New EASA rules for pilot examiners and licence holders in Europe threaten to turn the examination process into an ineffective, overly-bureaucratic nightmare with no apparent safety benefits.

As part of the new Part-FCL regulation, which entered into force in April 2013, all examiners conducting skill tests (ST), proficiency checks (PC) or Assessments of Competence (AC) on pilots holding a licence issued by a different country (than their own) are to inform the Civil Aviation Authority (CAA) of the country that issued the pilot’s licence about their intention to conduct such a check. Examiners have to provide evidence of their privileges as examiners and to receive a briefing from the CAA on national administrative procedures, requirements for protection of personal data, liability, accident insurance and fees. If this already sounds complicated, the process is in fact even more complex.

Put in practice, Part-FCL.1015, means that examiners have to inform and receive briefings from up to 31 national authorities in one of the 23 official languages of the EU. Anticipating the bureaucratic nightmare, numerous airlines have already advised pilots to transfer their licenses to the operator’s national authority so both pilots and their examiners would reside under the same national authority.

Such advice would have been an acceptable solution, if it wasn’t EASA’s task to “harmonise rules in Europe” in the first place. But now the new rules create an unnecessary load of administrative work and bring additional costs for examiners and pilots. Instead of harmonising the rules in Europe and facilitating mobility across borders, the requirements will rather have the perverse effect of bringing pilots and examiners back to times before JAR where licenses had been dealt with on a national basis with national/individual interpretations.

EASA and national civil aviation authorities have already been alerted about the implications of this regulation, but have not yet declared they would take any steps to address the issue. Until a solution is found, examiners and licence holders will keep watching with disbelief how this de-“harmonisation” unfolds across Europe.

In the meantime, ECA has compiled a list with links to the national administrative procedures to help its members find their way through this bureaucratic forest. This Examiners’ Briefing is regularly updated and available for download.