EASA Recency Requirements: When Am I Still Allowed to Fly?

It is Friday evening, Saturday’s forecast looks good, and the club Cessna is free. Two friends have already said yes. Then comes the question that makes a lot of pilots pause: when did I actually last fly – and am I allowed to take them along at all?

The answer is in your logbook. Which figures you need to check, however, depends on your licence and the flight you intend to make. Under EASA rules, several recency requirements interact: the 90-day rule in FCL.060 applies when carrying passengers, while LAPL(A) holders must additionally meet the rolling recency requirements of FCL.140.A. Mixing up these requirements can quickly lead to checking the wrong figures.

This article sorts the requirements the way they are actually needed at the airfield: who they apply to, what counts as evidence, what happens when recency lapses – and the six misunderstandings that keep coming up.

Recency is not the same as revalidation

Before any numbers, three terms that are routinely confused in the clubhouse deserve to be kept apart:

Recency, or recent flight experience: requirements concerning a pilot’s recent flying experience. FCL.060 sets out, among other things, the recent-experience requirements for carrying passengers. LAPL(A) holders must additionally comply with the specific recency requirements of FCL.140.A.
Class rating revalidation: extending the SEP or TMG rating, typically on a 12- or 24-month cycle. A separate process with separate requirements.
Validity of the licence itself, including medical certificate and language proficiency.

All three have to be in order for a flight to be legal, but they run independently. A valid SEP rating does not substitute for recency, and satisfying recency does not extend a rating.

FCL.060: the 90-day rule for carrying passengers

The legal basis is FCL.060 of Regulation (EU) No 1178/2011 (Part-FCL), consolidated in the EASA Easy Access Rules for Aircrew. Its scope is important: for aeroplanes, helicopters, powered-lift aircraft and airships, a pilot may generally operate an aircraft in commercial air transport or carry passengers only when the applicable recent-experience requirements are met. For typical private passenger flights, the 90-day rule is particularly relevant.

Day operations: three take-offs and three landings

Under FCL.060(b)(1), a pilot may act as pilot-in-command (PIC) or co-pilot of an aircraft carrying passengers only if, in the preceding 90 days, they have carried out at least three take-offs, approaches and landings in an aircraft of the same type or class, or in an equivalent FSTD. In short:

Window: 90 days, counted back from the intended day of flight.
Volume: at least three take-offs and three landings.
Who: PIC and co-pilot alike, as soon as passengers are on board.
Type and class: same type or same class is enough – within SEP(land), landings carry across aircraft.
Simulator: time in an equivalent FSTD may be credited.

Fly solo or with an instructor and FCL.060 simply does not bite. A PPL holder whose recency has lapsed may keep flying – just not with passengers.

Night currency: one landing is enough

Night flying with passengers falls under FCL.060(b)(2). It requires one take-off, approach and landing at night as pilot flying within the preceding 90 days, on the same type or class or in an equivalent FSTD. Alternatively, holding a valid instrument rating (IR) removes the requirement altogether.

Only one night landing is needed, not three as in day operations.
A full stop is not required – a touch-and-go at night counts.
IR holders are fully exempt from night currency.
When night begins is set by national rules; across EASA states this is usually from the end of evening civil twilight to the beginning of morning civil twilight.

In practice this catches out summer pilots. Someone who flies plenty of daytime hours and then departs for the first evening flight in October will comfortably meet day recency – and may well not meet night recency.

LAPL: FCL.140.A and the 24-month window

The LAPL(A) works differently. Rather than conventional class-rating revalidation, FCL.140.A imposes a rolling recency requirement over a 24-month period. This requirement applies to the exercise of LAPL privileges regardless of whether passengers are carried. When carrying passengers, the applicable requirements of FCL.060 must additionally be satisfied.

Route 1: hours and landings

At least 12 hours of flight time as PIC, including training or supervised solo time.
Within that, at least 12 take-offs and 12 landings.
At least 1 hour of refresher training with a flight instructor (FI).
All of it within the last 24 months.

Route 2: proficiency check

Pilots who cannot accumulate the hours may instead take a LAPL(A) proficiency check with an examiner (FE), following the syllabus of the LAPL(A) skill test.

Holding both SEP(land) and SEP(sea)

Pilots holding both class ratings may combine hours and landings. However, at least 1 hour and 6 of the 12 landings must be completed in each of the two classes.

Passengers on board: the four typical cases

PPL, passenger by day: FCL.060(b)(1) – three take-offs, approaches and landings within the preceding 90 days on the same type or class.
PPL, passenger at night: additionally FCL.060(b)(2) – at least one take-off, approach and landing at night within the preceding 90 days, unless the pilot holds an IR.
LAPL, passenger by day: the LAPL recency requirements of FCL.140.A must be satisfied; in addition, the 90-day passenger-carrying requirement of FCL.060(b)(1) applies.
LAPL, passenger at night: FCL.140.A must be satisfied, the required night privileges must be held, and the applicable requirements of FCL.060 also apply, including the night recency requirement of FCL.060(b)(2).

One detail from the Acceptable Means of Compliance (AMC1 FCL.060(b)(1)) matters in daily operations: when a pilot flies with an FI or FE on board specifically to complete the three landings and regain recency, that instructor or examiner does not count as a passenger. Actual passengers, however, may not be carried on those flights.

Recency has lapsed – what now?

PPL – passenger recency under FCL.060

The consequence is narrow but unambiguous: carrying passengers is not permitted. Doing it anyway risks an administrative offence and, if something goes wrong, your insurance cover. Solo flights and flights without passengers remain legal as long as the class rating is valid. There is no requirement to notify the authority – compliance rests with the pilot.

Restoring recency involves no paperwork at all: fly three take-offs and three landings in the same class or type, solo or with an instructor. With the third landing you are current again. Pilots who are going around the circuit anyway often do it with an FI, so the same time also counts toward class rating revalidation.

LAPL – recency under FCL.140.A

Here the effect reaches much further. If FCL.140.A is not satisfied, the pilot may not exercise the privileges of the LAPL at all – every flight is affected, not just those with passengers. Recovery means either catching up on the 12 hours, 12 take-offs and landings plus the FI hour, or passing a proficiency check with an FE.

An expired class rating is a different problem

An expired SEP rating has nothing to do with FCL.060. Within seven years of expiry it can be restored through a proficiency check with an FE, preceded by refresher training where needed. Since September 2023 there are no fixed hour requirements for that training: the training organisation (DTO or ATO) assesses the necessary scope case by case. Beyond seven years, stricter restoration requirements apply. Flying on an expired rating can lead to fines and can void insurance cover.

Six common misunderstandings

“Solo flights don’t count toward recency.” They do. Solo flights count fully toward the three landings required by FCL.060. The rule only prohibits carrying passengers while those three landings are missing – whether they are flown solo, dual or with an FI makes no difference to the count.
“PPL holders have to log 12 hours every 12 months.” That mixes up two regimes. The 12-hour logic comes from the LAPL system (FCL.140.A, 24 months). For carrying passengers, a PPL holder needs the 90-day rule in FCL.060. SEP rating revalidation has its own, separate requirements.
“Night currency doesn’t matter if I rarely fly at night.” That is precisely when it bites. To carry passengers at night you need a night landing within the last 90 days, or an IR. Meeting every other requirement is not enough.
“Only the PIC needs recency.” FCL.060 explicitly names both PIC and co-pilot once passengers are on board.
“I’ll just take another pilot along as a passenger while I build my recency back up.” Not an option. No passengers may be on board during recency-restoring flights. FIs and FEs are not treated as passengers.
“IR holders still need night currency.” No. FCL.060(b)(2) expressly exempts holders of a valid instrument rating from the night recency requirement.

Conclusion

The essentials in brief:

Passenger flight by day: generally requires three take-offs, approaches and landings within the preceding 90 days under FCL.060(b)(1).
Passenger flight at night: additionally requires at least one take-off, approach and landing at night within the preceding 90 days, or an IR, under FCL.060(b)(2).
LAPL(A): the rolling recency requirements of FCL.140.A must additionally be satisfied – 12 hours of flight time, 12 take-offs and landings and at least one hour of refresher training within the preceding 24 months, or alternatively a proficiency check.
PPL without passenger-carrying recency: passengers may not be carried; however, failure to meet FCL.060 alone does not generally prohibit a flight without passengers, provided all other applicable requirements are met.
LAPL without FCL.140.A recency: LAPL privileges may not be exercised until the applicable requirements have been restored.
Recency, rating revalidation and licence validity are separate requirements and must each be checked.

In practice, answering “am I allowed to?” rarely fails because of the rules themselves. It fails because the relevant landings are hard to find in the logbook. A digital logbook such as cloudlog.aero keeps the 90-day windows calculated continuously and shows your status before the flight, rather than leaving you to reconstruct it afterwards.

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.