Aviation licensing and training changes

Summary#

This is a proposed set of changes called the Regulations Amending the Canadian Aviation Regulations (Personnel Licensing and Training). It would tidy up wording, add a few definitions, codify three longstanding test‑pilot and simulator permissions, let flight schools send records electronically and allow satellite bases to operate longer, and tighten instrument‑flight recency. The government’s analysis estimates total monetized costs of $0.7 million, benefits of $1.2 million, and a net benefit of $0.5 million over 10 years; this is a proposal (not yet law) with a comment period of 30 days after publication.

What it does#

• Clarifies language and fixes inconsistencies in the Canadian Aviation Regulations (CARs) (for example, harmonizing terms like “pilot licence” and “full‑flight simulator”).
• Adds or clarifies definitions, including “family member” and “cross‑country flight time” (a cross‑country flight is defined as at least 25 nautical miles along a pre‑planned route).
• Codifies three existing, wide‑use exemptions so they become permanent rather than repeatedly reissued:
  • Allows qualified experimental, production and engineering test pilots to fly aircraft for testing without having the specific type rating.
  • Keeps simulator training (Level C/D full‑flight simulators) as an acceptable way to meet recency requirements.
• Shortens instrument‑flight (IFR) recency so that, starting in the 7th month of a pilot’s 24‑month validity period they must have, within the prior 6 months, completed 6 hours of instrument time and 6 instrument approaches to maintain IFR privileges.
• Changes validity periods for language proficiency booklets to 5 years for operational level and 10 years for expert level.
• Clarifies how medical certificate validity is calculated: from the first day of the month after the medical exam.
• Lets flight training units send pilot training records electronically to the Minister (trainees still get a paper copy).
• Allows flight training satellite bases to operate up to 240 days within a 12‑month period without repeated special approvals.
• Makes one maintenance‑quality assurance provision enforceable by administrative monetary penalties (AMPs) — up to $5,000 for an individual and $25,000 for a corporation.
• Prohibits a recreational pilot permit being endorsed with a multi‑engine rating and fixes minor drafting errors.

Who's affected#

• Private pilots who hold an IFR rating. Transport Canada estimates about 3,125 private IFR pilots in 2024 and says roughly 5% of those pilots would need to increase activity to meet the new recency rule; another 5% might let their IFR currency lapse.
• Flight schools and training units. There are about 384 flight schools in the analysis; approximately 346 are small businesses and about 22 operate satellite bases. The proposal aims to reduce paperwork and recurring approval work for them.
• Test pilots and engineering test pilots who currently rely on temporary exemptions — their permissions would be written into the CARs.
• Transport Canada (administrative workload) and the federal government (small projected cost savings such as $15,392 from not reissuing exemptions).
• The proposal notes a possible, limited timing impact on some recently pregnant pilots (noted in the regulatory analysis), because maternity restrictions can narrow the window to meet the new six‑month recency.

If any detail above is unclear in the source, the proposal says stakeholders were consulted and further comments were invited.

Why it matters#

• Safety: The shortened IFR recency (the 6‑month requirement for 6 hours and 6 approaches) responds to a Transportation Safety Board of Canada (TSB) recommendation after past accidents. The government expects better pilot proficiency for instrument flying as a result.
• Practical convenience for industry: Allowing electronic training records and reducing repeat satellite‑base approvals removes paperwork and saves money and time for flight schools (Transport Canada estimates about $0.9 million in industry savings over 10 years).
• Certainty for specialized work: Putting the test‑pilot permissions into the CARs avoids the repeated administrative work of reissuing exemptions and reduces uncertainty for manufacturers and test teams.
• Small cost and time impact on some private pilots: Transport Canada estimates incremental instrument‑training costs of about $0.6 million over 10 years (plus an opportunity cost of $0.1 million). Pilots who fly only occasionally may lose the ability to use IFR privileges unless they do extra training or retesting.
• Legal clarity and enforcement: The drafting fixes and the AMP designation aim to remove ambiguity the Standing Joint Committee for the Scrutiny of Regulations flagged, which should reduce disputes about what rules mean and make enforcement more consistent.

Next steps: this is a Part I notice (a proposal). If finalized, the amendments would come into force on the day they are published in Canada Gazette, Part II.