Flight Data Monitoring (FDM), which analyzes FDR data to accomplish things like ensuring that pilots are following SOP's, is a requirement for EASA's Third Country Operators (TCO) certification, however certain (older) aircraft do not seem to require an FDR.

Does this effectively change the requirement so that an FDR must be installed in an aircraft in order to accomplish FDM or is there an exception for FDM as well? I have been unable to find anything specifically addressing this.

  • $\begingroup$ Related documents: Annex III To ED Decision 2020-12-017R, ORO.AOC.130 and EU CAA CAP739 Flight Data Monitoring $\endgroup$
    – Ron Beyer
    Aug 11, 2016 at 1:47
  • $\begingroup$ Page 185 of the CAP739 document has some interesting tables that may help to clear this up. $\endgroup$
    – Ron Beyer
    Aug 11, 2016 at 1:54
  • $\begingroup$ @RonBeyer Interesting reading, but I don't see anything in either document which covers what I asked. $\endgroup$
    – Lnafziger
    Aug 11, 2016 at 2:58
  • $\begingroup$ Yeah its not a straight answer, probably just a few pieces to a complicated puzzle of EASA regulations. I did find some references that QAR's may be used instead of FDR's, I'm not sure though if a QAR would be an easier/cheaper install than an FDR/CVR. It is also possible that nobody is using an older aircraft over the 27,000kg requirement where an FDM would be required, I guess the only way to know would be to look at all the equipment of operators not on the EU ban list... $\endgroup$
    – Ron Beyer
    Aug 11, 2016 at 3:13
  • $\begingroup$ @RonBeyer Well, from what I understand, a QAR works in conjunction with an FDR and simply records data from it to an easily accessible / replaceable media. At any rate, I agree that it's complicated, which is what led me to ask this question in the first place, lol. $\endgroup$
    – Lnafziger
    Aug 11, 2016 at 4:17

1 Answer 1


For 20 PAX and more, it becomes mandatory.


Les boîtes noires sont obligatoires sur les appareils de transport public d'au moins vingt sièges.

  • $\begingroup$ My French is rusty, but the context of the article seems to be talking about a CVR, while the question is specifically asking about an FDR. Either way, the primary source of a regulation carries a lot more weight than what some reporter thinks he understood. (Not that the press ever gets their reporting wrong about aviation facts, right?) $\endgroup$
    – Ralph J
    Jun 9, 2019 at 20:26
  • $\begingroup$ It says the black boxes( in plural) become mandatory for 20 pax and more. Nevertheless I agree it is not strictly an aviation document. $\endgroup$
    – user40476
    Jun 10, 2019 at 9:43

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