What is the legal basis for VCA operators to set their own flight time and duty time rules?

The legal basis is that point IAM.GEN.VCA.100(b)(4) does not require compliance with the FTL rules of Regulation (EU) No 965/2012; instead, the operator establishes such requirements in accordance with the relevant national law of the Member State of its principal place of business (or place of establishment/residence if no principal place of business).

Which regulation's Subpart FTL is explicitly not applicable to VCA operators and crew?

Subpart FTL of Regulation (EU) No 965/2012 is explicitly not applicable to VCA operators, their pilots and other crew members.

If a VCA operator has no principal place of business, which law determines the flight time, duty time and rest requirements?

If a VCA operator has no principal place of business, the flight time, duty time and rest requirements are determined by the national law of the place where the operator is established or resides.

GM2 IAM.GEN.VCA.100 Pilot responsibilities

Q: Do VCA pilots have to follow the flight time, duty time and rest requirements of Subpart FTL of Regulation (EU) No 965/2012?

No, point IAM.GEN.VCA.100(b)(4) does not reckon that VCA operators, their pilots and other crew members should comply with the flight time, duty time and rest requirements (FTL) contained in Subpart FTL of Regulation (EU) No 965/2012.

Q: For VCA operations, where are the flight time, duty time and rest requirements established?

For VCA operations, flight time, duty time and rest requirements are established by the operator in accordance with the relevant requirements specified in the national law of the Member State in which the operator has its principal place of business, or, where the operator has no principal place of business, the place where the operator is established or resides.

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GM2 IAM.GEN.VCA.100 Pilot responsibilities

ED Decision 2025/010/R

FLIGHT TIME, DUTY TIME AND REST REQUIREMENTS

(a) Point IAM.GEN.VCA.100(b)(4) does not reckon that VCA operators, their pilots and other crew members should comply with the flight time, duty time and rest requirements (FTL) contained in Subpart FTL of Regulation (EU) No 965/2012[110] which applies to aircrew in CAT operations with aeroplanes.

(b) With regard to VCA operations, flight time, duty time and rest requirements are established by the operator in accordance with the relevant requirements specified in the national law of the Member State in which the operator has its principal place of business, or, where the operator has no principal place of business, the place where the operator is established or resides.

[110] Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 296, 25.10.2012, p. 1) (http://data.europa.eu/eli/reg/2012/965/oj).

Details

Source-Title: GM2 IAM.GEN.VCA.100 Pilot responsibilities View latest amendments

Erulesid: ERULES-1963177438-23847 Compare versions

Domain: Air operations

Amendedby: Issue 1

Applicabilitydate: 9 July, 2025

Entryintoforcedate: 9 July, 2025

Regulatorysource: ED Decision 2025/010/R Navigate

Regulatorysubject: Part-IAM

Typeofcontent: GM to IR (Guidance material to implementing rule)

Parentir: IAM.GEN.VCA.100 Crew responsibilities

Origin: EASA

Category: EAR