CASA EX11/25 — Medical Certification (Basic Class 2 Medical Certificate) Exemption 2025

The central new concept is the Aviation Medical Certificate (Basic Class 2), defined in section 4. It is not a conventional aviation medical certificate. It is a CASA-issued certificate granted only after a person has been assessed by a medical practitioner as meeting the "medical standard basic class 2" and after CASA itself is satisfied that standard is met. The certificate records an expiry date derived from the recommended date of next review on the person's most recent Fitness Report (CASA Form 1474).

The medical standard basic class 2 is defined by reference to the Austroads commercial vehicle driver medical standards for an unconditional licence, that is, the standards that apply to drivers of heavy vehicles, public passenger vehicles, or vehicles carrying dangerous goods, as published in "Assessing fitness to drive for commercial and private vehicle drivers" (6th edition, 2022). Crucially, the standard applies without conditions or restrictions other than a requirement to wear glasses or a hearing aid. A person who meets those standards in all other respects qualifies even if they need corrective lenses or hearing aids, but not if they require any other limitation. Note 1 to the definition makes this explicit.

The Fitness Report (CASA Form 1474) is the document that records the outcome of the medical practitioner's assessment against the basic class 2 standard and recommends a date of next review. That recommended date functions as the operative expiry trigger for eligibility under the exemption: no condition in the instrument allows flying after that date, even if the Aviation Medical Certificate (Basic Class 2) itself has not yet formally expired.

The instrument uses the phrase "current Aviation Medical Certificate (Basic Class 2)" with precision. Currency runs from the date of issue to the date and time of expiry recorded on the certificate. This definition is separate from the currency definition for recreational aviation medical practitioner's certificates, which tracks regulation 61.010 of CASR.

The instrument distinguishes throughout between different classes of actor: the pilot (or trainee), the flight instructor, the flight examiner, the Part 141 operator, the Part 142 operator, and the head of operations. Each class gets its own specific exemption because each class faces its own specific offence provision under Part 61 or Parts 141/142 of CASR. An exemption granted to the pilot does not automatically exempt the flight instructor who approved the solo, which is why section 7 exists separately.

The instrument affects several distinct groups.

Student pilots who hold a current Aviation Medical Certificate (Basic Class 2) are affected by sections 5 and 6. They can now conduct solo flights in both recreational and non-recreational aircraft without a class 1 or 2 medical certificate, provided they comply with the section 6 conditions.

Applicants for the grant or extension of a private pilot licence are affected by sections 8 and 9. They can sit a flight test without a standard aviation medical certificate.

Applicants for the grant or extension of a recreational pilot licence are affected by sections 11 and 12, on the same basis.

Holders of pilot licences applying for an aircraft class rating or pilot type rating are affected by sections 14 and 15 and section 15A.

Existing holders of private pilot licences who want to exercise those privileges in day-to-day flying are affected by sections 16, 17, and 18.

Existing holders of recreational pilot licences are affected by sections 19, 20, and 21.

Flight instructors who approve solo flights for student pilots in the Basic Class 2 scheme are directly exempted by section 7, because subparagraph 61.1225(1)(b)(iii) of CASR would otherwise render them liable for an offence.

Flight examiners conducting tests for private pilot licences, recreational pilot licences, and ratings where the applicant holds a Basic Class 2 certificate are exempted by sections 10, 13, and 15A respectively, because subparagraphs 61.1300(3)(b)(i), 61.1300(3)(b)(ii), and subregulation 61.1300(5) of CASR would otherwise expose them to offences.

Part 141 operators and their heads of operations who provide authorised Part 141 flight training to any of the above applicant categories are covered by section 22. Part 142 operators and heads of operations who provide corresponding training are covered by section 23. These provisions extend the coverage chain to ensure that training organisations are not exposed to regulatory liability simply because they are training or certifying people operating under the Basic Class 2 scheme.

Passengers are indirectly affected. Sections 18 and 21 impose mandatory pre-flight disclosure obligations that bear directly on the information passengers receive before deciding whether to board.

The rights granted by the instrument are exemptions from specific provisions of Part 61 of CASR and from offence provisions in Parts 141 and 142 of CASR. They are conditional and carry their own compliance obligations.

For student pilots, the conditions under section 6 require that: (a) the student must carry the Aviation Medical Certificate (Basic Class 2) during every solo flight; (b) the student must not commence a solo flight after the recommended date of next review on their most recent Fitness Report; (c) every solo flight must be conducted by day under the VFR, below 10,000 feet, within Australian territory, and in a piston-engined aircraft with a maximum take-off weight less than 8,618 kg; and (d) the student must produce the Aviation Medical Certificate (Basic Class 2) on request by an authorised CASA officer and must produce a copy of the most recent Fitness Report within 48 hours of such a request.

For private pilot licence applicants and recreational pilot licence applicants (sections 9 and 12 respectively), the conditions mirror those for student pilots in the test context: carry the certificate during the flight test, do not commence the test after the review date, and produce documents on request.

For private pilot licence holders exercising their privileges (sections 17 and 18), the conditions are more detailed. Section 17 imposes five limits on the exercise of privileges: (i) the pilot must carry the certificate during every flight; (ii) the pilot must not fly after the Fitness Report review date; (iii) the pilot must not carry more than five passengers; (iv) the pilot must not exercise privileges in conjunction with a flight activity endorsement or operational rating; (v) flight must be by day under the VFR, below 10,000 feet, within Australian territory, and in a piston-engined aircraft with a maximum take-off weight less than 8,618 kg. Subsection 17(5) creates an important exception: all of those restrictions (except the date and carry conditions) fall away if a flight control seat is occupied by a person who is authorised as pilot in command and holds a current class 1 or 2 medical certificate. This means a holder of a Basic Class 2 certificate can fly as co-pilot or second crew member alongside a fully medically certified pilot without the operational restrictions that otherwise apply to solo exercise of privileges.

Section 18 adds the passenger disclosure obligation. Before any flight carrying a passenger, the private pilot licence holder must inform each passenger (or their legal guardian, where applicable) that: the pilot does not hold a standard medical certificate; the pilot holds an Aviation Medical Certificate (Basic Class 2) assessed against Austroads commercial vehicle driver standards; the pilot is carrying that certificate and a copy of the section 17 conditions, available for inspection. The pilot must also physically carry during the flight both the certificate and a copy of the section 17 conditions.

The conditions for recreational pilot licence holders under sections 20 and 21 are structured identically to those for private pilot licence holders under sections 17 and 18, with the expected adjustments for the recreational licence context. The operational restrictions on recreational pilots (day VFR, within Australian territory, no flight activity endorsement or operational rating, no more than five passengers) are framed slightly differently from the private pilot conditions because the underlying CASR privileges for recreational licences are themselves narrower (section 20(4) requires only that flight is within Australian territory, rather than the full set of restrictions in section 17(4), because the other restrictions follow from the nature of the recreational licence itself). The flight-with-a-fully-certified-pilot escape route under subsection 20(5) mirrors subsection 17(5).

Rating applicants under section 15 must comply with the same carry, date-limit, and production-on-request obligations as other applicants.

For flight instructors, flight examiners, and training organisations, the duties are largely negative: provided the pilot holds a current Basic Class 2 certificate and the pilot complies with their conditions, the instructor, examiner, and operator are shielded from the corresponding offence provisions.

The instrument does not itself create any offence or penalty. It grants exemptions from existing obligations. However, the practical enforcement picture is that failure to comply with a condition of an exemption strips the exemption away, leaving the person exposed to the underlying Part 61 offence provisions that the exemption would otherwise have displaced.

The source text identifies the relevant underlying offences by cross-reference. Subregulation 61.1225(1) of CASR creates an offence for flight instructors who approve a person to pilot an aircraft as a student pilot where the approval is not authorised (including because the student lacks a standard medical certificate under regulation 61.114). Section 7 of the instrument exempts the instructor from subparagraph 61.1225(1)(b)(iii) only if the student holds a current Basic Class 2 certificate; if the student fails to comply with the conditions in section 6, the instructor's exemption may be at risk depending on whether CASA treats non-compliance as a failure of the precondition.

Subparagraph 61.1300(3)(b)(i) creates an offence for a flight examiner who conducts a flight test for a pilot licence where the examiner is not satisfied the applicant holds a current medical certificate or exemption. Sections 10 and 13 exempt flight examiners from this for private and recreational pilot licence tests respectively, and section 15A exempts them for rating tests, in each case provided the applicant holds a current Basic Class 2 certificate.

The document production obligations in sections 6(4), 9(3), 12(3), 15(3), 17(6), and 20(6) require production of the Aviation Medical Certificate (Basic Class 2) on request and production of the most recent Fitness Report within 48 hours of a request from an authorised CASA officer. An authorised CASA officer for these purposes means an officer holding an appointment as an authorised person for the purposes of regulation 302 of the Civil Aviation Regulations 1988. Failure to produce would again expose the person to the underlying licensing obligations from which the exemption has been withdrawn.

The instrument does not specify a civil penalty unit figure or a criminal penalty. The penalty consequences flow from the underlying CASR provisions rather than from EX11/25 directly.

The instrument is made under regulations 11.160 and 11.205 of CASR, which give CASA the power to grant exemptions from provisions of the Civil Aviation Act 1988 (CAA) and CASR by legislative instrument. It operates within the overarching framework of the CAA and CASR.

The core provisions it exempts from are located in Part 61 of CASR. These include: subregulation 61.114(2) and (4), which set out medical certificate requirements for student pilot solo flights; subregulation 61.065(1), which conditions the exercise of pilot licence privileges on compliance with the limitations in Part 61; subregulation 61.410(1), which limits private pilot licence holders to flying only if they hold a class 1 or 2 medical certificate or a medical exemption; subregulation 61.405(1), which imposes the equivalent restriction for recreational pilot licence holders; subregulation 61.465(2), which restricts recreational pilot licence holders from carrying more than one passenger without a class 1 or 2 certificate or a fully certified co-pilot; paragraph 61.235(2)(c), which requires flight test applicants for pilot licences to hold a current medical certificate of the required class; and subregulation 61.235(4), which imposes equivalent requirements for rating flight tests.

The instrument interacts with Part 141 of CASR (flight training operators) through section 22, exempting Part 141 operators and their heads of operations from subregulation 141.210(1) in respect of flight test eligibility, and from regulations 141.290 and 141.300 in respect of authorising persons to fly as pilot in command. It interacts with Part 142 of CASR (integrated training operators) through section 23, exempting Part 142 operators and heads of operations from subregulation 142.245(1) and from regulations 142.365 and 142.375 on equivalent terms.

The medical standard itself is defined by reference to external Austroads standards rather than internal CASA medical standards. This creates a dynamic reference: the definition of medical standard basic class 2 in section 4 incorporates the Austroads publication "as existing from time to time", meaning that if Austroads amends its commercial vehicle driver medical standards, the threshold for Basic Class 2 eligibility changes accordingly without any amendment to EX11/25. This is a significant point: the medical gatekeeping standard is set and updated by a separate body (the national road transport authority body) rather than by CASA, and EX11/25 simply picks it up by reference.

The instrument does not interact directly with the Civil Aviation Act 1988 provisions on airspace or with the Air Navigation Act 1920. Its scope is confined to the medical certification conditions for pilot licensing and the exercise of pilot licence privileges.

The source text records no amendment history for CASA EX11/25 itself, which is a new instrument registered in 2025. The instrument does, however, record that it repeals its immediate predecessor, CASA EX49/24 (Medical Certification (Private Pilot Licence Holders with Basic Class 2 Medical Certificate) Exemption 2024). This indicates that EX11/25 is at least the second instrument in this policy sequence, with EX49/24 being the first. EX49/24 was evidently narrower in scope, covering only private pilot licence holders rather than the broader set of persons covered by EX11/25. No further legislative history, explanatory statements, or consultation records are included in or annexed to the source text. No amendments to EX11/25 itself are recorded in the source.

The source text names no cases. No court or tribunal decisions are cited, referenced, or summarised anywhere in the instrument. This is consistent with the instrument being a new legislative instrument that had been in force for only weeks at the time of registration and had no litigation history. No cases are discussed in the notes to any provision. Accordingly, nothing can be said about how courts or tribunals have interpreted or applied EX11/25 or its predecessor EX49/24.

Several features of this instrument create practical traps for pilots and operators who read the headline exemption without working through the conditions carefully.

First, the date-of-next-review cutoff is harder in practice than the certificate expiry date. Section 6(2) (for student pilots), section 9(2) (for private pilot licence applicants), section 12(2) (for recreational pilot licence applicants), section 15(2) (for rating applicants), section 17(2) (for private pilot licence holders), and section 20(2) (for recreational pilot licence holders) all prohibit commencing a flight after the recommended date of next review recorded on the most recent Fitness Report. The Aviation Medical Certificate (Basic Class 2) itself runs until the expiry date recorded on the certificate, which may differ from the Fitness Report review date. A pilot who tracks only the certificate expiry date and ignores the Fitness Report review date may find they are flying in breach of a condition without realising it.

Second, the 10,000-foot altitude ceiling and the piston-engine/8,618-kg weight limit that apply to private pilot licence holders under section 17(4) do not apply to recreational pilot licence holders in the same explicit form under section 20, because the underlying recreational pilot licence privileges already contain restrictions that largely overlap. However, the section 17(4) restrictions do apply to student pilots under section 6(3)(b), (c), and (d), and the note to section 5(6) clarifies that the piston-engine/weight condition (section 6(3)(d)) applies to non-recreational solo flights (section 5(2)) but not to recreational aircraft solo flights (section 5(3)) because the definition of recreational aircraft in regulation 61.010 of CASR already limits maximum certificated take-off weight to less than 1,500 kg. Conflating these two regimes is a credible error.

Third, the passenger cap of five passengers (sections 17(3)(a) and 20(3)(a)) does not mean a Basic Class 2 holder can never carry a passenger in an aircraft with more than five passenger seats. The subsection 17(5) and 20(5) override permits full exercise of privileges (including passenger-carrying without limit) when a flight control seat is occupied by a pilot in command who holds a current class 1 or 2 medical certificate. Read carelessly, sections 17(3) and 20(3) look absolute but they are subject to the supervisory override in subsections (5).

Fourth, the pre-flight disclosure obligation in sections 18 and 21 is mandatory, not optional. A private pilot or recreational pilot who carries a passenger without first informing each passenger (or their legal guardian) of the matters in subsections 18(2) and 21(2) is in breach of a condition of the exemption. The disclosure must be given before commencing the flight; there is no provision for post-flight cure. The pilot must also physically carry during the flight a copy of the conditions (sections 17 and 20 respectively), not merely have access to them. This is a compliance step that goes beyond anything required of a standard aviation medical certificate holder.

Fifth, the instrument's expiry on 31 January 2028 is automatic and unconditional. There is no provision for rollover, extension, or continuation by reference to a succeeding instrument. Unless CASA makes a new instrument before that date, every pilot, instructor, examiner, and operator relying on EX11/25 reverts without notice to the full standard aviation medical requirements of Part 61. A pilot who has been flying for three years on a Basic Class 2 certificate and has not also obtained a standard class 1 or 2 medical certificate will need to do so by that date or cease flying.

Sixth, the medical standard incorporates Austroads standards "as existing from time to time". If Austroads tightens its commercial vehicle driver medical standards between now and 2028, a pilot who was previously eligible may cease to meet the Basic Class 2 standard without any change to EX11/25 or CASR. A pilot's eligibility is therefore not locked in by the fact of holding an Aviation Medical Certificate (Basic Class 2) issued under older standards: the next assessment will be against whatever standard Austroads has published by then.

Seventh, the exercise of privileges in conjunction with a flight activity endorsement or operational rating is prohibited for both private pilot licence holders (section 17(3)(b)) and recreational pilot licence holders (section 20(3)(b)). A pilot who holds, say, a night VFR rating alongside their private pilot licence cannot exercise that rating while relying on the Basic Class 2 exemption unless a fully medically certified pilot is occupying a flight control seat and is authorised as pilot in command under subsection 17(5).

Compliance operates at three levels: obtaining the credential, maintaining it, and observing the operational conditions on each flight.

To obtain eligibility, a person must first be assessed by a medical practitioner as meeting the medical standard basic class 2, which is the Austroads commercial vehicle driver medical standard for an unconditional licence (glasses and hearing aids permissible, no other conditions). The medical practitioner completes CASA Form 1474 (the Fitness Report), recording the assessment outcome and a recommended date of next review. The person then applies to CASA, certifying that they have been so assessed. CASA issues the Aviation Medical Certificate (Basic Class 2) if satisfied the applicant meets the standard, and records an expiry date derived from the Fitness Report review date.

To maintain eligibility, the person must not allow the review date from the most recent Fitness Report to pass without obtaining a fresh assessment and, if still eligible, a renewed Aviation Medical Certificate (Basic Class 2). The certificate itself will record an expiry, but because the Fitness Report review date governs the operational cutoff (not merely the certificate expiry), a person who defers their next assessment beyond the review date even within the certificate's nominal validity period will be in breach of the conditions.

On each flight, regardless of whether passengers are carried, a person relying on the exemption must carry their current Aviation Medical Certificate (Basic Class 2). That document must be available for immediate production on request to an authorised CASA officer (sections 6(4)(a), 9(3)(a), 12(3)(a), 15(3)(a), 17(6)(a), 20(6)(a)). Within 48 hours of a request from an authorised CASA officer, a copy of the most recent Fitness Report must also be produced (sections 6(4)(b), 9(3)(b), 12(3)(b), 15(3)(b), 17(6)(b), 20(6)(b)). Carrying only the certificate but not having access to the Fitness Report within 48 hours of a request would put the person in breach of a condition.

For private pilot licence holders and recreational pilot licence holders exercising privileges without a fully medically certified pilot in command on board, every flight must be: by day under VFR (sections 17(4)(a), and for recreational pilots this follows from the underlying licence); below 10,000 feet (section 17(4)(b), applying directly to private pilot licence holders); within Australian territory (sections 17(4)(c), 20(4)); and, for private pilot licence holders, in a piston-engined aircraft with a maximum take-off weight below 8,618 kg (section 17(4)(d)). No flight activity endorsement or operational rating may be exercised.

For any flight carrying passengers, before commencing the flight the pilot must inform each adult passenger, and the legal guardian of any minor passenger, of the three matters set out in sections 18(2) and 21(2): that they do not hold a standard medical certificate, that they hold a Basic Class 2 certificate assessed against Austroads commercial vehicle driver standards, and that they are carrying that certificate and a copy of the relevant conditions (sections 17 or 20) for inspection. The pilot must also carry during the flight both the certificate and a copy of those conditions. There is no prescribed form for the pre-flight disclosure, but the disclosure must cover all three specified matters.

Flight instructors who approve solo flights, and flight examiners who conduct tests, should confirm in their own records that the student or applicant holds a current Aviation Medical Certificate (Basic Class 2) before approving or commencing the flight or test. This is what triggers the exemption under sections 7, 10, 13, and 15A. Part 141 and Part 142 operators should update their operations manuals and standard operating procedures to reflect the new scheme, document their verification steps, and ensure their heads of operations are familiar with the dual exemption structure in sections 22 and 23. The instrument expires on 31 January 2028, so operators should build a review date into their compliance calendars well before that expiry.