FAA 61.31 or EASA Part-FCL: how type ratings differ and how to move between them

Both systems end with a pilot qualified on one aircraft type, but they get there differently. Here is what each rulebook requires, how long the rating lasts and what validation and conversion actually involve.

By the PilotinQ editorial team · based on 24 sourcesPublished 8 Nov 2026, 11:43 UTC · 6 min read
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The flight deck of a full flight simulator with a coastal runway visible on the outside visual system
The flight deck of a Thales full flight simulator built for the SSJ100 programme (archive image). Photo: SuperJet International via Wikimedia Commons · CC BY-SA 2.0
IN SHORT
  • 14 CFR 61.31 requires a type rating for pilots in command of large aircraft, turbojets and powered-lift.1
  • EASA FCL.700 requires a valid and appropriate class or type rating for anyone acting as pilot, including first officers.2
  • An EASA type rating lasts one year and revalidation needs a proficiency check or EBT assessment within the last three months.1415
  • Under Regulation (EU) 2020/723, adding a valid third-country aeroplane type rating to a Part-FCL licence needs 500 hours in type, the prerequisites, current flying practice and a skill test.21

A pilot licence does not let you fly an airliner. Both the FAA and EASA require a type rating for the specific aircraft, but the US rule starts from the kind of aircraft while the European rule starts from the licence holder. This guide compares the two rulebooks and sets out what validation and conversion between them involve. For the EASA course itself, see the separate answer on how a type rating works.

Who needs one

FAA

14 CFR 61.31(a) requires a type rating for a person acting as pilot in command of large aircraft, turbojet-powered airplanes, powered-lift and other aircraft the Administrator specifies through type certificate procedures1. 61.31(b) allows the FAA to authorise flights without a type rating for up to 60 days where compliance is impracticable and an equivalent level of safety is achieved. These must be ferry, training or test flights or practical tests, within the United States, with essential crew only and no compensation unless it is payment for using the aircraft for training or a practical test1.

EASA

FCL.700 is written around the holder of a licence: a pilot may act as pilot of an aircraft only with a valid and appropriate class or type rating, with narrow exceptions such as flight instruction or taking a skill test2. Which aircraft share one rating is decided by EASA's class and type rating lists2. Moving to another variant within a rating needs differences training or familiarisation under FCL.7103.

Second-in-command is treated differently

The clearest divergence is the right-hand seat. The FAA text in 61.31(a) applies to the pilot in command. A second-in-command under 61.55 needs at least a private certificate with the right category and class, an instrument rating or privilege for IFR flight plus a pilot type rating unless the flight is domestic within US airspace4. 61.55 also provides an SIC type rating marked "SIC Privileges Only", issued after familiarisation training or an approved SIC programme, with no practical test4.

EASA has no equivalent of the US SIC Privileges Only rating for first officers. FCL.700 applies to acting as pilot, so a first officer needs the type rating. FCL.720.A does allow a member state to issue a restricted rating for cruise relief co-pilots above FL200, provided the two other crew hold full ratings25.

Prerequisites and training

FAA

Under 61.63(d) an applicant must hold or concurrently obtain an appropriate instrument rating, have an instructor's endorsement attesting competence at the airline transport pilot certification level and pass the practical test at that level in actual or simulated instrument conditions6. No additional knowledge test is needed if the applicant already holds an airplane, rotorcraft, powered-lift or airship rating on the certificate6. 61.157 applies when the type rating is added to, or completed with, an airline transport certificate7. Employees of part 121 and part 135 operators can use the operator's approved training programme instead of the individual instructor endorsement route67.

EASA

FCL.720.A(b) requires, before a first multi-pilot type rating course, at least 70 hours as pilot in command in aeroplanes, a multi-engine instrument rating held now or previously, passes in the ATPL(A) theoretical knowledge examinations, an MCC course unless combined with the type rating or covered by an exception, plus the advanced UPRT course in FCL.745.A subject to limited exceptions58. Students on an MPL course are exempt from that list5. The training must take place at an approved training organisation and include the mandatory elements in the type's operational suitability data9. A multi-pilot type requires a written examination of at least 100 multiple-choice questions and a skill test under Appendix 9, passed within six months of starting the course and within six months before the application9.

Experienced pilots can use a zero flight time course under FCL.730.A: at least 1,500 hours or 250 route sectors for a Level C simulator, or 500 hours or 100 route sectors for Level D, on a multi-pilot turbojet or qualifying turbo-prop10. Cruise relief co-pilots follow hours-only thresholds of 1,500 or 750 hours and a switch between turbo-prop and turbo-jet needs additional simulator training10. Operators must then start the pilot on line flying under supervision within 21 days of the skill test, or after appropriate operator training, with six take-offs and landings in an FSTD under a type rating instructor in the same period unless operational suitability data reduces them11. The first four take-offs and landings of line flying are flown in the aeroplane with an instructor11.

How long the rating lasts

FAA

A certificate issued without an expiry date is valid until surrendered, suspended or revoked12. A pilot in command of a multi-crew or turbojet aircraft outside operations under part 121, 125, 133, 135, 137 or subpart K of part 91 still needs a proficiency check within 12 calendar months in such an aircraft and within 24 calendar months in the particular type13.

EASA

A type rating is valid for one year14. Revalidation needs a proficiency check within the three months before expiry, or an evidence-based training assessment, plus either 10 route sectors or one route sector with an examiner15. A commercial air transport pilot who combines the operator proficiency check with the licence check is exempt from the sector requirement15. An expired rating is renewed after an assessment and, if the organisation requires it, refresher training, followed by a proficiency check14.

Validation and conversion

Moving from one system to the other is where most assumptions go wrong. Commission Delegated Regulation (EU) 2020/723 now holds the EU rules for licences from third countries. Its Article 11 deleted the old Annex III to Regulation 1178/20111617.

Validation lets a pilot use a third-country licence for a period. Under Article 4 a competent authority may validate a licence issued in line with ICAO Annex 1 for no more than one year, with one extension of up to one year if the pilot has applied for or is training towards a Part-FCL licence18. For commercial air transport and other commercial activities, Article 5 requires the applicant to complete the type or class rating revalidation requirements as a skill test, show knowledge of the operational requirements and Part-FCL, demonstrate language proficiency, hold a Class 1 medical and meet the experience thresholds in the regulation's annex19.

Conversion gives a Part-FCL licence. Article 9 allows a third-country licence to be converted into a Part-FCL PPL with a single-pilot class or type rating, even from a CPL or ATPL, subject to a written examination in Air Law and Human Performance, the relevant skill test, the Subpart H requirements for the rating, a medical certificate, language proficiency and the other minimum requirements in that article20. Article 3 separately lets member states give full credit for the training course requirements before the theoretical knowledge examinations and skill test for ATPL holders who meet the Subpart F experience requirements and hold a valid type rating for the aircraft used in the ATPL skill test16.

A valid third-country type rating can be added to a Part-FCL licence under Article 10 if the applicant meets the Part-FCL prerequisites, passes the relevant skill test, is in current flying practice and has at least 500 hours as a pilot in that type for aeroplanes21. The EU-US bilateral does not solve this for airline pilots: EASA describes the Annexes signed on 19 November 2020 as extending the agreement to private pilot licence conversion, while Sweden's aviation authority says conversion under Annex 3 cannot go higher than a PPL(A)2223. In the other direction, 61.75 lets a foreign licence holder get a US private pilot certificate on that basis, with the ratings limited to private privileges24. That certificate depends on the foreign licence staying valid12.

What to check before you plan a move

Each rulebook answers whether you are qualified, not who pays. Before committing, confirm which national authority will process your application, whether your hours in type reach the Article 10 threshold and whether an operator will validate your licence or expect a full Part-FCL issue. FAA and EASA rules on simulator credit and operator conversion courses are set out in different documents, so a course accepted in one system may not transfer automatically.

About:RegulationFAAEASA
KEEP READINGANSWERHow does a type rating work?ANSWERATPL or MPL?ANSWERFrozen ATPL requirementsNEWSFAA certifies the 737 MAX 10: differences training for pilotsAsk your own pilot question

Sources

  1. 1eCFR · 14 CFR 61.31 Type rating requirements, additional training, and authorization requirements5 Nov 2026
  2. 2EASA · FCL.700 Circumstances in which class or type ratings are required (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  3. 3EASA · FCL.710 Class and type ratings, variants (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  4. 4Cornell LII · 14 CFR 61.55 Second-in-command qualifications
  5. 5EASA · FCL.720.A Experience requirements and prerequisites for the issue of class or type ratings, aeroplanes (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  6. 6eCFR · 14 CFR 61.63 Additional aircraft ratings5 Nov 2026
  7. 7eCFR · 14 CFR 61.157 Flight proficiency5 Nov 2026
  8. 8EASA · FCL.745.A Advanced UPRT course, aeroplanes (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  9. 9EASA · FCL.725 Requirements for the issue of class and type ratings (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  10. 10EASA · FCL.730.A Specific requirements for pilots undertaking a zero flight time type rating course (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  11. 11EASA · ORO.FC.220 Operator conversion training and checking (Easy Access Rules for Air Operations, revision 24, March 2026)1 Mar 2026
  12. 12eCFR · 14 CFR 61.19 Duration of pilot and instructor certificates and privileges5 Nov 2026
  13. 13eCFR · 14 CFR 61.58 Pilot-in-command proficiency check5 Nov 2026
  14. 14EASA · FCL.740 Validity and renewal of class and type ratings (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  15. 15EASA · FCL.740.A Revalidation of class and type ratings, aeroplanes (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  16. 16EUR-Lex via EASA · Regulation (EU) 2020/723, Article 3, Acceptance of licences from third countries (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  17. 17EUR-Lex via EASA · Regulation (EU) 2020/723, Article 11, Amendments to Regulation (EU) No 1178/2011 (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  18. 18EUR-Lex via EASA · Regulation (EU) 2020/723, Article 4, General provisions for validation of licences (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  19. 19EUR-Lex via EASA · Regulation (EU) 2020/723, Article 5, Pilot licences for commercial air transport (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  20. 20EUR-Lex via EASA · Regulation (EU) 2020/723, Article 9, Conditions for conversion of licences (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  21. 21EUR-Lex via EASA · Regulation (EU) 2020/723, Article 10, Conditions for acceptance of class and type ratings (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  22. 22EASA · EU - USA Bilateral Agreement
  23. 23Transportstyrelsen · FAA licence conversions, BASA agreement
  24. 24Cornell LII · 14 CFR 61.75 Private pilot certificate issued on the basis of a foreign pilot license
CHANGES8 Nov 2026, 11:43 UTC · PublishedSpotted an error? Tell us, corrections are noted under the article.Every fact is checked against the sources listed above. How we work

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FAA 61.31 or EASA Part-FCL: how type ratings differ and how to move between them

Both systems end with a pilot qualified on one aircraft type, but they get there differently. Here is what each rulebook requires, how long the rating lasts and what validation and conversion actually involve.

By the PilotinQ editorial team · based on 24 sourcesPublished 8 Nov 2026, 11:43 UTC · 6 min read
The flight deck of a full flight simulator with a coastal runway visible on the outside visual system
The flight deck of a Thales full flight simulator built for the SSJ100 programme (archive image). Photo: SuperJet International via Wikimedia Commons · CC BY-SA 2.0
IN SHORT
  • 14 CFR 61.31 requires a type rating for pilots in command of large aircraft, turbojets and powered-lift.1
  • EASA FCL.700 requires a valid and appropriate class or type rating for anyone acting as pilot, including first officers.2
  • An EASA type rating lasts one year and revalidation needs a proficiency check or EBT assessment within the last three months.1415
  • Under Regulation (EU) 2020/723, adding a valid third-country aeroplane type rating to a Part-FCL licence needs 500 hours in type, the prerequisites, current flying practice and a skill test.21

A pilot licence does not let you fly an airliner. Both the FAA and EASA require a type rating for the specific aircraft, but the US rule starts from the kind of aircraft while the European rule starts from the licence holder. This guide compares the two rulebooks and sets out what validation and conversion between them involve. For the EASA course itself, see the separate answer on how a type rating works.

Who needs one

FAA

14 CFR 61.31(a) requires a type rating for a person acting as pilot in command of large aircraft, turbojet-powered airplanes, powered-lift and other aircraft the Administrator specifies through type certificate procedures1. 61.31(b) allows the FAA to authorise flights without a type rating for up to 60 days where compliance is impracticable and an equivalent level of safety is achieved. These must be ferry, training or test flights or practical tests, within the United States, with essential crew only and no compensation unless it is payment for using the aircraft for training or a practical test1.

EASA

FCL.700 is written around the holder of a licence: a pilot may act as pilot of an aircraft only with a valid and appropriate class or type rating, with narrow exceptions such as flight instruction or taking a skill test2. Which aircraft share one rating is decided by EASA's class and type rating lists2. Moving to another variant within a rating needs differences training or familiarisation under FCL.7103.

Second-in-command is treated differently

The clearest divergence is the right-hand seat. The FAA text in 61.31(a) applies to the pilot in command. A second-in-command under 61.55 needs at least a private certificate with the right category and class, an instrument rating or privilege for IFR flight plus a pilot type rating unless the flight is domestic within US airspace4. 61.55 also provides an SIC type rating marked "SIC Privileges Only", issued after familiarisation training or an approved SIC programme, with no practical test4.

EASA has no equivalent of the US SIC Privileges Only rating for first officers. FCL.700 applies to acting as pilot, so a first officer needs the type rating. FCL.720.A does allow a member state to issue a restricted rating for cruise relief co-pilots above FL200, provided the two other crew hold full ratings25.

Prerequisites and training

FAA

Under 61.63(d) an applicant must hold or concurrently obtain an appropriate instrument rating, have an instructor's endorsement attesting competence at the airline transport pilot certification level and pass the practical test at that level in actual or simulated instrument conditions6. No additional knowledge test is needed if the applicant already holds an airplane, rotorcraft, powered-lift or airship rating on the certificate6. 61.157 applies when the type rating is added to, or completed with, an airline transport certificate7. Employees of part 121 and part 135 operators can use the operator's approved training programme instead of the individual instructor endorsement route67.

EASA

FCL.720.A(b) requires, before a first multi-pilot type rating course, at least 70 hours as pilot in command in aeroplanes, a multi-engine instrument rating held now or previously, passes in the ATPL(A) theoretical knowledge examinations, an MCC course unless combined with the type rating or covered by an exception, plus the advanced UPRT course in FCL.745.A subject to limited exceptions58. Students on an MPL course are exempt from that list5. The training must take place at an approved training organisation and include the mandatory elements in the type's operational suitability data9. A multi-pilot type requires a written examination of at least 100 multiple-choice questions and a skill test under Appendix 9, passed within six months of starting the course and within six months before the application9.

Experienced pilots can use a zero flight time course under FCL.730.A: at least 1,500 hours or 250 route sectors for a Level C simulator, or 500 hours or 100 route sectors for Level D, on a multi-pilot turbojet or qualifying turbo-prop10. Cruise relief co-pilots follow hours-only thresholds of 1,500 or 750 hours and a switch between turbo-prop and turbo-jet needs additional simulator training10. Operators must then start the pilot on line flying under supervision within 21 days of the skill test, or after appropriate operator training, with six take-offs and landings in an FSTD under a type rating instructor in the same period unless operational suitability data reduces them11. The first four take-offs and landings of line flying are flown in the aeroplane with an instructor11.

How long the rating lasts

FAA

A certificate issued without an expiry date is valid until surrendered, suspended or revoked12. A pilot in command of a multi-crew or turbojet aircraft outside operations under part 121, 125, 133, 135, 137 or subpart K of part 91 still needs a proficiency check within 12 calendar months in such an aircraft and within 24 calendar months in the particular type13.

EASA

A type rating is valid for one year14. Revalidation needs a proficiency check within the three months before expiry, or an evidence-based training assessment, plus either 10 route sectors or one route sector with an examiner15. A commercial air transport pilot who combines the operator proficiency check with the licence check is exempt from the sector requirement15. An expired rating is renewed after an assessment and, if the organisation requires it, refresher training, followed by a proficiency check14.

Validation and conversion

Moving from one system to the other is where most assumptions go wrong. Commission Delegated Regulation (EU) 2020/723 now holds the EU rules for licences from third countries. Its Article 11 deleted the old Annex III to Regulation 1178/20111617.

Validation lets a pilot use a third-country licence for a period. Under Article 4 a competent authority may validate a licence issued in line with ICAO Annex 1 for no more than one year, with one extension of up to one year if the pilot has applied for or is training towards a Part-FCL licence18. For commercial air transport and other commercial activities, Article 5 requires the applicant to complete the type or class rating revalidation requirements as a skill test, show knowledge of the operational requirements and Part-FCL, demonstrate language proficiency, hold a Class 1 medical and meet the experience thresholds in the regulation's annex19.

Conversion gives a Part-FCL licence. Article 9 allows a third-country licence to be converted into a Part-FCL PPL with a single-pilot class or type rating, even from a CPL or ATPL, subject to a written examination in Air Law and Human Performance, the relevant skill test, the Subpart H requirements for the rating, a medical certificate, language proficiency and the other minimum requirements in that article20. Article 3 separately lets member states give full credit for the training course requirements before the theoretical knowledge examinations and skill test for ATPL holders who meet the Subpart F experience requirements and hold a valid type rating for the aircraft used in the ATPL skill test16.

A valid third-country type rating can be added to a Part-FCL licence under Article 10 if the applicant meets the Part-FCL prerequisites, passes the relevant skill test, is in current flying practice and has at least 500 hours as a pilot in that type for aeroplanes21. The EU-US bilateral does not solve this for airline pilots: EASA describes the Annexes signed on 19 November 2020 as extending the agreement to private pilot licence conversion, while Sweden's aviation authority says conversion under Annex 3 cannot go higher than a PPL(A)2223. In the other direction, 61.75 lets a foreign licence holder get a US private pilot certificate on that basis, with the ratings limited to private privileges24. That certificate depends on the foreign licence staying valid12.

What to check before you plan a move

Each rulebook answers whether you are qualified, not who pays. Before committing, confirm which national authority will process your application, whether your hours in type reach the Article 10 threshold and whether an operator will validate your licence or expect a full Part-FCL issue. FAA and EASA rules on simulator credit and operator conversion courses are set out in different documents, so a course accepted in one system may not transfer automatically.

About:RegulationFAAEASA
KEEP READINGANSWERHow does a type rating work?ANSWERATPL or MPL?ANSWERFrozen ATPL requirementsNEWSFAA certifies the 737 MAX 10: differences training for pilotsAsk your own pilot question
PREPARETry an aptitude lite testStart practising

Sources

  1. 1eCFR · 14 CFR 61.31 Type rating requirements, additional training, and authorization requirements5 Nov 2026
  2. 2EASA · FCL.700 Circumstances in which class or type ratings are required (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  3. 3EASA · FCL.710 Class and type ratings, variants (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  4. 4Cornell LII · 14 CFR 61.55 Second-in-command qualifications
  5. 5EASA · FCL.720.A Experience requirements and prerequisites for the issue of class or type ratings, aeroplanes (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  6. 6eCFR · 14 CFR 61.63 Additional aircraft ratings5 Nov 2026
  7. 7eCFR · 14 CFR 61.157 Flight proficiency5 Nov 2026
  8. 8EASA · FCL.745.A Advanced UPRT course, aeroplanes (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  9. 9EASA · FCL.725 Requirements for the issue of class and type ratings (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  10. 10EASA · FCL.730.A Specific requirements for pilots undertaking a zero flight time type rating course (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  11. 11EASA · ORO.FC.220 Operator conversion training and checking (Easy Access Rules for Air Operations, revision 24, March 2026)1 Mar 2026
  12. 12eCFR · 14 CFR 61.19 Duration of pilot and instructor certificates and privileges5 Nov 2026
  13. 13eCFR · 14 CFR 61.58 Pilot-in-command proficiency check5 Nov 2026
  14. 14EASA · FCL.740 Validity and renewal of class and type ratings (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  15. 15EASA · FCL.740.A Revalidation of class and type ratings, aeroplanes (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  16. 16EUR-Lex via EASA · Regulation (EU) 2020/723, Article 3, Acceptance of licences from third countries (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  17. 17EUR-Lex via EASA · Regulation (EU) 2020/723, Article 11, Amendments to Regulation (EU) No 1178/2011 (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  18. 18EUR-Lex via EASA · Regulation (EU) 2020/723, Article 4, General provisions for validation of licences (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  19. 19EUR-Lex via EASA · Regulation (EU) 2020/723, Article 5, Pilot licences for commercial air transport (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  20. 20EUR-Lex via EASA · Regulation (EU) 2020/723, Article 9, Conditions for conversion of licences (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  21. 21EUR-Lex via EASA · Regulation (EU) 2020/723, Article 10, Conditions for acceptance of class and type ratings (Easy Access Rules for Aircrew, revision from October 2026)16 Oct 2026
  22. 22EASA · EU - USA Bilateral Agreement
  23. 23Transportstyrelsen · FAA licence conversions, BASA agreement
  24. 24Cornell LII · 14 CFR 61.75 Private pilot certificate issued on the basis of a foreign pilot license
CHANGES8 Nov 2026, 11:43 UTC · PublishedSpotted an error? Tell us, corrections are noted under the article.Every fact is checked against the sources listed above. How we work

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