Licence Validity Across a Registry Change
A pilot holds a commercial pilot licence and a Class 1 medical certificate issued by State A. She has 1,850 hours total time, 220 hours on type, and her medical was issued 14 months ago with no limitations. She has just been hired by an operator in State B to fly a twin turboprop on scheduled regional services. State B's regulations require a valid Class 1 medical, an instrument rating, and a type rating for the aircraft. Her instrument rating was issued by State A and is current. Her type rating was issued by State A four years ago and is still valid under State A's rules, which do not require recurrent training for the type rating itself, only for the instrument rating. State B requires type rating proficiency checks every 12 months. She has not flown the type in 11 months. The operator plans to put her on the line in 10 days after a two-day differences course. She has not yet applied for validation of her licences in State B.
1. Can the operator legally place her on the line in 10 days? Work through the licensing and medical requirements under the Chicago Convention and Annex 1.
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Not on the current plan, for three independent reasons.
Licence validation. Article 32 of the Chicago Convention requires flight crew to hold licences issued or rendered valid by the State of Registry, and Annex 1 sets the minimum standards for issuance. State B may either issue its own licence or render State A's licence valid. A validation is not automatic; it is an administrative act that State B must complete, usually on the basis of the State A licence, the medical, and any additional requirements State B imposes. Until State B has rendered the licence valid, she cannot act as a flight crew member on a State B-registered aircraft. The operator's plan assumes a validation that has not been applied for.
Medical. Annex 1 requires a Class 1 medical for commercial pilots, and the medical must be current at the time of flight. A medical issued 14 months ago may be within the validity period for a Class 1 under Annex 1 (which sets a 12-month validity for Class 1 in most cases, reducible to 6 months for older pilots or specific circumstances), so this needs checking against State B's implementation. If the validity period has expired, she cannot fly until renewed. The absence of limitations does not extend validity.
Type rating and recency. State A's type rating is valid under State A's rules, but State B requires 12-month proficiency checks. The State B validation will almost certainly be conditioned on meeting State B's recency and proficiency requirements, not State A's. She has not flown the type in 11 months, so she is close to the State B proficiency limit and must complete a proficiency check before line flying. A two-day differences course does not substitute for a proficiency check unless State B's approved programme says it does.
The operator should sequence: apply for validation, confirm medical validity, schedule a State B proficiency check, then line flying.
2. The operator argues that because her State A licence is ICAO-compliant, State B must accept it. Evaluate that argument.
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The argument misreads Article 33 and Annex 1.
Article 33 obliges a Contracting State to recognise licences issued or rendered valid by another Contracting State, provided the issuing State's requirements equal or exceed the minimum standards in Annex 1. But recognition is not the same as automatic authorisation to fly. The receiving State retains the right to verify that the licence meets the minimum standards and to impose additional requirements, including validation procedures, medical currency, recency, and proficiency checks. Annex 1 itself contemplates that a State may render a licence valid subject to conditions.
State B's 12-month proficiency check requirement is a condition of exercising the privileges of the licence in State B, not a re-issuance of the licence. It does not contradict Annex 1; it is a domestic operational requirement that sits alongside the licensing standard. The operator's argument that 'ICAO-compliant means automatically accepted' would, if correct, strip States of the ability to verify competence on their own registry, which is not what Article 33 says.
The practical point is that recognition is a precondition, not a clearance. The operator must still complete the validation, satisfy State B's recency rules, and hold a current medical. The pilot's 11-month gap on type is a real risk factor, and the operator's two-day course does not close it.