This has been going on for years.. recall a L-410 FO position at MAN(?) (on a 'N' reg) in the early to mid 90's you pay you fly.... this was the beginning....

EagleJet have been offering the 737 since the late 90's... and recently offered wide-body Captain positions for 50K+

It's one thing RHS P2F bad as it is.... but Widebody Captain? wtf.

Cabin crew scams are ten a penny as well. Engineers... no... too much of a shortage (and not as glamorous).

I know this is an old thread but I’ve been debating some of these questions recently and viewing the overlap between employment law and aviation regulations and struggling to see how airlines are able to legally charge for Type Ratings that include the non-delegable OCC components and are run to company SOPs! It seems very much like cost shifting, disguised employment and debt bondage to me.

I also noted the mention of safety throughout the thread and thought this recent article in the guardian may be of interest if any one revisits this thread.

https://www.theguardian.com/global/2...es-study-warns

One has to ask how safe is it for a pilot who is in masses of debt to be expected to call fatigued when required even though they know their pay will be heavily deducted on a disguised 0 hour Line Training Contract.

Why is nobody asking how is it possible that a 13 hours fdp is legal?

That's the core issue of fatigue, laughable FTLs.

Why can I legally fly an aircraft 18 hours after waking up?
Why is the daily limit only on FDP and not on total duty?
Why can we legally work 60 hours in 5 consecutive days?
Why is split duty even a thing?
Why (in my country) an office worker can't work more than 10 hours (so 8+2 overtime), but I can be rostered a 13 hours fdp (even more, in some circumstances)?

Let's say a certain airline I know that was bonding people illegally in a certain EU state, did it purely as a paper exercise. It was completely illegal. If you are in that company for at least a few months the word would have reached you that people still leave, and no one chases them for the money. Effectively it was an illegal practice (is it illegal if it is not enforced?), that was never enforced. A lot of people were still scared to leave regardless, so in a way it did work for that airline. The so called bonding is a piece of paper a person would have been forced to sign at a joining date in a form of IOU. I can't remember the exact wording, but it was very simply written on one side of A4 paper.

Ive seen group chats from a large carrier where they’re expecting / resulting in regular 18+ hours when you look at the duties they’re assigning people and account for the parts they like to omit.

With respect to pay to fly though and the whole safety question I’d like to put this to everyone.

Let’s assume you’re a new entry pilot 60-100k in debt or paid out already in licensing. A large part of the industry has pivoted it seems to the yellow and blue model of charging for large aircraft type ratings… these type ratings are 30k and coincidentally include the OCC a non-delegable provision of the operator rendering them airline specific… you’ve paid for and are unpaid during this period… amounting more debt. You are then given a contract to operate for the airline as crew for your lifus and beyond… crew definition being indistinguishable from the tests for direct employment you are paid a paltry fee that barely covers living costs, during this time the company also reserves the right to claw back money should you report sick/fatigued. You’re safety pilot released… you’re likely fatigued as they’re running you a new entry onto the line at FTL maximums while you’re still in LIFUS… and you literally can’t afford to call fatigued due to the clear debt bondage and fear of reprisals.

… how is that anything but a safety issue?

Let’s then consider your safety pilot released and the line training captain becomes incapacitated. You’re effectively paying to be there… scared to call fatigued, inordinate stress from debt as you continue to learn your trade… under significant cognitive load in a fast paced environment you have to then ensure the safety of 180+ pax and yourself.

The European system has been corrupted and it’s insidious and even if it doesn’t result in the worst scenario of an accident… what is it doing to the individual people involved is abhorrent.

it cannot be remotely compliant with the overlap between aviation, employment, labour, consumer and even contract law, which tells us regulators are s**ting the bed. As much as I abhor the cost of train tickets… you don’t see train drivers even close to accruing debt to transport passengers and isn’t safety and just culture supposed to be the absolute pinnacle.

Here you are again, on your ill informed soap box.
Many people have answered your questions, but you don’t seem to want to listen. You must be a nightmare on the flight deck.

Stating something doesn’t make it true. You seem very keen to close down arguments without anything of actual substance. I point to observed reality and the overlap of law … you point to the normalisation of something that I am suggesting should be illegal and regulated… I was looking for a debate… odd that on a forum. Got a vested interest that wants you to stop this conversation? I don’t see any other career front loading young people with debt to this extent… you seem to like that. Strange.

I’ve never had a problem on the flight deck, I can’t imagine you’re much of a conversationalist in person you just like to try and shut discussion down with platitudes. Now feel free to toddle off and don’t let me interrupt you servicing that low cost carrier ceo cock you clearly like to caress. 👍

Oh and I can only assume seeing as this thread was pretty dusty you sought me out for a cheap uniformed shot. My god you must have a lot of time 😂.

Dude, chill. He’s just explaining how broken the pay to fly setup actually is. He’s not ranting — he’s laying out a genuine safety and ethics issue. Maybe try engaging with the point rather than shooting the messenger.

Hey Dude, he has been on another forum banging on about how the regulator should be responsible for industrial aspects of pilots contracts,
I think that we all recognise that pay to fly is BS, but it’s not something for the regulator. It’s for the unions.

I refer you to your previous posts on a different forum, and the multitude of responses therein.
So no vested interest, just curious why you are trying to reinvent your old argument on a different forum.
Whats very interesting is that instead of a robust response, you have resorted to vulgar schoolboy insults. Well done.
Good luck getting a real job in a 2 crew environment champ.

So what… he’s raising the issue which people seem happy to pave over. I have to echo him why are we giving the regulators a free pass for not doing their job? “To regulate” literally means to control something — especially a business activity — by means of rules and regulations. If the operators they oversee are breaching employment law, then ensuring compliance with those laws is part of that job.

Unions are meant to be the backstop when regulators fail and to set better Ts&Cs … pay to fly isn’t a T&C is exploitation and now we’re in a scenario where all sides are failing — and everyone’s just passing the buck.

This guy is making that point and you’re shooting him down for it as if other opinions have no validity… I can’t excuse his joke but I can understand his frustration.

The role of the regulator, be it the UKCAA, FAA, EASA, CASA, GCAA etc is to regulate those who hold an AOC, with respect to the regulations and safety.
It is not the role of a regulator, or any government department, to get involved in industrial aspects of the AOC holder.
Similarly, the regulator must not get involved in the running of a business. It is not their area of expertise.

Ts & Cs are agreed, or set, by the operator, sometimes with union consultation. And sometimes not.
Ultimately, it is up to the individual to accept, or otherwise, an employment offer from an airline, depending on their view of the Ts & Cs. If not enough people accept the Ts & Cs, then market forces will drive an increase. This is something that we have seen several times since the 60s.

Regardless of your view of pay to fly (something I personally find offensive), if pilots accept this, then you can’t blame the airlines.
Similarly, airlines that make pilots pay for type ratings is, in my view, distasteful. But pilots continue to sign up for these.
Luckily, most airlines no longer require a pilot to,pay for their type ratings, which is good. And we are seeing more airlines fully sponsoring cadet pilot training, another positive step.
But these are business decisions, and it isn’t for the regulator to get involved. The regulator is there to ensure safety & compliance with the regulations.

I take your point — the regulator isn’t there to negotiate pay or interfere with industrial relations.



But when an operator is breaking employment law to maintain a structure that’s non-compliant, that surely does fall within the regulator’s remit — even outside of safety. Once illegality becomes part of how the business operates, it’s no longer a “terms and conditions” issue, it’s a compliance one.

And let’s not forget — the regulator already regulates crewing. Crew planning, fatigue management, and minimum rest requirements all sit squarely within the scope of oversight. The crew themselves are indistinguishable from employees in practice, so turning a blind eye to unlawful employment structures undermines that entire system.

So while I agree they shouldn’t set Ts & Cs, ensuring operators comply with all applicable law — including employment law — is still part of the job. Otherwise, you end up regulating aircraft, not airlines.


I think that’s what he’s getting at — not that regulators should be setting pay, but that they should be stopping hidden pay-to-fly schemes that only exist because no one’s enforcing the boundaries of the law.

Regulators are tasked with ensuring that operators remain compliant with the terms of their AOC, set out within their Ops manuals, which are governed by the applicable regulations. Those regulations are derived from an overarching law, or act. They are specific to the task at hand, ie operating aircraft for (eg) CAT/RPT, Public Transport etc.
They don't, never have, and never should cover employment law. That’s a role for departments other than the aviation regulator. For example, the fair work commission in Australia. The closest an aviation regulator will come to employment law is the airlines approved CTL scheme or FRMS.
Again, pay to fly is an ‘agreement’ between the airline and the pilot. An agreement. No one forces pilots to sign up to P2F schemes, or poor Ts & Cs. There is always a choice to agree the contract.
To be fair, there are far fewer of these schemes than, say, 10-15 years ago, as market forces have forced airlines to change behaviour.
If anyone needs to step up, it’s the unions. They have the power to influence airline contracts.

I think part of the problem is that people keep looking at each regulator in isolation. Aviation authorities aren’t supposed to operate in a vaccum — they’re meant to work in tandem with employment and labour regulators to make sure the whole operation stays lawful.


An AOC isn’t just about flight ops, it’s a licence to operate within the legal framework of the state. If an airline’s crewing or employment structure breaches those laws, it stops being an “industrial” issue and becomes an operator running unlawfully under a state-issued certficate

Take France for example — pay-to-fly is considered illegal under French social and employment law. The DGAC still issues and oversees AOCs under the EASA framework. So if an airline was running that kind of scheme in France, who steps in? The labour inspectorate, the DGAC, or EASA? If none of them act, it’s a pretty clear regulatory gap.

And this isn’t a problem you see in most other industries, because they don’t cross borders or hide behind another regulator’s remit. Aviation sits in that grey area where everyone assumes someone else is responsible — and that’s exactly how these practices survive.


Which is what I think Prometheus is getting at — yet people keep framing it as “choice” or a union issue, when in reality we’re talking about airlines that are clearly breaking the law. I do agree though the unions cowardice and lack of understanding themselves is a primary reason this has been able to continue.

Aviation regulators have no requirement to work with labour/employment regulators. They are required to regulate in accordance with ICAO SARPs and national regs, taking into account any ICAO variations filed by the nation.
The AOC is primarily centred around Flight Ops, with some elements of engineering & Ground Ops included. The Airline which holds the AOC will then have other business related functions too. In addition, there may be some maintenance functions requiring a separate approval but not forming part of the AOC. HR functions are part of the business, not the AOC.
Separately, there may be may be an Operating Licence which covers off the financial viability of the entity.

Airlines are not breaking the law by choosing to pay pilots poorly, have them on local contracts, or implement P2F. What law do you think they are breaking.
Again, it is a choice by the pilot. No one forces them to sign a rubbish contract, and they should not. It’s supply & demand, and this is legal. Note, I am not saying that legal,is sensible in this case, but it’s still legal.

Imwouldnt agree that the unions are cowards - they will do what their members ask of them. So if pilots are not a member of a union, then nothing will happen. Remember, the unions are the members. If the members are content, then why would the union rock the boat.

The bottom line is, as I see it, if pilots want the better Ts & Cs they deserve, do not enter into rubbish contracts, and then cry foul! History shows us that the supply/demand equation aligned with good union representation for the members, works.

Damn man, you guys got me digging through regs and statute last night 😅This was not a healthy use of free time lol. Sorry this is long but it needs laying out — I’ve linked the docs below.

There’s this common misconception that if something’s written in a contract it’s automatically legal — it isn’t. You can’t contract out of statutory law. Employment law sets minimum standards that can’t be signed away. An employer also can’t have you sign a contract that takes your pay below minimum wage — that’s a statutory floor, not a choice. Pay-to-fly breaches that through illegal deductions, even when disguised under shell companies or “training” fees.

By law, mandatory training must be an employer cost, not a worker’s debt. A type rating might arguably be private training, but OCC, LIFUS and any operator-mandated safety training are part of doing the job — legally they’re the company’s cost of doing business. The line between genuine private training and “operator-required” compliance is being blurred on purpose, shifting those costs onto the people who make the business run.

And yes, it is the regulator’s job to ensure legal compliance. Under ORO.GEN.105, operators must comply with all applicable requirements of the State. Under ARO.GEN.300, the CAA can only issue or maintain certificates when it’s satisfied that the operator complies with those requirements. That means the CAA has a duty to make sure operators follow all UK law, not just aviation rules.

The Department for Transport’s own CAA Framework Document (2023) says the same thing:
“1.2 The DfT and the CAA share the common objective of delivering safe, secure, accessible, competitive and sustainable aviation and aerospace activities and supporting consumers. To achieve this the CAA and the DfT will work together in recognition of each other's roles and areas of expertise, providing an effective environment for the CAA to achieve its duties and objectives through the promotion of partnership and trust and ensuring that the CAA also supports the strategic aims and objectives of the DfT and wider government.”
https://assets.publishing.service.gov.uk/media/67d2edd84702aacd2251cbd7/dft-caa-public-corporation-framework.pdf

The CAA’s own Regulatory Enforcement Policy goes even further:
“Where we identify that non-compliance falls under the enforcement remit of another organisation we will seek a commitment from that organisation that appropriate action will be taken.”
https://www.caa.co.uk/publication/download/15394

That’s a clear acknowledgment that regulation overlaps — and that they recognise a duty to act when non-compliance falls within another regulator’s remit.

UK Labour and Employment Enforcement Authorities:
• Employment Agency Standards Inspectorate (EAS) – regulates agencies under the Employment Agencies Act 1973.
• HMRC (NMW team) – enforces the National Minimum Wage Act 1998; investigates underpayment and unlawful deductions.
• Gangmasters & Labour Abuse Authority (GLAA) – tackles exploitation and debt bondage under the Gangmasters (Licensing) Act 2004.
• Health & Safety Executive (HSE) – enforces the Health and Safety at Work etc. Act 1974; has a formal MoU with the CAA.
• Employment Tribunals – enforce statutory rights under the Employment Tribunals Act 1996.

Under the Regulators’ Code (2014), § 4.1–4.2, regulators must “share information about compliance and risk… to help target resources and minimise duplication.” That’s binding guidance under s. 23 of the Legislative and Regulatory Reform Act 2006 — requiring UK regulators, including the CAA, to cooperate with others.

https://assets.publishing.service.go...ce=chatgpt.com

Clearly, that cooperation hasn’t worked. The government’s now creating the Fair Work Agency, a new body to take over from EAS, HMRC (NMW) and the GLAA because the current system isn’t joined up as it should be.
https://assets.publishing.service.go...ork-agency.pdf

So even the government and regulators basically admit this is a regulatory failure, not just an industrial one — they’re literally building a new regulator to fix what the others haven’t been doing.

There is no doubt that it’s a dogs @r5e.
There is no quick fix, and there appears to be no will to find one!
But both parties need to step up if there is to be a solution. The airlines will do what they can, that’s the nature of capitalism. Most will do the right thing, but a few will ‘try it on’. The reality is that the CAA/CASA/EASA/FAA do not look beyond that required to grant a certificate.
Of course, OCC/LFUS should be paid at the appropriate rate by the airline, but it’s quite likely that even a so called training wage will be above minimum wage levels in most countries. Therefore, compliance is assured.
Pay 2 Fly is a different subject, and is not the big thing it once was. Educate me - where is this a thing these days.

The CAA framework document is, in my view, a cop out in general, and still does not talk to industrial issues. And nor should it.
You talk about illegal contracts, and that’s a fair point. Do you have an example of one, or what makes it illegal? Most sharp operators have equally sharp lawyers, who ensure that they comply with the letter of the law.

I do maintain that pilots should be careful what they sign up to. If they are a member of a union, seek advice. If not, go see the friendly local lawyer, or citizens advice (or equivalent).

I also maintain that most airlines do the right thing contractually. They have to. The Ts & Cs might be ordinary, but they are likely legal.

But given that most aviation regulators don’t accept each others certificates, there’s little chance of them seeking to work better with other non aviation regulators

But isn’t that pretty much the point Prometheus has been trying to make all along? Nobody’s saying the regulators themselves are causing this — the issue is that they’re not acting/telling other regulators to act. And while this might not have started as an aviation-specific problem, the government’s clearly recognised the wider regulatory inaction and is now trying to fix it.He’s also been saying that off-loading costs and hiding OCC or company-specific training inside the “type rating” is a way of evading the letter of the law. On paper it might look compliant, but only if you don’t look too closely. Let’s not pretend companies and lawyers always act lawfully — the Post Office scandal and Dieselgate both looked “legitimate” until people dug into the detail. These things are often hiding in plain sight until someone joins the dots.

Does anyone actually believe that pilots operating for certain carriers really “work for” some third-party agency? Or do they, in reality, work for the operator that trains them, rosters them, supervises them, disciplines them, and literally has to legally onboard them as crew? In both aviation and employment law, crew and employee are practically indistinguishable. That’s the whole point of the Lutz case — it exposed “agency” and “contractor” setups as disguised employment. The reality is that for any large airline, you simply shouldn’t be able to have anyone other than a direct employee in the cockpit if you expect to meet the joint requirements of aviation and employment law. Anything else isn’t innovation — it’s evasion dressed up as flexibility.

Just because an airline creates a shell company, issues a sham contract, and charges an inflated “training fee” that obviously includes company SOPs and OCC time doesn’t suddenly make it clean. it actually means there’s a failure of regulation. What he’s getting at, I think, is that power and scale allow them to normalise practices that would be called fraud anywhere else. They can literally shape the market around their own rule-bending. Paying for the type with a certain low-cost carrier is, in effect, all those dodgy things rolled into one — it’s still pay-to-fly, just dressed up way better incredibly clever tbf but still immoral and likely a systemic threat to flight safety if pilots are so in debt they can’t call sick.

We’re taught a lot about power dynamics in the cockpit, but the same thing happens at the organisational level too — when a company gets big enough, it can consolidate power over its own regulators. Look at Boeing and the MAX crashes. That’s what happens when oversight becomes dependent on the very people it’s meant to police.

I think everyone here probably agrees that the regulators have many issues and they’re clearly not necessarily doing everything they can or should be doing… which is probably why these conversations need to be had here and in the wider community.

There are a lot of companies around the world, good airlines, who use contract pilots via specialist aircrew providers. Are you suggesting they should be regulated by FAA/HKCAD/GCAA/EASA/CASA/UKCAA?

There is a solution - if you don’t like the Ts & Cs, don’t sign the contract! Simplistic maybe, but it will work. Supply vs demand always works.