authorisation for the holder to exercise

privileges appropriate to the licence

Table 23 — certification.english Identifier certification.english Presence M

Description Certification concerning validity and authorisation for the holder to exercise privileges

appropriate to the licence. Expressed in English. UTF-8-encoded Latin characters.

Translation to English is recommended.

Encoding format tstr Maximum size 256 B

Table 24 — certification.national Identifier certification.national Presence O

Description Certification concerning validity and authorisation for the holder to exercise privileges

appropriate to the licence. Expressed in national language(s). UTF-8 encoded using the

full Unicode character set

Encoding format [*NationalCertification]

NationalCertification = {

language : tstr

NationalCertification : tstr

Maximum size Array length: 8

Language: 3 B

nationalcertification:

512 B

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}

5.2.3.3. Data unit X — electronic signature of officer issuing the licence and the date and time of

such issue

This data unit is not included in the MSO; therefore, it is not included in the EPLDM.

5.2.3.4. Data unit XIa — seal or stamp of authority issuing the licence

This data unit is excluded from the MSO as per EASA specifications.

5.2.3.5. Data unit XIb — date and time of last synchronisation with the server of the issuing

authority

This data unit is not included in the MSO; therefore, it is not included in the EPLDM.

5.2.3.6. Data unit XIc — machine-readable code to retrieve authentication data

This data unit is not included in the MSO; therefore, it is not included in the EPLDM.

5.2.4. Namespace int.easa.epl.ratings.1

(a) The namespace int.icao.epl.ratings.1 includes data unit XII of the EPLDS. This namespace has

been adapted because of the prevalence of personnel licences in the ICAO specifications, the

difficulty of linking remarks and the instrument rating (for pilot licences) to a certain class or

type rating.

(b) The list of ratings is provided by an array where each rating makes use of a row of the array, and

its particularities are provided as attributes of the rating. Table 25 provides a visual example for

the ratings array, where each column is an attribute of the rating.

Table 25 — EASA ratings array

Rating No archetype endorsement valid_since valid_until ir_valid_until other1 other2

…

the fact that each rating of the licence makes use of a row of the array and that the number of

rows in the array is limited to 64.

(d) The meaning of each one of the attributes is as follows:

(1) archetype:

The archetype defines which kind of rating is being provided. It can be seen as a grouping

of ratings of the same nature. For example, an archetype ‘fcl_type’ can be defined to

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classify all the type ratings of a pilot licence (A320, A340, B737, etc). Therefore, the

archetype is a classification of the ratings by their nature.

(2) endorsement:

The endorsement attribute contains the code or value used to endorse a rating. Together

with the archetype value, the rating endorsed on the licence is completely identified,

because it is known what kind of rating is being endorsed and what its value is. Table 26

provides some examples of this with different types of licences.

Table 26 — Examples of archetypes and endorsements

Type of licence Archetype Endorsement

FCL

fcl_class_rating MEP(land)

fcl_type_rating A320

fcl_additional_rating Aerobatic

(3) valid_since:

The valid_since attribute specifies the date on which the endorsement starts to be valid.

This is, it can be the date when a rating was endorsed, revalidated or renewed.

(4) valid_until:

This is the date on which the rating endorsed ceases to be valid. It will have no value for

non-expiring ratings.

(5) ir_valid_until:

This is the date on which the instrument rating associated with the rating endorsed

expires, if applicable.

(6) other1:

The other1 column specifies other information associated with the rating, with a

preference for privileges linked to the rating that is being endorsed.

(7) other2:

The other2 column specifies other information associated with the rating, with a

preference for the limitations linked to the rating that is being endorsed.

(e) Each type of licence requires a certain degree of standardisation in both taxonomy and

methodology when endorsing ratings in licences issued in electronic format. The archetypes

available, as well as the taxonomy and methodology of endorsement are provided in AMC1 Point

3.1 of Appendix I to Annex VI (Part-ARA).

(f) Therefore, the data model for ratings would be as in Table 27 and Table 28.

Table 27 — ratings.english Identifier ratings.english Presence M

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Description Ratings entered on or associated with the licence. Expressed in English. UTF-8-encoded

basic Latin characters

Encoding format [*Rating]

Rating = {

archetype : tstr

endorsement : tstr

valid_from : full-date

valid_until : full-date

ir_date : full-date

other_1 : tstr

other_2 : tstr

}

Maximum size Array length: 64

Table 28 — ratings.national Identifier ratings.national Presence O

Description Ratings entered on or associated with this licence. Expressed in national language /

working language. UTF-8-encoded full Unicode character set

Encoding format [*NationalRatings]

NationalRatings = {

language : tstr

Ratings : [*Rating]

}

Rating = {

archetype : tstr

endorsement : tstr

valid_from : full-date

valid_until : full-date

ir_date : full-date

other_1 : tstr

other_2 : tstr

Maximum size Array length: 8

language: 3 B

Ratings length: 64

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}

5.2.5. Namespace int.easa.epl.remarks.1

The namespace int.icao.epl.remarks.1 includes data units XIII and XIV of the EPLDS. This namespace

has been adapted into the namespace int.easa.epl.remarks.1 because, unlike int.icao.epl.remarks.1, it

does not include language proficiency. Section XIV has been developed to allow the endorsement of

national ratings.

5.2.5.1. Data unit XIII – remarks

Data unit XIII – remarks is composed of the items in Tables 29 and 30.

Table 29 — remarks.english Identifier remarks.english Presence M*

Description Remarks. Expressed in English. UTF-8-encoded Latin characters

Encoding format tstr Maximum size 512 B

Table 30 — remarks.national Identifier remarks.national Presence O

Description Remarks. Expressed in national language(s). UTF-8-encoded full Unicode character set

Encoding format [*NationalRemarks]

NationalRemarks = {

language : tstr

remarks : tstr

}

Maximum size Array length: 8

Language: 3 B

remarks: 1 024 B

5.2.5.2. Data unit XIV — state remarks

This section should specify any other remarks that the issuing authority considers necessary. It is

considered that all the remarks should be in Section XIII and this section could provide the national

ratings that the holder might have. It is composed of the items in Tables 31 and 32.

Table 31 — state_remarks.english Identifier State_remarks.english Presence M*

Description National ratings entered on or associated with the licence. Expressed in English. UTF-8-

encoded basic Latin characters

Encoding format [*NationalRating]

Maximum size Array length: 64

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NationalRating = {

archetype : tstr

endorsement : tstr

valid_from : full-date

valid_until : full-date

ir_date : full-date

other_1 : tstr

other_2 : tstr

}

Table 32 — state_remarks.national Identifier state_remarks.national Presence O

Description National ratings entered on or associated with this licence. Expressed in national

language / working language. UTF-8-encoded full Unicode character set

Encoding format [*NationalRatingsList]

NationalRatingsList = {

language : tstr

NationalRatings : [*NationalRating]

}

NationalRating = {

archetype : tstr

endorsement : tstr

valid_from : full-date

valid_until : full-date

ir_date : full-date

other_1 : tstr

other_2 : tstr

}

Maximum size Array length: 8

language: 3 B

National Ratings length:

5.2.6. Namespace int.icao.epl.medical.1

No changes from ICAO specifications.

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5.2.7. Namespace int.icao.epl.additional.1

No changes from ICAO specifications.

5.2.8. Namespace int.easa.epl.acronyms.1

This namespace has been included in order to facilitate comprehension for verifiers from third

countries who are not familiar with the taxonomy defined in the EU regulations and associated AMC

and GM.

5.2.8.1. Data unit – acronyms list

Table 33 — acronyms.english Identifier acronyms.english Presence O

Description List of acronyms used in the licence with an explanatory description. Expressed in

English. UTF-8-encoded Latin characters

Encoding format [*Acronym]

Acronym = {

code : tstr

description : tstr

}

Maximum size Array length: 25

code: 10 B

description: 256 B

Table 34 — acronyms.national Identifier Acronyms.english Presence O

Description List of acronyms used in the licence with an explanatory description. Expressed in

national language(s). UTF-8 encoded using the full Unicode character set

Encoding format [*NationalAcronym]

NationalAcronym = {

language : tstr

acronyms : [*Acronym]

}

Acronym = {

code : tstr

description : tstr

}

Maximum size Array length: 8

Language: 3 B

Array length: 25

code: 10 B

description: 256 B

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6. IMPACT OF THE IMPLEMENTATION OF AN EPLSYS

6.1. Impact on the LICSYS when implementing an EPLSYS

(a) The LICSYS is independent from the EPLSYS, so there is no need for the LICSYS to use specific

technologies of follow any specific data model. The issuing authorities can make use of solutions

that best suit their purposes.

(b) However, prior to deciding any implementation of an EPLSYS, they should be aware of the

implications that it can have for their LICSYS and assess whether they are ready and willing to

proceed with the implementation.

6.1.1. Need to store the data as structured data

(a) The EPLSYS requires that all the information in the licence issued in physical format and medical

certificates be transferred to an mdoc that follows the EPLDM. Therefore, the information

should be stored in the LICSYS as structured data and thus contain all the information about the

EPLDS. For example, the licence holder’s date of birth is displayed in the licence issued in

electronic format, so the database of the LICSYS should have a specific field for this information

in order to use it to feed the information to the licence issued in electronic format. A more

problematic example could be the issuing authority officer’s electronic signature; usually LICSYSs

used for licences issued in physical format do not need to store this signature, because this

licence is signed once the licence has been printed and it is signed outside the LICSYS, but if an

EPLSYS is implemented, this signature is electronic and must be stored in the LICSYS.

(b) It is not necessary that the LICSYS follow the EPLDM, even though the information from the

LICSYS is transferred to the mdoc, because the issuing authority, when developing the EPLSYS,

can use a process that transforms the LICSYS data model into the EPLDM. A LICSYS with a data

model aligned with the EPLDM would facilitate the transfer of information between the two

systems, but it is not necessary.

time, so they should prepare their systems to be ready to work with different versions of the

EPLDM.

6.1.2. Licence issuance format record

(a) If a competent authority decides to use both the physical format and the electronic format for

a type of licence, the LICSYS will need to keep a record of the format used for each licence that

has been issued in order to avoid the possibility that a licence in electronic format can be

generated when a licence in physical format exists and vice versa.

(b) The competent authority cannot issue the same type of licence in electronic and physical format

to the same individual.

6.1.3. Digital identification of the LICSYS users and traceability

(a) The EPLDS has information that comes from different data sources and is validated by people in

different roles in the issuing authority (officers, medical assessors, examiners).

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(b) The validation of the data is performed in the LICSYS and it will need to trace what information

is changed or validated, by whom and when. This requires a log of the actions performed by its

users.

password, but external users should be properly identified and access the LICSYS with at least

two-factor verification in order to guarantee a proper level of security when accessing the

LICSYS.

(d) Alternative and superior verification procedures can be applied, as long as they provide at least

an equivalent level of security.

6.1.4. Need to use electronic signatures in order to validate the data

(a) The validation of the data is executed by the electronic signature of an issuing officer, an

examiner or a medical assessor, each one responsible for the pertinent subset of licence data of

the licence issued in electronic format. Therefore, the LICSYS must be able to operate with the

use of electronic signatures.

(b) The electronic signature of the issuing officer is required to conform to recognised standards

and have an appropriate level of security. In the EU context, the recognised standard is provided

by Regulation (EU) No 910/20141 (eIDAS Regulation), and the appropriate level of security is at

least an advanced signature.

but they could use other forms of electronic signatures. In this case, at least a two-factor

verification process or one that provides a higher level of security should be used.

6.1.5. Authorisation of access to data held by the issuing authority

(a) Without the implementation of an EPLSYS, the data on the IAS can be managed only by internal

users of the issuing authority, or possibly by a controlled number of external users within the

Member State.

(b) When licences issued in electronic format are used, the information in the IAS will be frequently

accessed by external users, either for the generation of licences issued in electronic format or

for its verification by verifiers and other verifying authorities from third countries.

users to access the data. However, granting external parties access to the IAS has an impact on

the security measures the issuing authority will have to implement.

6.1.6. Access to LYCSYS for examiners and medical assessors from other Member States

(a) Under the EU regulatory framework, a licence holder might be examined for a certain rating or

have a medical assessment in a Member State other than the Member State issuing the licence.

This information cannot be reflected in the licence issued in electronic format until it is received

1 Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification

and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC (OJ L 257, 28.8.2014, p. 73).

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and inserted in the LICSYS of the issuing authority, causing a detrimental effect on the holder of

a licence issued in electronic format.

(b) Third countries normally are not affected when using licences issued in electronic format, since

the general rule is that all examiners and medical assessors belong to the same issuing authority.

authority that wants to implement an EPLSYS should be willing to provide the means for

examiners and medical assessors from other Member States to feed into their systems any new

information affecting one of their licences and transfer the information to the licence in

electronic format without unnecessary delays.

(d) Each issuing authority can decide how to grant this access to its LICSYS, but it will need to provide

appropriate means of identification and signing.

(e) If the issuing authority detects any irregularity in the data provided by an examiner or medical

assessor from another Member State, it should invalidate the licence issued in electronic format,

and a new licence in electronic format should be generated in accordance with the valid data.

6.1.7. Use of the issuing authority’s public key infrastructure certificate

(a) Licences issued in electronic format are automatically generated by the IAS when the licence

holder sends a request for its generation, and are electronically signed with the IAPKIC. Issuing

authorities willing to implement an EPLSYS also need to be willing to use the IAPKIC in

automation.

(b) In some Member States, the use of the IAPKIC may require the approval of the government or

some kind of national approval process.

6.2. Impact on the issuing authority’s procedures when implementing an EPLSYS

(a) An assessment of the impact on the issuing authority’s procedures caused by the

implementation of an EPLSYS should be carried out in order to identify which procedures should

be adapted.

(b) When an EPLSYS is implemented, the concepts of issuance, suspension and revocation of

licences should be reviewed because the introduction of electronic documents comes with

certain conventions within the digital world that challenge the standard practices with physical

documents.

AMC1 ARA.FCL.130(h) Licences issued in electronic format and establishment of an electronic personnel licence system PROCEDURE FOR THE LIMITATION, SUSPENSION OR REVOCATION OF A LICENCE ISSUED IN ELECTRONIC FORMAT

The procedure should describe the actions undertaken by the competent authority to ensure that the

limitation, suspension or revocation of a licence issued in electronic format is properly reflected in the

licence contained in the holder’s device application.

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Such actions should happen at the level of the electronic personnel licence system established by the

competent authority to:

— in cases of limitation, notify the holder and request that they generate a new instance of the

licence displaying only those categories, subcategories or ratings not subject to limitation;

— in cases of suspension or revocation, notify the holder and request that they update their

licence, thereby deleting the current instance of the licence contained in the application and

preventing the generation of new instances.

In cases of limitation or suspension of the licence, the procedure should include the generation of a

new instance of the licence on the date such limitation or suspension ends.

Alternatively, the competent authority may display a permanent indication regarding the applicable

limitation, suspension or revocation of the licence, without which the licence cannot be displayed by

the holder.

GM1 ARA.FCL.130(d) Licences issued in electronic format and establishment of an electronic personnel licence system

VERIFICATION OF THE AUTHENTICITY AND VALIDITY OF THE LICENCES ISSUED IN ELECTRONIC

FORMAT

(a) The verification described under this point allows the reader to confirm that the information in

the licence is authentic, meaning that it was issued by the competent authority mentioned in

the licence, and is valid, meaning that it contains the data that was applicable at the time it was

generated.

(b) Verifying the authenticity and validity of licences issued in electronic format may happen in two

ways:

(1) By using a reading device registered with the authority that issued the licence when an

internet connection is available. Alternatively, when no internet connection is available,

by using a reading device registered with the authority that issued the licence that is

linked with the list of the valid issuing authority public key infrastructure (PKI) certificates.

In such cases, verifying the authenticity and validity of the licence of the holder is done by

reading the machine-readable code included under field XIc of the licence.

The issuing authority PKI certificates are used to sign all licences in electronic format; they

attest to the authenticity and validity of the licences in real time, when the licence is

verified with internet connection available, or at the time they were downloaded from

the authority’s server, when the verification happens offline.

When it is expected that the verification will happen offline, the person authorised to

verify the authenticity and validity of licences on behalf of the competent authority can

ensure that they will be in possession of the most recent version of the list of the valid

issuing authority PKI certificates.

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(2) By reading the information contained in the licence of the holder when no internet

connection is available and the authorised person is not in possession of the list of the

valid issuing authority PKI certificates.

In such situations, the authorised person can compare the latest synchronisation date of

the licence with the current date.

Using the information available, it can be assessed whether the information in the licence

presented by the holder is up to date.

The person authorised to verify the authenticity and validity of licences can request

support in accessing information in the authority’s server if there is any suspicion that the

licence presented is outdated. The authorised person may also decide to verify the

authenticity and validity of the licence again when internet connection is available within

a reasonable time frame as defined in the competent authority’s administrative

procedures.

The update status of a licence can also be indicated by a notification system developed by

the issuing authority stating that the latest update has not yet been manually triggered

by the licence holder and, thus, that the licence information is outdated.

ARA.FCL.200 Procedure for issue, revalidation or renewal of a licence, rating or certificate

(a) Issue of licences, associated ratings or certificates. The competent authority shall issue a pilot

licence and associated ratings or certificates, using only one of the two formats as established

in Appendix I to this Part.

If a pilot intends to fly outside Union territory on an aircraft registered in a Member State other

than the Member State that issued the flight crew licence, the competent authority shall:

(1) add the following remark on the flight crew licence under item XIII: ‘“This licence is

automatically validated as per the ICAO attachment to this licence’”; and

(2) make the ICAO attachment available to the pilot in physical or electronic format.

(b) Issue of instructor and examiner certificates. The competent authority shall issue an instructor

or examiner certificate as:

(1) an endorsement of the relevant privileges in the pilot licence as established in Appendix I

to this Part; or

(2) for licences issued in physical format only, a separate document, in a form and manner

specified by the competent authority.

or renew ratings or certificates, the competent authority shall develop appropriate procedures.

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(d) Revalidation and renewal of a rating or certificate on a licence issued in electronic format by an

examiner or an EBT manager. The competent authority shall develop appropriate procedures

when a rating or certificate associated with a licence issued in electronic format:

(1) is revalidated, to give the examiner or the EBT manager access to the licensing system of

the pilot’s competent authority to enter the new validity date of the rating or certificate;

(2) is renewed, to give the examiner or the EBT manager access to the licensing system of the

pilot’s competent authority to provide the documentation to the competent authority

and, if authorised to do so, enter the new validity date of the rating or certificate.

(e) Issuance of an additional rating or certificate on a licence issued in electronic format by an

examiner or an EBT manager. The competent authority shall develop appropriate procedures

when a rating or certificate associated with a licence issued in electronic format is issued, to give

the examiner or the EBT manager access to the licensing system of the applicant’s competent

authority to provide the documentation to the competent authority and, if authorised to do so,

enter the rating or certificate.

(d)(f) Endorsement of licence by instructors. Before specifically authorising certain instructors to

revalidate a SEP or TMG class rating, the competent authority shall develop appropriate

procedures.

(g) Revalidation of a SEP or TMG class rating on a licence issued in electronic format. When a SEP

or TMG class rating endorsed on a licence issued in electronic format is revalidated, the

competent authority shall develop appropriate procedures to give access to authorised

personnel to enter the new validity date of the rating in the licensing system of the pilot’s

competent authority.

(h) Revalidation of a SEP or turbine helicopter type rating up to a maximum take-off mass of

3 175 kg on a licence issued in electronic format. When a SEP or turbine helicopter type rating

up to a maximum take-off mass of 3 175 kg endorsed on a licence issued in electronic format is

revalidated, the competent authority shall develop appropriate procedures to give access to

authorised personnel to enter the new validity date of the rating in the licensing system of the

pilot’s competent authority.

(e)(i) Instructors for FI(B) or FI(S) certificates: The competent authority shall develop appropriate

procedures for the conduct of the training flights under supervision specified in:

(1) points BFCL.315(a)(4)(ii) and BFCL.360(a)(2) of Annex III (Part-BFCL) to Regulation

(EU) 2018/395; and

(2) points SFCL.315(a)(7)(ii) and SFCL.360(a)(2) of Annex III (Part-SFCL) to Commission

Implementing Regulation (EU) 2018/1976.

GM1 ARA.FCL.200(d) Procedure for issue, revalidation or renewal of a licence, rating or certificate In the event that the revalidation or renewal of a licence, rating or certificate is performed in

accordance with Appendix 10 to Part-FCL, the competent authority gives access to the licensing system

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for the described purposes to the person who has been delegated by the EBT manager in accordance

with Appendix 10 A (4) (c) (2).

AMC1 ARA.FCL.215(d) Validity period

EXERCISING PRIVILEGES OF A LICENCE PENDING THE ENDORSEMENT OF THE LICENCE

(a) An examiner, an EBT manager or an instructor, as applicable, may enter a limited validity date

on a rating or a certificate of not more than 8 weeks after successful completion of the

examination(s), provided that all of the following applies:

(1) the applicant fulfils the relevant requirements and has successfully completed a

proficiency check, a skill test or an assessment of competence;

(2) the examiner, the EBT manager or the instructor is authorised to do so in the procedures

developed by the competent authority;

(3) the examiner, the EBT manager or the instructor provides documentation to the

competent authority about the successful completion of the applicable examination(s).

(b) In this case, the privilege(s) acquired by the licence or certificate holder should be shown in the

licence and can be exercised immediately.

manager or the instructor, the competent authority should modify the rating or certificate in

the licensing system so that the licence reflects the regular validity period in accordance with

points FCL.740, FCL.940 and FCL.1025.

GM1 ARA.FCL.215(d) Validity period

(a) The competent authority may develop procedures as mentioned in point ARA.FCL.215(d) for

licences or certificates issued in physical format or for licences or certificates issued in electronic

format.

(b) The procedure is needed to cover the time gap between the proficiency check, the skill test or

the assessment of competence and the update of the electronic personnel licence issued in

electronic format by the competent authority.

ARA.FCL.220 Procedure for the re-issue of a pilot licence issued in physical format

(a) In the case of a licence issued in physical format, tThe competent authority shall re-issue a

licence whenever necessary for administrative reasons and:

(1) after initial issue of a rating; or

(2) when paragraph XII of the licence established in Appendix I to this Part is completed and

no further spaces remain.

(b) Only valid ratings and certificates shall be transferred to the new licence document.

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ARA.FCL.221 Procedure for the update of a pilot licence issued in electronic format

(a) In the case of a licence issued in electronic format, the competent authority shall re-issue a

licence whenever necessary for administrative reasons and after the initial issue of a rating.

(b) Only valid ratings and certificates shall be transferred to the new licence. certificates

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APPENDICES TO ANNEX VI

Appendix I to ANNEX VI (Part-ARA) — Flight crew licence — EASA Forms 141 and 155

1. General requirements for the flight crew licence

1.1. The competent authority shall issue each flight crew licence in only one of the two following

formats:

(a) the physical format, referred to in point 2 of this Appendix; or

(b) the electronic format, referred to in point 3 of this Appendix.

1.2. When the competent authority uses both formats to issue flight crew licences, it shall establish

a procedure for changing from one format to the other.

1.3. Each licence holder shall have a unique licence holder number, established on the basis of a

national identifier and an alphanumeric designator.

1.4 The flight crew licence shall be issued in English and any language(s) determined by the

competent authority.

2. Requirements for the flight crew licence issued in physical format

2.1. The flight crew licence issued in physical format shall be issued in accordance with the format

and content of EASA Form 141.

2.2. The flight crew licence issued in physical format by a Member State in accordance with Annex I

(Part-FCL), Annex III (Part-BFCL) to Commission Regulation (EU) 2018/395 and Annex III (Part-

SFCL) to Commission Implementing Regulation (EU) 2018/1976 shall conform to the following

specifications:

(a) Content. The item number shown shall always be printed in association with the item heading.

Items I to XI are the ‘“permanent”’ items and items XII to XIV are the ‘“variable”’ items which

may appear on a separate or detachable part of the main form. Any separate or detachable part

shall be clearly identifiable as part of the licence.

(1) Permanent items:

(I) name of State of licence issue;

(II) title of licence;

(III) serial number of the licence commencing with the United Nations (UN) country

code of the State of licence issue and followed by ‘FCL’, ‘BFCL’ or ‘SFCL’, as

applicable, and a code of numbers and/or letters in Arabic numerals and in Latin

script;

(IV) name of holder (in Latin script, even if the script of the national language(s) is other

than Latin);

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(IVa) date of birth;

(V) holder’s address, if required by the competent authority;

(VI) nationality of holder;

(VII) signature of holder;

(VIII) competent authority and, where necessary, conditions under which the licence was

issued;

(IX) certification of validity and authorisation for the privileges granted;

(X) signature of the officer issuing the licence and the date of such issue; and

(XI) seal or stamp of the competent authority.

(2) Variable items:

(XII) ratings, certificates and, in the case of balloons and sailplanes, privileges: class,

type, instructor certificates, etc., with dates of expiry, as applicable. Radio

telephony (R/T) privileges may appear on the licence or on a separate certificate;

(XIII) remarks: i.e. special endorsements relating to limitations and endorsements for

privileges, including endorsements of language proficiency, remarks on the

automatic validation of the licence, and ratings for Annex II aircraft, when used for

commercial air transportation; and

(XIV) any other details required by the competent authority (e.g. place of birth/place of

origin).

(b) Material. The First quality paper or other suitable material, including plastic cards, shall be used

will to prevent or readily show any alterations or erasures. Any entries or deletions to in the

form shall be clearly authorised by the competent authority.

languages as the competent authority deems appropriate.

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Cover page

Competent Aauthority’s name and logo

(English and any language(s) determined by the competent authority)

EUROPEAN UNION

(English only)

FLIGHT CREW LICENCE

(English and any language(s) determined by the competent authority)

Issued in accordance with Part-FCL/Part- BFCL/Part-SFCL (non-applicable terms to be deleted)

This licence complies with ICAO standards, except for the LAPL and BIR privileges or when accompanied by an LAPL medical certificate

(English and any language(s) determined by the competent authority)

EASA Form 141 Issue 23

Requirements ‘"European Union"’ to be deleted for non- EU Member States The Ssize of each page shall be one-eighth A4

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Page 2

I Name of State of issue: Requirements: In bold type

III Licence number: The sSerial number of the licence will always commence with the UN country code of the State of the licence issue, followed by ‘“FCL.”’, ‘“BFCL.”’ or ‘“SFCL.”’, as applicable.

IV Last and first nName of holder in full:

IVa Date of birth: (see instructions) Standard date format is to be used, dd/mm/yyyy in full.

XIV Place of birth:

V Address of holder: Street, town, area, postal code

VI Nationality:

VII Signature of holder:

VIII Issuing cCompetent authority: E.g. This CPL(A) has been issued on the basis of an ATPL issued by ......... (third country) ……………

E.g. This CPL(A) has been issued on the basis of an ATPL issued by ......... (third country) ……………

X Signature of issuing officer and date of issue:

XI Seal or stamp of issuing competent authority:

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II Title of the licence, date of initial issue and country code

Abbreviations used will be as those used in Part-FCL (e.g. PPL(H), ATPL(A), etc.), Part- BFCL and Part-SFCL

Standard format is to be used, dd/mm/yyyy in full.

IX Validity: The privileges of the licence shall be exercised only if the holder has a valid medical certificate for the required privilege. A document containing a photo shall be carried for the purposes of identification of the licence holder.

This document is not specified, but a passport would suffice when outside the State of licence issue.

XII Radiotelephony privileges: The holder of this licence has demonstrated competence to operate R/T equipment on board aircraft in ………………….. (specify the language(s))

XIII Remarks: Language Pproficiency: (language(s)/level/validity date)

All additional licensing information required and privileges established by ICAO, EC or EU Directives/Regulations to be entered here.

Language proficiency endorsement(s), level and validity date shall be included.

In the case of BIR: BIR not issued in accordance with ICAO standards.

In the case of LAPL: LAPL not issued in accordance with ICAO standards.

In the case of SPL, except for the cases referred to in Point (a) of Article 3b(2) of Commission Implementing Regulation (EU) 2018/1976: Privileges for aerobatic and sailplane cloud flying as well as for launching methods to be exercised in accordance with points SFCL.155, SFCL.200 and SFCL.215 of Annex III (Part-SFCL) to Commission Implementing

Regulation (EU) 2018/1976, as applicable.

Additional pages — Requirements:

Pages 1, 2, and 3 of the licence shall be in accordance with the format laid down in the model in this

point. The competent authority shall include additional customiszed pages containing tables which

shall contain at least the following information:

— Ratings, certificates, endorsements and privileges;

— Expiry dates of the ratings, the instructor and examiner certificate privileges;

— Dates of the test or check;

— Remarks and restrictions (operational limitations);

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— Fields for the examiner and/or instructor certificate number and signature, as applicable;

— Abbreviations.

These additional pages are intended for use by the competent authority, or by specifically authorised

instructors or examiners.

Initial issues of ratings or certificates shall be entered by the competent authority. Revalidation or

renewal of ratings or certificates may be entered by the competent authority or by specifically

authorised instructors or examiners.

Operational limitations shall be entered in ‘“Remarks and Restrictions”’ against the appropriate

restricted privilege, e.g. IR skill test taken with co-pilot, restricted instruction privileges to one 1 aircraft

type.

Ratings that are not validated may be removed from the licence by the competent authority.

3. Requirements for the flight crew licence issued in electronic format

3.1. The flight crew licence issued in electronic format shall be issued in accordance with the format

and content of EASA Form 155 and replicate the information contained in the records of the

competent authority.

3.2. The flight crew licence issued in electronic format shall have the electronic signature of the

officer issuing the licence and the most recent date and time of issue.

3.3. The electronic signature shall be at least an advanced electronic signature issued in accordance

with Regulation (EU) No 910/2014.

3.4. The flight crew licence issued in electronic format shall include a feature identified with the

acronym ‘ICAO’ that allows it to display its contents in English.

3.5. The flight crew licence issued in electronic format shall contain suitable active security features

to differentiate it from a static image.

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The competent authority issuing the licence issued in electronic format shall insert information in EASA Form 155 as follows: — the authority shall determine the information to be inserted in the place of content between

brackets (‘[]’). When not applicable, such content shall be left blank,

— the content of EASA Form 155 that is not between brackets (‘[]’) shall be inserted as such,

— items IVa, V, VII and XIa shall be left blank,

— completing Sections XIV, XVIa, XVIb, XVIc and XVId is optional.

Content requirements Format requirements

EUROPEAN UNION

[Name of Member State]

[Name of Member State] in bold type ‘EUROPEAN UNION’ to be deleted for non-EU Member States

FLIGHT CREW LICENCE Issued in accordance with Part-FCL/Part-BFCL/Part-SFCL

(non-applicable terms to be deleted)

All content in very bold type

III Licence No [Member State code]

The serial number of the licence ([XXXX]) shall be in Arabic numerals. The Member State code shall be the United Nations country code of the Member State of the competent authority that issues the licence, followed by ‘FCL.’, ‘BFCL.’ or ‘SFCL.’, as applicable.

IVa

IVb Name of holder in full: [Name]

[Name] in Latin script too if script of national language is other than Latin

IVc Date of birth of holder: [Date]

The date format shall be dd-mm-yyyy (day-month- year)

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VI Nationality of holder: [Nationality]

VII

VIII

[Name of Competent Authority]

Certification concerning validity and authorisation for holder

to exercise privileges appropriate to the licence

X Electronic signature of officer issuing the licence: [Signature]

Date and time of such issue: [Date] [Time]

The date format shall be dd-mm-yyyy (day-month- year) [Time] in hh:nn:ss (hours:minutes:seconds).

24-hour format

XIa

XIb Date and time of last synchronisation with the server of the

issuing competent authority: [Date] [Time]

The date format shall be dd-mm-yyyy (day-month- year) [Time] in hh:nn:ss (hours:minutes:seconds).

24-hour format

XIc Machine-readable code to retrieve authentication data:

[Code]

XII

Rating(s) and certificate(s) with their expiry dates [Ratings endorsed on the licence]

[Ratings endorsed on the licence] shall be inserted in accordance with a documented taxonomy

XIII

Limitations and privileges

All additional licensing information required and privileges established by ICAO, EC or EU

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Other remarks, i.e. special endorsements relating to limitations and endorsements for privileges, including and

endorsement of language proficiency

Directives/Regulations to be entered here.

Language proficiency endorsement(s), level and validity date shall be included.

In the case of BIR: BIR not issued in accordance with ICAO standards.

In the case of LAPL: LAPL not issued in accordance with ICAO standards.

In the case of SPL, except for the cases referred to in point (a) of Article 3b(2) of Commission Implementing

Regulation (EU) 2018/1976: privileges for aerobatic and sailplane cloud flying and for launching methods to be exercised in accordance with points SFCL.155, SFCL.200 and SFCL.215 of Annex III (Part-SFCL) to Commission Implementing Regulation (EU) 2018/1976, as

applicable.

XIV

Any other details desired by the competent authority issuing

the licence (including national ratings)

XVa Medical class

Class 1, Class 2, Class LAPL

XVb Expiry date

dd-mm-yyyy (day-month- year)

XVc

Special medical limitation, if any

[Text]

XVd

Other information associated with the medical certificate

[Text]

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XVIa

Other information associated with the licence as determined

by the issuing competent authority: [Text]

XVIb

Other information associated with the licence as determined

by the issuing competent authority: [Text]

XVIc

Other information associated with the licence as determined

by the issuing competent authority: [Text]

EASA Form 155 Issue 1

AMC1 Point 1.2 of Appendix I to Annex VI (Part-ARA) — Flight crew licence — EASA Forms 141 and 155

PROCEDURE FOR CHANGING FROM ONE LICENCE FORMAT TO ANOTHER

The procedure should describe the triggering events, time and conditions associated with the format

change for a licence already issued by the authority.

Changing the format of a licence means either:

— generating a licence in electronic format to replace a licence in physical format for the same

holder; or

— producing a licence in physical format to replace a licence in electronic format for the same

holder.

The events triggering the change of format of a licence may include the strategy adopted by the

competent authority to issue licences in a specific format for one licence holder, a defined group of

licence holders or all licence holders.

Those events may also include any practical aspect justifying the use of one format rather than the

other. Such practical aspects could be related to the appropriate use of that licence by the licence

holder or the ability of the competent authority to issue licences as intended.

The time at which the format of a licence is changed should be predefined. It may be a date chosen by

the competent authority or be associated with any processing of the licence for other purposes, such

as:

— the addition of a new rating or certificate in the licence;

— the endorsement of the licence with a new aircraft or system rating;

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— the removal of a limitation in the licence.

The conditions under which the format of a licence is changed should include:

— the withdrawal of the existing licence issued in physical format or the invalidation of the existing

licence in electronic format before the new licence is generated or produced, as applicable;

— the means through which the licence holder is notified of such change and can obtain the new

licence.

AMC1 Point 3.1 of Appendix I to Annex VI (Part-ARA) — Flight crew licence — EASA Forms 141 and 155

1. RATING ENDORSEMENT IN FLIGHT CREW LICENCES ISSUED IN ELECTRONIC FORMAT

Flight crew licences issued in electronic format need to be readable by verifying devices worldwide to

achieve interoperability.

For that purpose, a common information structure that any device can process should be established,

so that reading applications developed by other authorities other than the issuing authority will be

effective.

Therefore, licences issued in electronic format should be endorsed using a list of values specific to each

rating (hereinafter referred to as endorsements) being included in or endorsed on the licence.

In addition, as licences may contain more than one rating, an array is necessary to list all the applicable

endorsements.

The values and the array are defined and structured through the namespace int.easa.epl.ratings.1 in

AMC1 ARA.FCL.130, with the attributes shown in Table 1.

Table 35 — EASA endorsement array

Rating No archetype endorsement valid_since valid_until ir_valid_until other1 other2

…

Note: The rating number is not part of the ratings array; it is presented to reflect the fact that each

rating makes use of a row and that the array is limited to 64 ratings.

For each endorsement, each column of the array contains information as defined in the list of values

set out in Parts 2 and 3 of this AMC.

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2. ARCHETYPES

2.1. Archetypes for aeroplane and helicopter licences

All endorsements belong to an archetype, which can be seen as a grouping of endorsements with

similar characteristics and a common information type.

Table 36 — Archetypes for aeroplane endorsements

Archetype Description

fcl_instrument_rating Group of instrumental ratings that the pilot may have, except those as

instrument instructor and instrument examiner, which will be endorsed as

a privilege of the instructor or examiner endorsements

fcl_class_rating Group of class rating endorsements that the pilot may have

fcl_type_rating Group of type rating endorsements that the pilot may have

fcl_additional_rating Group of additional ratings that the pilot may have and that do not belong

to any other kind of rating

fcl_instructor_rating Group of instructor ratings

fcl_examiner_rating Group of examiner ratings

radiotelephony Group of radiotelephony ratings

language_proficiency Group of language proficiency ratings

2.2. Archetypes for sailplane licences

Table 37 — Archetypes for helicopter endorsements

Archetype Description

fcl_class_rating Group of class rating endorsements that the pilot may have

fcl_launch_method Group of launching methods for sailplanes

fcl_additional_rating Group of additional ratings that the pilot may have and that do not belong

to any other kind of rating

fcl_instructor_rating Group of instructor ratings

fcl_examiner_rating Group of examiner ratings

radiotelephony Group of radiotelephony ratings

2.3. Archetypes for balloon licences

Table 38 — Archetypes for balloon endorsements

Archetype Description

fcl_class_rating Group of class rating endorsements that the pilot may have

fcl_additional_rating Group of additional ratings that the pilot may have and that do not belong

to any other kind of rating

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fcl_instructor_rating Group of instructor ratings

fcl_examiner_rating Group of examiner ratings

radiotelephony Group of radiotelephony ratings

3.1. Aircraft category taxonomy

Table 5 — Aircraft category endorsements

Endorsement Description

A Aeroplane

H Helicopter

S Sailplane

B Balloon

As Airship

3.2. Aeroplane licences

3.2.1. Title taxonomy

Table 6 — Title endorsements for aeroplanes

Endorsement Description

LAPL(A) Light aircraft pilot licence

PPL(A) Private pilot licence

CPL(A) Commercial pilot licence

MPL(A) Multi-crew pilot licence

ATPL(A) Airline transport pilot licence

3.2.2. Rating taxonomy

Table 7 — Taxonomy for aeroplane endorsements Endorsement Description Standardised

privileges/limitations

Comments

IR(A) Instrument

rating

FCL.610:

IFR by day only

FCL.720:

FCL.405:

MPO only

This endorsement is to be used

when the instrument rating is not

linked to a type rating.

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Endorsement Description Standardised

privileges/limitations

Comments

BIR Basic

instrument

rating

CCCC Class

endorsement

FCL.700(b):

Cruise relief COPI > FL200 only

FCL.720.A(g):

Under supervision of instructor

only

Appendix 9 Part FCL B.6(h):

MPO only

The endorsement for a class of

aeroplane will be as given on the

EASA class and type rating

endorsement list as published in

its current version on EASA’s

website.

TTTT Type

endorsement

FCL.700(b):

Cruise relief COPI > FL200 only

FCL.720.A(g):

Under supervision of instructor

only

Appendix 9 Part FCL B.6(h):

MPO only

Limited to airline XXXX

The endorsement for a type of

aeroplane will be as given on the

EASA class and type rating

endorsement list as published in

its current version on EASA’s

website.

AEROBATIC Aerobatic

rating

FCL.800(c):

Aeroplanes only

TMG only

SAILPLANE

TOWING

Sailplane

towing

FCL.805(d):

Aeroplanes only

TMG only

BANNER

TOWING

Banner towing FCL.805(d):

Aeroplanes only

TMG only

NIGHT Night rating

MOUNTAIN Mountain

rating

FCL.815:

Wheels only

Skis only

Wheels and skis

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

Endorsement Description Standardised

privileges/limitations

Comments

FTR Flight test

rating

CAT1

CAT2

One single rating for flight test

rating. Category is specified as a

privilege.

FI(A) Flight

instructor

FCL.910.FI:

RESTRICTED

LAPL

PPL

SENIGHT

STOW

BTOW

AEROBAT

IR SPIC and FSTD only

CPL

CRI

IRI

CRI(A) Class rating

instructor

FCL.905.CRI:

STOW

BTOW

AEROBAT

TRI(A) Type rating

instructor

FCL.905.TRI(3):

SPA

MPO

FCL.905.TRI(4):

MPA

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

Endorsement Description Standardised

privileges/limitations

Comments

FCL.910.TRI:

LIFUS

FFS only

IRI(A) Instrument

rating

instructor

FCL.905.IRI:

MPL BP only

FSTD only

BP stands for ‘basic phase’.

Not to be used if the instructor is

senior

SFI(A) Synthetic flight

instructor

FCL.905.SFI:

MPO

MCC and MPL restrictions

MCCI(A) Multi-crew

cooperation

instructor

STI(A) Synthetic

training

instructor

MI(A) Mountain

rating

instructor

FTI(A) Flight test

instructor

SENIOR I(A) Senior

instructor

FI, IRI, SFI, MCCI, STI, MI, FTI, CRI

(CCCC1, CCCC2, etc.), TRI (TTTT1,

TTTT2, etc.)

Senior instructors can instruct

other instructors.

The privileges for senior

instructors indicate the

instruction of the type of

instructor that can be performed.

FE(A) Flight examiner

FIE(A) Flight

instructor

examiner

CRE(A) Class rating

examiner

CCCC1, CCCC2, etc.

CCCC1, CCCC2, etc. represents the

list of class ratings for which the

examiner has privileges.

TRE(A) Type rating

examiner

TTTT1, TTTT2, etc.

TTTT1, TTTT2, etc. represents the

list of type ratings for which the

examiner has privileges.

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

Endorsement Description Standardised

privileges/limitations

Comments

IRE(A) Instrument

rating

examiner

SFE(A) Synthetic flight

examiner

SENIOR E(A) Senior

examiner

FE, IRE, FIE, SFE, CRE (CCC1,

CCCC2, etc.), TRE (TTTT1, TTTT2,

etc.)

A senior examiner can perform

assessments on other examiners.

The privileges for senior

examiners indicate the

assessments of the type of

examiner that can be performed.

RT(A) Radiotelephony LAN1, LAN2, etc. LAN1, LAN2, etc. represents the

list of languages with which the

holder of the licence can use

radiotelephony.

LAN ISO 639-2

codes for

languages (3

letters)

Language proficiency levels:

Each language is listed as an

endorsement attribute, and the

proficiency level is specified in the

attribute ‘other_1’.

3.2.3. Endorsement methodology

Ratings shall be endorsed specifying their attributes as shown in Table 8.

Table 8 — Rating endorsement methodology for aeroplanes archetype endorsement valid_since valid_until ir_date other_1 other_2

fcl_

instrument_

rating

IR(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

when IR is

not linked to

a class/type

CB IFR day only,

MPO only

Use if

applicable

fcl_

instrument_

rating

BIR dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

fcl_

class_

rating

CCCC dd/mm/yyyy

Date of

obtention,

dd/mm/yyyy dd/mm/yyyy

Expiry date of

IR, only if

This

attribute is

not used

Cruise relief

COPI > FL200

only, under

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

archetype endorsement valid_since valid_until ir_date other_1 other_2

revalidation

or renewal,

as applicable

Date of

expiry

linked to the

class rating

supervision

of instructor

only, MPO

only

Limitations,

if applicable,

go here

fcl_

type_

rating

TTTT dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

dd/mm/yyyy

Expiry date of

IR, only if

linked to the

type rating

This

attribute is

not used

Cruise relief

COPI > FL200

only, under

supervision

of instructor

only, MPO

only

Limitations,

if applicable,

go here

fcl_

additional_

rating

AEROBATIC dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

This

attribute is

not used

Aeroplanes

only, TMG

only

Limitations,

if applicable,

go here

fcl_

additional_

rating

SAILPLANETOW

ING

dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

This

attribute is

not used

Aeroplanes

only, TMG

only

Limitations,

if applicable,

go here

fcl_

additional_

rating

BANNER

TOWING

dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

fcl_

additional_

rating

NIGHT dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

archetype endorsement valid_since valid_until ir_date other_1 other_2

fcl_

additional_

rating

MOUNTAIN dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

This

attribute is

not used

Wheels only,

skis only,

wheels and

skis

Limitations,

if applicable,

go here

fcl_

additional_

rating

FLIGHT TEST dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

This attribute

is not used

This attribute

is not used

CAT 1, CAT 2

As applicable

This

attribute is

not used

fcl_

additional_

rating

FI(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

FI, SP, SE,

NIGHT,

STOW,

BTOW,

AEROBAT

Privileges, if

applicable,

go here

RESTRICTED

LAPL, PPL

Limitations,

if applicable,

go here

fcl_

instructor_

rating

CRI(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

STOW,

BTOW,

AEROBAT

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

instructor_

rating

TRI(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

LIFUS

Privileges, if

applicable,

go here

SPA, MPA,

FFS only

Limitations,

if applicable,

go here

fcl_

instructor_

rating

IRI(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

MPL BP only

Limitations,

if applicable,

go here

fcl_

instructor_

rating

SFI(A) dd/mm/yyyy

Date of

obtention,

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

MCC and

MPL

restrictions

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

archetype endorsement valid_since valid_until ir_date other_1 other_2

revalidation

or renewal,

as applicable

Limitations,

if applicable,

go here

fcl_

instructor_

rating

MCCI(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

instructor_

rating

STI(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

instructor_

rating

MI(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

instructor_

rating

FTI(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

instructor_

rating

SENIOR I(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

FI, IRI, SFI,

MCCI, STI,

MI, FTI, CRI

(CCCC1,

CCCC2, etc.),

TRI (TTTT1,

TTTT2, etc.)

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

examiner_

rating

FE(A) dd/mm/yyyy

Date of

obtention,

revalidation

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

archetype endorsement valid_since valid_until ir_date other_1 other_2

or renewal,

as applicable

fcl_

examiner_

rating

FIE(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

examiner_

rating

CRE(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

examiner_

rating

TRE(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

examiner_

rating

IRE(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

examiner_

rating

SFE(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

examiner_

rating

SENIOR E(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

FE, IRE, FIE,

SFE, CRE

(CCC1,

CCCC2, etc.),

TRE (TTTT1,

TTTT2, etc.)

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

archetype endorsement valid_since valid_until ir_date other_1 other_2

radio-

telephony

RT(A) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

LAN1, LAN2,

LAN3, etc.

ISO 639-2

codes for

languages (3

letters)

Limitations,

if applicable,

go here

language_

proficiency

LAN

ISO 639-2 codes

for languages (3

letters)

dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

4, 5, 6

Language

proficiency

level as

applicable

This

attribute is

not used

3.3. Helicopter licences

3.3.1. Title taxonomy

Table 9 — Title endorsements for helicopters

Endorsement Description

LAPL(H) Light aircraft pilot licence

PPL(H) Private pilot licence

CPL(H) Commercial pilot licence

ATPL(H) Airline transport pilot licence

3.3.2. Rating taxonomy

Table 10 — Rating taxonomy for helicopters Endorsement Description Standardised

privileges/limitations

Comments

IR(H) Instrument

rating

FCL.610:

IFR by day only

FCL.605(d):

IR restricted to COPI

BIR Basic

instrument

rating

TTTT Type

endorsement

FCL.700.H(b):

COPI only

The endorsement for a type of

aeroplane will be as given on the

EASA class and type rating

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

endorsement list as published in its

current version on EASA’s website.

BANNER

TOWING

Banner towing

NIGHT Night rating

FTR(H) Flight test

rating

CAT1, CAT2 Category is endorsed as a privilege.

FI(H) Flight

instructor

FCL.910.FI:

RESTRICTED

LAPL

PPL

CPL

IR(H)

IR(H) SPIC and FSTD only

NIGHT

TRI(H) Type rating

instructor

FCL.910.TRI(a):

FFS only

MPO

IRI(H) Instrument

rating

instructor

FCL.915.IRI:

FSTD only

SFI(H) Synthetic flight

instructor

FCL.905.SFI:

MCC

MPO

MCCI(H) Multi-crew

cooperation

instructor

STI(H) Synthetic

training

instructor

FTI(H) Flight test

instructor

SENIOR I(H) Senior

instructor

FI, IRI, SFI, MCCI, STI, FTI, TRI

(TTTT1, TTTT2, etc.)

Senior instructors can instruct

other instructors.

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

The privileges for senior

instructors indicate the instruction

of the type of instructor that can

be performed.

FE(H) Flight examiner

FIE(H) Flight

instructor

examiner

TRE(H) Type rating

examiner

IRE(H) Instrument

rating

examiner

SFE(H) Synthetic flight

examiner

SENIOR E(H) Senior

examiner

FE, IRE, FIE, SFE, TRE (TTTT1,

TTTT2, etc.)

A senior examiner can perform

assessments on other examiners.

The privileges for the senior

examiner indicate the assessments

of the type of examiner that can be

performed.

RT(H) Radiotelephony LAN1, LAN2, etc. LAN1, LAN2, etc. represents the list

of languages with which the holder

of the licence can use

radiotelephony.

LAN ISO 639-2

codes for

languages (3

letters)

Language proficiency levels:

Each language is listed as an

endorsement attribute and the

proficiency level is specified in the

attribute ‘other_1’.

3.3.3. Endorsement methodology

Ratings shall be endorsed specifying its attributes as shown in Table 11.

Table 11 — Rating endorsement methodology for helicopters archetype endorsement valid_since valid_until ir_date other_1 other_2

fcl_

instrument_

rating

IR(H) dd/mm/yyyy

Date of

obtention,

revalidation

dd/mm/yyyy

Date of

expiry

This attribute

is not used

when IR is

not linked to

a type rating

This

attribute is

not used

IFR DAY

only, IR

restricted to

COPI

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

or renewal,

as applicable

Use if

applicable

fcl_

instrument_

rating

BIR dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

This

attribute is

not used

fcl_

type_

rating

TTTT dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

dd/mm/yyyy

Expiry date of

IR, only if

linked to the

type rating

This

attribute is

not used

COPI only

Limitations,

if applicable,

go here

fcl_

additional_

rating

BANNER

TOWING

dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

fcl_

additional_

rating

NIGHT dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

fcl_

additional_

rating

MOUNTAIN dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

This

attribute is

not used

Wheels

only, skis

only, wheels

and skis

Limitations,

if applicable,

go here

fcl_

additional_

rating

FTR(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

CAT1, CAT2

Use as

applicable

This

attribute is

not used

fcl_

additional_

rating

FI(H) dd/mm/yyyy

Date of

obtention,

revalidation

dd/mm/yyyy

Date of

expiry

This attribute

is not used

IR, NIGHT

Privileges, if

applicable,

go here

RESTRICTED,

LAPL,PPL,

CPL

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

or renewal,

as applicable

Limitations,

if applicable,

go here

fcl_

instructor_

rating

TRI(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

FFS only

Limitations,

if applicable,

go here

fcl_

instructor_

rating

IRI(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

instructor_

rating

SFI(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

MPO

Privileges, if

applicable,

go here

MCC and

MPL

restrictions

Limitations,

if applicable,

go here

fcl_

instructor_

rating

MCCI(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

instructor_

rating

STI(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

instructor_

rating

FTI(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

instructor_

rating

SENIOR I(H) dd/mm/yyyy

Date of

obtention,

revalidation

dd/mm/yyyy

Date of

expiry

This attribute

is not used

FI, IRI, SFI,

MCCI, STI,

FTI, TRI

Limitations,

if applicable,

go here

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

or renewal,

as applicable

(TTTT1,

TTTT2, etc.)

Privileges, if

applicable,

go here

fcl_

examiner_

rating

FE(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

examiner_

rating

FIE(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

examiner_

rating

TRE(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

examiner_

rating

IRE(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

examiner_

rating

SFE(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

fcl_

examiner_

rating

SENIOR E(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

FE, TRE

(TTTT1,

TTTT2, etc.),

IRE, FIE, SFE

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

Radio-

telephony

RT(H) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

LAN1, LAN2,

LAN3, etc.

ISO 639-2

codes for

languages (3

letters)

Limitations,

if applicable,

go here

language_

proficiency

LAN

ISO 639-2

codes for

languages (3

letters)

dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This attribute

is not used

4, 5, 6

Language

proficiency

level as

applicable

This

attribute is

not used

3.4. Sailplane licences

3.4.1. Title taxonomy

Table 12 — Title taxonomy for sailplanes

Endorsement Description

SFCL Sailplane flight crew licence

3.4.2. Rating taxonomy

Table 13 — Rating taxonomy for sailplanes Endorsement Description Standardised

privileges/limitations

Comments

SPL Sailplane SFCL.150 (a)

TMG Touring motor

glider

SFCL.150 (b)

WINCH Winch

launching

method

SFCL.155

CAR Car launching

method

SFCL.155

AERO Aero launching

method

SFCL.155

SELF Self-launching

method

SFCL.155

BUNGEE Bungee

launching

method

SFCL.155

AEROBATIC

BAS

Aerobatic basic

flight

SFCL.200 (b)

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

Endorsement Description Standardised

privileges/limitations

Comments

AEROBATIC

ADV

Aerobatic

advanced flight

SFCL.200 (c)

SAILPLANE

TOWING

Sailplane

towing with

TMG

SFCL.205 (b)

BANNER

TOWING

Banner towing

with TMG

SFCL.205 (c)

NIGHT Night rating SFCL.210

CLOUD Cloud flying

rating

SFCL.215

FI(S) Flight

instructor

SPL, TMG, CAR, AERO, SELF,

BUNGEE

AEROBATIC BAS, AEROBATIC

ADV, CLOUD, SAILPLANE

TOWING, BANNER TOWING,

NIGHT

SFCL.350(A) → RESTRICTED

SFCL.315

SENIOR I(S) Senior

instructor

FI(SPL), FI(TMG), FI(CAR, AERO,

SELF, BUNGEE)

FI(AEROBATIC BAS),

FI(AEROBATIC ADV), FI(CLOUD),

FI(SAILPLANE TOWING),

FI(BANNER TOWING), FI(NIGHT)

SFCL.315 (7)

Senior instructors can instruct

other instructors.

The privileges for senior

instructors indicate the instruction

of the type of instructor that can

be performed.

FE(S) Flight examiner SFCL.415 (a) → SPL

SFCL.415 (b) → TMG

SFCL.415 (c) (1) (i) → FI(SPL)

SFCL.415 (c) (1) (ii) → FI(TMG)

SENIOR E(S) Senior

examiner

FE(SPL), FE(TMG), FE(FI(SPL)),

FE(FI(TMG))

A senior examiner can perform

assessments on other examiners.

The privileges for the senior

examiner indicate the assessments

of the type of examiner that can be

performed.

RT(S) Radiotelephony LAN1, LAN2, etc. LAN1, LAN2, etc. represents the list

of languages with which the holder

of the licence can use

radiotelephony.

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

3.4.3. Endorsement methodology

Ratings shall be endorsed specifying its attributes as shown in Table 14.

Table 14 — Endorsement methodology for sailplanes archetype endorsement valid_since valid_until ir_date other_1 other_2

fcl_class_

rating

SPL dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_class_

rating

TMG dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_launch_

method

WINCH dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_launch_

method

CAR dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_launch_

method

AERO dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_launch_

method

SELF dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_launch_

method

BUNGEE dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_

additional_

rating

AEROBATIC

BAS

dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_

additional_

rating

AEROBATIC

ADV

dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_

additional_

rating

SAILPLANE

TOWING

dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_

additional_

rating

BANNER

TOWING

dd/mm/yyyy This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

archetype endorsement valid_since valid_until ir_date other_1 other_2

Date of

obtention

fcl_

additional_

rating

NIGHT dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_

additional_

rating

CLOUD dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_

instructor_

rating

FI(S) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

This attribute

is not used

This

attribute is

not used

SPL, TMG,

CAR, AERO,

SELF,

BUNGEE

AEROBATIC

BAS,

AEROBATIC

ADV,

CLOUD,

SAILPLANE

TOWING,

BANNER

TOWING,

NIGHT

Privileges, if

applicable,

go here

RESTRICTED

Limitations,

if applicable,

go here

fcl_

instructor_

rating

SENIOR I(S) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

This attribute

is not used

This

attribute is

not used

FI(SPL),

FI(TMG),

FI(CAR,

AERO, SELF,

BUNGEE)

FI(AEROBATI

C BAS),

FI(AEROBATI

C ADV),

FI(CLOUD),

FI(SAILPLAN

E TOWING),

FI(BANNER

TOWING),

FI(NIGHT)

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

archetype endorsement valid_since valid_until ir_date other_1 other_2

fcl_

examiner_

rating

FE(S) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This

attribute is

not used

FE(SPL),

FE(TMG),

FE(FI(SPL)),

FE(FI(TMG))

Privileges, if

applicable,

go here

RESTRICTED

Limitations,

if applicable,

go here

fcl_

examiner_

rating

SENIOR E(S) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

dd/mm/yyyy

Date of

expiry

This

attribute is

not used

SPL, TMG,

FE(FI(SPL)),

FE(FI(TMG))

Privileges, if

applicable,

go here

Limitations,

if applicable,

go here

radio-

telephony

RT(S) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal,

as applicable

This attribute

is not used

This

attribute is

not used

LAN1, LAN2,

LAN3, etc.

ISO 639-2

codes for

languages (3

letters)

This

attribute is

not used

3.5. Balloon licences

3.5.1. Title taxonomy

Table 15 — Title taxonomy for balloons

Endorsement Description

BFCL Balloon flight crew licence

3.5.2. Rating taxonomy

Table 39 — Rating taxonomy for balloons Endorsement Description Standardised

privileges/limitations

Comments

HAB-A Class

endorsement

Hot air balloon,

group A

BFCL.010

HAB-B Class

endorsement

Hot air balloon,

group B

BFCL.010

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

Endorsement Description Standardised

privileges/limitations

Comments

HAB-C Class

endorsement

Hot air balloon,

group C

BFCL.010

HAB-D Class

endorsement

Hot air balloon,

group D

BFCL.010

GAS Class

endorsement

Gas balloon

BFCL.010

MIXED Class

endorsement

Mixed balloon

BFCL.010

HAS Class

endorsement

Hot-air airship

BFCL.010

TETHERED Tethered rating BFCL.200

NIGHT Night rating BFCL.210

COMMERCIAL Commercial

operations

rating

BFCL.215

FI(B) Flight

instructor

HAB-A, HAB-B, HAB-C, HAB-D,

GAS, MIXED, HAS, TETHERED,

NIGHT

BFCL.315

SENIOR I(B) Senior

instructor

FI(HAB-A, HAB-B, HAB-C, etc.),

FI(TETHERED), FI(NIGHT)

Senior instructors can instruct

other instructors.

The privileges for senior

instructors indicate the instruction

of the type of instructor that can

be performed.

FE(B) Flight examiner HAB-A, HAB-B, HAB-C, HAB-D,

GAS, MIXED, HAS, TETHERED,

NIGHT, COMMERCIAL, FI(HAB-A,

HAB-B, HAB-C, etc.),

FI(TETHERED), FI(NIGHT)

Senior FEs (with privileges to test

other FEs) will have an ‘FE’

privilege endorsed.

BFCL.400 Balloon flight examiner

certificates

BFCL.415 FE(B) certificate –

Privileges and conditions

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

Endorsement Description Standardised

privileges/limitations

Comments

SENIOR E(B) Senior

examiner

FE(HAB, HAS, MIXED, etc.),

FE(COMMERCIAL), FE(FI(HAB-A,

HAB-B, etc.))

A senior examiner can perform

assessments on other examiners.

The privileges for the senior

examiner indicate the assessments

of the type of examiner that can be

performed.

RT(B) Radiotelephony LAN1, LAN2, etc. LAN1, LAN2, etc. represents the list

of languages with which the holder

of the licence can use

radiotelephony.

3.5.3. Endorsement methodology

Ratings shall be endorsed specifying their attributes as shown in Table 17.

Table 17 — Rating endorsement methodology for balloons archetype endorsement valid_since valid_until ir_date other_1 other_2

fcl_class_

rating

HAB-A dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_class_

rating

HAB-B dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_class_

rating

HAB-C dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_class_

rating

HAB-D dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_class_

rating

GAS dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_class_

rating

MIXED dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_class_

rating

HAS dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

archetype endorsement valid_since valid_until ir_date other_1 other_2

fcl_

additional_

rating

TETHERED dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_

additional_

rating

NIGHT dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_

additional_

rating

COMMERCIAL dd/mm/yyyy

Date of

obtention

This attribute

is not used

This

attribute is

not used

This

attribute is

not used

This

attribute is

not used

fcl_

instructor_

rating

FI(B) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal, as

applicable

This attribute

is not used

This

attribute is

not used

SENIOR,

HAB-A,

HAB-B,

HAB-C,

HAB-D, GAS,

MIXED,

HAS,

TETHERED,

NIGHT

Use if

applicable

Limitations,

applicable,

go here

fcl_

instructor_

rating

SENIOR I(B) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal, as

applicable

This attribute

is not used

This

attribute is

not used

FI(HAB-A,

HAB-B, HAB-

C, etc.),

FI(TETHERE

D),

FI(NIGHT)

Privileges, if

applicable,

go here

Limitations,

applicable,

go here

fcl_

examiner_

rating

FE(B) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal, as

applicable

dd/mm/yyyy

Date of expiry

This

attribute is

not used

SENIOR,

HAB-A,

HAB-B,

HAB-C,

HAB-D, GAS,

MIXED,

HAS,

TETHERED,

NIGHT,

COMMERCI

AL, FI(B),

FIE(B)

Use if

applicable

Limitations,

applicable,

go here

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

archetype endorsement valid_since valid_until ir_date other_1 other_2

fcl_

examiner_

rating

SENIOR E(B) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal, as

applicable

dd/mm/yyyy

Date of expiry

This

attribute is

not used

FE(HAB,

HAS, MIXED,

etc.),

FE(COMME

RCIAL),

FE(FI(HAB-

A, HAB-B,

etc.))

Privileges, if

applicable,

go here

Limitations,

applicable,

go here

radio-

telephony

RT(B) dd/mm/yyyy

Date of

obtention,

revalidation

or renewal, as

applicable

This attribute

is not used

This

attribute is

not used

LAN1, LAN2,

LAN3, etc.

ISO 639-2

codes for

languages (3

letters)

This

attribute is

not used

GM1 Point 3.1 of Appendix I to Annex VI (Part-ARA) — Flight crew licence — EASA Forms 141 and 155 ELECTRONIC PERSONNEL LICENCE SYSTEM

(a) Implementing the electronic personnel licence system

(1) The issuance of electronic personnel licences by Member States is optional.

However, the Convention on International Civil Aviation (Doc 7300), Annex 1 ‘Personnel

licensing’, mentions the obligation for all ICAO States to recognise them.

(2) The electronic personnel licence system can be scalable to the needs of each Member

State, its service providers, licence holders and applicants.

An efficient electronic personnel licence system will be achieved through thoughtful

planning and implementation, ensuring that it meets not only requirements of the

Convention on International Civil Aviation (Doc 7300) and its Annexes, but also the

applicable national and European regulations.

(3) When implementing an electronic personnel licence system, Member States may also

take into consideration its integration with already existing licensing systems, including,

but not limited to:

(i) initial issuance of the licence;

(ii) licence conversion, limitation, suspension or revocation;

(iii) integration with the software used by the competent authority; and

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

(iv) links to other IT frameworks required (e.g. other Member State entities,

organisations), when applicable.

(4) Prior to introducing the electronic personnel licence system, Member States may

consider the following aspects:

(i) Regulatory framework

Member States need to determine whether the current national regulatory

framework would allow the implementation of the electronic personnel licence

system regulations (e.g. privacy laws, relevant information technology regulations,

data protection). If not, Member States may need to amend their current national

regulations or introduce new regulations.

(ii) Risk analysis

The electronic personnel licence system will inherently be exposed to new risks. In

order to address new risks, the introduction of the system may be driven by the

results of a risk assessment in each phase of the project. A risk assessment could

be a part of the Member State’s integrated risk management that would allow the

identification and evaluation of common risks, as well as the development of an

action plan that addresses key risks and effective mitigation of those risks.

The electronic personnel licence system may be incorporated in the information

security management system of the competent authority or in a suitable

equivalent, which is used by the competent authority. Guidance on conducting risk

assessments is provided in the Safety Management Manual (ICAO Doc 9859).

(iii) Resources

Competent authorities need to ensure that they have sufficient resources to

introduce and maintain an electronic personnel licence system. This includes

financial resources, as well as human resources.

If a competent authority does not have qualified personnel to develop and

maintain the electronic personnel licence system, some of the work may be

outsourced.

A competent authority may invest time and resources not only in implementation,

but also in equipment and technology, the work environment, employees and

operating systems.

The competent authority may be prepared to invest in the systems and processes,

as well as to develop policies that provide optimal global interoperability and

performance of the electronic personnel licence system.

(iv) Service providers and licence holders

Competent authorities need to consider how the electronic personnel licence

system will affect their service providers, licence holders and applicants.

(5) It is recommended that the competent authority prepare a comprehensive project

initiation document defining the scope, the impact on the existing national licensing

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

system and the electronic personnel licence system, and including a risk assessment and

other features.

(6) While developing the electronic personnel licence system, it is advisable to consider the

potential scalability of the system in terms of how the system could be applied to other

licensing or certification areas, in order to capitalise on the work involved and the know-

how developed by the Member State during the implementation of the electronic

personnel licence system.

(7) It is advisable to conduct a post-implementation analysis of the electronic personnel

licence system in order to capture the lessons learned and the benefits of the realisation

of the project.

(b) Features of the electronic personnel licence system

(1) The electronic personnel licence system typically consists of the following major parts:

(i) a server-based licence management system with a user interface management

system;

(ii) (an) application(s) installed on (a) self-contained mobile electronic visual display

device(s); and

(iii) a system to support surveillance activities by the Member State’s own inspectors

and by inspectors from other competent authorities.

(2) The purpose of the application installed on a self-contained mobile electronic visual

display device is to provide the licence holder with a means to show the approved and

updated privileges conferred upon the individual by the competent authority.

Secure communication between the electronic personnel licence system of the

competent authority and the self-contained mobile electronic visual display device can

be via the internet or other electronic means as deemed appropriate by the issuing

competent authority.

(3) In addition, the electronic personnel licence system can enable authorised persons to

perform verification.

(c) Expected level of performance

Competent authorities intending to introduce an electronic personnel licence system may

ensure the following:

(1) a high degree of security, preventing forgery, data leaking and other security events;

(2) highly reliable delivery of the correct information, at the right time and to the right

person;

(3) the ability to detect corrupted data and service interruptions, and to initiate timely

corrective actions;

(4) the ability of the electronic personnel licence system to be used for verification purposes

in circumstances where electronic access to the information is not possible; and

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

(5) robust contingency arrangements to manage unexpected events; for example, in the

event of a primary component outage of the electronic personnel licence system within

the competent authority, a process to transfer to back-up systems in order to maintain

the availability of the data.

(d) Electronic personnel licence system elements

The electronic personnel licence system may include the following:

(1) infrastructure for processing, storage, network communications, security and other

enabling software and hardware;

(2) data access to provide secure licence information resource support for services related

to the electronic personnel licences, licence holders and persons authorised to verify the

authenticity and validity of the licences, and a comprehensive level of integration with

the regulatory information management system of the competent authority;

(3) a business application to provide services for the issue, conversion, limitation, revocation

or suspension of flight crew licences issued in electronic format, and for the display,

query, verification and record-keeping of the electronic personnel licences;

(4) a user-friendly interface that provides correct data to the right addresses when needed;

The system architecture of the electronic personnel licence system may be supported by security

controls in layers providing role-based access to data, as well as by operations and the

maintenance support functions.

The integration of these controls and functions may be aligned with relevant and appropriate

standards and specifications, as well as regulatory system integration standards and

requirements. It is recommended not to implement single points of failure in any of the layers.

(e) Compliance with the applicable national and EU regulations, including privacy and personal

data protection

The electronic personnel licence system is subject to compliance with the applicable national

and EU regulations, including the privacy and data protection laws.

In reviewing the privacy and data protection laws, Member States may consider the following:

(1) What is personal data?

(2) What personal data is collected and for what purposes?

(3) How is personal data retained?

(4) With whom will personal data be shared and for what purposes?

(5) How long is personal data retained?

(6) Is there any international transfer of personal data? Where? Under which legal basis?

(7) How can data subjects access, update, delete or correct their personal data?

(8) What steps are taken to ensure the security of personal data?

(9) Whom can data subjects contact to exercise their rights in accordance with national and

EU regulations on personal data protection?

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

(10) What is the complaint process?

(f) Security specifications

(1) Member States intending to implement an electronic personnel licence system may

ensure a high degree of security to prevent forgery, data leaking and other security

events. Information security as well as compliance with the applicable national and EU

regulations concerning information security may be considered during all phases.

(2) The main areas of security risks may include:

(i) loss or inauthenticity of data (e.g. invalidity, spoofing);

(ii) network or device malware infection; and

(iii) protection of private data.

(3) A risk assessment may be performed by the competent authority in order to identify the

major risks associated with an electronic personnel licence system. In addition, it is

recommended that a register of identified risks be maintained to minimise the likelihood

that the competent authority will lose sight of its known risks.

(g) Training and supporting guidance material

(1) The development of training and supporting guidance material, appropriate to their roles

and responsibilities, are recommended for all personnel who may interact with the

electronic personnel licence system. Such personnel may include licence applicants and

holders, competent authority personnel, inspectors (both domestic and foreign) and

electronic personnel licence system personnel.

Possible training and guidance topics could include:

(i) the use of the electronic personnel licence system, including its features and

capabilities;

(ii) the online and offline verification of the authenticity and validity of the electronic

personnel licences, including the use of any tools or applications, as well as the

description of included features (e.g. active security features to differentiate it

from a static image);

(iii) contingency actions, including cases of loss of or damage to the self-contained

mobile electronic visual display device used for the electronic personnel licences;

(iv) any other training and guidance that a Member State may find to be necessary.

(2) In addition to the topics identified in point (1), it is recommended that personnel whose

responsibilities include verifying, adding, deleting, amending or approving amendments

to electronic personnel licence data also receive regularly updated training in the

following subjects:

(i) administration of the electronic personnel licence system, including record-

keeping, maintenance and troubleshooting;

(ii) security training and awareness; and

(iii) training in monitoring of emerging risks.

European Union Aviation Safety Agency NPA 2024-08 (B)

Proposed regulatory material

An agency of the European Union

AMC1 Point 3.2 of Appendix I to Annex VI (Part-ARA) — Flight crew licence — EASA Forms 141 and 155

INTEGRITY LEVEL OF ELECTRONIC SIGNATURES IN THE LICENCES ISSUED IN ELECTRONIC FORMAT

The electronic signatures in flight crew licences issued in electronic format should be affixed in

accordance with the specifications of Section 5.1.4 of AMC1 ARA.FCL.130.

GM1 Point 3.5 of Appendix I to Annex VI (Part-ARA) — Flight crew licence — EASA Forms 141 and 155

ACTIVE SECURITY FEATURES OF LICENCES ISSUED IN ELECTRONIC FORMAT

Active security features include dedicated visual effects triggered by specific actions such as tilting the

device, shaking it or touching the screen.

Such visual effects typically cannot be replicated using images of the licence captured through a

screenshot or another device.

npa_2024-08_c.pdf

European Union Aviation Safety Agency

Notice of Proposed Amendment 2024-08 (C) in accordance with Article 6 of MB Decision 01-2022

An agency of the European Union

Proposed amendments to Commission Regulation (EU) 2015/340

(air traffic controllers’ licences and certificates)

European Union Aviation Safety Agency NPA 2024-08 (C)

Table of contents

An agency of the European Union

Table of contents

Proposed regulatory material ......................................................................................................... 4

Commission Regulation (EU) 2015/340 (Air traffic controllers’ licences and certificates) ................. 4

Article 4 — Definitions ........................................................................................................................ 4 Article 12 – Transitional measures regarding the inclusion of the information regarding the medical certificate in licences issued in electronic format ................................................................. 5

ANNEX I (Part ATCO) ....................................................................................................................... 6

ATCO.A.005 Application for the issue of licences, ratings and endorsements ............................... 6 ATCO.A.017 Obligation to present documents ............................................................................... 6 ATCO.A.020 Revocation and suspension of licences, ratings and endorsements ........................... 6

ANNEX II (Part ATCO.AR) ................................................................................................................. 7

ATCO.AR.D.001 Procedure for the issue, revalidation and renewal of licences, ratings, endorsements and authorisations ................................................................................................... 7 AMC1 ATCO.AR.D.001(a)(2) Procedure for the issue, revalidation and renewal of licences, ratings, endorsements and authorisations ...................................................................................... 7 GM1 ATCO.AR.D.001(e) Procedure for the issue, revalidation and renewal of licences, ratings, endorsements and authorisations ................................................................................................... 8 ATCO.AR.D.002 Licences issued in electronic format and establishment of an electronic personnel licence system ................................................................................................................ 8 AMC1 ATCO.AR.D.002 Licence issued in electronic format and establishment of an electronic personnel licence system ................................................................................................................ 9

1. DEFINITIONS ......................................................................................................................................................... 9 2. ABBREVIATIONS ................................................................................................................................................... 9 3. PRIOR TO IMPLEMENTATION ............................................................................................................................. 10

3.1 Licensing system and electronic personnel licence system ......................................................................... 10 3.2 The data set for the licence issued in electronic format (EPLDS) ................................................................. 11 3.3 The term ‘licence’ and life cycles ................................................................................................................. 12 3.4. Verification of the authenticity and validity of a licence issued in electronic format ................................. 18

4. EPLSYS ................................................................................................................................................................ 19 4.1. EPLSYS introduction .................................................................................................................................... 19 4.2. Data exchange phases................................................................................................................................. 20 4.3. Chain of trust .............................................................................................................................................. 31 4.4. EPLAPP ........................................................................................................................................................ 31 4.5. EPLRAP ........................................................................................................................................................ 37

5. DATA MODEL ...................................................................................................................................................... 40 5.1 EPLDS ........................................................................................................................................................... 40 5.2. EPLDM ......................................................................................................................................................... 41

6. IMPACT OF THE IMPLEMENTATION OF AN EPLSYS ............................................................................................ 55 6.1. Impact on the LICSYS when implementing an EPLSYS ................................................................................ 55 6.2. Impact on the issuing authority’s procedures when implementing an EPLSYS ........................................... 57

GM1 ATCO.AR.D.002(d) Licences issued in electronic format and establishment of an electronic personnel licence system .............................................................................................................. 57 AMC1 ATCO.AR.D.002(h) Licences issued in electronic format and establishment of an electronic personnel licence system .............................................................................................................. 58 ATCO.AR.D.003 Change of competent authority .......................................................................... 59 AMC1 ATCO.AR.B.010 Changes to the management system ........................................................ 59

ANNEX IV (Part ATCO.MED) .......................................................................................................... 60

ATCO.MED.A.046 Suspension or revocation of a medical certificate ........................................... 60

European Union Aviation Safety Agency NPA 2024-08 (C)

Table of contents

An agency of the European Union

APPENDIX 1 TO ANNEX II — Format for licence(Student) air controller licence — EASA Forms 152 and 156 60 AMC1 Point 1.2 of Appendix 1 to Annex II — (Student) air traffic controller licence ................... 69 AMC1 Point 3.1 of Appendix 1 to Annex II — (Student) air traffic controller licence ................... 70 1. Archetypes for (student) air traffic control licences ....................................................... 71 2. Title taxonomy ................................................................................................................ 71 3. Rating taxonomy ............................................................................................................. 71 4. Endorsement methodology ............................................................................................ 73 GM1 Point 3.1 of Appendix 1 to Annex II — (Student) air controller licence — EASA Forms 152 and 156 75 AMC1 Point 3.2 of Appendix 1 to Annex II — (Student) air controller licence — EASA Forms 152 and 156 80 GM1 Point 3.4 of Appendix 1 to Annex II — (Student) air controller licence — EASA Forms 152 and 156 80

European Union Aviation Safety Agency NPA 2024-08 (C)

Proposed regulatory material

An agency of the European Union

Proposed regulatory material

The text of the amendment is arranged to show deleted, new or amended, and unchanged text as

follows:

— deleted text is struck through;

— new or amended text is highlighted in blue;

— an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.

Where necessary, the rationale is provided in blue italics.

Commission Regulation (EU) 2015/340 (Air traffic controllers’ licences and

certificates)

Article 4 — Definitions For the purposes of this Regulation, the following definitions shall apply:

[…]

(14) ‘licence’ means a document issued in physical or electronic format and endorsed in accordance

with this Regulation and entitling its lawful holder to exercise the privileges of the ratings and

endorsements contained therein;

[…]

(33) ‘licence issued in electronic format’ means a licence issued on a self-contained mobile electronic

visual display device. A licence issued in electronic format may be referred to as an ‘electronic

personnel licence’;

(34) ‘licence issued in physical format’ means a licence issued on paper or other suitable material,

including plastic cards;

(35) ‘electronic personnel licence system’ means an integrated system comprised of the computer

hardware, network and communication facilities, computer software, validated data, users and

associated regulatory framework to enable the issuance of licences in electronic format and the

conduct of verification activities;

(36) ‘self-contained mobile electronic visual display device’ means a device such as a mobile phone,

tablet or other mobile device that enables the generation and verification of the authenticity

and validity of a licence issued in electronic format;

(37) ‘medical certificate’ means a document issued in either physical or electronic format containing

the items specified in point ATCO.AR.F.005 of Annex II (Part ATCO.AR), confirming compliance

with the medical requirements in Annex IV (Part ATCO.MED).

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Article 12 – Transitional measures regarding the inclusion of the information regarding the medical certificate in licences issued in electronic format

1. By way of derogation from point ATCO.AR.D.002(g) of Annex II (Part ATCO.AR), Member States

may decide to not include in a licence issued in electronic format the mandatory information

regarding the medical certificate of the licence holder as required in Appendix 2 to Annex II (Part

ATCO.AR) until [date of entry into force/applicability date + 10 years]. In that case, the holder of

a licence issued in electronic format shall hold a medical certificate issued in physical format in

accordance with Annex IV (Part ATCO.MED).

European Union Aviation Safety Agency NPA 2024-08 (C)

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ANNEX I (Part ATCO)

ATCO.A.005 Application for the issue of licences, ratings and endorsements

[…]

the competent authority. The licence holder shall sign the licence.

[…]

ATCO.A.017 Obligation to present documents

(a) A (student) air traffic controller shall without undue delay present his or her licence, medical

certificate, and a personal identification document (containing his or her photo) for inspection

upon request by an authorised representative of a competent authority.

(b) The holder of the (student) air traffic controller licence issued in electronic format shall report

to the competent authority that issued his or her licence the loss or theft of the self-contained

mobile electronic visual display device on which the licence was generated.

ATCO.A.020 Revocation and suspension of licences, ratings and endorsements

(a) Licences, ratings and endorsements may be suspended or revoked by the competent authority

according to ATCO.AR.D.005 when the licence holder does not comply with the requirements of

this Part.

(b) When the licence holders haves his/her their licence suspended or revoked, they he/she shall

immediately return the licence issued in physical format to the competent authority according

to the administrative procedures established by that authority.

revoked and shall, in case it is a licence issued in physical format, be returned to the competent

authority which is issuing the air traffic controller licence.

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ANNEX II (Part ATCO.AR)

ATCO.AR.D.001 Procedure for the issue, revalidation and renewal of licences, ratings, endorsements and authorisations

(a) The competent authority shall establish procedures for the application, issue and exchange of

licences, issue of ratings and endorsements, as well as the revalidation and renewal of

endorsements. These procedures may include:

(1) the issue of temporary OJTI authorisation and temporary assessor authorisation; and

(2) if applicable, the authorisation for assessors to revalidate and renew unit endorsements

in which case assessors shall submit all records, reports and any other information to the

competent authority as defined in such procedures.

(b) Upon receiving an application and, if relevant, any supporting documentation, the competent

authority shall verify the application completeness and whether the applicant meets the

requirements set out in Annex I.

revalidate or renew, when appropriate, the relevant licence, rating(s) and endorsement(s) using

only one of the two formats for licences established in Appendix 1 of to Annex II. The temporary

OJTI authorisation referred to in point ATCO.C.025 and the temporary assessor authorisation

referred to in point ATCO.C.065 shall be issued as a separate document wherein the privileges

of the holder as well as the validity of the authorisation shall be specified.

(d) For the purpose of reducing unnecessary administrative burden, the competent authority may

establish procedures for establishing a unique date of validity for several endorsements. In any

case, the validity periods of the endorsements concerned shall not be extended.

(e) The competent authority shall replace the air traffic controller licence if necessary for

administrative reasons and when point (XIIa) of the licence issued in physical format is

completed and no further space remains. The date of the first issue of the ratings and rating

endorsements shall be transferred to the new licence.

AMC1 ATCO.AR.D.001(a)(2) Procedure for the issue, revalidation and renewal of licences, ratings, endorsements and authorisations

EXERCISE OF LICENCE PRIVILEGES BEFORE THE INFORMATION IN THE ELECTRONIC PERSONNEL

LICENCE SYSTEM HAS BEEN UPDATED

When licences issued in electronic format are used, the competent authority may develop procedures

to allow privileges to be exercised by the licence holder before the information in the electronic

personnel licence system has been updated following the issue, revalidation or renewal of a unit

endorsement. The period for application of this procedure should be a maximum of 8 weeks after

successful completion of the applicable examination(s) and assessment(s).

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GM1 ATCO.AR.D.001(e) Procedure for the issue, revalidation and renewal of licences, ratings, endorsements and authorisations ADMINISTRATIVE REASONS

For the purpose of issuing a new licence, administrative reasons may be the following but are not

limited to:

(a) loss of the licence issued in physical format or of the self-contained mobile electronic visual

display device;

(b) theft of the licence issued in physical format or of the self-contained mobile electronic visual

display device;

(d) replacement of the self-contained mobile electronic visual display device.

ATCO.AR.D.002 Licences issued in electronic format and establishment of an electronic personnel licence system

(a) The competent authority may decide to issue licences in electronic format to all licensed groups

of personnel, certain groups of personnel or certain individuals. For the same type of licence,

the same individual licence holder cannot hold both a licence issued in physical format and a

licence issued in electronic format.

(b) By way of derogation from point (a), the (student) air traffic controller is entitled to have a

licence issued in electronic format together with a document in physical format, issued in

accordance with point ATCO.AR.D.001, allowing the licence holder to exercise the privileges of

the licence for a maximum period of 8 weeks after successful completion of the applicable

examination(s), pending the endorsement of the licence issued in electronic format.

authorised personnel can verify the authenticity and validity of the licence and are able to

determine its privileges.

(d) The authenticity and validity of a licence issued in electronic format shall be electronically

verifiable:

(1) online when an internet connection is available; or

(2) offline when no internet connection is available through a means that imposes no undue

burden on the authorised personnel verifying the authenticity and validity of the licence.

(e) When the competent authority issues licences in electronic format, it shall establish and

implement procedures for the establishment and operation of an electronic personnel licence

system.

(f) The electronic personnel licence system shall ensure interoperability, security, confidentiality,

data protection, authentication, and accessibility of the licences issued in electronic format.

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(g) A licence issued in electronic format shall include the current information on the medical

certificate with class, expiry date and any medical information deemed relevant by the

competent authority in accordance with Part ATCO.MED.

(h) The competent authority shall develop and apply an administrative procedure for the update of

the licence issued in electronic format, including its limitation, suspension or revocation.

(i) When holders of a licence issued in electronic format have reported the loss or theft of the self-

contained mobile electronic visual display device on which their licence was issued, the

competent authority shall invalidate this licence and generate a new licence licence on another

device declared by the holder and to which they have access.

AMC1 ATCO.AR.D.002 Licence issued in electronic format and establishment of an electronic personnel licence system

ELECTRONIC PERSONNEL LICENCE SYSTEM

1. DEFINITIONS

The following definitions apply to this Acceptable Means of Compliance.

‘Issuing authority’ means a competent authority with competence to issue licences, including licensing

authorities from third countries.

‘Mdoc’ means a document or application that resides on a self-contained mobile electronic visual

display device or requires such a device as part of the process to gain access to the document or

application.

‘Verifying authority’ means a competent authority with competence to verify the validity and

authenticity of licences, including authorities from third countries with competence to verify the

validity and authenticity of licences.

2. ABBREVIATIONS

API application programming interface

CSR certificate-signing request

EPL electronic personnel licence

EPLAPP application for a licence issued in electronic format

EPLDM electronic personnel licence data model

EPLDS data set for the licence issued in electronic format

EPLHD electronic personnel licence holder device

EPLRAP reading application for licences issued in electronic format

EPLRD electronic personnel licence reading device

EPLSYS electronic personnel licence system

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HDPKIC holder device public key infrastructure certificate

IAPKIC issuing authority public key infrastructure certificate

IAS issuing authority server

JWT Java web token

LICSYS licensing system

MSO mobile security object

PKI public key infrastructure

RDPKIC reading device public key infrastructure certificate

TLS transport layer security

URL uniform resource locator

3. PRIOR TO IMPLEMENTATION

Once an issuing competent authority has decided that one or several types of licence will be issued in

electronic format, it should decide on one of the following options:

(a) All the licences of that type will always be issued in electronic format.

(b) The two formats of the licence will be maintained (both physical format and electronic format).

format will be issued just for certain groups of personnel or specific individuals.

3.1 Licensing system and electronic personnel licence system

The licensing system (LICSYS) used by an issuing authority is not the electronic personnel licence

system (EPLSYS). The LICSYS and the EPLSYS are independent systems that share the source where the

information is stored: the issuing authority server (IAS) — see Figure 1.

Figure 1 — LICSYS and EPLSYS schema

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(a) The LICSYS provides the tools that allow an issuing authority to manage the licence information

in accordance with its procedures for issuing, updating and invalidating the licence data. Only

data that has been validated in the national LICSYS and stored as valid licence information can

be used by the EPLSYS.

(b) The LICSYSs used by different issuing authorities might be different one from another: maybe

some issuing authorities use an existing market solution, and others have developed their own

LICSYS in accordance with their needs. Each LICSYS should work in accordance with the

requirements of the regulatory framework that applies to the issuing authority (such as EU

regulations, national regulations and national procedures established for the issuance, renewal,

revalidation, suspension and revocation of a licence).

of an issuing authority are converted to an mdoc and are transferred to the holder device

(EPLHD).

(d) The EPLSYS also provides the method by which external parties (inspectors or other parties, who

will be generally called ‘verifiers’) can get the licence information on an electronic personnel

licence reading device (EPLRD) and proceed with the verification the authenticity and validity of

the of the licence issued in electronic format. Both the EPLHD and the EPLRD will need the

installation of software that can process the licence information..

3.2 The data set for the licence issued in electronic format (EPLDS)

(a) Each type of licence issued in electronic format has a specific set of data defined in the

Appendices to each applicable Regulation, such as Commission Regulation (EU) 2015/340 (air

traffic controllers’ licences and certificates).

(b) In contrast to licences issued in physical format, licences issued in electronic format share a

common structure, a common data set of information that is the same for all types of licences.

This common structure has been included in the affected regulations, and in this AMC it will be

referred to as the data set for the licence issued in electronic format (EPLDS).

medical certificate information of the licence holder, if applicable, as certain types of licence

might not require a medical certificate) — see Figure 2.

Figure 2 — Data sources for the licence issued in electronic format

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(d) Generally, the EPLDS is composed of two subsets of data: a subset related to the licence data

issued in physical format and a subset related to the medical certificate — see Table 1. This

creates unavoidable differences between the licence issued in physical format and the licence

issued in electronic format.

(e) Some licences issued in physical format allow the endorsement of rating revalidations by writing

them down on the licence issued in physical format. The revalidation information is handwritten

and signed by an examiner. Therefore, revalidations, even though they are part of the licence

issued in physical format, are validated by a person in a different role: the examiner instead of

the officer who signs the issuance of the licence. This creates a third source of licence

information of licences issued in electronic format — see Figure 3.

3.3 The term ‘licence’ and life cycles

(a) A licence issued in electronic format should be seen as a representation of the licence

information of the licence issued in physical format and the medical certificate at a particular

moment in time. It will remain valid as long as the licence issued in physical format and the

medical certificate remain the same, but the moment one of these subsets of data varies, this

Table 1 — Information data set for each type of document

Figure 3 — Revalidations as a third data source

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representation is no longer valid, and another licence issued in electronic format supersedes the

existing licence issued in electronic format. Therefore, licences issued in electronic format

should be considered something that works in a similar way to how medical certificates do. The

invalidation of a licence issued in electronic format does not equal the invalidation of a licence

issued in physical format or the invalidation of a medical certificate; it only means that the

information in that representation is no longer accurate.

(b) Both the licence issued in physical format and the licence issued in electronic format grant the

licence holder the right to make use of the privileges given by them, and it makes no difference

having one format or the other, but technically they are not the same because of the

particularities of the licence issued in electronic format.

3.3.1 Issuance of a licence