Consultation Hub

We asked for views on a proposal to remove restrictions on the application and management of operational multi-pilot limitations (OML) on Class 1 medical certificates.

We invited stakeholders to consider the relevant implementing rules in Annex IV (Part-MED) of the Aircrew Regulation (UK Regulation (EU) No 1178/2011).

The consultation ran from 2 July 2025 to 31 July 2025.

We received 338 responses to the consultation from both individuals and organisations. The majority were in favour of the proposed changes to the legislation.

97% of responders agreed with the proposal to permit the issue of Class 1 medical certificates with an OML endorsement to initial applicants with certain well-controlled long-term medical conditions.

Several comments related to the dichotomy that currently exists between a commercial licence holder and a new applicant with the same medical condition. Responders felt that initial applicants should be treated in the same way as qualified pilots with medical conditions that are acceptable for multi-pilot operations. They also supported the removal of unnecessary barriers to individuals wanting to start a career as a commercial pilot.

Only ten responders disagreed with the addition of an OML to an initial Class 1 medical certificate. There were three comments. One response suggested that the medical standard should be higher for initial applicants than existing pilots. However, medical impairment and incapacitation events are rare, providing evidence that the current standards for a fit assessment with an OML are appropriate. In addition, the presence of another pilot (or pilots) in multi-pilot operations is a significant mitigation for risks associated with pilot incapacitation.

Two other responders felt that an OML should only be used to extend the careers of pilots already in the profession but this forgoes the opportunity to enable more individuals to access training, which in turn will contribute to addressing the shortage of pilots.

94% of responders supported the proposal to remove the rostering restrictions for commercial licence holders with an OML on their medical certificate.

Most comments indicated that the current legislation is overly restrictive. Reasons in support of removing the constraints included:

• lifestyle rather than age as the determinant of health and fitness
• advances in the management and monitoring of medical conditions
• the presence of another pilot on the flight deck and often additional ‘heavy’ crew on board
• informed risk assessment in the case of known medical conditions
• the extremely low probability of two medical events occurring at the same time

Some responders commented on the benefits of removing the restrictions, including:

• easier rostering and workforce flexibility
• better choice and career prospects for existing pilots
• opportunities for older individuals wanting to enter the profession
• wider deployment of experienced instructors and examiners who have an OML or have reached the age of 60 years
• less operational disruption

Nineteen responders opposed lifting the rostering restrictions, with only two comments. One responder was concerned about two pilots flying together, each having an OML for the same susceptibility or condition, such as hypoxia or an allergy. The other raised the potential for older pilots to have reduced performance or to be less fit.

In response to these concerns, notwithstanding the proposed amendments, the CAA would retain the authority to impose any limitation on the holder of a medical certificate to ensure flight safety. It is also the case that commercial pilots with an OML and older pilots are subject to more frequent review and examination on account of their medical condition and / or age.

In line with Government principles, the CAA consults on matters that include changes to legislation and policy. This was a valuable opportunity to seek views and participation from interested parties. We appreciate the feedback on the proposed amendments, and have considered the responses and comments.

The CAA recognises the importance of acting proportionately and minimising the legislative burden to industry. We see this as an opportunity to remove barriers and restrictions on the application and management of the OML endorsement on Class 1 medical certificates created by the current legislation, with no adverse effect on flight safety.

Most responders supported the proposal to amend the legislation in the two areas consulted upon. The revised policy will benefit both new and existing pilots, provide resource and rostering flexibility to aircraft operators, and support the safe and sustainable functioning of the aviation industry. We will therefore be proceeding with the next phase of the rulemaking task. Work has commenced with the Department for Transport to prepare the Statutory Instrument for Parliament. We anticipate that the amendments to the Aircrew Regulation (UK Regulation (EU) No 1178/2011) will be implemented in late 2026 or early 2027.

For comments on the proposal that the CAA introduces a Special Condition to be used in addressing the integration of a moveable wall into a mini-suite seat, resulting in a “PRM Suite”, in twin aisle large aeroplane interiors.

The Consultation Paper Special Condition UK.SC.D.0001 Issue 1 provides the full detail of the identified issue, and the associated Special Condition.

We received 3 responses.

The first response provided confirmation that the development of a Special Condition would not be applicable to the organisation’s designs or its products. This required no action by the CAA.

The second response proposed addition of further Interpretive Material to support understanding, and to further improve alignment with other global Regulators.

The third response proposed enhancement to the definitions within the text, and proposed wording changes aimed at making the text more specific to the crew operation of a moveable wall, and proposed to remove some text due to being unduly prescriptive.

We acknowledge the responses and thank the responders for their suggestions.

For the second response the comment is accepted and has been incorporated. Additional Interpretive Material has been included in the final SC publication.

For the third response, the comment is partly accepted. The suggestion of enhancement of definitions has been incorporated, and the text within the Identification of Issue section has been revised in the final SC publication. The proposal for wording changes and removal of some text considered prescriptive, has not been incorporated.

The CAA believes the context of the existing text to be clear and the parts subject to comment well aligned to that of other Regulators, and while the comments are relevant, the removal of the text proposed would also remove the intent of the requirement.

We asked for feedback on a proposal to amend the legislation to permit either physical or electronic form of licence or certificate to be issued.

The consultation ran from 12 May 2025 to 22 June 2025 and stakeholders were encouraged to review the copy of ICAO Annex 1 Chapter 5 and Appendix 4 included with the consultation prior to responding.

We received a total of two hundred and twenty (220) responses to the consultation. Across all licensing and certification areas an average of 69% of respondents supported the proposed amendments, 5% did not support the proposals and 26% indicated the question was not applicable.

Two responses questioned the cost and/or need to consult on this regulatory change.

Thirty-one licensing and twelve medical certificate responses expressed a preference to have the option of both physical and electronic licences, some suggesting a card style format to replace the current paper licence. A small number of responses said the choice of physical or electronic should be the licence holders. The licence form used by other Authorities was mentioned in several responses. 

Multiple responses offered views and feedback on the design of a digital licensing system including use of wallet technology; validation technology; inclusion of photo identification and the ability to sign up in the field.

Confidence concerns surrounding the introduction of an electronic system were shared in feedback. Specific areas of concern were identified as: issues with access to the electronic licence; access to internet or loss of data connection; mobile phone loss or failure; battery charge issues; difficulties associated with rolling out an electronic system; widespread system failures; integration of systems; and GDPR concerns due to the requirement to carry an electronic device.

We acknowledge the responses and thank the responders for their suggestions.

The need to consult with interested parties on the development of rules that could have important social implications is set out in the Basic Regulation. The consultation process is also inherent in UK law and consultation is widely used to support this principle.  

The CAA recognises the importance to licence holders of having physical evidence of achieving licence status. It is not possible to run concurrent systems whereby an individual holds both an electronic and a hard copy licence issued for the same kind of licence.

ICAO Doc 9379 states that issuance of an electronic licence is optional and can be introduced for all licenced aviation personnel or certain groups, however no individual should have both an EPL (electronic personnel licence) and a hard copy for the same kind of licence. Following the introduction of the electronic personnel licence for a specific licence group, issuing both a physical copy and an electronic copy of the licence would leave the UK at variance with the Convention on International Civil Aviation. The UK, being an ICAO signatory state, follows ICAO requirements.

It should be noted that the FAA, EASA, CASA, and Transport Canada are exploring digital licensing. Brazil has introduced an electronic licensing system. China has already introduced a digital licensing system that is ICAO compliant.  

The CAA will ensure that all aspects of GDPR and the Data Protection Act under UK law are complied with. ICAO Doc 9379 requires all signatory states to the Convention on International Civil Aviation to provide appropriate security in accordance with their national legislation.

All feedback, recommendations on the application process/design and functionality of a digital licensing system, and confidence concerns surrounding the introduction of a digital licensing system have been shared with the Customer Experience and Modernisation Programme (Cx&M) team delivering this project, to feed into and inform their work. Further feedback can be sent directly to cx@caa.co.uk. The Cx&M Team will be conducting user research in 2026 on possible designs, and opportunities to take part in this research will be posted on the CAA website.

Conclusion

The CAA considers that the proposal to amend the legislation to permit either physical or electronic form of licence or certificate to be issued, in all areas consulted, is supported by the majority of responses.

We are working with the Department for Transport (DfT) to implement the proposed changes by Q2-Q3 2026.

In some areas, we need to develop appropriate Acceptable Means of Compliance (AMC), Guidance Material (GM) and other CAA publications (CAPs) to support the planned changes to regulation. These will be consulted on prior to the introduction of the Statutory Instrument.