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What are the requirements for a frozen ATPL?
By the PilotinQ editorial teamUpdated 25 Oct 2026
THE ANSWERConfirmed60 sec read

A frozen ATPL comprises passed ATPL theory exams, a CPL with instrument rating and multi-engine rating, and an MCC certificate; the full ATPL(A) requires an MPL, or a CPL(A) with a multi-engine IR and MCC instruction, and at least 1,500 hours of flight time.21

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  • Primary source: Easy Access Rules for Aircrew (Regulation (EU) No 1178/2011), FCL.02521
Updated 25 Oct 2026All 21 sources →

The route, step by step

The requirements at a glance
Vacancies often ask for a valid ICAO CPL with instrument rating and a frozen ATPL from a recognised flight school. When converting a foreign (ICAO) ATPL into an EASA ATPL, the same experience requirements apply as for training within EASA. According to a student in 2025, on the modular route after the ATPL theory you can choose between IR plus CPL first, or the whole frozen ATPL package in one go. A frozen ATPL comprises completed ATPL theory (13 subjects), a CPL with Instrument Rating and Multi-Engine Rating, and an MCC certificate. A CPL alone is not enough for an airline job; in practice the Instrument Rating, Multi-Engine Rating, ATPL theory and MCC are needed for a frozen ATPL.181619
Medical requirements
A Class 1 medical is a common requirement for a frozen ATPL.513
Exceptions and borderline cases
The ATPL is the highest pilot licence you can obtain, allowing a pilot to be responsible as captain on all types of flights, provided the right ratings are held. Although an ATPL does not explicitly require work experience as a first officer, in practice that is what it comes down to, because there is no other realistic way to build the minimum of 500 hours in multi-crew aircraft. A frozen ATPL is converted into a full ATPL after reaching 1,500 flying hours, of which at least 500 multi-crew. Only after this conversion may a pilot fly as captain. The theory of a frozen ATPL does not expire as long as the CPL/IR is kept current, because a pass in the ATPL(A) theory exams remains valid for 7 years from the last validity date of the IR(A) on the CPL(A).11921
What pilots experienced
Pilots report that the theory of a frozen ATPL does not expire as long as you keep the CPL/IR current.3
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TRAINING AND LICENCES

What are the requirements for a frozen ATPL?

By the PilotinQ editorial teamUpdated 25 Oct 2026
THE ANSWERConfirmed60 sec read

A frozen ATPL comprises passed ATPL theory exams, a CPL with instrument rating and multi-engine rating, and an MCC certificate; the full ATPL(A) requires an MPL, or a CPL(A) with a multi-engine IR and MCC instruction, and at least 1,500 hours of flight time.21

Was this useful?
HOW SURE IS THIS
  • Primary source: Easy Access Rules for Aircrew (Regulation (EU) No 1178/2011), FCL.02521
Updated 25 Oct 2026All 21 sources →

Step by step

The requirements at a glance
Vacancies often ask for a valid ICAO CPL with instrument rating and a frozen ATPL from a recognised flight school. When converting a foreign (ICAO) ATPL into an EASA ATPL, the same experience requirements apply as for training within EASA. According to a student in 2025, on the modular route after the ATPL theory you can choose between IR plus CPL first, or the whole frozen ATPL package in one go. A frozen ATPL comprises completed ATPL theory (13 subjects), a CPL with Instrument Rating and Multi-Engine Rating, and an MCC certificate. A CPL alone is not enough for an airline job; in practice the Instrument Rating, Multi-Engine Rating, ATPL theory and MCC are needed for a frozen ATPL.181619
Medical requirements
A Class 1 medical is a common requirement for a frozen ATPL.513
Exceptions and borderline cases
The ATPL is the highest pilot licence you can obtain, allowing a pilot to be responsible as captain on all types of flights, provided the right ratings are held. Although an ATPL does not explicitly require work experience as a first officer, in practice that is what it comes down to, because there is no other realistic way to build the minimum of 500 hours in multi-crew aircraft. A frozen ATPL is converted into a full ATPL after reaching 1,500 flying hours, of which at least 500 multi-crew. Only after this conversion may a pilot fly as captain. The theory of a frozen ATPL does not expire as long as the CPL/IR is kept current, because a pass in the ATPL(A) theory exams remains valid for 7 years from the last validity date of the IR(A) on the CPL(A).11921
What pilots experienced
Pilots report that the theory of a frozen ATPL does not expire as long as you keep the CPL/IR current.3
SOURCES
  1. Pilot community experience20 discussions · 2004-2026
  2. 21Easy Access Rules for Aircrew (Regulation (EU) No 1178/2011), FCL.025EASA
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