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ORA.ATO.135 Training aircraft and FSTDs

ANNEX VII (Part-ORA) · Regulation (EU) No 1178/2011 · EAR revision 25 Nov 2025

IRImplementing rule

ORA.ATO.135Training aircraft and FSTDs

(a)The ATO shall use an adequate fleet of training aircraft or FSTDs appropriately equipped for the training courses provided. The fleet of aircraft shall be composed of aircraft that comply with all requirements defined in Regulation (EU) 2018/1139. Aircraft that fall under points (a), (b), (c) or (d) of Annex I to Regulation (EU) 2018/1139, may be used for training if all of the following conditions are met:

(1)during an evaluation process the competent authority has confirmed a level of safety comparable to the one defined by all essential requirements laid down in Annex II to Regulation (EU) 2018/1139;

(2)the competent authority has authorised the use of the aircraft for training in the ATO.

(b)The ATO shall only provide training in FSTDs when it demonstrates to the competent authority:

(1)the adequacy between the FSTD specifications and the related training programme;

(2)that the FSTDs used comply with the relevant requirements of Part-FCL;

(3)in the case of full flight simulators (FFSs), that the FFS adequately represents the relevant type of aircraft; and

(4)that it has put in place a system to adequately monitor changes to the FSTD and to ensure that those changes do not affect the adequacy of the training programme.

(c)If the aircraft used for the skill test is of a different type to the FFS used for the visual flight training, the maximum credit shall be limited to that allocated for flight and navigation procedures trainer II (FNPT II) for aeroplanes and FNPT II/III for helicopters in the relevant flight training programme.

(d)Flight test training organisations. Aircraft used for flight test training shall be appropriately equipped with flight testing instrumentation, according to the purpose of the training.

IR · ORA.ATO.135 — Regulation (EU) No 1178/2011 · Regulation (EU) 2019/1747 · Aircrew Easy Access Rules · EAR revision 25 Nov 2025

AMCAcceptable means of compliance

AMC1 ORA.ATO.135Training aircraft and FSTDs

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ALL ATOs, EXCEPT THOSE PROVIDING FLIGHT TEST TRAINING

(a)The number of training aircraft may be affected by the availability of FSTDs.

(b)Each training aircraft should be:

(1)equipped as required in the training specifications concerning the course in which it is used;

(2)except in the case of balloons or single-seat aircraft, fitted with primary flight controls that are instantly accessible by both the student and the instructor (for example dual flight controls or a centre control stick). Swing-over flight controls should not be used.

(c)The fleet should include, as appropriate to the courses of training:

(1)aircraft suitably equipped to simulate instrument meteorological conditions (IMC) and for the instrument flight training required. For flight training and testing for the instrument rating and the basic instrument rating (BIR), an adequate number of IFR-certificated aircraft should be available;

(2)in the case of aeroplanes and sailplanes, aircraft suitable for demonstrating stalling and spin avoidance;

(3)for the flight instructor (FI) training courses on aeroplanes and sailplanes, aircraft suitable for spin recovery at the developed stage;

(4)in the case of helicopters, helicopters suitable for autorotation demonstration;

(5)in the case of a non-complex ATO, one aircraft fulfilling all the required characteristics for a training aircraft might be sufficient;

(6)each FSTD should be equipped as required in the training specifications concerning the course in which it is used.

AMC · AMC1 ORA.ATO.135 — Regulation (EU) No 1178/2011 · ED Decision 2025/002/R · Aircrew Easy Access Rules · EAR revision 25 Nov 2025

AMCAcceptable means of compliance

AMC2 ORA.ATO.135Training aircraft and FSTDs

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EVALUATION PROCESS Two cases for the evaluation process of Annex-I aircraft are distinguished:

(a)Annex-I aircraft that hold an ICAO-level certificate of airworthiness (CoA)

(1)To support the evaluation process performed by the competent authority and provide the competent authority with sufficient data related to the aircraft in question, an instructor who is qualified in accordance with Annex I (Part-FCL) to Regulation (EU) No 1187/2011 and nominated by the head of training (HT) of the ATO should assess that the aircraft is appropriately equipped and suitable for the training courses provided. The result of this assessment should be submitted to the competent authority and may be included already in the application for the authorisation.

(2)During the evaluation process, the competent authority should consider aircraft that hold a CoA issued in accordance with Annex 8 to the Chicago Convention to provide a level of safety comparable to that required by Annex II to the Basic Regulation, unless the competent authority determines that the airworthiness requirements used for certification of the aircraft, or the service experience, or the safety system of the State of design, do not provide for a comparable level of safety.

(b)Annex-I aircraft that do not hold an ICAO-level CoA Before the inclusion of these aircraft in the fleet of an ATO and their use in training to obtain Part-FCL licences and ratings, the ATO should apply for the authorisation to the competent authority that should perform the evaluation process in the following order:

(1)Initial assessment by the competent authority and criteria taken into consideration The competent authority should take into account the following criteria (non-exhaustive list):

(i)national airworthiness requirements based on which the aircraft CoA was issued;

(ii)aircraft similarities to a certified variant;

(iii)aircraft with a satisfactory in-service experience as training aircraft;

(iv)simple and conventional aircraft design;

(v)aircraft that does not have hazardous design features or details, judging by experience; and

(vi)operable aircraft systems, equipment, and appliances that do not require exceptional skills or strength.

(2)Additional assessment by a qualified instructor To support the evaluation process performed by the competent authority and provide the competent authority with sufficient data related to the aircraft in question, after the positive initial assessment by the competent authority as per point (1), an instructor who is qualified in accordance with Part-FCL and nominated by the HT of the ATO should show through an evaluation report that the aircraft is appropriately equipped and suitable for the training courses provided. That evaluation report should consider all of the following criteria:

(i)the aircraft should be safely controllable and manoeuvrable under all anticipated operating conditions, including after failure of one or more propulsion systems;

(ii)the aircraft should allow for a smooth transition from one flight phase to another without requiring exceptional piloting skills, alertness, strength, or workload under any probable operating conditions;

(iii)the aircraft should have sufficient stability to ensure that the demands made on the pilot are not excessive, considering the phase and duration of flight; and

(iv)the assessment should take into account control forces, flight deck environment, pilot workload, and other human factors (HF) considerations, depending on the phase and duration of flight. Subject to a positive evaluation report as per point (2), the competent authority should issue the authorisation.

AMC · AMC2 ORA.ATO.135 — Regulation (EU) No 1178/2011 · ED Decision 2020/005/R · Aircrew Easy Access Rules · EAR revision 25 Nov 2025

All rules in SUBPART ATO – APPROVED TRAINING ORGANISATIONS

Consolidated from the EASA Easy Access Rules (revision 25 Nov 2025, 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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