SEP revalidation 7 weeks after expiration

[Level Attitude]

This is just so wrong!

Revalidations and Renewals do not just happen by magic, it is up to the Licence Holder (Pilot) to apply for them.

After any successful Licence Proficiency Check, the Examiner would, undoubtedly, just complete the process for the Candidate automatically.

However, for SEP Revalidation by Experience, the Licence Holder must apply to an authorised person for the actual Revalidation: CAA Representative, any FE, or the specific individual FI who carried out the required 1 Hour Dual Flight.

The OP is correct that:

that the pilot has the right do do all of 12 hours within 12months.....that means he may do the 12 th in the last evening before expiration

However, meeting the requirements is not Revalidation, which is defined as “the administrative action” – ie completing the paperwork.

So any Licence Holder needs to also plan, and allow the time, for this and, by definition, if the administrative action is not carried out during the current validity of a Rating then IT IS NOT a Revalidation.

ANNEX I [PART-FCL] SUBPART A GENERAL REQUIREMENTS

FCL.010 Definitions
For the purposes of this Part, the following definitions apply:

‘Revalidation’(of, e.g. a rating or certificate) means the administrative action taken within the period of validity of a rating or certificate which allows the holder to continue to exercise the privileges of a rating or certificate for a further specified period consequent upon the fulfilment of specified requirements.

The OP says he went to many FIs to try and get his “Revalidation” signed, but none of them would have been able to even if within the timeframe as, unless they had flown the DUAL Flight with him, they would not be authorised to do so.

The OP was wrong to try and challenge this but, even more worrying as they are going against their own definitions, EASA were wrong to allow this.