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EU law: opportunities and risks when flagging out pilot licences

Last updated on 3 October 2025
More and more private pilots in Germany are considering transferring their licence to a foreign EASA authority - a process colloquially referred to as "flagging out". The main reasons for this are concerns about restrictive medical decisions by the German Federal Aviation Authority (LBA) and the reliability check (ZÜP), which is unique in Germany. Austria's Austro Control in particular is a popular destination, as it is considered customer-friendly and efficient. However, the move abroad brings new risks as well as benefits and should be carefully considered.

Background: Standardised rules in the EASA area

Since the harmonisation of European aviation authorities, pilot licences have been standardised within the EASA area. Regardless of whether the licence was issued in Germany, Austria, France or another member state, it is equally valid in all EASA states. This makes it easier for pilots to transfer their licence from one national authority to another.

The trend towards "flagging out" has increased significantly in recent years, especially among private pilots. This is less about the licence rights themselves and more about administrative practice and how the respective authorities deal with medical and legal issues.

Main motives: Medical and ZÜP

The aeromedical department of the LBA, which many pilots perceive as non-transparent and restrictive, is a particular focus of attention. It is feared that even minor medical abnormalities could result in the loss of the medical. The loss of the medical in turn automatically leads to de facto unfitness and invalidates the licence rights.

A second key reason is the Background check (ZÜP)which only exists in Germany. Every five years, pilots must prove that there are no criminal or safety-related reasons against their flying activities. Even comparatively minor offences - such as insulting politicians or minor tax offences - can lead to a negative decision. The licence may not be exercised in Germany without a valid ZÜP.

Although other EASA states such as Austria have similar examinations, these are not usually a prerequisite for exercising the licence, but are limited to applying for an airport ID card, for example.

Risks associated with flagging out

As attractive as the change may seem, it is no guarantee of a carefree future. Medical requirements can also be strict abroad. One example: Austro Control sometimes sets stricter limits for blood values than the LBA. In addition, the legal situation can change at any time - national authorities are authorised to tighten their requirements.

There is also the political dimension: a member state leaving the EU would automatically mean that licences issued there would no longer be valid in the EASA area. An alternative destination that is still attractive today could therefore lead to problems in a few years' time.

Transfer procedure

Anyone wishing to flag out their licence must submit an application to the foreign authority. Austria, for example, offers an uncomplicated online form. The documents are then exchanged between the old and new authorities. Finally, a new licence is issued by the foreign authority.

The greatest risk lies in the area of medical records. Old medical reports are not always fully digitalised, and some aviation physicians have given up their practices. Missing data can delay the process considerably or even bring it to a standstill. It is therefore recommended that you obtain a complete copy of the aeromedical file yourself in good time.

Furthermore, it is generally not possible to transfer a licence if a negative decision has already been made by Medical or ZÜP. The applicant must therefore fulfil all requirements.

Duration and costs

The duration of a licence transfer varies considerably. In some cases, the process only takes a few months, in others it can take over a year. Sometimes internal delays at the LBA also play a role, particularly in the medical department.

The costs are manageable and are usually in the low to mid three-figure range. During the transfer, the previous licence remains valid so that pilots can continue to fly during the transition period.

Conclusion: weigh things up carefully, act early

Flagging out a licence can be a sensible option to make yourself less dependent on the German authorities. The medical and ZÜP issues in particular are understandable reasons for changing licences. However, you should not get the impression that everything is simpler and easier abroad.

Anyone planning a change should do so in good time - preferably before any problems arise with the medical or ZÜP. All medical documents should also be available in full. Ultimately, flagging out remains a tool that brings relief in certain cases, but is not a panacea.


Source references:
Aviation magazine

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