EASA has recently published information via an Acceptable Means of Compliance that affects Recency and Revalidation Requirements for private pilots flying Annex I (see end for definition) (non-EASA) aircraft.

Please note this information only applies where the UK CAA is the issuing Competent Authority for the license holder.

Light Aircraft Pilot Licence (LAPL) and Sailplane Pilot Licence (SPL)

For these licences to be current you must fly a certain amount of hours in the preceding 24 months. This flight experience can be made up of flight time as Pilot in Command (PIC), dual or supervised solo.

The guidance from EASA means that you can now include flight time in non-EASA aircraft (apart from weightshift microlights); flight experience is now considered to be part of the definition of hourly requirements.

If the hours are supervised by a flight instructor (either dual or solo) then the aircraft must be subject to an authorisation by the ATO or DTO (ORA.ATO.135 or DTO.GEN.240).

Single Engine Piston (SEP) and Touring Motor Glider (TMG)

For pilots with these ratings to revalidate by experience, you must fly a certain amount of hours in the 12 months before the rating expires. This can be made up of flight time as pilot in command or dual. There is a minimum number of take offs and landing that must be as pilot in command.

The guidance from EASA means that you can now include flight time in non-EASA aircraft (apart from weightshift microlights); flight experience is now considered to be part of the definition of hourly requirements.

There is also a requirement for a refresher training flight with an instructor and this cannot be conducted in a microlight aircraft of any configuration. In addition, the aircraft used must be subject to an authorisation by the ATO or DTO (ORA.ATO.135 or DTO.GEN.240).

Pilots can use hours flown from 18 March 2020 towards meeting the recency or revalidation requirements. The use of this Acceptable Means of Compliance is not compulsory, as this is one of a number of means to comply with the regulation, so licence holders do not have to use non-EASA aircraft if they do not want to.

The hours flown in non-EASA aircraft cannot be used to obtain a Part-FCL licence, rating, or certificate or towards meeting their prerequisites.

All of these requirements only apply to non-EASA Sailplanes, Single-Engine Piston (SEP) Aeroplanes and Touring Motorgliders (TMGs).

Annex I (non-EASA aircraft 1) is defined in the Basic Regulation (Regulation (EU) 2018/1139) as;

1(a) Historical aircraft,
1(b) Research, experimental and or scientific aircraft,
1(c) Homebuilt aircraft, 
1(d) Former military aircraft,
1(e) Microlight aircraft (as defined)

Acceptable Means of Compliance (AMC)

AMC: This is an Acceptable Means of Compliance (AMC) AMC1 to FCL.140.A, FCL.140.S and FCL.740.A(b)(1)(ii) Recency and Revalidation Requirements

Annex 1 aircraft is an aircraft not issued with a Certificate of Airworthiness in accordance with Part 21 and the appropriate Certification Specifications, but hold a Certificate of Airworthiness or Permit to Fly in accordance with the current revision of the Air Navigation Order.