What is the FTL 2026 amendment and why does it affect charter operators?
The European Union Aviation Safety Agency (EASA) released the FTL 2026 amendment to the Flight Time Limitations (FTL) part of Regulation (EU) 965/2012. The amendment expands the scope of EASA’s FTL rules to include aircraft and operators that were previously exempt, most notably non‑scheduled charter flights that operate under a “private” or “non‑commercial” designation.
Historically, charter operators could avoid the detailed duty‑time recording and crew‑rest requirements that apply to scheduled airlines by classifying a flight as “private” or “non‑commercial.” The FTL 2026 update removes that loophole. From 1 January 2026, any aircraft used for the transport of passengers or cargo for remuneration, regardless of the marketing model, must comply with the same crew‑fatigue safeguards that airlines already follow.
Key definitions that changed in 2026
Understanding the new definitions is the first step to compliance.
- Charter operation: Any flight that carries passengers or cargo for remuneration and is not part of a regular published schedule. This includes ad‑hoc business‑jet trips, ACMI (aircraft‑crew‑maintenance‑insurance) leases, and “wet‑lease” operations.
- Non‑scheduled commercial operation: A flight that is not on a fixed timetable but still generates revenue – the category now covered by FTL 2026.
- Private flight: A flight that carries no remuneration, no passengers other than the owner or invited guests, and no cargo for hire. Only these truly private flights remain exempt.
What the new duty‑time limits are
The amendment does not create new numerical limits; instead, it obliges charter operators to apply the existing FTL tables that were designed for scheduled airlines. The most relevant tables are:
- Table 1 – Day‑time operations: Maximum flight duty period (FDP) of 13 hours for a single‑pilot operation, 14 hours for two‑pilot, with rest requirements that increase with duty length.
- Table 2 – Night‑time operations: Reduces the maximum FDP by up to two hours compared with day‑time limits and imposes stricter rest periods.
- Table 3 – Cumulative limits: No more than 100 hours of flight time in any 28‑day period or 900 hours in any 12‑month period, unless a specific waiver is granted.
Charter operators must now map each flight to the appropriate table, calculate the crew’s FDP, and ensure that subsequent rest periods meet the required minimums.
How the rules affect crew scheduling
Planning tools need updating
Many charter operators use proprietary or off‑the‑shelf scheduling software that was configured to ignore FTL rules for non‑scheduled flights. Those tools must be re‑programmed to:
- Identify every revenue‑generating flight as “commercial” regardless of how it is marketed.
- Apply the correct FDP and rest‑time calculations automatically.
- Generate alerts when a crew member approaches cumulative limits.
Impact on crew contracts
Contracts that previously referenced “private‑flight duty” will need amendment. Common changes include:
- Explicit inclusion of the FTL tables as contractual standards.
- Clause allowing the operator to re‑assign crews to meet rest‑period obligations.
- Procedures for recording FDP start and end times in a manner acceptable to EASA auditors.
Record‑keeping requirements
EASA now expects a digital “Flight Duty Log” for every crew member on charter flights. The log must capture:
- Start and end of each duty period (including “stand‑by” and “pre‑flight” activities).
- Exact block‑out and block‑in times.
- Rest periods taken, with timestamps and location (e.g., hotel, crew‑rest facility).
- Any deviations with written justification (e.g., operational exigency, medical emergency).
Records must be retained for at least 24 months and made available to the competent authority on request.
What exemptions and waivers are still possible?
The amendment retains a narrow set of exemptions, mainly for truly private flights and for certain state‑owned aircraft used for official duties. Additionally, an operator may apply for a “Specific Operational Deviation” (SOD) if:
- Operating in a remote area where crew‑rest facilities are unavailable.
- Conducting a one‑off humanitarian mission that cannot be scheduled within normal limits.
Approval for an SOD requires a risk assessment, a mitigation plan, and documented monitoring of crew fatigue. The application is evaluated by the national aviation authority (NAA) and must be justified with objective data.
Implementation timetable
EASA gave operators a two‑year transition period. The key dates are:
| Milestone | Date |
|---|---|
| Publication of Amendment (FTL 2026) | 1 January 2024 |
| Mandatory compliance deadline | 1 January 2026 |
| Final audit window (NAA) | 1 January 2026 – 31 December 2026 |
Operators were expected to begin internal audits in 2024, update SOPs in 2025, and complete crew training before the 2026 cut‑off.
Practical steps for charter operators to become compliant
- Gap analysis: Compare current SOPs, scheduling software, and crew contracts against the FTL tables.
- Software upgrade or replacement: Ensure the flight‑duty log can automatically calculate FDPs and mandatory rest.
- Policy rewrite: Insert the FTL tables into the Operations Manual and into crew contracts.
- Training: Conduct a two‑day classroom session for all pilots and operations staff covering the new limits, record‑keeping, and fatigue‑risk management.
- Internal audit: Run a mock audit three months before the deadline, using a random sample of past flights to verify compliance.
- Engage the NAA early: Submit any intended SOD applications well before the compliance date to avoid last‑minute rejections.
Common misconceptions clarified
- “Charter = private”: The new rules draw a clear line. Only flights that carry no passengers for hire are exempt.
- “We can keep using the old schedule template”: Templates that ignore night‑time reductions or cumulative limits will produce non‑conforming duty periods.
- “A single‑pilot flight is automatically safe”: The FDP for single‑pilot operations is shorter (13 hours) and rest periods are stricter; operators must still track them.
- “We don’t need a rest facility if we pay for a hotel”: Rest periods must be “uninterrupted” and of a minimum duration; a hotel stay qualifies only if the crew is not required to be on call.
Impact on the broader charter market
Compliance costs will rise for small operators that previously relied on minimal paperwork. However, the uniform application of fatigue rules levels the playing field with scheduled airlines, reducing the competitive advantage of “loophole‑based” scheduling.
In the medium term, operators that integrate robust fatigue‑management systems may market the safety benefit to corporate clients that demand higher standards. Insurance premiums are also expected to reflect the reduced risk of fatigue‑related incidents.
What to watch for after 2026
Once the amendment is fully in force, EASA may issue supplementary guidance on:
- Use of electronic flight bag (EFB) data for automatic duty‑time recording.
- Integration of fatigue‑risk management tools with crew resource management (CRM) training.
- Potential future revisions that address emerging technologies such as remote‑piloted aircraft used for charter services.
Staying informed through EASA’s “Aviation Safety Newsletter” and national authority updates will help operators adapt quickly.
