EU Regulatory Correction in Pilot Licenses: What ATOs Must Review in 2026

Key data

Approved aviation schools (ATO) and civil aviation authorities of Member States have a specific task ahead: to review the corrected texts of the Commission Implementing Regulation (EU) 2019/1747 and compare them with their current procedures. This correction of errors, published on 4 August 2026, does not introduce new obligations from scratch, but it may alter the correct interpretation of requirements already in force.

Regulation 2019/1747 amended Regulation (EU) No 1178/2011, which is the European base standard on flight crew licenses and certificates. The inaccuracies corrected affect three specific areas: the requirements applicable to certain pilot licenses, the standards for approved training organizations (ATO) and the obligations of national competent authorities. Any internal procedure that was designed following the previous wording must now be compared with the corrected text.

What does this regulation establish?

This publication is a correction of errors ("errata") of Commission Implementing Regulation (EU) 2019/1747, which in turn amended Regulation (EU) No 1178/2011. Corrections of this type remedy technical or drafting inaccuracies detected in the original text published in the EU Official Journal (OJ L 268 of 22.10.2019).

The areas affected by the correction are as follows:

Although the text does not detail each specific error corrected (something common in this type of publication), the practical impact can be significant: corrected wording may change which requirements are enforceable, when and to what extent. Ignoring a correction of this type is equivalent to working with an outdated version of the regulation.

Economic and operational impact

Unlike new regulation with implementation dates and direct costs, a correction of errors generates a cost of internal review and adaptation that falls on the affected organizations. The main operational impacts are:

• Review of manuals and internal procedures: ATOs that have documented their training and approval processes based on the previous text must compare those documents with the corrected version.
• Possible update of training programs: If the correction affects rating or license renewal requirements, curricula and evaluation criteria may need adjustment.
• Risk of non-compliance in audits: National competent authorities conduct inspections and audits of ATOs. Working with the text prior to the correction may generate non-compliance findings.
• Impact on pilots in renewal process: If the correction affects license or rating renewal requirements, pilots with ongoing processes must verify that they meet the requirements according to the corrected text.

No penalty amounts or direct regulatory costs associated with this specific correction have been published. The actual cost for each organization will depend on the scope of changes in the corrected texts and the degree of divergence with their current procedures.

Who does it affect?

• Approved Training Organizations (ATO): Aviation schools with EASA approval that train pilots under the framework of Regulation 1178/2011. They must review their training organization manuals (TOM) and approval procedures.
• Pilots and license applicants: Especially those in the process of obtaining, renewing or extending ratings affected by the corrected articles.
• Flight crews with valid certificates: Any crew member whose certificate is subject to the requirements of Regulation 1178/2011 as amended by 2019/1747.
• National Civil Aviation Authorities: In Spain, the State Agency for Air Safety (AESA) must update its supervision procedures and ATO approval criteria in accordance with the corrected text.
• Air operators: Airlines and operators that manage the training and rating of their crews may be indirectly affected if their associated ATOs must modify programs.

Practical example

A Spanish ATO with EASA approval that provides type rating training courses for commercial pilots has documented its approval and renewal procedures following the text of Regulation 2019/1747 published in October 2019.

Following the publication of this correction of errors on 4 August 2026, the ATO's compliance officer must:

1. Download the corrected text from the EU Official Journal and compare it article by article with the previous version.
2. Identify whether the changes affect the rating or renewal requirements that the ATO currently manages.
3. If there are discrepancies, update the Training Organization Manual (TOM) and communicate it to AESA before the next supervision audit.

Failure to do so may result in a non-compliance finding in the next AESA inspection, with the resulting obligation to implement corrective actions within the deadline.

What should companies do now?

1. Download the corrected text: Access the EU Official Journal and obtain the corrected version of Regulation 2019/1747 to compare it with the previous version (OJ L 268 of 22.10.2019).
2. Identify the affected articles: Locate exactly which requirements have been corrected: licenses, ratings, renewals or ATO approval procedures.
3. Review internal documentation: Compare training organization manuals, approval procedures and evaluation criteria with the corrected text.
4. Update procedures if necessary: If discrepancies are detected, update internal documentation and record the change with date and regulatory reference.
5. Inform the competent authority: If the changes affect already granted approvals or ongoing programs, communicate this to the national civil aviation authority (in Spain, AESA) to avoid audit findings.
6. Verify the status of pilots in renewal process: Check that license or rating renewal files in process comply with the requirements according to the corrected text.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202690653