How to “Unfreeze” an EASA ATPL(A): Flight-Time and Logbook Requirements
To “unfreeze” an EASA ATPL(A), reaching 1,500 hours is only the starting point. Under Part-FCL, an applicant must satisfy a set of overlapping prerequisites, experience requirements and testing requirements—and be able to support the application with a reliable flight-time record.
The central provision is FCL.510.A, but it should not be read as a simple total-time threshold. The 1,500 hours must include specified amounts of multi-pilot operations, pilot-in-command (PIC) or pilot-in-command under supervision (PICUS), cross-country flight time, instrument time and night flight. The required experience must also be completed before the ATPL(A) skill test.
This guide explains how the requirements fit together, how the relevant time should be identifiable in a logbook following the AMC1 FCL.050 format or an equivalent record, and where pilots commonly find discrepancies when preparing an ATPL(A) application.
Important: This article is a general guide to the European Part-FCL framework, not licensing advice or a determination of eligibility. Application forms, acceptable evidence and administrative procedures are set by the competent authority responsible for the licence. Always check that authority’s current requirements before applying.
Strictly speaking, EASA does not issue pilot licences. What pilots commonly call an “EASA ATPL” is a Part-FCL licence issued by the national aviation authority of an EASA Member State in accordance with the common European rules.
How do you unfreeze an EASA ATPL(A)?
To obtain the issue of an ATPL(A), the pilot must meet the FCL.510.A prerequisites and complete at least 1,500 hours with the required multi-pilot, PIC/PICUS, cross-country, instrument and night experience. That experience must be complete before the ATPL(A) skill test. The pilot must then pass the test and apply to the competent authority with acceptable supporting records.
An applicant for the issue of an ATPL(A) will generally need to:
be at least 21 years of age;
hold an MPL, or hold a CPL(A) with a multi-engine IR and have received instruction in multi-crew cooperation (MCC);
have completed the applicable ATPL theoretical knowledge course and examinations;
hold a valid Part-MED Class 1 medical certificate;
meet the experience requirements in FCL.510.A, including at least 1,500 hours and the required subcategories;
meet the type-rating requirements for the aeroplane used for the skill test;
pass the ATPL(A) skill test in accordance with FCL.520.A and Appendix 9; and
apply to the appropriate competent authority in its prescribed form, with the evidence it requires.
The authoritative wording is contained in Annex I (Part-FCL) to Regulation (EU) No 1178/2011. EASA also publishes the rules together with acceptable means of compliance and guidance material in its Easy Access Rules for Aircrew.
“Frozen ATPL” is industry shorthand, not a Part-FCL licence category
The expressions “frozen ATPL” and “unfreezing an ATPL” are widely used by pilots, ATOs and recruiters, but they are not formal licence categories in Part-FCL.
In common European usage, a pilot described as holding a frozen ATPL has normally completed ATPL-level theoretical knowledge and holds the professional licence and ratings needed to begin an airline career—often a CPL(A), multi-engine IR and MCC course completion certificate. The exact combination depends on the training route; an MPL holder follows a different prerequisite route under FCL.510.A.
What is informally called “unfreezing” is therefore better understood as applying for the issue of an ATPL(A) after satisfying the relevant Part-FCL requirements. Nothing changes automatically on the day the pilot’s total flight time reaches 1,500 hours.
That distinction matters. A pilot may have more than 1,500 total hours but still be short of one required category, lack acceptable PICUS evidence, need to resolve the status of multi-pilot time, or not yet have completed the ATPL(A) skill test.
FCL.510.A prerequisites before the experience calculation
Under FCL.510.A(a), an applicant must hold either:
an MPL; or
a CPL(A) and a multi-engine IR for aeroplanes, together with MCC instruction.
These are prerequisites, not substitutes for the experience requirements. The applicant must also meet the common ATPL provisions, including the training and theoretical knowledge requirements in FCL.515.
Under FCL.025, completion of the ATPL theoretical knowledge examinations remains valid for ATPL issue for seven years from the last validity date of the IR entered in the licence. Pilots whose IR history is unusual, interrupted or transferred between authorities should confirm the position with their competent authority before scheduling the skill test.
The EASA ATPL(A) 1,500-hour requirements
FCL.510.A(b) requires at least 1,500 hours of flight time in aeroplanes, subject to the permitted FFS and FNPT credit described below. Within that total, the applicant must have at least:
500 hours in multi-pilot operations on aeroplanes;
one of the specified PIC/PICUS combinations;
200 hours of cross-country flight time, including at least 100 hours as PIC or PICUS;
75 hours of instrument time, of which no more than 30 hours may be instrument ground time; and
100 hours of night flight as PIC or co-pilot.
The categories overlap. They are not separate blocks that should be added to produce a total greater than 1,500 hours. One flight can contribute to several categories when the facts of the flight and the applicable definitions support each credit.
The practical task is therefore not simply to calculate one grand total. It is to build a traceable breakdown showing that the overall total and every required subcategory are independently satisfied without double-counting the same time within a single category.
500 hours in multi-pilot operations on aeroplanes
Part-FCL defines a multi-pilot operation as an operation requiring at least two pilots using multi-crew cooperation in either a multi-pilot or a single-pilot aircraft. This is not identical to the definition of a multi-pilot aeroplane, which for aeroplanes concerns certification for a minimum crew of at least two pilots.
The distinction is important. Time does not become multi-pilot time merely because two qualified pilots were on board. The operation must meet the applicable requirement for at least two pilots and be conducted using MCC. Depending on the operation, that requirement may arise from the aircraft type certification, the regulations or the operator’s operations manual.
For logbook purposes, AMC1 FCL.050 states that co-pilot time may be logged when the licence holder occupies a pilot seat as co-pilot on an aircraft on which more than one pilot is required by the type certification, the regulations or the operator’s operations manual. The record should also make it possible to distinguish single-pilot (SP) from multi-pilot (MP) operations.
GM6 FCL.010 adds two points that are frequently missed. For crediting prior experience, State aircraft operations—such as military or search-and-rescue flying—may be treated as multi-pilot operations where two pilots were required by national rules, the relevant operations manual or an equivalent document. By contrast, operations under Part-NCO are not in the multi-pilot-operation category, except for operations at an ATO providing multi-pilot training in accordance with its training manual.
Before claiming 500 hours of multi-pilot operations, check that:
the aircraft and operation were correctly classified;
the pilot function—co-pilot, PIC or PICUS—is clear;
the records cover the full period being claimed;
operator records and the personal logbook reconcile; and
time from single-pilot operations has not been placed in the MP column merely because another pilot was present.
This is especially important for pilots combining airline, business aviation, State aircraft or specialised-operations experience. The regulatory basis for a two-pilot crew may differ between operations, and the competent authority may ask for supporting evidence.
The three PIC and PICUS routes
FCL.510.A(b)(2) provides three alternative ways to meet the command-experience element. An applicant needs one of the following:
500 hours as PIC under supervision; or
250 hours as PIC; or
250 hours comprising at least 70 hours as PIC, with the remainder as PIC under supervision.
In Part-FCL terminology, pilot-in-command under supervision is abbreviated PICUS. FCL.010 defines PICUS as a co-pilot performing the duties and functions of the PIC under the supervision of the PIC.
AMC1 FCL.050 adds important recording conditions. A co-pilot may log qualifying PICUS as PIC flight time when the supervision method is acceptable to the competent authority and the pilot carried out all PIC duties and functions without a safety intervention by the PIC. PICUS entries are to be certified by the aircraft PIC in the remarks column.
Because PICUS is entered in the PIC column, an unstructured export can make all command time appear to be the same. For an ATPL(A) application, the underlying entries should allow actual PIC and PICUS to be separated. A PIC total that includes PICUS without identifying the supervised component is difficult to test against the three alternatives above.
For a detailed treatment of qualifying time, certification and common recording errors, see PilotAudit’s EASA PICUS logbook guide.
200 hours of cross-country time, including 100 hours as PIC or PICUS
The applicant must have at least 200 hours of cross-country flight time, with at least 100 hours as PIC or PICUS.
Part-FCL defines cross-country as a flight between a point of departure and a point of arrival following a pre-planned route using standard navigation procedures. The important point for the ATPL calculation is not only the overall cross-country total, but the pilot function attached to at least 100 of those hours.
A logbook or digital export that contains route information but no calculated cross-country field may still hold the necessary source data. However, the method used to derive the total should be consistent and explainable. Pilots should be particularly cautious with:
local flights returning to the departure aerodrome;
positioning or training entries with incomplete route information;
imported opening balances that contain a cross-country total but no underlying entries; and
PICUS flights that are not separately identifiable or certified.
75 hours of instrument time, with no more than 30 hours of instrument ground time
The requirement is 75 hours of instrument time. No more than 30 hours of that total may be instrument ground time.
Part-FCL distinguishes several similar expressions:
instrument flight time is time during which a pilot controls an aircraft in flight solely by reference to instruments;
instrument ground time is time receiving instruction in simulated instrument flight in an FSTD; and
instrument time means instrument flight time or instrument ground time.
It also defines flight time under IFR separately as all flight time during which the aircraft is operated under the Instrument Flight Rules. A record should therefore preserve the terminology and source data used rather than silently treating every IFR-labelled entry as an interchangeable category.
The logbook should make FSTD sessions identifiable by date, device type, qualification number where applicable, exercise and session time. Instrument ground time must also remain distinguishable from flight time in an aeroplane so the 30-hour cap can be tested.
Common problems include combining aircraft instrument time and FSTD time in one field, importing FSTD sessions as aircraft flights, or counting the same session in both an FSTD total and the 1,500-hour total without checking the separate FCL.510.A limits.
100 hours of night flight as PIC or co-pilot
FCL.510.A requires 100 hours of night flight as PIC or co-pilot.
This wording makes pilot function material. A total night figure is not enough if the record cannot show how much was completed as PIC or co-pilot. Time recorded only as dual, or time carried forward without its pilot-function breakdown, should not be assumed to satisfy this requirement.
The night total should reconcile with the flight entries, the relevant pilot-function columns and any operator-supplied records. Where records have been converted between formats, ensure that night time has not been lost, moved into a remarks field or duplicated when sectors span midnight UTC.
How much FFS and FNPT time can count?
Of the 1,500-hour requirement, up to 100 hours may have been completed in an FFS or FNPT. Within that 100-hour allowance, no more than 25 hours may have been completed in an FNPT.
This is separate from the rule that no more than 30 of the required 75 hours of instrument time may be instrument ground time. A candidate needs to test both limits; satisfying one does not automatically prove compliance with the other.
FSTD entries should be kept as FSTD sessions, not made to resemble aeroplane sectors. The record should preserve the device category and session details needed to establish what may be credited.
Credit for helicopter, sailplane, TMG and flight-engineer experience
FCL.510.A(c) permits limited credit for experience outside the aeroplane category:
TMG or sailplane experience may be credited up to 30 hours flown as PIC;
helicopter experience may be credited at 50% of all the flight-time requirements in FCL.510.A(b); and
holders of a flight engineer licence issued under applicable national rules may receive credit for 50% of flight-engineer time, up to 250 hours. The same credit may be applied to the 1,500-hour total and the 500-hour multi-pilot requirement, but no more than 250 hours of flight-engineer credit is available under this provision.
These provisions are easy to misapply because they affect more than a single grand total. A pilot claiming credit should prepare a category-by-category calculation and provide the licence or records needed to support it. Do not apply a percentage to the total in isolation and assume every subrequirement has been met.
Why the required hours overlap—but should not be double-counted
The FCL.510.A categories describe different attributes of flight time. A qualifying multi-pilot cross-country flight at night, for example, may contribute to the total-time, multi-pilot, cross-country and night requirements. If it was flown as PICUS under an acceptable supervision scheme and correctly certified, it may also contribute to the relevant PICUS totals.
That is legitimate overlap. Double-counting is different: it occurs when the same flight time is counted twice inside one total—for example, once from the pilot’s logbook and again from an operator summary—or when time already contained in an opening balance is added again as individual entries.
A sound ATPL worksheet should therefore use one underlying set of flight records and calculate each required category from those records. It should not build the categories by adding disconnected summaries whose periods may overlap.
What an ATPL(A)-ready flight-time record should show
FCL.050 requires a pilot to keep a reliable record of all flights in the form and manner established by the competent authority. AMC1 FCL.050 describes the information expected for flights and FSTD sessions and provides for records to be kept electronically, subject to its conditions and the competent authority’s requirements.
For an ATPL(A) application, a well-prepared record should make the following traceable:
total flight time in aeroplanes;
SP and MP operations;
PIC, PICUS, co-pilot, dual, instructor and other applicable pilot functions;
cross-country time and the PIC/PICUS component within it;
night time by qualifying pilot function;
instrument flight time, instrument ground time and FSTD sessions;
aircraft type, make/model/variant and registration;
departure and arrival points and times;
the name of the PIC where applicable;
PICUS or SPIC certification in the remarks; and
accumulated totals and any opening balances or carried-forward figures.
Commercial air transport flights may be recorded in an electronic format maintained by the operator, and the operator should make those records available to the flight crew member on request. Pilots should still retain a dependable personal record and preserve source documents that can explain discrepancies.
Common logbook problems discovered before an ATPL(A) application
The pilot has 1,500 hours, but not 500 hours of qualifying multi-pilot operations
This often arises when two-pilot time has been assumed to be multi-pilot time without checking why two pilots were required. The type certification, applicable rules and operations manual may be relevant.
PICUS has been merged into the PIC total
Because EASA’s recording convention places PICUS in the PIC column, digital systems often report one combined figure. The applicant still needs to demonstrate which FCL.510.A(b)(2) route is being used and how much of the figure is actual PIC versus PICUS.
PICUS entries are not properly certified
AMC1 FCL.050 calls for PICUS entries to be certified by the PIC. A spreadsheet label or employer letter may not correct deficiencies in the underlying record to the satisfaction of every competent authority. Resolve the evidence question with the authority rather than manufacturing or backdating entries.
The cross-country total cannot be traced to routes
Historic logbooks and some airline exports do not include a cross-country field. A derived total can be useful, but the calculation should follow the Part-FCL definition and remain reproducible from the flight entries.
IFR, instrument flight time and instrument ground time have been combined
These terms are not identical in Part-FCL. A single “instrument” total without source detail can conceal an excessive amount of instrument ground time or an unsupported conversion from IFR flight time.
FSTD sessions have been included as ordinary flight sectors
FFS and FNPT time can receive limited credit, but should remain recognisable as FSTD time. Otherwise it is difficult to verify both the overall 100-hour limit and the 25-hour FNPT sublimit.
Operator totals and the personal logbook do not agree
Differences may arise from block-time conventions, omitted sectors, roster corrections, deadhead travel mistakenly imported as duty, duplicate uploads or different cut-off dates. The solution is to reconcile the records by date and source, not simply select the larger figure.
A carried-forward balance contains no category detail
An opening balance may preserve total time while losing MP, PICUS, cross-country, night or instrument breakdowns. If the original logbooks still exist, retain and use them to rebuild the supporting categories rather than guessing.
When to audit an EASA logbook before applying
The best time to review an ATPL(A) record is before booking the skill test or submitting the application—not after a competent authority has queried the figures.
A pre-application review should compare:
the personal logbook against operator or training records;
the 1,500-hour total against the underlying entries;
each FCL.510.A subcategory against its definition and limit;
the command-time calculation against the chosen PIC/PICUS route;
PICUS entries against the available certifications;
FSTD credits against the FFS/FNPT limits; and
the application totals against the logbook cut-off date.
PilotAudit’s Professional Pilot Logbook Audit is designed for this record-preparation stage. We reconcile the material supplied by the pilot, review flight-time totals and categories, cross-check application figures and identify entries or assumptions that require clarification. The service does not issue licences or replace a competent authority’s decision; it helps the pilot present a cleaner, traceable set of records.
Pilots with handwritten records can also use PilotAudit’s Paper-to-Digital Logbook Conversion. We convert the source entries into an organised digital file and flag anything unreadable or inconsistent rather than inventing missing information. Pilots should retain the original logbooks and other source records because the competent authority may require primary evidence.
For a broader explanation of record preparation before airline selection, see our EASA pilot logbook and airline-assessment guide.
The ATPL(A) skill test comes after the experience requirement
FCL.510.A(d) states that the required experience must be completed before the ATPL(A) skill test.
Under FCL.520.A, the applicant must pass a skill test in accordance with Appendix 9 and demonstrate the ability to perform the relevant procedures and manoeuvres as PIC of a multi-pilot aeroplane under IFR. The test is conducted in the aeroplane or an adequately qualified FFS representing the same type.
The applicant must also have fulfilled the requirements for the type rating of the aeroplane used in the skill test. Depending on the circumstances, the ATPL skill test may also serve as a proficiency check for type-rating revalidation and may be combined with the skill test for issue of a multi-pilot type rating.
Under FCL.015(f), the applicant must apply for the issue of the licence no later than six months after passing the skill test. Pilots should confirm the test, examiner and application arrangements with their competent authority in advance.
Your competent authority decides the application procedure
EASA develops the common European rules, but licences are issued and administered by national competent authorities. FCL.015 requires an application to be submitted in the form and manner established by the competent authority, accompanied by evidence of compliance with Part-FCL and Part-MED.
A licence holder submits the application to the authority designated by the Member State in which the licence was issued, unless a formal change of competent authority has been completed. Evidence requirements can differ in presentation even where the underlying Part-FCL standard is the same.
For example, the Irish Aviation Authority’s current ATPL application guidance asks applicants to submit all original flying logbooks and states that PICUS hours must be countersigned by the PIC, with electronic signatures not accepted for that process. That is an IAA procedure, not a rule to be generalised to every EASA Member State.
Before applying, check the current authority page for:
the correct application form;
logbook or certified-copy requirements;
PICUS evidence and signature expectations;
examiner and FSTD documentation;
medical and identity documents;
fees and processing times; and
any national guidance on presenting electronic records.
EASA ATPL(A) logbook checklist
Before booking the skill test or submitting the application, confirm that you can evidence all of the following:
At least 1,500 hours of creditable flight time under FCL.510.A
At least 500 hours in multi-pilot operations on aeroplanes
One complete PIC/PICUS route under FCL.510.A(b)(2)
At least 200 hours of cross-country flight time
At least 100 cross-country hours as PIC or PICUS
At least 75 hours of instrument time
No more than 30 hours of instrument ground time within that requirement
At least 100 hours of night flight as PIC or co-pilot
No more than 100 hours of FFS/FNPT credit within the 1,500 hours
No more than 25 hours of FNPT time within that FSTD credit
Clearly identifiable and certified PICUS entries
Reconciled operator, training and personal-logbook totals
A traceable explanation for opening balances and corrections
The required licence, rating, theoretical-knowledge and medical documentation
The authority’s current application form and supporting evidence
Frequently asked questions
Is a frozen ATPL an EASA licence?
No. “Frozen ATPL” is an industry expression rather than a licence category defined in Part-FCL. The pilot normally holds a CPL(A) or MPL and the relevant ratings, training and ATPL theoretical knowledge credit. The formal step is the issue of an ATPL(A) after the applicable requirements have been met.
Does an EASA ATPL automatically unfreeze at 1,500 hours?
No. The pilot must meet all applicable prerequisites and FCL.510.A subrequirements, complete the required experience before the skill test, pass the FCL.520.A skill test and apply to the competent authority with acceptable evidence.
How many multi-pilot hours are required for an EASA ATPL(A)?
FCL.510.A requires at least 500 hours in multi-pilot operations on aeroplanes. The operation—not merely the number of pilots physically on board—must meet the Part-FCL meaning of a multi-pilot operation.
How much PIC or PICUS time is required?
The applicant needs either 500 hours as PICUS, 250 hours as PIC, or 250 combined hours containing at least 70 hours as PIC and the remainder as PICUS.
Can co-pilot time count towards the 1,500 hours?
Yes, subject to the Part-FCL crediting and logging rules. FCL.035 generally allows a licence holder acting as co-pilot or PICUS to receive credit for co-pilot time towards the total required for a higher grade of licence, unless Part-FCL determines otherwise. The specific FCL.510.A subcategories still have to be met.
Can simulator time count towards an EASA ATPL(A)?
Limited FSTD credit is available. Up to 100 of the 1,500 hours may have been completed in an FFS or FNPT, and no more than 25 of those hours may be FNPT time. Separately, no more than 30 of the required 75 instrument hours may be instrument ground time.
Can helicopter time count towards an ATPL(A)?
FCL.510.A permits helicopter experience to be credited at 50% of all the flight-time requirements in paragraph (b). Because the provision interacts with the subrequirements, pilots should prepare a detailed calculation and confirm the evidence with their competent authority.
Can an electronic logbook be used for an EASA ATPL application?
AMC1 FCL.050 provides for electronic records, and commercial air transport flights may be held in an operator-maintained electronic format. The record must contain the relevant data, remain available and satisfy the competent authority’s form-and-manner requirements. A particular authority may still request original logbooks, certified copies, original signatures or other supporting evidence for its application process.
Who issues an EASA ATPL(A)?
EASA does not issue pilot licences. A Part-FCL ATPL(A) is issued by the competent authority of an EASA Member State. An existing licence holder applies to the authority designated by the Member State that issued the licence, unless the holder has completed a change of competent authority.
Does this guide apply to a UK CAA ATPL(A)?
No. Since 1 January 2021, a UK-issued licence has been treated as a third-country licence within the EASA system. UK Part-FCL applicants should follow the UK CAA’s requirements; holders seeking a Part-FCL licence in an EASA Member State should follow the relevant EASA conversion rules and the receiving authority’s procedure. EASA explains the post-withdrawal position in its aircrew licensing guidance for UK-issued licences.
Does PilotAudit certify that a pilot qualifies for an ATPL(A)?
No. Only the competent authority determines whether an applicant meets the requirements and issues the licence. PilotAudit provides independent record preparation: we reconcile totals, cross-check application figures, organise source records and flag discrepancies or unclear entries for the pilot to resolve.
Primary regulatory sources
This guide was prepared using official material, principally EASA’s current Aircrew regulations and AMC/GM index, the EASA Easy Access Rules for Aircrew, revision from November 2025, the consolidated Aircrew Regulation on EUR-Lex, the Part-FCL provisions on ATPL(A) experience and skill testing, EASA’s provisions on recording flight time under FCL.050, Part-MED medical-certificate requirements, and EASA’s explanation of how Part-FCL licences are issued by national aviation authorities.
Regulatory currency note: The official EASA Aircrew index was checked through 22 August 2026. It lists Commission Implementing Regulation (EU) 2026/781 and AMC & GM to Part-FCL, Issue 1, Amendment 15. These introduce a revised FSTD capability-signature framework that is largely applicable from 30 April 2028. They do not change the current numerical FFS/FNPT credit limits quoted from FCL.510.A in this guide.
EASA advises users to check for rules adopted after the publication date of the current Easy Access Rules. Pilots should also consult the latest instructions published by their competent authority.
Final thoughts
The 1,500-hour threshold is only the headline. The real ATPL(A) task is demonstrating that the pilot’s experience satisfies every element of FCL.510.A and that the underlying record is reliable enough for the competent authority to follow.
Start early. Separate PIC from PICUS, verify the basis for multi-pilot time, preserve the distinction between instrument categories, keep FSTD sessions identifiable and reconcile operator records before the skill test. A clean calculation cannot replace qualifying experience, but it can prevent valid experience from being obscured by poor record structure or inconsistent totals.
If your records span several logbooks, operators or digital systems, PilotAudit can help you prepare them through a professional logbook audit or paper-to-digital logbook conversion. Any unclear entry is flagged for confirmation; it is never guessed or silently changed.
