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The provider of my EASA Integrated Training Course states that my ATPL theory exams are only valid for 36 months before a CPL or IR skills test.

Where is this regulation listed and described?

Additionally, is this from the date the ATPL theory series is completed, or when the earliest ATPL exam is completed? Finally, do both the CPL and IR skills tests both have to be completed within 36 months, or, just the CPL?

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I don't know much about EASA regulations, but this seems to be a reference to Part FCL.025(c)(1):

(1) The successful completion of the theoretical knowledge examinations will be valid:
[...]
(ii) for the issue of a commercial pilot licence, instrument rating (IR) or en route instrument rating (EIR), for a period of 36 months;
(iii) the periods in (i) and (ii) shall be counted from the day when the pilot successfully completes the theoretical knowledge examination, in accordance with (b)(2).

Having said that, (c)(2) gives a much longer validity period for the ATPL exams:

(2) The completion of the airline transport pilot licence (ATPL) theoretical knowledge examinations will remain valid for the issue of an ATPL for a period of 7 years from the last validity date of:
(i) an IR entered in the licence;
or (ii) in the case of helicopters, a helicopter’s type rating entered in that licence.

My understanding of that is:

  • Your IR theory exam is valid for 36 months from the date of the exam
  • Your ATPL exams are valid for 7 years from the date you receive your IR (although the wording is ambiguous, in my opinion)

It's possible that your provider is combining those two points somehow. The easy thing to do here is simply ask them to explain their statement in more detail and include a reference to the regulations.

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