CASA EX225/15 - Exemption — from completion of an approved course of training in MCC

The instrument is built around a small set of defined concepts and administrative mechanisms, each expressed in the instrument’s definitions and schedules (s 3; Schedules 1-2).

MCC (multi‑crew cooperation) is central. The instrument exempts certain people from CASR requirements that they complete an approved course of training in MCC (see s 5-12). “Approved course of training” is an expression drawn to the meaning in CASR regulation 61.010; the instrument repeats that an approved course of training is one where the provider has an approval under regulation 61.040, or a CASR Part 141/142 operator is authorised to conduct it, or a person holds approval under regulation 141.035 or 142.040 (s 3, note). The instrument therefore treats the formal MCC course requirement as a discrete regulatory obligation, and replaces it for certain people with alternative qualifications and documentary proof.

Equivalence and alternative pathways are core concepts. Schedule 1 lists five alternative requirements that, if satisfied, allow a person to rely on the exemption instead of completing an approved MCC course. These alternatives are: (1) successful completion of an MCC course approved by the European Aviation Safety Agency (EASA); (2) completion of training required for an EASA multi‑crew type rating; (3) holding a type rating plus at least 50 hours’ experience in multi‑crew operations in RPT by Australian AOC holders within the “last 3 years”; (4) holding a type rating plus at least 100 hours’ multi‑crew experience in charter operations and two operator proficiency checks in multi‑crew operations including HF&NTS assessment within the last three years; and (5) any combination of training/qualifications/experience that CASA considers at least equivalent to items (1)-(4), evidenced by a CASA certificate of equivalence (Schedule 1).

HF&NTS, human factors and non‑technical skills, appear as part of the competence assessment requirement for item (4) and are to be guided by CAAP SMS‑3(1) (Schedule 1(4) and its note). Thus the instrument gives weight to HF&NTS competence as an alternative compliance metric when supported by operator proficiency checks.

The instrument assigns documentary and endorsement mechanisms in Schedule 2. For each alternative pathway the instrument lists what documentary evidence must be supplied (for example, EASA course completion certificates and the provider’s EASA approval for item (1); logbook evidence and endorsements by specified senior personnel or flight examiners for items (2)-(4); and a CASA certificate of equivalence plus supporting evidence for item (5)). It specifies who may endorse logbook entries (head of flying operations, head of training and checking, or holder of a flight examiner rating) and to whom evidence must be supplied depending on whether the person is an ATPL applicant or an operator pilot exercising privileges (Schedule 2(6)-(7)). CASA retains the administrative power to request further documents to determine the application or continued application of the exemption (Schedule 2(8)).

“Last 3 years” is defined precisely in s 3 and has a different reference point for ATPL applicants (date of application) and others (first flight for which exemption relied upon). This temporal definition directly shapes eligibility under Schedule 1 items 3-4.

The instrument also contains a delegation of equivalence discretion to CASA: CASA may issue a “CASA certificate of equivalence” stating that a person’s combination of training/qualifications/experience is equivalent to one of the named alternative pathways (s 3 definition; Schedule 1(5); Schedule 2(5)(b)). That constitutes an administrative equivalence route.

Finally, the instrument is temporary and administrative: it revokes a previous instrument (s 2), commences immediately (s 1(a)), and expires on a fixed date (s 1(b)). The legal effect is to alter regulatory obligations only for the instrument’s duration and for persons who meet the conditions and evidence rules set out.

The instrument identifies several discrete categories of individuals and organisational actors whose regulatory obligations and administrative interactions change while the exemption is in force.

Primary individuals directly affected are pilots at different licence levels:

• Members and former members of the Australian Defence Force who apply for an ATPL: they are granted an exemption from subparagraph 61.285(f)(ii) of CASR 1998 if they have completed an ADF multi‑crew operational conversion training course for an aircraft normally operated by two pilots, and they must provide a copy of the relevant ADF qualification to CASA as evidence (s 5-6).
• Holders of a multi‑crew pilot licence (MPL) with an aircraft category rating applying for an ATPL: exempt from paragraph 61.700(3)(e) if they meet the alternative requirements and evidence rules (s 7).
• Holders of a commercial pilot licence (CPL) with an aircraft category rating applying for an ATPL: similarly exempt from paragraph 61.700(3)(e) subject to Schedule 1 and 2 compliance (s 8).
• Holders of private pilot licences (PPLs) and holders of CPLs who wish to exercise licence privileges in multi‑crew operations: granted exemption from subregulation 61.510(1) (PPL) and 61.575(1) (CPL) respectively, if they satisfy the alternative requirements and evidence/endorsement obligations (s 9-10).
• Holders of single‑pilot (SP) type ratings who do not hold a multi‑crew type rating but wish to exercise SP privileges in multi‑crew operations: exempt from paragraph 61.785(1)(b) if they meet Schedule 1 and 2 requirements (s 11).

Operators and employer organisations are affected administratively:

• Australian AOC holders engaged in RPT or charter operations are relevant because Schedule 1 items 3 and 4 require experience gained operating under CAO 82.3/82.5 (RPT) or CAO 82.1 (charter). That links operator operations and logbook entries to eligibility (Schedule 1(3)-(4), Schedule 2(3)-(4)).
• Heads of the flying operations part of the relevant AOC holder, heads of training and checking, or holders of flight examiner ratings are the persons authorised to endorse logbook entries or other documents evidencing experience and privileges (Schedule 2(6)). Those persons must be prepared to verify and endorse evidence.

CASA is the decision‑maker and administrator:

• For ATPL applicants, evidence is supplied to CASA (Schedule 2(7)(a)) and CASA may issue a certificate of equivalence under Schedule 1(5) and Schedule 2(5)(b).
• CASA may request additional information or documents to determine the application, or continued application, of the exemption (Schedule 2(8)), including proof of authenticity of copies (note to Schedule 2(8)).

Who pays and who undertakes the burden of compliance is stated indirectly by the instrument’s documentary requirements: the person seeking to rely on the exemption must assemble and supply specified documents; the operator or person endorsing logbook entries must verify and endorse; CASA bears the administrative burden of assessing applications and equivalence requests and may require further proof. The instrument therefore shifts some certification burden from course completion to documentary proof and endorsements by employers or CASA. The instrument does not, within its text, create or allocate monetary fees; it creates documentary and administrative duties for the named individuals and heads of operator functions.

The instrument creates a set of rights (exemptions) and attaches duties and documentary obligations to exercise those rights. The core right is the exemption from specified CASR requirements to complete an approved MCC course, granted to different categories of pilots in sections 5-11. Each right is conditional on satisfying alternative requirements (Schedule 1) and producing evidence as prescribed (Schedule 2).

Rights (exemptions)

• ADF applicants for an ATPL may rely on an exemption from subparagraph 61.285(f)(ii) of CASR 1998 (s 5). The exemption entitles the applicant to not complete an approved MCC course provided the condition in s 6 is met.
• MPL and CPL holders applying for an ATPL are exempt from paragraph 61.700(3)(e) of CASR 1998 (s 7-8).
• Holders of PPLs and CPLs are exempt from subregulations requiring an MCC course to exercise privileges in a multi‑crew operation (s 9-10).
• Holders of SP type ratings lacking a multi‑crew type rating are exempt from paragraph 61.785(1)(b) to exercise SP privileges in multi‑crew operations (s 11).

Duties and documentary obligations

• Compliance with conditions: Many exemptions are contingent on the person satisfying at least one alternative requirement in Schedule 1 (s 12(a)). Meeting that requirement is a substantive duty before the exemption can be relied upon.
• Evidence production: Compliance must be evidenced in accordance with Schedule 2 (s 12(b)). Schedule 2 prescribes, for each Schedule 1 pathway, the precise documentary items to be produced (for example, EASA course completion certificates and provider approvals for item (1), licences and logbook entries for items (2)-(4), or evidence plus a CASA certificate of equivalence for item (5)).
• Endorsements: Logbooks or other documents used as evidence must be endorsed by specific officeholders: the head of the flying operations part of the relevant AOC holder, the head of training and checking of the relevant AOC holder, or a holder of a flight examiner rating (Schedule 2(6)). This creates a duty on these persons to inspect and endorse entries when called upon.
• Where to supply evidence: The place of supply differs. For ATPL applicants the evidence must be supplied to CASA (Schedule 2(7)(a)); for PPL/CPL/SP holders exercising privileges the evidence must be supplied to the head of the flying operations part of the relevant AOC holder or other operator for whom the pilot operates (Schedule 2(7)(b)). This creates duties both on applicants and on operators to exchange and retain evidence.
• Additional information: An applicant or holder must, on written request, supply CASA with any information or documents CASA considers necessary to determine the application, or continued application, of the exemption (Schedule 2(8)). This is an ongoing compliance duty while the exemption is relied upon.

Administrative discretions and procedural rules

• CASA has discretion to assess equivalence and may issue a CASA certificate of equivalence stating that a person’s training/qualifications/experience are equivalent to the listed alternatives (s 3 definition; Schedule 1(5)).
• For item (4) the instrument requires that operator proficiency checks include HF&NTS competence assessments, and the note references CAAP SMS‑3(1) as guidance for the assessment of HF&NTS competences (Schedule 1(4)).
• For the ADF ATPL exemption, the right is conditioned on completion of a specified ADF operational conversion course for an aircraft normally operated by two pilots, and must be evidenced by an ADF qualification copy supplied to CASA (s 6).

Rights are therefore conditional and contingent on documentary verification and endorsements. The exemptions do not operate automatically; they operate only where the documentary conditions and other specified requirements are satisfied, and CASA retains an administrative role in evaluating and continuing those rights.

The instrument itself does not specify criminal or civil penalties or attach sanctioning provisions. It operates as an exemption instrument that modifies the application of specified CASR requirements for persons who meet its conditions; enforcement and penalty mechanisms for non‑compliance with underlying CASR obligations remain in the broader regulatory framework, which is not reproduced in this instrument. The instrument does, however, create administrative enforcement levers and evidential processes that affect how compliance is monitored and sustained.

Administrative enforcement mechanisms in the text

• Documentary verification and endorsement obligations act as the primary compliance mechanism. The person relying on the exemption must assemble the specific documents listed in Schedule 2 and secure endorsement by an authorised person as required (Schedule 2(1)-(6)). The need for endorsement by heads of flying operations, heads of training and checking, or flight examiner rating holders (Schedule 2(6)) places responsibility on operators and authorised personnel to verify and attest to the authenticity of experience and privileges before a pilot relies on the exemption.
• Destination of evidence creates enforcement responsibilities: ATPL applicants must supply evidence to CASA (Schedule 2(7)(a)); PPL/CPL/SP holders exercising privileges must supply evidence to the head of flying operations or operator for whom they operate (Schedule 2(7)(b)). This produces administrative checkpoints where compliance can be assessed.
• CASA’s information request power: CASA may, on written request, require an applicant or holder to supply any information or documents CASA considers necessary to determine the appropriate application, or continued application, of the exemption (Schedule 2(8)). The instrument explicitly notes that CASA may require proof of authenticity of copies of documents (note to Schedule 2(8)). This creates an ongoing administrative compliance obligation and a mechanism for CASA to investigate or verify claimed equivalence.
• CASA certificate of equivalence: For cases relying on alternative training/qualifications/experience combinations under Schedule 1(5), a CASA certificate of equivalence is required (Schedule 1(5); Schedule 2(5)(b)). CASA controls issuance of these certificates and thereby controls that method of approval.

What the instrument does not do

• It does not itself create penalty provisions for false documentation or misuse of exemptions. Any enforcement action for fraudulent documents or false declarations would need to be pursued under the general offence provisions and enforcement powers in CASR, the Civil Aviation Act, or other relevant laws, none of which are contained within this instrument.
• The instrument does not set out administrative processes for withdrawal or suspension of the exemption where evidence is found deficient beyond requiring CASA to assess continued application. It does not set out appeal routes or administrative review rights within the instrument text.

Practical enforcement implications

• Operators, in receiving evidence from a holder under Schedule 2(7)(b), become gatekeepers for safe exercise of multi‑crew privileges without completion of an approved MCC course, because they must be satisfied that the documentary and endorsement conditions are met before allowing a pilot to operate.
• CASA remains a central gatekeeper for ATPL applicants, and for any equivalence assessments through the CASA certificate of equivalence (Schedule 2(5)(b)). CASA’s request power (Schedule 2(8)) supports verification and the ability to require prove-of‑authenticity.

In short, enforcement under the instrument is primarily administrative and evidentiary. The instrument structures who must verify what, who must receive proof, and gives CASA discretion and information powers to determine whether an exemption can be applied or continued, but it does not itself prescribe penalties.

This instrument is expressly framed as an exemption from specified provisions of the Civil Aviation Safety Regulations 1998 (CASR 1998). Its legal effect operates by excluding particular persons from compliance with those discrete CASR obligations for the instrument’s duration, subject to the instrument’s conditions. The instrument therefore interacts with CASR by altering statutory compliance obligations; it does not repeal or amend CASR directly but operates as an administrative exemption made under regulation 11.160 of CASR 1998 (instrument preamble).

Direct references to CASR provisions

• The instrument cites the precise CASR provisions from which it exempts people: subparagraph 61.285(f)(ii) (ATPL ADF applicants) (s 5); paragraph 61.700(3)(e) (MPL and CPL holders applying for ATPL) (s 7-8); subregulation 61.510(1) (PPL exercising privileges in multi‑crew operations) (s 9); subregulation 61.575(1) (CPL exercising privileges in multi‑crew operations) (s 10); and paragraph 61.785(1)(b) (SP type rating privilege in multi‑crew operations) (s 11). The instrument therefore modifies compliance obligations under those CASR provisions by creating specified exemptions.

References to other aviation instruments and guidance

• Schedule 1 items 3 and 4 require experience to have been gained for Australian AOC holders engaged in regular public transport (RPT) operations in accordance with CAO 82.3 or 82.5, and in charter operations in accordance with CAO 82.1 (Schedule 1(3)-(4)). Those CAO references identify the operational contexts relevant to experience credit and therefore tie operator classification under CAOs to eligibility for the exemption.
• The instrument references European Aviation Safety Agency (EASA) approvals and qualifications (Schedule 1(1)-(2) and Schedule 2(1)-(2)). Where a person proffers an EASA‑approved MCC course completion or an EASA flight crew licence with a multi‑crew type rating, the instrument recognises those non‑Australian approvals as alternative compliance routes. That creates a cross‑jurisdictional compliance interaction between Australian CASA administration and EASA regulatory approvals.
• For HF&NTS competence assessment, the Schedule references CAAP SMS‑3(1) as guidance for assessing human factors and non‑technical skills (Schedule 1(4) note). This ties the instrument to CASA’s advisory materials for the substantive assessment of HF&NTS competencies, even though CAAPs are advisory and not themselves legislative.

Administrative interplay

• CASA’s role under this instrument includes assessing evidence, issuing CASA certificates of equivalence, and requesting further material to verify applications (Schedule 2(5)(b), Schedule 2(8)). That adds an administrative layer that complements statutory requirements in CASR by providing pathways to substitute documentary proof for course completion.
• Operators are required to endorse and receive evidence under Schedule 2(6)-(7). That places operator internal compliance processes and rostering/qualification checks in the compliance chain for CASR obligations, effectively integrating operator verification into the regulatory enforcement of crew qualification requirements.

Temporal and repeal interactions

• The instrument revokes a prior exemption instrument (CASA EX192/15) (s 2). That is an internal CASA regulatory housekeeping interaction. The instrument is time‑limited and expires 31 August 2018 (s 1(b)), at which point the underlying CASR MCC course requirements resume full effect for persons who would otherwise have used the exemption. Practitioners must therefore manage transitions when the exemption lapses.

Limitations on interaction claims

• The instrument does not amend or restate the broader CASR training, licensing, operational or penalty regimes. It is an exemption instrument made under CASR rule‑making authority but it does not itself set out the full content of the CASR requirements it exempts from. Consequently, to understand the full scope of obligations, compliance officers must read the cited CASR provisions together with this instrument.

In sum, the instrument operates as an administrative overlay to CASR licensing requirements, creating alternative compliance pathways that interact with CAOs, EASA approvals and CASA guidance documents, while embedding operator endorsement and CASA equivalence processes into the legal compliance chain.

The instrument records a concise, discrete administrative history within its text. It was made by Mark Alan Skidmore, Director of Aviation Safety, on 24 December 2015 (instrument header and signature). Its commencement is the day after registration and it expires at the end of 31 August 2018, as if repealed by another instrument (s 1(a)-(b)). The instrument expressly revokes a prior CASA exemption instrument, CASA EX192/15 (s 2).

There are no other amendments or variation clauses contained within the text. The instrument includes no schedules that amend or modify other instruments beyond the revocation of CASA EX192/15. The instrument sets out definitions, exemptions, conditions and schedules within a single instrument; it does not indicate any successive amendments or delegations other than the procedural material within Schedules 1 and 2 regarding evidence and equivalence.

What the instrument’s history shows within its text:

• Creation date: signed 24 December 2015 (instrument heading).
• Commencement: day after registration (s 1(a)).
• Expiry: 31 August 2018 (s 1(b)). The expiry clause expressly frames the end date “as if it had been repealed by another instrument,” indicating an administrative termination rather than an implied indefinite continuation.
• Revocation of earlier instrument: CASA EX192/15 is revoked as of this instrument’s commencement (s 2).

The instrument does not include any transitional provisions beyond its expiry and revocation of EX192/15. It does not record any past amendments, variations, or revocations beyond EX192/15. There is no text in the instrument that amends CASR itself; it operates by exemption. If further amendments or successor exemptions exist, they are not contained in this instrument and therefore are outside the record provided here.

Practitioners should therefore treat the instrument’s operative period as fixed by s 1(b) and should check for any subsequent instruments or legislative changes after 31 August 2018 if relying on the exemption at later dates. Within the instrument itself, the only amendment action noted is the revocation of CASA EX192/15 (s 2).

The instrument contains no references to litigation, judicial review, case law, or disputes. It names no cases and cites no judicial decisions. The text itself is an administrative exemption and does not include any statements about past or ongoing litigation.

Because the instrument’s text does not record litigation, there is no litigation history contained within the instrument to summarise. Any legal disputes about its application, the issuance of CASA certificates of equivalence, the endorsement obligations of operators, or the authenticity of evidence are not documented here. The instrument does provide procedural mechanisms (for example CASA’s power to request documents and proof of authenticity at Schedule 2(8)) that could be implicated in disputes, but no case law or adjudicative outcomes are referenced in the instrument.

Practitioners seeking litigation history or judicial interpretation of exemptions under CASA instruments would need to consult external legal databases, tribunal or court records, or CASA administrative decisions. Those sources are outside the instrument’s text and are not summarised herein because the instrument does not itself include any litigation material.

Within the instrument’s administrative lifecycle, the only formal administrative action recorded is the revocation of an earlier instrument (CASA EX192/15) at s 2; that is an administrative replacement rather than a judicial development. If judicial or tribunal decisions have since addressed the interpretation or validity of this exemption instrument, they are not contained in the instrument text and are not summarised here.

This instrument contains several technical features and procedural traps that materially affect how and when the exemptions operate. Practitioners should attend to the following specific points, each rooted in the instrument text.

Time‑limited operation

• The instrument expires on 31 August 2018 (s 1(b)). Exemptions operate only during the instrument’s term. After expiry, the underlying CASR MCC course requirements resume full force; reliance on this instrument’s exemptions is not legitimate after expiry.

Different evidentiary destinations and processes

• For ATPL applicants, evidence must be supplied to CASA (Schedule 2(7)(a)); for other holders exercising privileges, evidence is supplied to the head of flying operations of the AOC holder or other operator for whom the pilot operates (Schedule 2(7)(b)). A pilot who provides evidence to the wrong recipient will not have satisfied the instrument’s procedural condition.

“Last 3 years” definition is not uniform

• The instrument defines “last 3 years” with different reference points: for an ATPL applicant the period is the three years immediately preceding the date of application; for others it is the three years immediately preceding the first flight for which the pilot relies on the exemption (s 3). This temporal asymmetry affects eligibility and must be applied carefully.

ADF exemption is narrowly framed

• The ADF ATPL exemption applies only where the applicant has “successfully completed a course of training conducted by the ADF for a multi‑crew pilot operational conversion qualification” and that must be demonstrated by supplying the relevant ADF qualification showing the operational conversion training was for an aircraft normally operated by two pilots (s 6(a)-(b)). Completion of other ADF courses is not automatically sufficient; the instrument’s language is specific.

Endorsement requirement

• Logbooks and other documents must be endorsed by the head of flying operations, the head of training and checking of the relevant operator, or by a holder of a flight examiner rating (Schedule 2(6)). If the endorsement is absent or provided by any other person, the evidence does not meet the instrument’s requirements.

Scope of exemption is limited

• The instrument exempts only from the statutory MCC course completion requirement cited. It does not purport to waive other CASR training, recency, medical, or operational requirements. The instrument does not alter other licensing preconditions found in CASR; practitioners must not assume broader waivers.

CASA equivalence is discretionary and necessary in some cases

• Item (5) in Schedule 1 requires a CASA certificate of equivalence; neither experience nor training alone substitutes without CASA’s certificate (Schedule 1(5); Schedule 2(5)(b)). Expect an administrative approval process and potential request for further documents (Schedule 2(8)).

HF&NTS assessment specification

• For Schedule 1(4), operator proficiency checks must include assessment of HF&NTS competences and the note references CAAP SMS‑3(1) for guidance (Schedule 1(4) and its note). Practitioners should not assume any proficiency check suffices; the HF&NTS element is explicit.

EASA evidence requirements

• For reliance on EASA‑approved MCC courses or EASA type ratings, the instrument requires both the course completion certificate and proof the provider’s EASA approval is valid and current (Schedule 2(1)(a)-(b)). A stale or invalid EASA approval will not meet the requirement.

Operator operational context matters

• The required experience hours in Schedule 1 items 3 and 4 must be gained operating for an Australian AOC holder in specified operation types under CAO 82.3/82.5 or CAO 82.1. Experience gained in other contexts or jurisdictions is not automatically credited under those items.

Proof authenticity may be required

• Schedule 2(8) explicitly allows CASA to require proof of authenticity of copies of documents. Practitioners should anticipate verification procedures and be prepared to provide authenticated or certified copies.

No penalty provisions in instrument text

• Because the instrument contains no penalty clauses, consequences for false or fraudulent evidence will arise under other laws and enforcement mechanisms. Practitioners should not interpret the absence of penalties as absence of liability.

Operator acceptance is a practical gatekeeper

• Even where an individual holds the necessary documents, the operator must be willing to accept them and endorse logbook entries when required. If an operator refuses to endorse, the pilot cannot rely on the exemption for that operator’s multi‑crew operations.

These are concrete procedural and interpretive risks contained in the instrument’s wording. Compliance requires strict adherence to the documentary, endorsement and temporal conditions set out in the schedules and sections cited above.

The instrument prescribes precise documentary steps and endorsement procedures to be followed to rely on the exemptions. Compliance is documentary, conditional and context‑sensitive. Below are step‑by‑step actions mapped to each category in the instrument, with references to the relevant sections and schedules that specify the evidence required.

For ADF members or former members applying for an ATPL (s 5-6)

1. Confirm you have successfully completed an ADF operational conversion course for a multi‑crew aircraft normally operated by two pilots (s 6(a)).
2. Obtain a certified copy of the relevant ADF qualification showing completion of the operational conversion training for the appropriate aircraft type (s 6(b)).
3. Supply that copy to CASA as part of your ATPL application (Schedule 2(7)(a) read with s 6).

For MPL or CPL holders applying for an ATPL (s 7-8; Schedule 1 & 2)

1. Choose which alternative requirement in Schedule 1 you will rely on (items 1-5).
2. Collect the specific documents required by Schedule 2 for the chosen item:
   • Item (1): EASA MCC course completion certificate and current EASA approval of the training provider (Schedule 2(1)(a)-(b)).
   • Item (2): Copy of current EASA flight crew licence endorsed with the multi‑crew type rating and logbook evidence of exercising the rating privileges (Schedule 2(2)(a)-(b)).
   • Item (3): CASA flight crew licence with multi‑crew type rating and logbook evidence of at least 50 hours’ multi‑crew experience with an Australian AOC holder engaged in RPT operations (Schedule 2(3)(a)-(b); Schedule 1(3)).
   • Item (4): CASA flight crew licence with type rating, logbook evidence of at least 100 hours’ multi‑crew experience with an Australian AOC holder engaged in charter operations, and evidence of two operator proficiency checks within the last three years that included HF&NTS assessment (Schedule 2(4)(a)-(c); Schedule 1(4)(a)-(c)).
   • Item (5): Evidence of training/qualifications/experience and obtain a CASA certificate of equivalence (Schedule 2(5)(a)-(b); Schedule 1(5)).
3. Ensure all logbook entries or supporting documents are endorsed by one of the authorised persons listed in Schedule 2(6) (head of flying operations, head of training and checking, or holder of a flight examiner rating).
4. Supply the assembled, endorsed evidence to CASA as part of the ATPL application (Schedule 2(7)(a)).
5. Be prepared to respond to any written request from CASA for further information or proof of authenticity (Schedule 2(8)). The “last 3 years” timing for ATPL applicants uses the date of application as the reference point (s 3).

For PPL, CPL or SP type rating holders who will exercise privileges in multi‑crew operations (s 9-11; Schedule 1 & 2)

1. Select one of the alternative requirements in Schedule 1 (items 1-5) that you meet.
2. Assemble the supporting evidence per Schedule 2, matching the chosen item (see step 2 under ATPL compliance).
3. Ensure logbook or other documentary evidence is endorsed by an authorised person per Schedule 2(6).
4. Supply the endorsed evidence to the head of flying operations of the AOC holder or other operator for whom you operate, as per Schedule 2(7)(b), before exercising the privileges.
5. If relying on Schedule 1(4) proficiency checks, ensure the operator proficiency checks included HF&NTS assessment and retain evidence thereof; CAAP SMS‑3(1) is noted guidance for HF&NTS assessment (Schedule 1(4) and its note).
6. Keep in mind the definition of “last 3 years” for persons other than ATPL applicants: it is the three years immediately preceding the first flight for which the exemption is relied upon (s 3).

For those seeking a CASA certificate of equivalence (Schedule 1(5); Schedule 2(5))

1. Prepare comprehensive evidence of training, qualifications or experience, or a combination thereof, that you consider equivalent to the enumerated items (Schedule 2(5)(a)).
2. Submit that evidence to CASA and apply for a CASA certificate of equivalence (Schedule 2(5)(b)).
3. Anticipate that CASA may request further information and proof of authenticity (Schedule 2(8)). The certificate is required as part of reliance on Schedule 1(5).

Document and endorsement checklist

• Ensure logbook entries showing exercise of privileges and acquisition of experience are clear, dated, and attributable to the correct operator and operation type (Schedule 2(6)(a)-(d)).
• Obtain endorsement from an authorised person as defined in Schedule 2(6)(e)-(g). Operators should have internal processes to verify and sign off these endorsements.
• Where relying on EASA approvals, include the provider’s approval certificate demonstrating the approval is valid and current (Schedule 2(1)(b)).
• Retain originals and be prepared to produce authenticated copies if CASA requests proof of authenticity (Schedule 2(8) note).

Operational steps for operators and heads of flying operations

• Establish procedures to verify logbook endorsements, operator proficiency check results (including HF&NTS elements), and to confirm CAO operation types for which experience is claimed (Schedule 1(3)-(4); Schedule 2(6)-(7)).
• Maintain records of endorsements and supporting documents in case CASA requests evidence (Schedule 2(8)).

Timing and expiry considerations

• Because the instrument expires on 31 August 2018 (s 1(b)), document and certify evidence well before that date if the exemption is intended to be relied upon for operations or applications within the instrument’s life. ATPL applicants should note that “last 3 years” is measured to the date of application (s 3).

Practical compliance recommendations

• Before relying on an alternative pathway, confirm which Schedule 1 item best matches your actual experience and training and gather the corresponding Schedule 2 evidence.
• Obtain endorsements early; coordinate with the head of flying operations or head of training and checking to avoid last‑minute refusals or administrative delays.
• For equivalence pathways, contact CASA early to understand the certificate of equivalence process and evidentiary expectations to reduce the risk of additional requests under Schedule 2(8).

Following these steps maps directly to the instrument’s requirements and provides the documentary trail necessary to rely on the exemptions while they remain in force.