Applicable legal framework

GD No. 204/2020 consists of eight annexes, divided into subparts, sections and appendices:

• Annex 1 – Part FCL
• Annex 2 – Conditions for conversion of existing national licences and ratings for aeroplanes and helicopters
• Annex 3 – Conditions for recognition of licences issued by or on behalf of third countries
• Annex 4 – Part MED
• Annex 5 – Cabin crew qualification involved in commercial air transport operations — Part CC
• Annex 6 – Requirements for the Civil Aviation Authority — Part ARA
• Annex 7 – Requirements for organisations for aircrew — Part ORA
• Annex 8 – Requirements for declared training organisations (DTO) — Part DTO

For compliance with the provisions of GD No. 204/2020, the AMC&GM to GD No. 204/2020 may be applied, available at: AMC&GM la HG nr.204/2020

The civil aeronautical procedures and instructions for aircrew certification (PIAC-CPN) are available at: PIAC-CPN 

The forms to be completed by applicants are available at: Anexe

The implementation period for the provisions of GD No. 204/2020 has been set at two years from the date of entry into force.

In accordance with the provisions of GD No. 204/2020:

1. JAR-compliant licences issued or recognised by the CAA at the date of application of this Regulation shall be deemed to have been issued in accordance with this Regulation. The CAA shall replace these licences with ones complying with the format laid down in Annex 7 (Part ARA) within two years of the entry into force of this Regulation.
2. Non-JAR-compliant licences, including all associated ratings, certificates and/or authorisations issued or recognised by the CAA before the application of this Regulation, shall be converted by the CAA into licences compliant with Annex 1 (Part FCL).
3. Non-JAR-compliant licences shall be converted into licences and ratings compliant with Annex 1 (Part FCL) in accordance with:
   1. the provisions of Annex 2; or
   2. the elements set out in the conversion report.
4. Pilots holding IR ratings without PBN privileges may only operate on routes and perform approaches that do not require PBN privileges, and renewal of their IR ratings shall not require any PBN element, within two years of the entry into force of this Regulation; after that date, PBN privileges shall be required for each IR rating.

In accordance with GD No. 204/2020, cabin crew members holding, before the date of application of GD No. 204/2020, a cabin crew attestation issued by the CAA in accordance with the requirements in force at that time:

1. shall be deemed to comply with this Regulation if they meet the applicable requirements for training, checking and recent experience from JAR-OPS 1; or
2. if they do not meet the applicable requirements for training, checking and recent experience from JAR-OPS 1, shall complete all necessary training courses and checks before being deemed to comply with this Regulation; or
3. if they have not been engaged in commercial aeroplane operations for more than five years, shall complete the initial training course and pass the associated examination in accordance with the requirements of Annex 5 (Part CC) before being deemed to comply with this Regulation.

In accordance with the provisions of GD No. 204/2020:

1. Pilot training organisations holding JAR-compliant certificates issued or recognised by the CAA before the date of application of this Regulation shall be deemed to hold a certificate issued in accordance with this Regulation. In such a case, the privileges of these organisations are limited to the privileges included in the certificate issued by the CAA.
2. Pilot training organisations shall adapt their management system and training programmes, procedures and manuals to comply with Annex 7 (Part ORA) within two years of the entry into force of this Regulation.