PICUS Under EASA: Logging, ATPL(A) Credit and Airline Applications
An authoritative guide for European pilots on how PICUS is recorded under FCL.050, what certification is required, how it counts towards an ATPL(A), and how it should be presented during airline selection.
PICUS is usually straightforward while it is being flown. It often becomes less straightforward several years later, when the same hours need to support an ATPL(A) application, command progression or an airline recruitment form.
The reason is simple: qualifying pilot-in-command under supervision, or PICUS, is entered as PIC within the EASA flight-time recording framework, but the underlying experience must remain identifiable as PICUS. Part-FCL may credit that time towards specific licensing requirements, while an airline may ask for PIC, command time and PICUS as separate figures.
All of those treatments can be correct.
The key is to separate three questions:
How should PICUS be recorded in the logbook?
How can it be credited towards a licence?
How should it be reported to an airline or operator?
This guide addresses each question and explains how to preserve enough detail in your flight-time record to answer them confidently.
For a wider review of preparing your records before airline selection, see our EASA pilot logbook guide for airline assessments.
PICUS Under EASA: The Essential Answer
Under Part-FCL, PICUS means a co-pilot performing the duties and functions of the pilot-in-command under the supervision of the designated PIC.
Qualifying PICUS may be recorded as PIC when the conditions in AMC1 FCL.050 are met. The PICUS time must be countersigned by the PIC, and its supervised-command nature should remain clear within the record.
PICUS is also expressly recognised within the ATPL(A) experience requirements. It can therefore be both validly recorded as PIC and credited towards an ATPL(A).
That does not mean every airline must treat it as ordinary command experience during recruitment.
Recording, licensing credit and recruitment reporting are three separate exercises.
What Does PICUS Mean Under EASA Part-FCL?
Part-FCL defines pilot-in-command under supervision as a co-pilot who performs, under the supervision of the pilot-in-command, the duties and functions of a pilot-in-command.
That definition is narrower than simply being the pilot flying on a sector.
A normal co-pilot flight does not become PICUS merely because the first officer carried out the take-off, approach and landing. Nor does a flight automatically qualify as PICUS because the PIC did not physically intervene.
Under AMC1 FCL.050, the method of supervision must be acceptable to the competent authority. The co-pilot must also have carried out the duties and functions of PIC in such a way that intervention by the PIC in the interest of safety was not required.
PICUS should therefore arise from a genuine and properly documented supervised-command arrangement. It should not be created retrospectively by reviewing ordinary PF sectors and deciding that they appear similar to command flying.
PilotAudit review note: Who manipulated the controls and who performed the regulated function are not necessarily the same question. PF/PM information alone is not sufficient evidence that a flight qualified as PICUS.
How Is PICUS Logged Under EASA FCL.050?
The legal starting point is FCL.050 — Recording of flight time.
FCL.050 requires a pilot to keep a reliable record of all flights flown in a form and manner established by the competent authority. AMC1 FCL.050 provides EASA’s accepted framework for the content and format of that record.
For PICUS, the AMC contains two important elements.
First, it provides that a co-pilot acting as PICUS on an aircraft for which more than one pilot is required may log the qualifying flight time as PIC, provided that the PICUS time is countersigned by the PIC.
Second, it states that the supervision method must be acceptable to the competent authority and that the co-pilot must have carried out the duties and functions of PIC without requiring intervention by the PIC in the interest of safety.
PICUS is entered as PIC
The EASA logbook instructions provide that PIC, SPIC and PICUS are entered in the PIC pilot-function column. They also require SPIC and PICUS time to be identified and certified in the remarks column.
This is why a PIC-column total does not necessarily represent one single type of operational experience.
For example, a pilot showing 800 hours in the PIC column may have accumulated that figure through a combination of actual PIC and qualifying PICUS. Both may have been entered correctly, but the underlying categories still need to be distinguishable.
A useful flight-time record should therefore allow you to answer both of these questions:
How much time is recorded as PIC?
How much of that recorded PIC is PICUS?
If an electronic system combines the categories in its regulatory report, it should still retain enough underlying data for the PICUS subset to be identified separately.
What Certification Is Required for PICUS?
AMC1 FCL.050 states that qualifying PICUS time must be countersigned by the PIC.
The associated logbook instructions require the name and signature of the PIC in the remarks column when the pilot is recording PICUS.
For a paper logbook, that evidence should remain visible and traceable in the original record.
For an electronic record, the practical method of certification can depend on the system used and the form accepted by the competent authority. FCL.050 leaves the acceptable form and manner of the record to that authority, so pilots should avoid assuming that every national authority applies identical administrative procedures to electronic signatures or imported evidence.
If you intend to rely on PICUS for the issue of a licence, make sure you understand what the authority handling your application expects.
A summary total by itself may not demonstrate that the underlying PICUS was properly recorded and certified.
PICUS vs PIC: What Is the Difference?
The pilot-in-command is the pilot designated as being in command and charged with the safe conduct of the flight.
A pilot flying as PICUS remains a co-pilot who is performing the duties and functions of PIC under supervision. The designated PIC remains responsible for the flight.
Qualifying PICUS can be entered as PIC for flight-time recording purposes, but that does not change the operational role that existed during the flight.
This is the distinction that must be preserved:
PICUS can be recorded within PIC without becoming indistinguishable from actual command.
That distinction matters particularly when an airline asks for actual PIC, command experience on type or PIC excluding PICUS.
PICUS vs SPIC: They Are Not the Same
PICUS and SPIC can both appear within the PIC portion of an EASA flight-time record, but they arise from different circumstances.
PICUS involves a co-pilot performing the duties and functions of PIC under the supervision of the designated PIC.
SPIC — student pilot-in-command — involves a student pilot acting as PIC on a flight with an instructor who observes the student without influencing or controlling the flight.
SPIC is primarily associated with flight training. PICUS is associated with a co-pilot carrying out a supervised command function.
The fact that both may be entered as PIC does not make them the same category of experience.
When reviewing an old logbook or electronic import, the correct question is not simply:
“Was this time placed in the PIC column?”
It is:
“What was the pilot’s actual function on that flight?”
PICUS vs Normal Co-Pilot Time
A licence holder occupying a pilot seat as co-pilot may log co-pilot time where more than one pilot is required by the aircraft type certification, the applicable regulations or the operator’s operations manual.
PICUS is a more specific function within a multi-pilot environment. It requires the co-pilot to perform the duties and functions of PIC under an acceptable method of supervision.
A pilot may therefore accumulate thousands of hours of valid co-pilot experience without having any PICUS.
Likewise, being PF on a normal co-pilot sector does not convert the flight into PICUS.
This is especially important when reviewing records imported from a roster. A roster may identify PF and PM duties, but it does not necessarily establish that the operator’s supervised-command requirements were met.
Does PICUS Count Towards an EASA ATPL(A)?
Yes, provided the underlying experience satisfies the applicable requirements.
FCL.035 states that, unless Part-FCL determines otherwise, a licence holder acting as co-pilot or PICUS is entitled to credit with all of that co-pilot time towards the total flight time required for a higher grade of pilot licence.
For the issue of an ATPL(A), FCL.510.A requires at least 1,500 hours of flight time in aeroplanes, including at least 500 hours in multi-pilot operations.
Within the PIC and PICUS component, an applicant must have one of the following:
500 hours as PIC under supervision;
250 hours as PIC; or
250 hours comprising at least 70 hours as PIC, with the remaining time as PIC under supervision.
The ATPL(A) requirements also include 200 hours of cross-country flight time, of which at least 100 hours must be as PIC or PIC under supervision.
In this context, PIC under supervision is PICUS.
PICUS is therefore not merely a presentation convention within the EASA logbook. It is expressly recognised within the ATPL(A) experience structure.
This article addresses the aeroplane ATPL. The experience requirements for an ATPL(H) are different and should be reviewed separately.
Does PICUS Count as Command Time on an Airline Application?
Not automatically.
Part-FCL establishes how qualifying experience is recorded and credited for licensing. It does not require every airline to use identical definitions on its recruitment forms.
An operator may ask separately for:
actual PIC;
command time;
PICUS;
supervised command;
multi-pilot command;
command time on type; or
another specifically defined category.
Follow the wording and guidance issued by the airline concerned.
A practical example
Suppose your flight-time record contains:
300 hours actual PIC
450 hours PICUS
Both may legitimately appear within the PIC portion of an EASA flight-time record.
If an airline asks for PIC excluding PICUS, the answer would not be the combined 750-hour PIC-column total.
If the next field asks for PICUS, the 450 hours should be reported separately.
The underlying logbook should not be rewritten simply because the operator asks for a different breakdown. Instead, calculate the recruitment figures from the source record using the operator’s definitions.
PilotAudit’s Professional Pilot Logbook Audit can cross-check customer-provided application figures against the supporting records and flag categories that may require further review. The service is designed to identify total-time issues, category discrepancies and unclear or inconsistent entries rather than changing unsupported information.
Why PICUS Becomes Difficult to Reconstruct
Most PICUS problems do not begin when the airline application is completed.
They begin when the original record is created, transferred or summarised.
A balance-forward entry removes the detail
A pilot may transfer from a paper logbook to an electronic system by entering only the accumulated totals.
The electronic logbook might then show 750 hours of PIC, but it may no longer know that 450 of those hours were PICUS.
The overall figure is still present. The underlying classification has been lost.
Remarks and certification do not transfer
Individual flights may be transcribed correctly while the remarks column is omitted.
In that situation, the electronic record may retain the dates, aircraft and flight times but lose the information identifying the entries as PICUS and the evidence that they were countersigned.
PF sectors are incorrectly reclassified
A pilot may import roster information and later classify every PF sector as PICUS.
That is not supported by AMC1 FCL.050. The qualifying supervision arrangement and PIC duties must have existed during the flight.
A report combines categories
Some electronic systems retain PICUS internally but combine it with PIC in the EASA-style output.
That is not necessarily a problem if the PICUS subset can still be produced separately. It becomes a problem when the combined report is the only surviving record.
Personal and operator records differ
An operator record, paper logbook and personal electronic logbook may use different labels or totals for the same period.
The correct response is not to force one record to match another. It is to establish why they differ and which source supports the classification being claimed.
PilotAudit review note: A PIC total can be mathematically correct and still be unsuitable for an airline application if the underlying record no longer distinguishes PICUS from other PIC.
Converting Paper PICUS Records to Digital
PICUS requires particular care during a paper-to-digital conversion.
A basic balance-forward conversion may preserve the total while removing the information needed to explain it later. An individual-entry conversion provides a far more useful record because each flight can retain its date, aircraft, role, remarks and other supporting detail.
PilotAudit’s Professional Paper-to-Digital Pilot Logbook Conversion is available to pilots internationally, including pilots maintaining records under EASA Part-FCL.
We build a structured electronic record from the individual entries supplied by the pilot. Where information is unclear or cannot be read confidently, it is flagged rather than guessed.
For PICUS, that approach matters.
A proper conversion should not:
invent a missing countersignature;
reclassify ordinary co-pilot time as PICUS;
silently merge PICUS into actual PIC; or
discard remarks that help explain the nature of the experience.
The original signed paper logbooks should still be retained. A digital conversion can make the record easier to search, calculate and review, but it cannot recreate evidence that was absent from the source documents.
What If Historic PICUS Was Logged Incorrectly?
Do not begin by changing the totals.
Start by establishing what happened.
Review the original flight-time record, the remarks and countersignatures, any operator or training documentation, and the corresponding electronic entries. Determine whether the issue is:
a transcription error;
a calculation error;
an incorrect software classification;
lost supporting information; or
a source entry that may not have qualified as PICUS.
These situations require different solutions.
If the original paper record correctly supports PICUS and the electronic system classified it incorrectly, the problem may be a straightforward data correction.
If the source record does not establish that the time qualified as PICUS, changing an electronic field will not resolve the underlying issue.
Do not manufacture or infer missing evidence. Where licensing credit depends on an unclear historic record, seek guidance from the operator involved or the competent authority handling the application.
PilotAudit specialises in this type of flight-time reconciliation. A Professional Pilot Logbook Audit can help locate where PIC, PICUS and co-pilot figures begin to diverge and identify entries that require further investigation.
How to Review PICUS Before an ATPL(A) Application
If PICUS forms a material part of your ATPL(A) experience, begin with the individual entries rather than the summary total.
Confirm that the supervised-command period was conducted within an appropriate arrangement. Check that the PICUS entries can be identified and that the required certification is present. Then reconcile the total against any electronic summaries or operator records.
Once the underlying record is clear, compare it with the requirements in FCL.510.A and the application procedure used by your competent authority.
Do not assume that an electronic total labelled “PICUS” will be sufficient without the supporting entries.
The aim is to be able to demonstrate:
which flights were PICUS;
how the total was calculated;
and why the experience qualifies for the credit being claimed.
How to Review PICUS Before Airline Selection
For airline recruitment, begin with the operator’s definition.
If the application requests PICUS separately, produce the PICUS total from the underlying entries. If it requests actual PIC or command excluding PICUS, remove the supervised-command subset from that particular calculation.
Keep a clear note of how each figure was derived.
This is especially important when the same application asks for several overlapping categories, such as PIC, PICUS, multi-pilot time and time on type.
The figures should reconcile logically without being double counted or presented under a category the operator did not ask for.
If the airline’s wording is unclear, seek clarification from the recruitment team rather than assuming that an EASA logbook column and a recruitment field mean exactly the same thing.
PilotAudit’s Expertise With PICUS and Flight-Time Records
PilotAudit specialises in the audit, classification, reconciliation and conversion of pilot flight-time records.
PICUS is precisely the kind of area where that expertise matters. The arithmetic may be correct while the underlying classification, supporting remarks or application breakdown requires closer review.
Our Professional Pilot Logbook Audit can examine customer-provided records for:
PIC and PICUS classification inconsistencies;
differences between paper and electronic records;
missing or unclear remarks;
carried-forward and opening-balance errors;
co-pilot time incorrectly presented as PICUS;
airline application totals that do not reconcile; and
entries requiring confirmation from the pilot, operator or competent authority.
For handwritten records, our Paper-to-Digital Pilot Logbook Conversion creates a structured electronic record from the individual source entries rather than reducing the pilot’s history to a small number of opening balances.
PilotAudit is an independent logbook audit and conversion service. We are not EASA, a national competent authority, an ATO or an airline recruitment department.
Our expertise lies in the structure and reconciliation of flight-time records: helping pilots identify what the record shows, where the figures came from and which items may need further evidence or clarification.
PICUS Review Checklist
Before relying on PICUS for an ATPL(A) application, airline selection or another professional requirement, confirm that:
The flights were conducted under a qualifying supervised-command arrangement.
PICUS has not been inferred solely from PF sectors.
The individual PICUS entries can be identified.
The required PIC countersignature or accepted certification is present.
The PICUS total agrees with the supporting entries.
PICUS remains distinguishable from actual PIC.
A paper-to-electronic conversion has not removed relevant remarks.
Your ATPL(A) calculation follows FCL.510.A.
Your airline application follows the operator’s own definitions.
Any uncertainty has been resolved before the figures are submitted.
Frequently Asked Questions About PICUS Under EASA
What does PICUS mean?
PICUS means pilot-in-command under supervision. Part-FCL defines PICUS as a co-pilot performing, under the supervision of the pilot-in-command, the duties and functions of a pilot-in-command.
Is PICUS logged as PIC under EASA?
Yes, where the applicable requirements are satisfied. AMC1 FCL.050 provides for qualifying PICUS to be logged as PIC, and the EASA logbook instructions place PICUS within the PIC pilot-function column. Its PICUS nature and certification should remain identifiable in the record.
Does being pilot flying mean I can log PICUS?
No. Acting as PF is not sufficient on its own. PICUS requires an acceptable method of supervision and the performance of the duties and functions of PIC under the conditions stated in AMC1 FCL.050.
Does PICUS need to be countersigned?
Yes. AMC1 FCL.050 requires qualifying PICUS time to be countersigned by the PIC. The associated logbook instructions require the PIC’s name and signature in the remarks when PICUS is recorded. Pilots using electronic records should also check the format accepted by their competent authority.
Does PICUS count towards the 1,500-hour ATPL(A) requirement?
Qualifying co-pilot and PICUS time can be credited towards the total flight time required for a higher-grade licence, subject to Part-FCL. FCL.510.A also expressly includes PIC under supervision within the ATPL(A) experience requirements.
How much PICUS is required for an ATPL(A)?
FCL.510.A provides three alternatives for the PIC/PICUS component: 500 hours as PIC under supervision; 250 hours as PIC; or 250 hours made up of at least 70 hours as PIC with the remainder as PIC under supervision.
Does PICUS count as command time for an airline application?
That depends on the definition used by the airline.
A recruitment form may ask for PICUS separately from actual PIC or command time. Do not assume that the complete PIC-column total is the answer to every command-time question.
What is the difference between PICUS and SPIC?
PICUS involves a co-pilot carrying out the duties and functions of PIC under supervision. SPIC involves a student pilot acting as PIC while an instructor observes without influencing or controlling the flight.
What should I do if my PICUS is missing from my electronic logbook?
Compare the electronic record with the original paper entries and any supporting operator records. Establish whether the issue is a missing category, an incorrect opening balance or a conversion that failed to preserve the remarks.
Do not simply increase the electronic PICUS total without supporting entries.
Can PilotAudit review my PICUS records?
Yes. PilotAudit’s Professional Pilot Logbook Audit can review customer-provided records for PIC/PICUS classification issues, discrepancies and application totals that may need further investigation.
If the entries remain in handwritten records, our Paper-to-Digital Pilot Logbook Conversion can transfer the individual flights into a structured electronic format while flagging unclear information.
Primary Regulatory Sources
This guide is based principally on:
Regulation (EU) No 1178/2011, Annex I, including FCL.035, FCL.050 and FCL.510.A; and
EASA AMC1 FCL.050 and the associated pilot-logbook instructions.
The current consolidated regulation is dated 30 April 2026. EASA’s current Aircrew publications and Part-FCL amendment records should be checked periodically for later changes.
Final Thoughts
PICUS is not difficult because the acronym is difficult to understand.
It becomes difficult when the same hours are expected to serve several different purposes.
Within the EASA flight-time recording framework, qualifying PICUS is entered as PIC. Within Part-FCL licensing, it can receive specific credit towards an ATPL(A). During airline recruitment, an operator may require it to be separated from other command experience.
The answer is not to choose one treatment and ignore the others.
The answer is to preserve the underlying nature of the flight time.
Keep PICUS identifiable. Retain the required certification. Do not treat every PF sector as supervised command. Do not allow a paper-to-electronic conversion to collapse PICUS into an unexplained PIC balance. And when an airline asks for a particular category of experience, answer the question using the definition the operator has provided.
For pilots with a substantial amount of supervised command, accurate classification can make the difference between producing a reliable total immediately and spending days reconstructing years of flying.
PilotAudit helps pilots across Europe and internationally audit their professional flight-time records and convert historic paper logbooks into structured digital records before ATPL applications, airline assessments, operator changes and other important career events.
PICUS should not merely appear in your total. You should be able to show what it is, where it came from and why it belongs there.
