SEP (land) Revalidation Renewal 

Fly EPT Spain provides a wide range of flight training services including: 

- initial training 

- refresher training 

- revalidation 

- renewal 

Introduction

Are you recent?  Are you current?  SEP(land) class rating revalidation or renewal?  Am I legal to fly?  

If you are NOT sure about the legalities of flying in accordance with (i.a.w.) your license, read on.

Here, we clarify the definition of recency and how pilots can revalidate and renew their Single Engine Piston (SEP) (Land) class rating.

While we refer to an SEP (Land), as this is the most common class rating that general aviation pilots need to revalidate, the process is the same for all other class ratings whether it be an SEP (Sea), MEP or a B737/A320 type rating.

This thread has been comprehensively addressed, pitched to general aviation PPL pilots as well as instructors who need clarity. 

PPL validity 

The Private Pilot License (PPL) is valid for life.

However, to exercise the privileges of the PPL, you are required to revalidate (keep current) ratings and certificates, namely:

(a) Single Engine Piston (SEP) (land or Sea) class rating 

(b) Class 2 medical certificate 

(c) English Language Proficiency (ELP)

If (a) or (b) or (c) has lapsed, you can NOT legally exercise the privileges of your PPL. 

Recency 

Are you recent?

To remain recent, you must have completed 3 take-offs and 3 landings in the preceding 90 days. This is the legal minimum requirement to operate the aircraft as Pilot-in-Command (PIC) and carry passengers on board.

If you are NOT recent, you can still fly but you can NOT legally fly with passengers (Pax) on board.

If you do fly with Pax and you do NOT have recency, this is illegal and you are breaking the law.

If you lose recency, you effectively automatically relegate your license back into the ‘student’ pilot category whereby you can fly solo, but you can NOT fly with passengers on board.

However, as a PPL holder, if you are out of recency, you do NOT need an FI to sign you off to fly solo. As a PPL holder, you can authorize yourself to fly solo, providing your: - 

(a) SEP class rating is valid and current

(b) Class 2 medical certificate is valid and current 

(c) ELP is valid and current 

(d) Proficiency has been checked by an instructor at the school/club (for insurance purposes). 

Once your proficiency has been checked by the school/club, if a PPL holder is NOT recent, providing (a), (b) and (c) is valid and current, it is perfectly okay for you to jump into a single engine piston (SEP) aeroplane and fly three (3) solo circuits. Once done, you have regained your recency, and once again you can continue to exercise the privileges of your PPL and legally fly with passengers on board.

These three (3) circuits, in the preceding 90 days, must be in the same class or similar type and category of aircraft as you plan to take the passengers in. So, for example, if you are now a Boeing/Airbus pilot and you decide to fly a friend on a jolly in a Cessna C172, a type you have not flown in for more than 3 months, beforehand, you must first fly 3 solo circuits in the same class of aeroplane (as the C172 in this case) because the three (3) take-offs and three (3) landings you did last week as an airline pilot will NOT count.

Furthermore, if you plan to fly passengers at night, these three (3) take-offs and three (3) full stop landings in the preceding 90 days must be completed at night, in order to also maintain night recency. Likewise, if you are outside night recency, you do NOT need to fly with an instructor. PPL holders can take the decision themselves to fly three (3) solo night circuits, providing (a), (b) and (c) above are all valid and current.

If you fly a multi-engine piston (MEP) aeroplane, these three (3) take-offs and three (3) landings in the preceding 90 days will count towards Single Engine Piston (SEP) aeroplane, but NOT vice versa.

You may also do these three (3) take-offs and three (3) landings in an approved Flight Simulator Training Device (FSTD).

If you hold an Instrument Rating (IR), and you want to fly with passengers in IMC, then you must have completed two (2) instrument approaches within the preceding 90 days, in either simulated or actual conditions, with a minimum of one (1) approach in the actual aircraft.

Single Engine Piston (SEP) class rating

The Single Engine Piston (SEP) class rating (land / sea) allows you to pilot a Single Engine Piston (SEP) Aeroplane.

The initial issue of an SEP class rating requires a skill test to be passed, in accordance with (i.a.w.) Appendix 9 to Part-FCL to demonstrate the skill required for the safe operation of this class of aeroplane.

SEP class rating validity period

The period of validity of class and type ratings shall be one (1) year, except for single-pilot single-engine piston (SEP) class ratings, which shall be valid for a period of 24 months i.e. two (2) years, from the date when you passed the SEP skills test. 

If pilots choose to fulfil the revalidation requirements earlier than prescribed in points FCL.740.A, the new validity period shall commence from the date of the proficiency check. 

While the validity period of an SEP (land) class rating revalidation or renewal starts on the day you passed your license proficiency check / skill test. The expiry date, however, is rounded up to the last day of the month, plus 2 years. So, for example, if your proficiency / skill test was on the 3 March, the expiry date becomes 31 March plus (+) two (2) years later. If you fail an SEP (land) license proficiency check, the SEP (land) class rating becomes suspended, and you can no longer exercise the privileges of an SEP (land) class rating i.a.w. FCL.740(a) 

How can I keep my SEP class rating current ?

There are three (3) ways to keep your SEP class rating current / valid: 

- Revalidate by Experience 

- Revalidate by Test (i.e. a Proficiency Check)

- Renewal 

By definition: 

- ‘revalidation’ is the process of further extending the validity of a rating. 

- ‘Renewal’ refers to making valid a rating that has expired.

Simply and practically speaking:

Revalidation = a Rating has NOT yet reached its expiry date in accordance with the entry in the licence.

Renewal = Rating in licence has expired 

Important note: 

While a flight instructor can revalidate a current SEP class rating. An instructor can NOT renew an expired rating. Only an examiner can renew an expired rating.

When can the single-engine piston (SEP) aeroplane class rating and TMG rating be revalidated by experience ?

If a rating will expire within three (3) months of the 2 years validity period, you can apply directly to take a proficiency check at an ATO or DTO to have the SEP rating revalidated, without having to take an assessment first. 

Note: Single Engine Piston (SEP), Touring Motor Glider (TMG) and Flight Instructor (FI) ratings can be revalidated up to 12 months in advance. 

To extend an SEP class rating before it expires, the license holder shall fulfil one (1) of the following conditions: 

Revalidate by Test

(1) Within three (3) months of the SEP rating expiry date, pass a proficiency check in the relevant class with an examiner

OR 

Revalidate by Experience

(2) Within 12 months before the rating expires, complete 12 hours of flight time in the relevant class, including: 

      * 12 takeoffs and 12 landings; 

      * 6 hours of flight time as PIC; and 

      * ‘refresher’ training of at least 1 hour of total flight time with a flight instructor (FI) or a Class Rating Instructor (CRI) 

Note: Applicants shall be exempted from this refresher training if they have passed a class or rating proficiency check, skill test, or an Assessment of Competence (AoC) in any other class or type of aeroplane e.g. MEP, SEP(Sea), FI AoC  

Applicants holding both an SEP rating and a touring motor glider (TMG) rating may fulfil the above requirements in either class or in a combination thereof, and may be revalidated on both ratings. Flight time in TMGs may only be counted if the pilot holds a TMG rating.

Therefore, flight experience amassed in three (3) axis microlight aeroplanes or Annex 1 / Non-Part 21 aeroplane can be counted towards meeting the revalidation requirements for SEP Class Ratings and the recency requirements for SEP privileges. A 3-axis Microlight, however, can NOT be used for the refresher training. 

How do I Revalidate my SEP class rating by experience ?

AMC1 FCL.740.A(b)(1)(ii) Revalidation of Class and Type Rating

So, if your SEP class rating remains valid (i.e. you are within the 2 years validity period), providing the revalidation criteria has been met, that is, you have flown 12 hours in the past 12 months (including 12 take-offs + 12 landings and 6 hours PIC), a flight instructor or an examiner who has FCL.945 privileges mentioned in his/her licence, can ‘revalidate by experience’ your SEP class rating after flying a one (1) hour ‘refresher’ training flight with you. 

If you have NOT flown 12 hours in the past 12 months, you can NOT ‘revalidate by experience’ your SEP rating by doing a one (1) hour refresher trainer flight.

What is the content of the 'refresher' training flight ?

Training flight items should be based on the exercise items of the proficiency check, as deemed relevant by the instructor, and depending on the experience of the candidate. The briefing should include a discussion on TEM with special emphasis on decision-making when encountering adverse meteorological conditions or unintentional IMC, as well as on navigation flight capabilities.

Can an instructor sign the revalidation of my rating in my Part-FCL issued EASA licence when I want to revalidate by experience?

Yes, but only if the instructor has FCL.945 privileges mentioned in their licence

If the instructor who completed your one (1) hour refresher training flight(s) as part of your 12-hour revalidation by experience has FCL.945 privileges mentioned in his/her Part-FCL issued licence, this instructor can sign your rating revalidation and process the paperwork to your SOLI. 

If the instructor performing your 1-hour refresher training flight does NOT have FCL.945 privileges mentioned in their licence, you must see an EASA flight examiner for the revalidation signature.

What is FCL.945 ?

In simple terms, FCL.945 allows an instructor to complete the revalidation of a SEP class rating and/or TMG rating.

FCL.945 ONLY applies to Part FCL licences 

FCL.945 does NOT apply to National Licences (NPPL)

Instructors (FI or CRI) who have their licences endorsed with 'FCL.945' under 'Remarks and Restrictions' are specifically authorised by their State of Licence Issue (SOLI) to conduct 'refresher training' towards the revalidation of an SEP class rating and/or TMG i.a.w. FCL.740.A(b)(1)(ii). 

The FI or CRI shall have flown with the pilot before any revalidation action can be completed. An FI or CRI who has not flown with the pilot can NOT carry out the revalidation action FCL.740.A(b)(1)(ii) i.e. 'refresher' training of at least 1 hour of total flight time with a flight instructor (FI) or a class rating instructor (CRI)

Some EASA competent authorities automatically give the FCL.945 privilege to most FI / CRI on application during licence issue. Other EASA states, however, may limit the number of instructors with FCL.945 privileges and/or may carry out a selection process followed by training.

If an FI wishes to apply for the removal of the restriction, send to your state of licence issue (SOLI) form: FI(A) - Removal of restriction 

Note: FI restricted to teaching for the LAPL only, may not get the FCL.945 privilege because a LAPL uses recency to maintain validity

Note: For ‘revalidation by experience’, any EASA instructor or examiner can endorse your EASA licence, providing they have FCL.945 privileges. 

UK CAA licences, however, post-Brexit, cannot be endorsed by an EASA Examiner / Instructor. 

How does an FI apply to have their restriction removed ?

A newly qualified (restricted) flight instructor shall have his/her privileges restricted to conducting flight instruction under the supervision of an FI (who is unrestricted) for the same category of aircraft for the issue of the PPL (SPL, BPL and LAPL)

Newly qualified flight instructors will have a restriction in their licence, which means they can NOT send PPL students solo, and their licence will be endorsed 'Restricted'. In order to have restriction removed, an FI must complete at least: 

(a) 100 hours of flight instruction in aeroplanes or TMGs; and 

(b) Supervised at least 25 student solo flights. 

Once complete, the HT of an ATO can sign off form:  FI(A) - Removal of restriction and the FI can apply for the removal of the restriction of a FI(A), according to Part-FCL.910.FI.

How do I Revalidate my SEP class rating by Test i.e. Proficiency Check ?

If you can NOT 'revalidate by experience', you must 'revalidate by test'

To ‘revalidate by test’ your SEP (land) class rating, you need to do a proficiency check with an examiner, and this must be revalidated within 90 days (3 months) of the expiry date of your SEP, in order to stay within the expiry pattern stipulated in FCL.740.A.(b)(1)(i)

What is a proficiency check 

By EASA Part-FCL definition, a proficiency check is a demonstration of skill to revalidate or renew ratings or privileges, and includes an oral examination, as required. 

A proficiency check can sometimes be referred to as a Licence Proficiency Check (LPC) and is essentially a check flight with an examiner to revalidate the rating (SEP class rating). Or to renew its validity once expired. 

The proficiency check programme shall be based on the skill test for the PPL(A). 

The proficiency test is a simple pass or fail.

In the case of an SEP class rating revalidation or renewal, the proficiency check is the same, and is documented in Part-FCL.740

The examiner must be either a Class Rating Examiner (CRE) or a Flight Examiner (FE) with SEP (land) privileges. 

Before the test, an applicant’s class 2 medical certificate and ELP must be current and valid. 

While a written exam at an ATO is a part of the testing for single pilot, multi-engine aircraft, and for multi-pilot or single-pilot high performance aircraft a test of at least 100 multiple-choice questions. In the case of an examiner proficiency check for a single engine piston (SEP) aircraft, only a verbal exam is conducted during the skill test to determine whether or not a satisfactory level of knowledge has been achieved. This will take the form of a general quiz. 

Note: In the case of a flight instructor certificate, there is no proficiency check, only an assessment of competence (AoC) 

What is content of the proficiency check ?

The EASA proficiency check for revalidation of a class rating for single-engine piston (SEP) aeroplanes is subject to the paragraph FCL.740.A(b)(1)

The scope of the proficiency check with examiner is described in Appendix 9 of Part-FCL, Regulation (EC) 1178/2011.

SEP(land) holder has to demonstrate the ability to perform maneuvers, and procedures on that particular variant of SEP aeroplane with competency appropriate to the privileges granted as a pilot in command (PIC) to the flight examiner - FE(A) - or to the class rating examiner - CRE SEP(land).

The duration of the SEP(land) license proficiency check flight with the flight examiner takes approximately 1 hour block time in total. Plus any pre-flight preparation time and post-flight debriefing and any theoretical knowledge oral examination.

The SEP(land) LPC includes following items:

- general handling of the aeroplane (normal procedures)

- general handling of the aeroplane (abnormal and emergency procedures)

The route of the cross-country flight will be chosen by the flight examiner. The SEP(land) candidate is responsible for flight planning and we well as being responsible to ensure that all equipment and all aircraft documents, certificates and materials required for the flight are all on board the aircraft during the check flight.

My SEP has expired - How can I Renew ?

If your SEP class rating has lapsed i.e. you did not ‘revalidate by experience’ or 'revalidate by test' before the 2-year SEP expiry date, a pilot needs to follow the renewal process which, under Part-FCL, is essentially ‘refresher training’ (FAA for ‘training as required’) with an instructor, followed by a proficiency check (FAA for flight review) with an examiner.

Renewal process 

The renewal process is the administrative action taken after a rating or certificate has lapsed for the purpose of renewing the privileges of the rating (or certificate) for a further specified period of time, upon fulfilment of specified requirements. 

If your SEP class rating has expired, you will have to go to an ATO or DTO where the Head of Training will determine how much training you need before completing the proficiency check (LPC). 

The amount of training to be done depends on many aspects such as: 

- the last time you have flown the aircraft 

- your experience 

- the complexity of the aircraft 

If your SEP class rating has expired, the applicant must complete ‘refresher training’, as required:

- at a DTO or ATO if SEP (land) class rating has expired by more than three (3) years 

OR

- at a DTO, or ATO, or with an instructor, if the SEP (land) class rating expired less than three (3) years before. 

This was approved in late 2019, whereby if your SEP class rating expired less than 3 years ago, you can now complete ‘refresher training’ with an independent certified flight instructor without the need for a flight school to get involved. 

They will establish the SEP (land) renewal procedure which essentially involves regaining the skills and proficiency of the SEP (land) holder. 

A flight instructor will make an initial assessment and the FI will assess the need for any further refresher training before notifying the examiner to book a proficiency check. 

Subject to the recommendation of the flight school / instructor, the SEP (land) holder can be put forward for a proficiency check with the examiner. You will be issued with a ‘refresher training’ course completion certificate which you must present to the examiner before your LPC.

To renew the SEP (land) class rating, you need to fulfil the requirements of Part.FCL.740(b): 

- Complete an SEP (land) proficiency check with an examiner, in accordance with Appendix 9 to Part-FCL 

- Prior to SEP (land) proficiency check, complete ‘refresher training’ in order to reach the level of proficiency needed to safely operate the SEP (land) class.

The SEP applicant may be exempt from refresher training if:  the pilot: 

(a) holds a valid rating for the same class on a pilot license issued by a third country i.a.w. Annex 1 to the Chicago convention; and 

(b) is entitled to exercise the privileges of that rating. 

In practice, this means:  if your SEP (land) class rating has expired in your EASA Part-FCL (flight crew license), but at the same time in your FAA / ICAO / UK CAA license you have a valid SEP (land) class rating, you are exempt from refresher training, because you can demonstrate currency. 

Refresher training for SEP (land) renewal

FCL.740(b) requires SEP (land) class rating renewal refresher training to be conducted at a flight school. 

AMC1 FCL.740(b) further describes the content of SEP (land) renewal fresher training and its purpose.  

The objective of the SEP (land) refresher training is for the applicant to reach the level of proficiency necessary to safely operate the single engine class rating aeroplane. 

The amount of refresher training needed is determined on a case-by-case basis by the flight school (ATO or DTO) or instructor, taking into account: 

- the experience of the applicant; 

- the amount of time elapsed since the privileges of the rating were last used; 

- the complexity of the aircraft; 

- whether the applicant has a current rating on another aircraft type or class; and 

- where considered necessary, the performance of the applicant during a simulated proficiency check for the rating in an FSTD or an aircraft of the relevant class 

The amount of training needed to reach the level of proficiency will increase with time elapsed since the privileges of the rating were last used. 

Nevertheless, taking into account the factors above, the instructor may decide that the applicant already possess the required level of proficiency and that no further refresher training is needed. In which case, it should be documented and the respective ‘Certificate of No Further Training’ should be evidenced with a statement of sufficient reasoning. 

If it is deemed that the SEP (land) applicant requires further refresher training, the instructor should develop an individual training programme based on the initial SEP (land) training syllabus, with a focus on where the pilot has shown the greatest needs. 

SEP refresher training should include theoretical knowledge instruction, as necessary. The one exception to this is FCL.740(b)(2)(i) 

Theoretical knowledge instruction should include: 

- type-specific system failures in complex aircraft (e.g. retractable landing gear failure)

The performance of the applicant should be reviewed during the training and additional instruction should be provided to the applicant pilot, as necessary, to reach the standard required for the SEP (land) proficiency check. 

‘Refresher training’ Course Completion Certificate

After successful completion of the refresher training, the flight school / instructor should issue the applicant pilot with a ‘refresher training’ course completion certificate (CCC), or a specified form issued by the competent authority, which will stipulate the type of refresher training received, describing the evaluation of the factors essential to the scope of the refresher training. 

The CCC will have a statement confirming that the refresher training has been successfully completed. 

The refresher training CCC should be presented to the examiner prior to the proficiency check. The competent authority has maintained that this is necessary, that the examiner should NOT accept an applicant for a proficiency check without such a certificate.

How to update your Licence: SEP class rating ?

Current ratings are on the front of your license, under:  Section XII: 'Certificate of Revalidation'

Here is an example of how an SEP (land) class rating is indicated on the front of the licence when it is valid.

Expired ratings are on the back of your license, under section 'XII:  Ratings, certificates and privileges'

Here is an example of how an SEP (land) class rating is indicated on the back of the licence when it has expired.

Whether it is a revalidation or renewal, the section of your Part-FCL licence in which the examiner signs the rating’s new validity date will be on the front page of the licence under ‘XII:  Certificate of Revalidation’ 

If the examiner has signed your licence in the field: ‘Certificate of Revalidation’ (front of your licence), there is no need to make an application to your State of Licence Issue (SOLI) to have the licence page updated and reissued. 

Examiners are only authorised to sign the front page of your licence i.e. 'Certificate of validation' in Section XII (page 5 onwards) of a Part-FCL-issued licence, when the rating is still shown on page 4 (Section XII). If the rating is no longer printed on page 4 (Section XII), but appears in the section “ratings previously held by holder”, the rating is no longer included with the licence and can NOT be reinstated by an examiner. 

In these circumstances, where an expired rating is on the back of the licence, a different process needs to be followed.  

Expired ratings are NOT lost but if they are NOT valid at the time of a licence update re-issue, they are placed on the back of a Part-FCL licence as a reference that you once held this rating. After a successful proficiency check, this will prevent the examiner from being able to sign the rating as it will NOT be listed on the front page of your licence under the ‘Certificate of Revalidation’ where all your valid ratings are listed.

In these circumstances, an application for renewal of the 'expired' rating must be made to the competent authority so that the rating can be made valid again. In this case, an applicant needs to apply to the SOLI for an updated licence page and when it returns, your SEP class rating will once again be listed back on the front page of the licence under 'Certificate of validation'. 

Examiners endorsing the logbook following an SEP proficiency check ?

The pilot’s logbook must be endorsed with the result of the SEP (land) proficiency check, including any cases of a failed or partially passed test or check. 

Pilots and examiners are recommended to review AMC1 FCL.050 and PLAM 024 to ensure entries in their logbooks are made in a compliant and a manner acceptable to the competent authority. Failure to comply with the prescribed format and standard shall result in denied new or initial administrative process/es for which the logbook was submitted. 

All pilot logbook entries are to be certified by the PIC or FI in the ‘Remarks’ column of the logbook. Such certification shall include the printed name and licence number of the PIC. 

What documents shall I submit following a ‘revalidation by test’ i.e. Proficiency Check

There is no need to make an application to your SOLI. However, you still need to make sure that your examiner emails the paperwork to your State of Licence Issue (SOLI), so your licence page can be updated, and your valid rating can be stored on file. 

If your examiner has NOT endorsed your licence, you will need to submit yourself:  

- Online Form: Application for the issue, renewal or revalidation of a rating (EASA)

- SRG3108 (UK CAA)

For SEP 'revalidation by test', you will need to upload the following documents: 

- Examiner report form 

- A copy of your Examiner's licence, medical and authorisation 

- A certified copy of your licence 

What documents shall I submit following an SEP (land) class rating 'renewal' ?

Following the successful renewal of the SEP class rating, the following supporting documents should be submitted to the State of License Issue (SOLI):

- Examiner report form

- Copy of your Examiner's licence, medical and authorisation 

- 'refresher training' course completion certificate (or equivalent other document as specified by your competent authority); and the 

- Online Form: Application for the issue, renewal or revalidation of a rating (Note: only if the examiner cannot sign the 'certificate of revalidation' in Section XII of the Part-FCL issued licence)

- Copy of the EASA ATO Approval Certificate 

- Certified copy of your licence 

A Flight Crew Licensing Officer or assistant from your SOLI’s licencing department, following an acceptable assessment of your licence, will process your SEP renewal application, sign your licence in the XII CERTIFICATE OF REVALIDATION section, record it on file and dispatch it back to you in the post. You will be contacted if they have any queries, and they may keep your application pending if any additional requirements need to be met.