Canadaā€™s New ATPL Licensing Requirements: CAR 421.34
Transport Canada has overhauled Standard 421.34 for the Airline Transport Pilot Licence (ATPL-A). Second-in-Command (SIC) PPCs are no longer accepted, single-pilot checkrides now receive a domestic-only remark, and a new early assessment route has been established for upgrading First Officers. Here is what every Canadian pilot needs to know.
Interactive ATPL Eligibility & Licence Status Checker
Determine whether your application results in an Unrestricted ATPL, an Annotated ATPL, or a Refusal to Issue under CAR 421.34.
For decades, Canadian pilots had a unique route to the Airline Transport Pilot Licence (ATPL-A). Many pilots obtained their ATPL by completing a Group 1 Instrument Rating flight test in a light twin (such as a Seminole or Seneca), an Instrument Proficiency Check (IPC), or by submitting a Second-in-Command (SIC) Pilot Proficiency Check (PPC) flown from the right seat at an airline or charter operator.
Transport Canada has now updated Canadian Aviation Regulation (CAR) Standard 421.34. The rules regarding which flight tests and checkrides can be used toward an ATPL have changed significantly.
Why Did Transport Canada Change CAR 421.34?
The core privilege of an ATPL is distinct from a Commercial Pilot Licence (CPL). The primary operational difference is that an ATPL permits you to act as Pilot-in-Command (Captain) of a two-crew aircraft in commercial air services.
Under international licensing standards, to hold a full ATPL, an applicant must demonstrate the ability to perform as Pilot-in-Command in an aircraft operated with a co-pilot. The old Canadian standard diverged from this in two key areas:
When Canadian pilots attempted to convert their licences abroad (with the FAA, EASA, or UK CAA), foreign regulators frequently reviewed logbooks and discovered the ATPL was issued on a single-pilot aircraft or from an SIC right-seat PPC. This often resulted in delayed or rejected foreign conversions.
Aligning the skill test standard ensures that Canadian ATPLs maintain international recognition and can be transferred seamlessly across global carriers.
The 3 Outcomes: How Your Skill Test is Assessed
Unrestricted ATPL
Issued with full international compliance and no endorsements or restrictions.
- PIC PPC/PCC in a type-certified two-crew aeroplane (or Level C/D FFS).
- PIC PPC/PCC in a single-pilot multi-engine aircraft operated two-crew under Subpart 604, Part VII, or RCAF.
Annotated ATPL
The licence is issued, but stamped with the mandatory remark: "Skill test does not meet ICAO requirements."
- Flown as PIC/Sole pilot during a single-pilot Group 1 flight test, IPC, or single-pilot PPC.
- Full domestic Canadian privileges, but foreign regulators may refuse recognition.
Refusal to Issue
Transport Canada will reject the application. No licence or remark will be granted.
- SIC (Co-Pilot) PPC/PCC on two-crew aircraft.
- Tests conducted on single-engine aircraft or center-line thrust twins.
Transport Canada Official Evaluation Matrix
| Skill Test Submitted | Licence Issued | Operational Notes |
|---|---|---|
| PIC PPC/PCC in a type-certified two-crew, multi-engine aeroplane or Level C/D FFS | Airline Transport Pilot Licence - Aeroplane (Unrestricted) | Fully international compliant. |
| PIC PPC/PCC in a single-pilot certified multi-engine aeroplane operated as two-crew under Subpart 604, Part VII, or RCAF | Airline Transport Pilot Licence - Aeroplane (Unrestricted) | Satisfies CAR 421.34(9) definition of two-crew operation. |
| Group 1 Initial Flight Test, Group 1 IPC, or PPC/PCC operated single-pilot in a certified single-pilot multi-engine aeroplane |
ATPL with Remark: "Skill test does not meet ICAO requirements" |
Full domestic Canadian privileges. Remark can be removed at no charge once an approved two-crew PIC test is passed. |
| SIC (Co-Pilot) PPC/PCC in a type-certified two-crew multi-engine aeroplane or Level C/D simulator | No Licence Issued (Refusal) | Fails PIC requirement under CAR 421.34(5). |
| Line Operational Evaluation (LOE) & Manoeuvres Validation (MV) under Part 705 AQP | Airline Transport Pilot Licence - Aeroplane (Unrestricted) | Deemed compliant per CAR 421.34(5)(b). |
What Counts as "Two-Crew"? (CAR 421.34(9))
A common question among First Officers flying aircraft like the King Air, Metro, or PC-12 is whether their aircraft is legally considered "two-crew." Under subsection 421.34(9), an aeroplane is considered "required to be operated with a co-pilot" if it meets either of the following criteria:
Aircraft Flight Manual (AFM) Type Certification
The aircraft's type certificate explicitly mandates a minimum flight crew of two pilots (e.g., Dash 8, CRJ, ATR-42/72, Boeing 737, Challenger 604).
Operational Manual Requirement
Even if the aircraft is certified for single-pilot flight, it is operated under IFR with two pilots as legally mandated by the operator's approved Company Operations Manual (COM) under Part VII, a Private Operator Registration Document (Subpart 604), or RCAF Flying Orders.
The 90-Day Early Assessment Process
Because Second-in-Command (SIC) PPCs are no longer accepted for ATPL issuance, many First Officers faced a dilemma: You cannot act as Captain without an ATPL, but you cannot obtain an unrestricted ATPL without completing a PIC flight check during your upgrade course.
If an airline waits for a pilot to complete their command course and then submits the ATPL application, standard Transport Canada logbook auditing times (often 60 to 90 days) can leave newly trained Captains waiting in the right seat.
To resolve this, Transport Canada introduced the Early ATPL Assessment Program:
Email your regional Transport Canada Civil Aviation office requesting an "Early ATPL Assessment." Submit your complete digital or scanned logbooks, proof of payment via the Online Payment System (OPS), SAMRA/SARON/INRAT results, and a completed Form 26-0083 with Part B, Section 5 (Skill) left completely blank.
The regional licensing service team reviews your hours, cross-country night breakdown, instrument time, and exam validity. They will issue an official confirmation stating that you meet all CAR 421.34 requirements pending only the skill test.
The moment you complete your PIC PPC in the simulator, email your regional team with confirmation. If submitted electronically by the Approved Check Pilot (ACP), TC matches the file and issues your licence sticker without re-auditing your logbook.
Experience Requirements & Flight Time Credits
At least 900 hours must be completed in aeroplanes. Simulator instrument ground time cannot be counted toward the 1,500-hour total.
In aeroplanes. May include up to 100 hours of PIC Under Supervision (PICUS) per CAR 421.11. Must include at least 100 hours of X-C (min. 25 hours by night).
100 additional hours cross-country flight time as PIC, or 200 hours as co-pilot, or any proportional combination thereof.
As PIC or Co-Pilot. A minimum of 30 hours must be completed in aeroplanes.
Maximum 25 hours in approved ground trainers and maximum 35 hours in helicopters. Ground sim time does not count toward the 1,500-hour total.
Holders of a Glider Pilot Licence may credit up to 50 hours, and three-axis ultra-light pilots may credit up to 50 hours toward the 1,500-hour requirement.
How to Remove the "Skill Test Does Not Meet ICAO Requirements" Remark
If you were issued an annotated ATPL via a single-pilot multi-engine flight test or single-pilot IPC, you do not need to take another licensing written exam or re-audit your logbook hours.
1. Complete a Compliant Flight Check: Pass a Pilot Proficiency Check (PPC) or Pilot Competency Check (PCC) as Pilot-in-Command on an aircraft required to be operated two-crew (under AFM certification or Company Operations Manual).
2. Contact Your TC Regional Office: Email your regional Flight Crew Licensing service team with your PPC/PCC paperwork.
3. Free Re-issuance: Transport Canada will verify the checkride and issue a new Aviation Document Booklet (ADB) sticker free of charge.
Frequently Asked Questions
Can I still fly in Canada if my ATPL has the ICAO remark?
Yes. An annotated ATPL has complete legal validity across Canadian domestic airspace. You can exercise all privileges of an Airline Transport Pilot Licence within Canada under Subpart 604 and Part VII operations. However, if you fly internationally or seek to convert your licence to an FAA, EASA, or foreign CAA certificate, foreign inspectors may refuse to recognize it.
I am a First Officer on a Dash 8 or B737. Can my regular recurrent PPC count for my ATPL?
Not unless your PPC is explicitly designated as a PIC PPC. Standard recurrent checks for First Officers are Second-in-Command (SIC) PPCs. Under ACP Manual TP6533E Section 6.26(3)(b)(iii), an operator may designate a Commercial Pilot Licence holder as PIC during a PPC for the purpose of an ATPL application with prior Transport Canada Principal Operations Inspector (POI) approval. Speak to your chief pilot or training department to see if your company supports this.
What is the deadline for the 12-month skill test validity?
Under CAR 421.34(5)(a), your skill test must have been conducted within the 12 months preceding the official date of application. If your flight check was completed more than 12 months ago, Transport Canada will not accept it for ATPL issuance, and you will need to complete a fresh PPC, PCC, or flight test.
What happens to pilots who got their ATPL before these rules changed?
Existing Canadian ATPL holders are grandfathered. Transport Canada is not retroactively reviewing or revoking existing licences. However, if you apply to convert an older Canadian ATPL to a foreign licence, foreign civil aviation authorities may still review your historical flight test records.
Does an AQP Line Operational Evaluation (LOE) count?
Yes. Under CAR 421.34(5)(b), an applicant who successfully completes both a Line Operational Evaluation (LOE) and a Manoeuvres Validation (MV) under an approved Part 705 Advanced Qualification Program (AQP) is deemed to meet the skill requirement for an unrestricted ATPL.
Where can I direct official licensing inquiries?
Official licensing inquiries regarding CAR Standard 421.34 may be directed to Transport Canada Civil Aviation Pilot Training and Licensing at pilotlicensing-licencesdepilote@tc.gc.ca.
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