General Aviation Pilot Licensing Review - Acceptable Means of Compliance (AMC) and Guidance Material (GM) to the UK Aircrew Regulation

We asked for feedback on a proposal to amend the Acceptable Means of Compliance (AMC) and Guidance Material (GM) to the UK Aircrew Regulation.

The consultation ran from 25 March 2025 to 6 May 2025. To help with the contextual understanding of the consultations, draft implementing rules were included for reference purposes only as per the Opinion and Instruction Documents (OID) submitted to the Department for Transport (DfT).

The implementing rules provided for reference had already been the subject of consultation in Phase 2 of the project. Stakeholders were reminded that while the legislative drafting process continued, the draft implementing rules should not be taken as the final wording of UK law as all amendments to legislation are subject to a drafting process by Government.

We received a total of ninety-five (95) responses to the consultation. We received overwhelming support for the changes relating to partial power loss (PPL(A)) and the use of moving maps in both PPL syllabi, with 85% and 95% agreeing respectively as well as including it in the PPL skill tests, with 86% in support.

We sought comments on the new NPPL(A) to PPL(A) theoretical knowledge bridging requirements. A total of 37 respondents had a view. The majority supported our proposals. A small number felt it was unnecessary as any NPPL SEP/TMG holder would have already completed the PPL(A) exams.

In addition, we sought feedback on the revised crediting of previous flight experience towards a PPL(A). 80% of respondents supported the changes to the AMC for FCL.210.A and 74% supported the changes to the GM.

Some of the comments on the proposed AMC to facilitate the new 35 hour PPL(A) course indicated that this may be unrealistic to achieve as the average hours to complete a PPL(A) is around 55-60 and they felt it may give new student pilots false expectations of saving money.

We also sought feedback on the AMC to FCL.740.A. We saw broad support to all amendments as well as comments on each of them. Some common themes in the comments were:

• Too prescriptive/detailed
• Too similar to a skill test/exam
• Training flight shouldn’t have to be an hour long
• Training flight shouldn’t have to be one flight
• Exemption from the refresher flight for IMC flight tests

Finally, we sought feedback on the AMC and GM to the revised DTO.GEN.240 and ORA.ATO.135. We received majority support with 56% of respondents agreeing. 37% of respondents had no view on the amendments.

We acknowledge the responses and thank the responders for their suggestions. A number of editorial changes were made as a result of feedback, but the AMC / GM was largely published as consulted.

The feedback regarding the AMC to FCL.740.A was reviewed in detail and we may publish further supplementary material in the future. It is emphatically not the intention for the relevant refresher training to become a test, and instructors are expected to exercise discretion in terms of what flight exercises they focus on.

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.  

Conclusion

The CAA has now amended/implemented the proposed AMC and GM into the UK Aircrew Regulation.