Consultation on proposed amendments to operational multi-pilot limitations (UK Regulation (EU) No 1178/2011)

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.