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CAT.IDE.A.195 Data link recording

ANNEX IV (Part-CAT) · Regulation (EU) No 965/2012 · EAR revision 27 Mar 2026

IRImplementing rule

CAT.IDE.A.195Data link recording

(a)Aeroplanes first issued with an individual CofA on or after 8 April 2014 that have the capability to operate data link communications and are required to be equipped with a CVR, shall record on a recorder, where applicable:

(1)data link communication messages related to ATS communications to and from the aeroplane, including messages applying to the following applications:

(i)data link initiation;

(ii)controller-pilot communication;

(iii)addressed surveillance;

(iv)flight information;

(v)as far as is practicable, given the architecture of the system, aircraft broadcast surveillance;

(vi)as far as is practicable, given the architecture of the system, aircraft operational control data; and

(vii)as far as is practicable, given the architecture of the system, graphics;

(2)information that enables correlation to any associated records related to data link communications and stored separately from the aeroplane; and

(3)information on the time and priority of data link communications messages, taking into account the system’s architecture.

(b)The recorder shall use a digital method of recording and storing data and information and a method for retrieving that data. The recording method shall allow the data to match the data recorded on the ground.

(c)The recorder shall be capable of retaining data recorded for at least the same duration as set out for CVRs in CAT.IDE.A.185.

(d)If the recorder is not deployable, it shall have a device to assist in locating it under water. By 16 June 2018 at the latest, this device shall have a minimum underwater transmission time of 90 days. If the recorder is deployable, it shall have an automatic emergency locator transmitter.

(e)The requirements applicable to the start and stop logic of the data link recorder are the same as the requirements applicable to the start and stop logic of the cockpit voice recorder (CVR) that are contained in point CAT.IDE.A.185.

IR · CAT.IDE.A.195 — Regulation (EU) No 965/2012 · Regulation (EU) 2021/1296 · Air OPS Easy Access Rules · EAR revision 27 Mar 2026

AMCAcceptable means of compliance

AMC1 CAT.IDE.A.195Data link recording

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GENERAL

(a)As a means of compliance with CAT.IDE.A.195(a), the recorder on which the data link messages is recorded may be:

(1)the CVR;

(2)the FDR;

(3)a combination recorder when CAT.IDE.A.200 is applicable; or

(4)a dedicated flight recorder. In that case, the operational performance requirements for this recorder should be those laid down in EUROCAE Document ED-112 (Minimum Operational Performance Specification for Crash Protected Airborne Recorder Systems) dated March 2003, including amendments No 1 and No 2, or any later equivalent standard produced by EUROCAE.

(b)As a means of compliance with CAT.IDE.A.195(a)(2), the operator should enable correlation by providing information that allows an accident investigator to understand what data was provided to the aeroplane and, when the provider identification is contained in the message, by which provider.

(c)The timing information associated with the data link communications messages required to be recorded by CAT.IDE.A.195(a)(3) should be capable of being determined from the airborne-based recordings. This timing information should include at least the following:

(1)the time each message was generated;

(2)the time any message was available to be displayed by the crew;

(3)the time each message was actually displayed or recalled from a queue; and

(4)the time of each status change.

(d)The message priority should be recorded when it is defined by the protocol of the data link communication message being recorded.

(e)The expression ‘taking into account the system architecture’, in CAT.IDE.A.195(a)(3), means that the recording of the specified information may be omitted if the existing source systems involved would require a major upgrade. The following should be considered:

(1)the extent of the modification required;

(2)the down-time period; and

(3)equipment software development. The intention is that new designs of source systems should include this functionality and support the full recording of the required information.

(f)Data link communications messages that support the applications in Table 1 below should be recorded.

(g)Further details on the recording requirements can be found in the recording requirement matrix in Appendix D.2 of EUROCAE Document ED-93 (Minimum Aviation System Performance Specification for CNS/ATM Recorder Systems, dated November 1998).

Table 1 Applications

Item NoApplication TypeApplication DescriptionRequired Recording Content
1Data link initiationThis includes any application used to log on to, or initiate, a data link service. In future air navigation system (FANS)-1/A and air traffic navigation (ATN), these are ATS facilities notification (AFN) and context management (CM) respectively.C
2Controller/pilot communicationThis includes any application used to exchange requests, clearances, instructions and reports between the flight crew and air traffic controllers. In FANS-1/A and ATN, this includes the controller pilot data link communications (CPDLC) application. It also includes applications used for the exchange of oceanic (OCL) and departure clearances (DCL) as well as data link delivery of taxi clearances.C
3Addressed surveillanceThis includes any surveillance application in which the ground sets up contracts for delivery of surveillance data. In FANS-1/A and ATN, this includes the automatic dependent surveillance-contract (ADS-C) application.C, F2
4Flight informationThis includes any application used for delivery of flight information data to specific aeroplanes. This includes for example, digital automatic terminal information service (D-ATIS), data link operational terminal information service (D-OTIS), digital weather information services (D-METAR or TWIP), data link flight information service (D-FIS), and Notice to Airmen (electronic NOTAM) delivery.C
5Aircraft broadcast surveillanceThis includes elementary and enhanced surveillance systems, as well as automatic dependent surveillance-broadcast (ADS-B) output data.M*, F2
6Aeronautical operational control (AOC) dataThis includes any application transmitting or receiving data used for AOC purposes (in accordance with the ICAO definition of AOC). Such systems may also process AAC messages, but there is no requirement to record AAC messages.M*
7GraphicsThis includes any application receiving graphical data to be used for operational purposes (i.e. excluding applications that are receiving such things as updates to manuals).M* F1

AMC · AMC1 CAT.IDE.A.195 — Regulation (EU) No 965/2012 · ED Decision 2014/015/R · Air OPS Easy Access Rules · EAR revision 27 Mar 2026

GMGuidance material

GM1 CAT.IDE.A.195Data link recording

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DEFINITIONS AND ACRONYMS

(a)The letters and expressions in Table 1 of AMC1 CAT.IDE.A.195 have the following meaning: C: complete contents recorded M: information that enables correlation with any associated records stored separately from the aeroplane. *: Applications that are to be recorded only as far as is practicable, given the architecture of the system. F1: graphics applications may be considered as AOC messages when they are part of a data link communications application service run on an individual basis by the operator itself in the framework of the operational control. F2: where parametric data sent by the aeroplane, such as Mode S, is reported within the message, it should be recorded unless data from the same source is recorded on the FDR.

(b)The definitions of the applications type in Table 1 of AMC1 CAT.IDE.A.195 are described in Table 1 below.

Table 1 Definitions of applications type

Item NoApplication TypeMessagesComments
1CMCM is an ATN service
2AFNAFN is a FANS 1/A service
3CPDLCAll implemented up and downlink messages to be recorded
4ADS-CADS-C reportsAll contract requests and reports recorded
Position reportsOnly used within FANS 1/A. Only used in oceanic and remote areas.
5ADS-BSurveillance dataInformation that enables correlation with any associated records stored separately from the aeroplane.
6D-FISD-FIS is an ATN service. All implemented up and downlink messages to be recorded
7TWIPTWIP messagesTerminal weather information for pilots
8D-ATISATIS messagesRefer to EUROCAE Document ED-89A dated December 2003. Data Link Application System Document (DLASD) for the ‘ATIS’ Data Link Service
9OCLOCL messagesRefer to EUROCAE Document ED-106A dated March 2004. Data Link Application System Document (DLASD) for ‘Oceanic Clearance’ Data Link Service
10DCLDCL messagesRefer to EUROCAE Document ED-85A dated December 2003. Data Link Application System Document (DLASD) for ‘Departure Clearance’ Data Link Service
11GraphicsWeather maps & other graphicsGraphics exchanged in the framework of procedures within the operational control, as specified in Part-ORO. Information that enables correlation with any associated records stored separately from the aeroplane.
12AOCAeronautical operational control messagesMessages exchanged in the framework of procedures within the operational control, as specified in Part-ORO. Information that enables correlation with any associated records stored separately from the aeroplane. Definition in EUROCAE Document ED-112, dated March 2003.
13SurveillanceDownlinked aircraft parameters (DAP)As defined in ICAO Annex 10 Volume IV (Surveillance systems and ACAS).

AAC aeronautical administrative communications ADS-B automatic dependent surveillance — broadcast ADS-C automatic dependent surveillance — contract AFN aircraft flight notification AOC aeronautical operational control ATIS automatic terminal information service ATSC air traffic service communication CAP controller access parameters CPDLC controller pilot data link communications CM configuration/context management D-ATIS digital ATIS D-FIS data link flight information service D-METAR data link meteorological airport report DCL departure clearance FANS Future Air Navigation System FLIPCY flight plan consistency OCL oceanic clearance SAP system access parameters TWIP terminal weather information for pilots

GM · GM1 CAT.IDE.A.195 — Regulation (EU) No 965/2012 · ED Decision 2014/015/R · Air OPS Easy Access Rules · EAR revision 27 Mar 2026

GMGuidance material

GM1 CAT.IDE.A.195(a)Data link recording

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APPLICABILITY OF THE DATA LINK RECORDING REQUIREMENT

(a)If it is certain that the aeroplane cannot use data link communication messages for ATS communications corresponding to any application designated by CAT.IDE.A.195(a)(1), then the data link recording requirement does not apply.

(b)Examples where the aeroplane cannot use data link communication messages for ATS communications include but are not limited to the cases where:

(1)the aeroplane data link communication capability is disabled permanently and in a way that it cannot be enabled again during the flight;

(2)data link communications are not used to support air traffic service (ATS) in the area of operation of the aeroplane; and

(3)the aeroplane’s data link communication equipment cannot communicate with the equipment used by ATS in the area of operation of the aeroplane.

GM · GM1 CAT.IDE.A.195(a) — Regulation (EU) No 965/2012 · ED Decision 2015/030/R · Air OPS Easy Access Rules · EAR revision 27 Mar 2026

All rules in SUBPART D: INSTRUMENTS, DATA, EQUIPMENT

Consolidated from the EASA Easy Access Rules (revision 27 Mar 2026, extracted 17 Aug 2026) for convenience. Not the official publication — verify against the Official Journal of the European Union and the EASA publications before operational use.

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