Amendments to Pilot Licensing and Training

Summary#

This is a proposed set of changes called the Regulations Amending the Canadian Aviation Regulations (Personnel Licensing and Training), published in the Canada Gazette, Part I on March 30, 2024. Transport Canada is proposing to tidy up wording, codify long-standing exemptions, allow electronic training records, and tighten some pilot recency rules — especially for instrument flying — while estimating a small net economic benefit over 10 years (2024–2033).

What it does#

• Clarifies wording and fixes inconsistencies in the Canadian Aviation Regulations (CARs) so the rules read more clearly.
• Codifies three long-standing exemptions that let qualified test pilots fly aircraft for testing without a specific type rating and let simulator sessions count toward recency. This makes those permissions permanent instead of renewed as temporary exemptions.
• Shortens the time pilots can go without instrument practice:
  • Requires instrument-rated pilots to have 6 hours of instrument flying and 6 instrument approaches within the 6 months before flying under instrument flight rules (so recency starts in month 7, not month 13).
• Lets flight training records be sent electronically to the Minister instead of by mail.
• Sets a clear limit for temporary satellite training bases: up to 240 days within a 12‑month period.
• Adds or tightens definitions:
  • Defines “cross-country flight time” as a pre-planned route of at least 25 nautical miles from departure.
  • Defines “family member” (parent, child, sibling, spouse) for a training-related rule.
• Changes validity periods for language proficiency:
  • Operational level reduced to 5 years; expert level set to 10 years.
• Clarifies how medical certificate renewals are dated (from the month after the medical exam).
• Designates one maintenance-quality requirement as enforceable by administrative monetary penalties (AMPs) to improve follow-up on quality findings.
• Explicitly prevents recreational pilot permits from being endorsed with a multi-engine class rating.
• Estimated monetized impacts over the analysis period (Transport Canada’s calculation):
  • Total costs $0.7 million
  • Total benefits $1.2 million
  • Estimated net benefit $0.5 million

Who's affected#

• Private pilots who hold an instrument rating. Transport Canada estimates about 3,125 such private pilots in 2024, and says roughly 5% of them would need to increase their instrument flying to meet the new recency rule.
• Flight schools and flight training units. The proposal assumes 384 flight schools in Canada, about 90% (roughly 346) of which are small businesses. Flight schools with satellite bases (about 28 bases) will be affected by the new 240‑day rule and by the shift to electronic records.
• The federal government and regulators (Transport Canada) will gain small administrative savings from not reissuing exemptions and from fewer satellite-base applications.
• Passengers and the general public indirectly, through the stated safety aim of more recent instrument flying by private pilots.

Why it matters#

• Safety: The change to instrument recency responds to a Transportation Safety Board of Canada (TSB) recommendation after past accidents. Requiring more recent instrument practice aims to keep instrument flying skills sharper and reduce risk on flights that need instrument flying.
• Practical effects for pilots: A small share of private instrument-rated pilots may need to spend time and money (simulator or aircraft time) to meet the new 6‑hour / 6‑approach / 6‑month rule. Transport Canada estimates incremental costs to pilots of about $0.6 million over 10 years.
• Administrative and cost savings: Flight schools would save on postage and paperwork by sending records electronically, and many schools would save time by not applying for repeated short satellite-base authorizations. Transport Canada estimates overall benefits of $1.2 million (monetized) over 10 years.
• Equity note: Transport Canada’s review flagged a possible short-term burden for pilots who have limited opportunity to fly — for example, some women who are pregnant or recently postpartum may have a smaller window to meet the recency requirement. Transport Canada judged the safety benefits to outweigh this and did not propose specific mitigation measures, but it flagged the issue in its analysis.

If you want to comment on the proposal: the Canada Gazette notice offered a 30‑day comment period after publication (this item was published on March 30, 2024).