Self-study hours do not count towards the required 100 hours of theoretical knowledge instruction. Relevant essential requirements for aircrew made in annex IV to the Basic Regulation include:
1.8. Training course
1.8.1. Training must be executed through a training course.
1.8.2. A training course must meet the following conditions:
(a) a syllabus must be developed for each type of course; and
(b) the training course must comprise a breakdown of theoretical knowledge and practical flight instruction (including synthetic training), if applicable.
1.9. Instructors
1.9.1. Theoretical instruction
Theoretical instruction must be given by appropriately qualified instructors. They must:
(a) have appropriate knowledge in the field where instruction is to be given; and
(b) be capable of using appropriate instructional techniques.
1.9.2. ...
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Compliance with these essential requirements is mandated by article 20 of the Basic Regulation.
Article 20
Essential requirements
Pilots and cabin crew involved in the operation of aircraft referred to in point (b) of Article 2(1), other than unmanned aircraft, as well
as flight simulation training devices, persons and organisations involved in the training, testing, checking or medical assessment of
those pilots and cabin crew, shall comply with the essential requirements set out in Annex IV.