Frequently asked questions

For the purposes of European legislation, the term «pilot» may be interpreted as a person who is qualified to perform pilot duties.

That consideration is not limited exclusively to those who already hold a licence, but may also cover those who, during their training, perform flight time as a student pilot on a supervised flight only, provided that they are authorised to perform those duties in accordance with the applicable legislation.

The reference to «pilot» in certain provisions of European legislation must therefore be analysed in the light of the specific context of each requirement and not necessarily as a synonym for a «licence holder».

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.

Yes, provided that the requirements of Article 13.2 of Royal Decree 123/2015 are met. The validation process will be carried out via a ULM school authorised by AESA.

They will come into force on 1 April 2026.

An information circular has been issued on this matter.

An application will be submitted to AESA (until 31/3/2026 included) where the interested party proves, in his flight time record or by certificate issued by an ultralight flight school, 5 hours of flight in the previous 12 months (to the application).

If the qualification expires on the same day 31/3/2026 and the application is submitted later, the completion of a proficiency check with an authorised examiner will be required for its processing.

An application must be submitted to EASA attesting in the last 24 months prior to the expiry of the rating that the pilot has fulfilled any of the following conditions [a) or (b)] in each of the corresponding ratings:

a) have completed at least 12 hours of flight time as pilot-in-command, or of flight time in double command or only under the supervision of an instructor, in the relevant ultra-light aircraft category or, if qualified, in equivalent aircraft of maximum take-off mass at higher take-off; The 12 flight hours referred to above shall include:

• 12 take-offs and 12 landings; y
• The successful completion of 1 flight with a qualified instructor if, in the last 12 months prior to the expiry of the rating, 5 of the 12 flight hours required to demonstrate recent experience have not been completed or if, in the last 24 months, at least 1 flight in the relevant ULM aircraft category has not been completed.

b) Have passed a proficiency check with an authorized examiner. The verification shall be based on the programme for obtaining the rating for the category of ULM aircraft in which it intends to exercise its privileges.

In case of compliance with a) or b), AESA will issue the ULM licenses with the appropriate ratings with indefinite validity (without expiration date).

From that moment, the previous ratings will remain in force (without formality before AESA), if the pilot complies with a) or b) in the last 24 months before the planned flight in ULM.

The following shall be required:

• Successfully passing additional training flights with a qualified instructor until complying with point (a) of the previous question; or
• Pass a proficiency check with an authorized examiner. The verification shall be based on the programme for obtaining the rating for the category of ULM aircraft in which it intends to exercise its privileges.

The above points are under the responsibility of the pilot (without formality before AESA), since they do not already have the authorization of expiration date.

An application for renewal of the rating shall be submitted to EASA, attesting that a proficiency check has been passed with an authorised examiner.

Once the above has been verified, AESA will issue the ULM license with the corresponding qualification without an expiration date. This would maintain a validity of at least 24 months (but no flight will be made in that period).

The flights and tests reflected in the above questions conducted under the supervision of an instructor or an authorised examiner shall be recorded in the pilot's flight time record and signed by the instructor responsible for the flights or by the authorised examiner responsible for the test, clearly identifying the instructor or examiner.

In that sense, AESA may check its compliance at any time by requiring the pilot to show the original of its flight log.