TC did it again - ATPL skill requirement amended
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Joined: Apr 2016
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From: Ontario
TC did it again - ATPL skill requirement amended
(5) Skill
(5) Skill
- (a) Within the 12 months preceding the date of application for the licence, an applicant shall demonstrate in flight or in a level C or D full flight simulator, and on the ground, familiarity with and the ability to successfully perform, as pilot-in-command of a multi-engine aeroplane (with no central thrust configuration) required to be operated with a co-pilot as defined in subsection (9), and fitted with instruments and equipment suitable for two crew IFR flight in controlled airspace:
- (i) both normal and emergency flight procedures and manoeuvres appropriate to the aeroplane in which the flight test is conducted and to successfully execute all manoeuvres and procedures set forth in Division XIV for issue of a Group 1 instrument rating.
- (ii) a Pilot Proficiency Check (PPC) for operations under IFR in accordance with Part VII; or
- (iii) a Pilot Proficiency Check (PPC) or Pilot Competency Check (PCC) for operations under IFR in accordance with Subpart 604 conducted by a person designated by the Minister to conduct the flight test.
- (b) An applicant who successfully completes a Line Operational Evaluation (LOE) and a Manoeuvres Validation (MV) from an approved Advanced Qualification Program (AQP) in accordance with Subpart 705 is deemed to have met the requirement of clause (5)(a)(ii).
- (c) For issue of the Airline Transport Pilot Licence - Aeroplane, the Minister shall only endorse a Group 1 Instrument Rating on the licence.
So now, a PPC must be done on an airplane that requires at least two crew pilots AND it must be done as a PIC.
Failure to meet those requirements:
(6) Restricted Licence
(6) Restricted Licence
- (a) Where the applicant has not completed the skill test in an aeroplane required to be operated with a co-pilot as specified in subsection (9), the licence shall be issued with the remark, “Skill test does not meet ICAO requirements.”
Note - changes came in affect December 17, 2025.
Any creative ideas? Because as I see it, no company is going to send you to get a PPC as captain without being able to act as one, unless you go through the restricted and than unrestricted route, assuming the company does not operate to the US.
Joined: Dec 2005
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From: Hong Kong
What is the problem? The only person who needs an unrestricted ATPL is the captain, and he does his check as PIC. Surely it's a good thing that getting an ATPL (a licence to sit in the left seat of an airliner in multi crew operations) requires actually demonstrating that skill?
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Joined: Apr 2016
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From: Ontario
The problem is no company is going to pay you to get a PPC done as a captain if you can't be a captain.
The PPC as a FO used to be enough to obtain the ATPL, but now companies will be expect to pay for a candidate who is not eligible to be a captain.
When you apply to be hired as an FO, you are eligible to be one. Yes you need a PCC/PPC, but you are legally entitled for it.
Not the case with a the ATPL.
Also, MANY people work for companies with PC12 and other airplanes that are NOT a two crew airplanes, yet the insurance require unrestricted ATPL for captains positions. How do you expect those captains to obtained that? They can get an ATPL with ICAO restrictions, but like I said - they won't be able to fly to the US or Europe or even list a US alternate on their IFR flight plan, which is very restrictive.
The PPC as a FO used to be enough to obtain the ATPL, but now companies will be expect to pay for a candidate who is not eligible to be a captain.
When you apply to be hired as an FO, you are eligible to be one. Yes you need a PCC/PPC, but you are legally entitled for it.
Not the case with a the ATPL.
Also, MANY people work for companies with PC12 and other airplanes that are NOT a two crew airplanes, yet the insurance require unrestricted ATPL for captains positions. How do you expect those captains to obtained that? They can get an ATPL with ICAO restrictions, but like I said - they won't be able to fly to the US or Europe or even list a US alternate on their IFR flight plan, which is very restrictive.
Joined: Dec 2005
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From: Hong Kong
Maybe I drank too much last night, I really don't follow your logic! I've never heard of a company that hires or upgrades you as a captain and just chucks the keys to a multi crew jet at you. They train you. They put you through a type rating if you need one or an OCC if you don't. Both scenarios require you to sit in the left seat of a simulator and fly a check. That gives you an ATPL.
As for flying a PC12 - then yes that's a problem, but one for the insurance companies to deal with. There is no difference in skill between a full ATPL done last year in a Seneca and a restricted ATPL done this year in a Seneca.
A captain operating a PC12 as single pilot would only need a CPL by regulation, thus could fly anywhere in the world including the US and Europe. A captain operating a PC12 multi pilot would take a check ride as part of a crew and thus get a full ATPL.
As for flying a PC12 - then yes that's a problem, but one for the insurance companies to deal with. There is no difference in skill between a full ATPL done last year in a Seneca and a restricted ATPL done this year in a Seneca.
A captain operating a PC12 as single pilot would only need a CPL by regulation, thus could fly anywhere in the world including the US and Europe. A captain operating a PC12 multi pilot would take a check ride as part of a crew and thus get a full ATPL.
Last edited by rudestuff; 13th February 2026 at 03:07.
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From: Wherever I go, there I am
I'm not against the idea of having the ATPL tied to two crew operations. It always seemed a little silly to me that one could get license permitting you to act as pilot in command of a transport category aircraft without having any previous two crew or transport category aircraft experience. It's not that doing so takes extraordinary skill, but every other licence or rating was tied to some form of development. The PPL was learning how to fly during the day, the night rating while doing so when it was dark. The CPL was learning the CARs and the basics of how to ply the trade as a professional pilot. The Instrument Rating was learning how not to die in the clouds. The ATPL was always the weird one out - while you did write two exams that might (but might not) examine high altitude operations, the subject material was generally easy if you had flown any sort of complex airplane, so really it was somewhat along the lines of you built a bunch of time, did a PPC, and bob's your uncle you had an ATPL. Now, the ATPL is tied to learning how to work in a two crew environment, as that's where you use the licence: the airlines. While most pilots make the transition into two crew ops just fine, I've come across a few ex-military fighter guys and long-time instructors who could have benefited from a little more time sitting right seat before they upgraded, but they were upgraded because they had the magic letters in their ADB and the next guy did not.
I'm not so sure of that. 421.34(9) says that one of the ways to meet the "required to be operated with a co-pilot" is for the company operations manual of an air operator or private air operator states that two pilots are required. I assume (meaning I would argue the point with TC) this means even if the type certificate only requires one pilot.
Say you run a company that has a mix of Navajos, King Airs, Twin Otters, and maybe a Dash-8 or ATR or two, and you run all of them as two crew. You've got a pilot whose career path you're pretty certain on, but they're right seat of any of those aircraft right now. So you throw them left seat of the Navajo to build up some PIC while they're running on their CPL doing 703 ops. A year or so later you've got enough data to know they're a competent and capable commander, and you want to now upgrade them to the left seat of the King Air, which 704 requires an ATPL for IFR work. So either, you throw them left seat of the King Air for VFR only work on their CPL or you confirm that they have the necessary knowledge and experience requirements met for the ATPL, make the necessary request of TC that this pilot acts as PIC during the PPC, and send them off to their King Air training, knowing the PPC will do double duty. That's not too much different from how it was when I came up.
For those CPL holders who went straight to the airlines, seniority is king and you will either pass or fail your upgrade training - which for most pilots will be a few years on type anyways given the upgrade time in Canada is from as low as 2 years to as long as 12 depending on the airline. Thus, you'll be obtaining an unrestricted ATPL not with 1,500 hours anywhere from 3,000 to 9,000 hours. If the airline doesn't know after no less than 3 PPCs and 3 LOFTs whether you're going to pass your upgrade, you probably shouldn't be sitting left seat anyways. But, let's say you're in this position and you just want the unrestricted licence while you sit right seat - get it out of the way kind of thinking. You could always ask the airline to allow you to act as PIC on your next PPC and "challenge" the flight test from the left seat without you actually upgrading to Captain. If you fail, maybe there is a monetary penalty for wasted sim resources, along with some form of clause in the contract that said any F/O challenging the upgrade flight test would not be upgraded or given any additional pay just because they now held an ATPL, but that's one creative way to get around it...that would be somewhat the same as PICUS is right now - you're able to log a bit of time as PIC, but you're not the Captain.
Where this will have the largest impact is on flight instructors, pilots flying their plane around to build time, and pilots wanting to hop to another company to upgrade. Thats where things could get interesting.
no company is going to send you to get a PPC as captain without being able to act as one
Say you run a company that has a mix of Navajos, King Airs, Twin Otters, and maybe a Dash-8 or ATR or two, and you run all of them as two crew. You've got a pilot whose career path you're pretty certain on, but they're right seat of any of those aircraft right now. So you throw them left seat of the Navajo to build up some PIC while they're running on their CPL doing 703 ops. A year or so later you've got enough data to know they're a competent and capable commander, and you want to now upgrade them to the left seat of the King Air, which 704 requires an ATPL for IFR work. So either, you throw them left seat of the King Air for VFR only work on their CPL or you confirm that they have the necessary knowledge and experience requirements met for the ATPL, make the necessary request of TC that this pilot acts as PIC during the PPC, and send them off to their King Air training, knowing the PPC will do double duty. That's not too much different from how it was when I came up.
For those CPL holders who went straight to the airlines, seniority is king and you will either pass or fail your upgrade training - which for most pilots will be a few years on type anyways given the upgrade time in Canada is from as low as 2 years to as long as 12 depending on the airline. Thus, you'll be obtaining an unrestricted ATPL not with 1,500 hours anywhere from 3,000 to 9,000 hours. If the airline doesn't know after no less than 3 PPCs and 3 LOFTs whether you're going to pass your upgrade, you probably shouldn't be sitting left seat anyways. But, let's say you're in this position and you just want the unrestricted licence while you sit right seat - get it out of the way kind of thinking. You could always ask the airline to allow you to act as PIC on your next PPC and "challenge" the flight test from the left seat without you actually upgrading to Captain. If you fail, maybe there is a monetary penalty for wasted sim resources, along with some form of clause in the contract that said any F/O challenging the upgrade flight test would not be upgraded or given any additional pay just because they now held an ATPL, but that's one creative way to get around it...that would be somewhat the same as PICUS is right now - you're able to log a bit of time as PIC, but you're not the Captain.
Where this will have the largest impact is on flight instructors, pilots flying their plane around to build time, and pilots wanting to hop to another company to upgrade. Thats where things could get interesting.
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From: Wherever I go, there I am
Also, MANY people work for companies with PC12 and other airplanes that are NOT a two crew airplanes, yet the insurance require unrestricted ATPL for captains positions. How do you expect those captains to obtained that? They can get an ATPL with ICAO restrictions, but like I said - they won't be able to fly to the US or Europe or even list a US alternate on their IFR flight plan, which is very restrictive.
Joined: Dec 2005
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From: Hong Kong
A restricted ATPL sounds very much like a non-licence, just like a frozen ATPL - it's basically a CPL with a fancy name.
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From: cowtown
Lots of changes coming after the ICAO audits . Medicals standards and Medevac operations changes are coming according to the local scuttlebutt expert . Work duty and flight duty are going to be the flavour of the month at the ice cream shoppe ( I scream shoppe ) 
Thread Starter
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From: Ontario
So many medavac are forced to officially change their COM to single pilot now. I won't name them, but even the biggest one is moving into a single pilot operation and forcing the province to change their contract.
The province tried to contact TC - TC refuse to change the amendment.
Since most operates PC12, they won't be even eligible for the restricted ATPL (the Multi Engine part is non-negotiable).
Having said that - they will operate two pilots and ATPL requirement for the PIC will be removed, since officially they are going to be a single pilot.
That is straight out from their chief pilot
Last edited by aviran; 19th March 2026 at 17:40. Reason: typo
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From: Canada
It did.
So many medavac are forced to officially change their COM to single pilot now. I won't name them, but even the biggest one is moving into a single pilot operation and forcing the province to change their contract.
The province tried to contact TC - TC refuse to change the amendment.
Since most operates PC12, they won't be even eligible for the restricted ATPL (the Multi Engine part is non-negotiable).
Having said that - they will operate two pilots and ATPL requirement for the PIC will be removed, since officially they are going to be a single pilot.
That is straight out from their chief pilot
So many medavac are forced to officially change their COM to single pilot now. I won't name them, but even the biggest one is moving into a single pilot operation and forcing the province to change their contract.
The province tried to contact TC - TC refuse to change the amendment.
Since most operates PC12, they won't be even eligible for the restricted ATPL (the Multi Engine part is non-negotiable).
Having said that - they will operate two pilots and ATPL requirement for the PIC will be removed, since officially they are going to be a single pilot.
That is straight out from their chief pilot
Thread Starter
Joined: Apr 2016
Aviation Qualifications: CPL
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From: Ontario
There must be more to that story. Even today, if you operate a type that's approved for single pilot operations, the PIC does not need to hold an ATPL even when you operate multicrew. I think Pemiter/Bearskin had a couple of metros that were operated multi crew with captains without an ATPL, due to the certification of those airframes.
