Sooner or later the question comes up. Your class rating is about to expire, the club wants proof of your hours, or an examiner asks to see your logbook before a proficiency check. If you have been recording your flights in an app for years, the same doubt surfaces every time: does this actually count? Or do you still need a bound paper book in your flight bag?
The short answer is that a digital logbook is legal under European rules. The longer answer is more useful, because legal does not mean anything goes. EASA attaches specific content and technical conditions to electronic records, and the national authorities across Germany, Austria and Switzerland apply them very differently. This article sets out the legal basis, lists what has to be recorded, and explains how to tell whether a digital logbook actually meets the requirements.
The legal basis: FCL.050 and AMC1 FCL.050
Everything starts with Regulation (EU) No 1178/2011, commonly known as Part-FCL. The operative sentence in FCL.050 is remarkably short: “The pilot shall keep a reliable record of the details of all flights flown in a form and manner established by the competent authority.”
Two things stand out. First, what is required is a reliable record. Paper, ink and bound volumes are never mentioned. Second, the actual form is set by the competent national authority, which means FCL.050 deliberately does not prescribe a format at all.
The detail lives in AMC1 FCL.050, the Acceptable Means of Compliance attached to the rule. That document defines what a logbook has to contain and, for the past few years, the conditions under which it may be kept electronically.
When did electronic logbooks become explicitly acceptable?
The turning point was ED Decision 2020/005/R, issued on 18 March 2020. Since then AMC1 FCL.050 names the electronic logbook directly: the pilot should record the details “in the following logbook format”, “which may be kept in electronic format”. The version currently in force is ED Decision 2025/002/R.
That settles the most common source of uncertainty. Since 2020 the debate is no longer about whether electronic records are allowed, but about what the software has to do so the record qualifies as reliable in the sense of FCL.050.
The twelve mandatory entries under AMC1 FCL.050
AMC1 FCL.050 describes a logbook format built around twelve groups of entries. They apply the same way whether you use a ballpoint pen or an app:
- Date of the flight in dd/mm/yy format
- Departure aerodrome with ICAO identifier and time in UTC
- Arrival aerodrome with ICAO identifier and time in UTC
- Aircraft type and registration
- Type of operation: single or multi-engine, single-pilot or multi-pilot
- Total flight time for the flight plus the running cumulative total
- Name of the pilot in command, or SELF for your own flights
- Landings, counted separately for day and night
- Operational conditions, in particular night time and IFR time
- Pilot function: PIC, co-pilot, dual, instructor or examiner
- Simulator time with device type and qualification number, recorded separately
- Remarks, for example proficiency checks and signatures
What matters when logging times
All times are recorded in UTC. That sounds trivial until you fly on a summer evening, local time and UTC are two hours apart, and the date rolls over between departure and landing. It is the single most common bookkeeping error in general aviation.
There is one welcome simplification for circuit work. Several flights may be combined into a single entry provided they took place on the same day, used the same departure and arrival aerodromes, and the breaks between them did not exceed 30 minutes. Well-designed software reflects that instead of forcing twelve separate rows for an hour in the pattern.
What a digital logbook has to be able to do
The practically important part sits in AMC1 FCL.050 (e)(2), which lists the conditions under which an electronic record is usable for regulatory purposes. In summary:
- Format: acceptable to the competent authority
- Content: every mandatory item from FCL.050(a)
- Certification: entries are digitally signed by the pilot
- Availability: the record is accessible at any time on request by the authority
- Immutability: once signed, entries cannot be silently altered
- Calculated values: block time and rotor time are computed rather than freely editable
- Integrity: any later change remains traceable
- Data protection: GDPR-compliant processing and access control for pilot data
- Backup: serious backup policies, regular security updates, mirroring across devices
- Exportability: machine-readable output as CSV, TSV or JSON
Immutability and the audit trail
In a paper logbook, handwriting does the anti-tampering work: erasing leaves a mark. In a digital system the software has to provide that guarantee. What the rule asks for is an audit trail, a traceable history of who changed which value and when. An app that lets you quietly overwrite an entry from last year does not meet the requirement.
Digital signatures and eIDAS
AMC1 FCL.050 requires entries to be digitally signed by the pilot but does not define in technical terms what counts as a digital signature. EASA guidance on electronic documents published in May 2023 points to the European eIDAS framework and describes the qualified electronic signature (QES) as the highest level of assurance. In everyday general aviation, most solutions sit below that level and rely on authentication combined with an audit trail. If legal certainty matters to you, ask your provider directly which signature level is actually implemented.
Export, backup and data protection
The export requirement is routinely underestimated. What is asked for is a machine-readable format such as CSV, TSV or JSON. A PDF printout does not qualify, because it cannot be carried into another system without manual rework. Export is therefore less a convenience feature than an exit guarantee: it decides whether your flight hours travel with you when you change providers.
Paper or digital: the regulatory comparison
In regulatory terms the two are equivalent, provided the conditions in AMC1 FCL.050 (e)(2) are fully met. What changes is the risk profile:
- Tamper protection: handwriting on paper, audit trail plus signature in software
- Risk of loss: fire, water and theft on paper against software faults, cyber attacks and provider insolvency in the cloud
- Backup: effectively impossible on paper, both possible and expressly required in digital form
- Authority access: physical presentation against export or printout
- Calculations: manual totals against automatic accumulation
National differences across the DACH region
Because FCL.050 leaves the form to the competent authority, day-to-day practice varies considerably even inside the EASA system.
Switzerland
FOCA has anchored AMC1 FCL.050 as binding law and goes furthest of the three. Back in 2020 the authority certified a digital logbook following an audit, described at the time as the first anywhere in the world. As of August 2026 only two officially certified logbooks exist, one of them the authority’s own dLogbook. With a certified logbook the recorded hours count as automatically validated, so no separate confirmation is needed to revalidate an SEP rating.
Germany
The LBA has transposed AMC1 FCL.050 into binding law through NfL 2212-21. The historical reference to a physically bound book in §120 LuftPersV does not stand in the way of a digital logbook, since EU law takes precedence. The practical obstacle lies elsewhere: more than fifteen regional aviation authorities apply the rules inconsistently. Printouts from digital logbooks are accepted most of the time, but there is no dependable nationwide commitment. If you have a check ride or a revalidation coming up, clarify the point with your responsible office in advance.
Austria
Austro Control takes the route of tacit acceptance. Digital logbooks are recognised in practice and printed exports are largely accepted, yet no official letter or written ruling exists. For pilots that means a working arrangement that is not formally secured.
Common misconceptions
- “Digital logbooks are not allowed in Europe.” Out of date. Since ED Decision 2020/005/R, AMC1 FCL.050 names the electronic format explicitly.
- “If an app advertises EASA compliance, it is certified by an authority.” It is not. Certification is a formal act by an authority and so far exists only in a handful of cases. Saying that a product supports the EASA format is something entirely different.
- “A PDF export is good enough as a backup.” Not in the sense of the requirement, which asks for a machine-readable format such as CSV, TSV or JSON.
- “My provider takes care of the backups.” Under FCL.050 responsibility for the reliable record rests with the pilot, not with the software vendor.
- “European rules mean the same treatment everywhere.” Implementation is national, and Switzerland, Germany and Austria differ noticeably in practice.
When data is lost
FCL.050 demands a reliable record but names neither minimum technical standards nor a recovery procedure. The realistic risks are software faults and data corruption, cyber attacks, a provider data centre outage, a vendor going out of business, and deletion of data after a subscription lapses, with some providers clearing accounts after twelve months.
If the record is gone, there is no legally defined way to restore it. Hours then have to be reconstructed from flight school, club or operator records, and if that fails, revalidating your ratings can be seriously at risk. That is why a regular export in a machine-readable format, stored on hardware you control, belongs to basic airmanship, no matter how solid your provider looks.
Key takeaways
- The legal basis is FCL.050 of Regulation (EU) No 1178/2011, detailed in AMC1 FCL.050.
- Electronic logbooks have been explicitly acceptable since ED Decision 2020/005/R, currently in the version ED Decision 2025/002/R.
- The same twelve groups of entries apply as on paper, with all times in UTC.
- AMC1 FCL.050 (e)(2) requires digital signature, immutability with an audit trail, GDPR-compliant data protection, backup and machine-readable export, among others.
- Certified is not the same as compliant: formal certifications remain rare and are concentrated in Switzerland.
- National practice differs, so check with your competent authority before a check ride or revalidation.
cloudlog.aero is a digital logbook built around the AMC1 FCL.050 format with support for machine-readable exports.
Sources
This article is provided for general information and reflects the sources consulted at the time of publication. It does not constitute legal advice or an authoritative statement by an aviation authority. The applicable laws, regulations, and the current guidance and decisions of the competent aviation authorities always take precedence.