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Frequently asked questions

Must the 100 flight hours required for the conversion of a third country licence under Implementing Regulation (EU) 2020/723 have been completed after the licence was obtained?

Not necessarily.


The European Union Aviation Safety Agency (EASA) has indicated that the reference to the term ​​​​«pilot» in Article 9(f) of Implementing Regulation (EU) 2020/723 can be interpreted as a person qualified to perform pilot functions.


According to that interpretation, in order to establish the 100 flight hours required by that provision, account could be taken both of:

  • Flight hours completed after obtaining the licence; as
  • Flight hours during training as a student pilot under supervised flight only.


EASA recognises that the wording of Article 9(f) may give rise to different interpretations and considers that both possibilities are compatible with the concept of ‘pilot’ used in that provision.