Flight crew licensing miscellaneous amendments - (CD 2516FS)
Feedback updated 7 Oct 2025
We asked
The flight crew licensing (FCL) suite of regulations includes Parts 61, 64, 141 and 142 of the Civil Aviation Safety Regulations 1998 (CASR). The FCL regulations are supported by various legislative instruments.
Since the FCL regulations came into force in 2014, we have sought to make continuous ongoing improvements to the regulations to ensure they operate as intended. Many of these have been consolidated into CASA EX32/24 — Flight Crew Licensing and Other Matters (Miscellaneous Exemptions) Instrument 2024.
We intend to incorporate several Parts of CASA EX32/24 and various other exemptions into the regulations.
On 30 July 2025, we opened consultation on Proposed amendments to Parts 61 and 141 of CASR, and Part 5 of CAR – Flight Crew Licensing miscellaneous amendments (CD 2516FS).
The proposed amendments would:
- improve consistency for flight review and proficiency check validity periods, and provide greater flexibility in achieving these requirements
- correct minor errors, such as typographical errors, and unintended consequences.
The consultation closed on 27 August 2025. We analysed each response received and developed this Summary of Consultation to outline the key feedback received and our next steps.
About this consultation
A total of 21 responses were received:
- fourteen (14) respondents identified as representing pilots, including one response from the Australian Airline Pilots’ Association (AusALPA).
- four (4) respondents identified as representing flight instructors and flight examiners.
- two (2) respondents identified as representing Part 141 of CASR operators.
- one respondent identified as 'other', comprising 'Pilots, Flying Instructors, Aerial Work and Part 61, AOC Holders, Chief Pilots'.
Twelve (12) respondents gave permission for their response to be published.
We value the contributions made by all respondents. Where permission to publish has been granted by the respondent, individual consultation responses can be found at Flight crew licensing miscellaneous amendments - (CD 2516FS) - Civil Aviation Safety Authority - Citizen Space.
You said
The consultation included 3 questions, which sought comment on:
- the proposed amendments to incorporate exemptions relating to flight reviews and instrument proficiency checks. This question received 14 responses.
- the proposed amendments to correct errors. This question received 11 responses.
- any additional comments about the proposed policy, including any impact the changes may have on them or their operation. This question received 10 responses.
The analysis of each response indicates that 10 respondents consider the proposed amendments to have positive impact.
Six (6) respondents provided comments that related more broadly to flight crew licensing policy or were otherwise out of scope for the consultation.
Five (5) respondents did not provide any comment to the questions.
Summary of feedback
Proposed amendments would have positive impact
Ten (10) respondents provided feedback indicating that the proposed amendments:
- are sensible and would streamline the regulations by correcting identified errors and inconsistencies
- will formalise existing exemptions, which can be confusing and difficult to find
- would have positive impact for pilots and smaller operators by removing unnecessarily onerous recurrent checks, thus making general aviation and smaller operations more sustainable.
Other comments and suggestions
Six (6) respondents provided comments that related more broadly to flight crew licensing policy or were otherwise out of scope for the consultation. These comments:
- suggested further alignment of the validity periods of flight reviews for operational ratings and type and class ratings, and to extend the validity period of the low-level rating flight review to the end of the 24th month, rather than to the day of the review.
- queried whether the 24-month validity period for the low-level rating may be too long to maintain adequate competency for low-level flying.
- suggested changes to the type rating training endorsement to make this endorsement no longer type-specific, which would enable flight instructor rating and simulator instructor rating holders to conduct training for all type-rated aircraft the instructor is authorised to operate.
- suggested recognition of flight reviews conducted by a foreign ICAO-compliant NAA, where the flight review meets CASA's standards.
- suggested introducing a weight limit where aircraft below 8,618 kg should be treated the same as multi-engine aeroplane class-rated aircraft.
- suggested to allow operator proficiency checks to satisfy a pilot's instrument proficiency check requirements on different aircraft types.
- suggested simplifying the CASRs.
We did
Aligning flight review validity periods
We are currently progressing work to further align the validity periods of flight reviews for operational ratings and type and class ratings, and to extend the validity period of the low-level rating flight review to the end of the 24th month, rather than to the day of the review. We will consult on any proposed changes through the CASA Consultation Hub.
Concern about low-level rating flight review validity period
We acknowledge that one respondent indicated concern that the 24 month validity period for the low-level rating may be too long to maintain adequate competency for low-level flying.
The potential impact on aviation safety was considered when the underpinning exemption was first prepared more than 10 years ago, at each subsequent remake of the exemption, and when the proposed amendment was developed.
We consider that the risk profile for low-level operations would not deteriorate due to the proposal as most operators conduct annual checks of their pilots and the safety performance of pilots conducting low-level operations has not been identified as problematic due to the 24 month flight review requirement. It is noted that the previous regulations did not include regular checks of competency like the CASR provisions, which also include safety controls for low-level operations under Part 138 of CASR. The amendments also include an additional limitation for pilots who conduct higher-risk aerial mustering operations to ensure an acceptable level of aviation safety is preserved.
Other changes to flight crew licensing policy
We are not currently contemplating changes to the type rating training endorsement to make this endorsement no longer type-specific. We are aware of industry views on this matter and will progress any further work as resources permit.
We are not currently contemplating changes to the recognition of flight reviews conducted overseas, the introduction of any new weight limit, or for an operator proficiency check to satisfy a pilot's instrument proficiency check requirements on different aircraft.
We invite proposals and supporting evidence to improve the rules through the following link: Submit improvement to the rules | Civil Aviation Safety Authority.
CASA's GA Workplan also includes an action to scope a review of general aviation elements of Part 61 of CASR against the original policy objectives. Other changes to flight crew licensing policy might be contemplated in that scoping activity.
Next steps
Noting the support indicated for the proposed amendments, we will progress making the amendment instrument.
We will continue to develop guidance material and supporting documentation to explain the operation and intent of the amendments, and to ensure a smooth transition.
More broadly, we acknowledge that this regulation package is limited and that a range of exemption instruments will continue to operate.
Published responses
View submitted responses where consent has been given to publish the response.
Overview
We want your feedback on proposed amendments that aim to improve consistency for flight review and proficiency check validity periods and provide greater flexibility in achieving these requirements.
The amendments would also incorporate longstanding exemptions which support the flight crew licensing (FCL) regulations, and correct minor errors.
Legislation
The amendments apply to Parts 61 and 141 of the Civil Aviation Safety Regulations 1998 (CASR) and Part 5 of the Civil Aviation Regulations 1988 (CAR).
Since the FCL regulations came into force in 2014, CASA has been working to improve them so they work as intended. Many of these improvements were included in CASA EX32/24.
The proposed amendments would incorporate the effect of several Parts of CASA EX32/24 (specifically Parts 4, 5, 15 and 17) and CASA EX76/24 into the FCL regulations, and correct other identified errors and unintended consequences.
Summary of proposed amendments
As an overview, the amendments relate to:
- Flight reviews: provide circumstances in which the holder of an aircraft class or type rating is taken to have a valid flight review for the relevant rating
- Proficiency checks: provide circumstances in which the holder of a pilot type rating is taken to have a valid instrument proficiency check for the aircraft type covered by the rating
- Low-level rating updates:
- remove the recent experience rule for the low-level rating
- extend the low-level rating flight review validity period from 12 months to 24 months
- add a condition on the exercise of the privileges of the aerial mustering endorsement
- Remove outdated definitions: delete the definition of published lowest safe altitude and the related note
- Recreational pilot licence: clarify what recreational pilots can do, matching longstanding policy
- Instructor and operator offences: correct some offence rules so instructors and Part 141 operators are not penalised when pilots don’t meet certain aeronautical experience requirements
- Balloon licensing: update references to private pilot (balloon) permits issued by CASA, to ensure that pilots can continue to apply for and be qualified for a commercial pilot (balloon) licence
- Fix errors and remove incorrect references.
For more detail on the proposed amendments, see the Summary of proposed change and the accompanying explanation document linked below.
Previous consultations
Most of the amendments incorporate the effect of longstanding exemption instruments into the CASR. These were previously subject to consultation with industry including the FCL technical working group (TWG).
Amendments to correct minor errors such as typographical errors have not been subject to previous consultation.
Why your views matter
Your feedback will help ensure that the proposed amendments are suitable and will work as intended. It will also help us to target our development of guidance material and implementation activities. We will make sure that the changes are clearly explained, and that adequate guidance is provided to industry and CASA staff.
Please submit your comments using the survey link on this page.
If you are unable to provide feedback via the survey link, please email regulatoryconsultation@casa.gov.au for advice.
Documents for review
All documents related to this consultation are attached in the ‘Related’ section at the bottom of the overview page. They are:
- Summary of proposed change on CD 2516FS, which provides background on the proposed amendments
- Explanation document – Civil Aviation Safety Amendment (Minor Changes) Regulations 2025, which includes the proposed amendments and a side-by-side explanation of the intent of each amendment, and how they will work
- Exposure draft – Civil Aviation Safety Amendment (Minor Changes) Regulations 2025, which includes the proposed amendments
- MS Word copy of online consultation for ease of distribution and feedback within your organisation.
What happens next
At the end of the response period, we will:
- review all comments received
- make responses publicly available on the consultation hub (unless you request your submission remain confidential)
- publish a Summary of Consultation which summarises the feedback received and outlines any intended changes and next steps.
All comments received on the proposed amendments will be considered. Relevant feedback that improves upon the proposed amendments will be incorporated into the final instrument.
Audiences
- Balloon pilots
- Flight instructors and flight examiners
- Flight training operators
- Flight training organisations
- Hot air balloon operators
- Instructors and flight examiners
- Part 141 of CASR operator
- Part 142 of CASR operator
- Pilots
- Sport and recreational balloon owners and pilots
Interests
- Flight training
- Licensing
Share
Share on Twitter Share on Facebook