FAA Part 117 vs EASA FTL: Complete Comparison Guide for 2026

What are FAA Part 117 and EASA Flight Time Limitations (FTL)?

FAA Part 117 is the United States regulation that governs flight‑time limits and rest requirements for airline crew members. First issued in 2014 and updated through 2025, it replaced the older Part 121 rules and introduced a more flexible, data‑driven approach.

EASA Flight Time Limitations, commonly referred to as EASA FTL, are the European Union’s equivalent set of rules. They are defined in Commission Regulation (EU) No 965/2012, amended several times, and are administered by the European Union Aviation Safety Agency (EASA). Both frameworks aim to prevent fatigue‑related errors while allowing airlines to operate efficiently.

Key Objectives of Both Regimes

Protect crew health and safety.
Maintain high levels of operational safety.
Provide predictable, enforceable limits for airlines.
Allow flexibility to match airline schedules and crew preferences.

How the Regulations Are Structured

Both FAA Part 117 and EASA FTL break crew duty into three main elements: flight time, duty time, and rest periods. The details differ in the way limits are calculated, the use of “cumulative” versus “rolling” windows, and the role of fatigue risk management systems (FRMS).

FAA Part 117 Structure

Flight Time (FT): The airborne portion of a flight, measured from take‑off roll to landing roll.
Duty Period (DP): The interval that starts when a crew member reports for duty and ends when they are released from the aircraft.
Rest: Minimum uninterrupted sleep opportunity (USO) and mandatory rest periods before a duty period.
Limits: Maximum daily, weekly, and monthly limits for FT and DP, plus a 30‑day “cumulative” window for FT.
Fatigue Risk Management System (FRMS): Optional for most carriers, required for those seeking a “Tier 2” approval that permits higher limits.

EASA FTL Structure

Flight Duty Period (FDP): Combines flight time and pre‑flight duties; measured in minutes.
Rest Period: Includes a “minimum rest” and a “sleep opportunity” (normally 8‑10 hours).
Limits: Daily, weekly, and monthly FDP limits; additional “cumulative” limits for 28‑day and 90‑day periods.
Fatigue Risk Management System (FRMS): Mandatory for airlines seeking “extended FDP” authorisations beyond the standard limits.

Daily Limits: A Side‑by‑Side Look

Aspect	FAA Part 117 (2026)	EASA FTL (2026)
Maximum Flight Time per 24 h	8 hours for most crews; up to 9 hours after 3 years of experience, 10 hours after 6 years (subject to fatigue‑risk analysis).	Maximum FDP of 13 hours (8 hours for “early‑start” duty, up to 14 hours with extended FDP approval).
Maximum Duty Period per 24 h	14 hours for two‑pilot operations; up to 16 hours with “FAA‑approved FDP extension” after fatigue assessment.	Maximum FDP of 14 hours (standard), up to 16 hours with FRMS approval.
Minimum Rest before Duty	10 hours “rest” with at least 8 hours of uninterrupted sleep opportunity; 12 hours after a duty period of 12 hours or more.	10 hours “rest” with 8 hours of sleep opportunity; 12 hours after a duty period exceeding 12 hours.

Weekly and Monthly Limits

Both authorities impose limits to guard against cumulative fatigue.

FAA Part 117: 30 hours of flight time in any 7‑day period and 100 hours in any 28‑day period. Duty limits are 60 hours weekly and 190 hours monthly.
EASA FTL: 60 hours of FDP in any 7‑day period and 100 hours in any 28‑day period. Monthly FDP cap is 150 hours. A 90‑day cumulative limit of 840 hours FDP applies.

How Rest Is Defined and Measured

Rest definitions are a major source of confusion for operators that work across the Atlantic.

FAA Rest Requirements

“Uninterrupted Sleep Opportunity” (USO) must be at least 8 hours within a 24‑hour window.
Rest can be split, but at least one block of 2 hours must be taken in any 24‑hour period if the total rest is shorter than 8 hours.
“Reserve” time does not count as rest; crews must be “ready to report” but not actively on duty.

EASA Rest Requirements

Minimum rest = 10 hours, of which at least 8 hours must be a “sleep opportunity.”
Rest can be split into two periods, but one block must be ≥6 hours.
“Stand‑by” periods count toward rest only if they are “inactive” (crew not required to be at the airport).

Fatigue Risk Management Systems (FRMS)

Both regulators now accept FRMS as a pathway to exceed standard limits, but the expectations differ.

FAA FRMS

FRMS is optional for Part‑117 carriers. Most large U.S. airlines operate under the “standard” limits.
To obtain a “Tier 2” FRMS, an airline must submit a data‑driven fatigue model, validation evidence, and a monitoring plan.
Tier 2 approval allows extensions of daily flight time up to 11 hours for senior crew, provided the model demonstrates no increase in risk.

EASA FRMS

EASA requires FRMS for any operator that wishes to use “extended FDP” beyond the default limits.
The FRMS must be approved by the competent authority (the national aviation authority of the airline’s state). EASA audits the system annually.
Extended FDP can reach 16 hours for certain long‑haul operations, but only after a comprehensive scientific justification.

Operational Impact: Scheduling and Crew Pairing

Airlines that fly both U.S. and European routes often need separate crew rosters, because the two regimes treat duty and rest differently.

FAA rules consider “flight time” only while airborne, whereas EASA counts pre‑flight duties (engine start, push‑back) as part of the FDP.
When a crew member works a mixed‑fleet schedule, the airline must calculate limits under the stricter of the two regimes for each duty segment.
Software tools that support “dual‑compliance” can automatically convert FAA duty blocks to EASA FDP equivalents, reducing manual errors.

Common Misunderstandings

“Flight time” is the same everywhere. It is not. FAA counts only airborne minutes; EASA includes taxi, boarding, and post‑flight checks.
Rest periods are interchangeable. US‑based carriers may split rest differently than EU carriers. The 2‑hour block rule under FAA does not exist in EASA.
FRMS automatically grants higher limits. Both authorities require rigorous scientific validation; approval is not a certificate of unlimited flexibility.

Compliance Verification and Record Keeping

Both regulators demand precise electronic records, but the formats and audit frequencies diverge.

FAA Record Keeping

Electronic Flight Duty Period (eFDP) logs are mandatory for all Part‑117 operators.
Records must be retained for at least 2 years, with 6 months readily accessible for inspection.
Audits are typically conducted by the FAA’s Flight Standards Service during scheduled or unscheduled inspections.

EASA Record Keeping

Operators must maintain an “Operational Performance Monitoring” (OPM) file that includes FDP calculations, rest compliance, and fatigue reports.
Retention period is 3 years, with the latest 12 months required on‑site for any audit.
EASA conducts both routine audits and “targeted fatigue inspections” based on risk profiling.

Transition Scenarios: Moving a Crew Between Jurisdictions

When an airline transfers crew members from a U.S. base to a European base (or vice versa), the following steps help maintain compliance:

Map each existing duty block to the destination regime’s definition (e.g., add pre‑flight duties for EASA).
Re‑calculate cumulative limits using the appropriate rolling windows (30 days for FAA, 28 days for EASA).
Adjust rest schedules to meet the stricter minimum (usually the 10‑hour rest with 8‑hour sleep opportunity).
Update the crew member’s FRMS profile if they are covered by a system that differs between the two authorities.
Document the transition in the airline’s OPM or eFDP system, noting the date of regulatory change.

Future Outlook for 2026 and Beyond

Both FAA and EASA are moving toward greater integration of real‑time fatigue monitoring technologies. By 2026, many carriers are piloting wearable sensors that feed data into FRMS platforms, allowing dynamic adjustments to duty assignments. However, the core regulatory limits described above remain the baseline that any such technology must respect.

Practical Takeaways for Operators

Know the exact definition of “flight time” in each jurisdiction; mis‑classification can cause unintentional violations.
Maintain separate but compatible scheduling tools for FAA and EASA compliance.
Invest in a robust FRMS if you need to exceed standard limits; the approval process is demanding but can provide competitive scheduling flexibility.
Document every rest period and duty block accurately; audits focus on gaps in electronic records.
When planning crew exchanges between the U.S. and Europe, use the stricter limit as the default to avoid compliance gaps.