Introduction: What does N-registration mean?
The N-registration refers to the registration of an aircraft in the USA, as all US aircraft begin with the letter "N". This registration is under the supervision of the Federal Aviation Administration (FAA). Many pilots choose to have an aircraft N-registered in the USA, even if it is operated in the EU. But why does this make sense?
Advantages of N-registration
- Maintenance flexibility: FAA maintenance regulations are often more flexible and cost-effective than EASA regulations.
- Sales opportunities: An N-registered aircraft is easier to sell on the international market as the FAA rules are recognised worldwide.
- Access to FAA licences: With an FAA licence, pilots can fly N-registered aircraft worldwide. Please note that if your place of residence is in the EU, the American licence must be converted into an EASA licence (see below).
- Independence from EASA regulations: Some owners prefer the FAA rules because they are less complex or restrictive.
Challenges of N-registration
The owner of an N-registered aircraft must either be a US citizen or set up a US trust in order to fulfil the legal requirements. There are various providers for this.
An N-registered aircraft may only be flown by pilots with an FAA licence. Pilots with EASA licences must have their licence validated (validation) or converted (conversion). This is what this article is about.
Options for flying an N-registered aircraft in the EU
You have an FAA licence (but no EASA licence) but a residence in the EU and want to fly the N-registered aircraft in the EU.
This is only relevant if you (only) have a US pilot licence from the FAA (e.g. PPL) and want to fly in the EASA area. While this was previously possible with the US licence without any further requirements, since mid-2023 a transfer to a European EASA licence has been necessary. This step is necessary for all pilots with a US licence who are resident in the EASA area and wish to fly N-registered aircraft in Europe. A bilateral agreement between the EU and the USA, known as BASA (Bilateral Aviation Safety Agreement), and its technical implementation provisions in TIP-L (Technical Implementation Procedures for Airworthiness and Environmental Certification), have simplified the conversion process.
Key points and requirements for the transcription:
- EASA medical certificate: A valid EASA medical certificate is required. People who can only obtain the FAA medical face problems.
- German radiotelephony certificate: A BZF (for VFR licences) or AZF (with instrument rating) limited to English is issued on the basis of the US licence. The German part of the radiotelephony licence can be obtained through a simplified examination without a written part. The entry "English proficient" in the US licence is regarded as ICAO language certificate level 4, which must be renewed every four years.
- Background check (ZÜP): A background check of the applicant is required.
Rewriting process for specific authorisations:
PPL (Private Pilot Licence): After applying to the state aviation authority and obtaining an EASA certificate of airworthiness and the required radiotelephony licence, only a practical test is required. The theoretical knowledge is also tested.
Night flight authorisation: A minimum of 5 hours flying time at night is required, including 3 hours with instructor, 1 hour cross-country flight and 5 solo takeoffs and landings. FAA training is recognised.
Instrument rating (IFR): A simple revalidation is possible if more than 50 hours of IFR flight time as PIC (Pilot in Command) can be demonstrated. It is important to note that the FAA counts one flight hour as IFR time when flying exclusively under instruments, whereas the EASA counts flight time under IFR flight plan, even in good weather. If you have less than 50 hours of IFR experience, a written theory test is also required. Acclimatisation flights are also necessary if you do not have 10 hours of PIC under IFR in the EASA area.
Recommendations:
- Early application for transfer of the licence including the necessary additional authorisations and checks.
- Refreshing European theory knowledge for the practical exam.
- Aim for at least 50 hours of IFR flight time as PIC to avoid the expense of the theory test.
In summary, pilots with a US licence who wish to fly in Europe must go through this revalidation process to obtain the required European licences and ratings.
You have an EASA pilot licence and want to fly your N-registered aircraft within the EASA area
As long as you only fly in the country in which you obtained your pilot licence, you can continue to do so and do not need to do anything else. However, if you want to fly outside your home country but within the EASA with your N-aircraft, you basically have two options: Either you convert your EASA licence into a full FAA licence (called "conversion") or you use the simplified "validation" process, which means that you do not have a full FAA licence, but a licence that is only valid in conjunction with the EASA licence.
Option 1: Conversion
Of course, you can always choose to get a full FAA licence. For commercial licences such as CPL or ATPL, this is the only way to go. For private pilot licences, however, you can also take a simplified route and "rewrite" your EU licence. The procedure used for this is the "TIP-L":
"On November 19, 2020, the United States and the European Union (EU) approved the Technical Implementation Procedures Licensing (TIP-L), which details the conversion of an EU Part-FCL private pilot licence (PPL(A)), and night and instrument ratings (IR(A)) for single-engine piston (SEP) land airplane and multiengine piston (MEP) land airplane categories for single-pilot operations, excluding type ratings."
The individual steps are (see also: Conversion training - Dr Schwahn Flying in the USA)
- Step 1: Registration on IACRA (Integrated Airman Certification and Rating Application): https://iacra.faa.gov - the account is required for everything to do with the FAA licence
- Step 2: Log in to IACRA -> new application -> verification of foreign licence and complete everything there. The FAA then contacts the relevant aviation authority of the country issuing the EASA licence (e.g. the LBA for Germany) and requests a copy of the EASA licence and the EASA medical. As soon as this has been received, you will receive a "Letter of Authentication (LoA)" via the IACRA system, which is valid for 6 months.
- Step 3: Despite the confirmation of the EASA medical, you still need an FAA medical. For this you have to go to an authorised aviation physician who you can find via the Pilot Hub.
- Step 4: Register for the theoretical exam
If you want to convert your PPL, the code is: "PEP" which stands for "Private Pilot Airplane EU Part-FCL Conversion". If you also want to convert your instrument rating, the code is: "IEP" which stands for "Instrument Rating EU Part-FCL Conversion".
Log in to the following website: Login - Talogyregisters there and signs up for PEP and/or IEP at one of the test centres listed. In contrast to a standalone theory test, the theory is reduced and focusses on the areas of air law, flight planning and communication. ASA is recommended as preparation (Prepware study software for FAA Pilot Knowledge Exams). For the IR test I can recommend the "FAA Knowledge Prep" book by Gleim Aviation. - Step 5: Once you have passed the theory, apply for the licence via IACRA: .->new application-> Type of application: Pilot->certification: private pilot -> TIP-L (EASA)->Private Pilot.
For the PPL transcription, click on ->Original.
For the rewriting of an Instrument Rating to ->added Rating->Instrument Rating or ->Multi Engine Rating for the rewriting of an ME Rating.
You will receive an FTN (File Transfer Number) with your application, which you will need for the rest of the process - Step 6: Flight training in the USA. Flight training must then take place at an appropriate school in the USA. Previous flight experience is taken into account for this
- Step 7: Flight review. This is followed by an official flight review (i.e. a "test") for the PPL in accordance with § 61.56 with a flight instructor, which consists of a theoretical and practical part, including FAR Part 91. This is the American Aviation Regulation. For the possible IR, an Instrument Proficiency Check (IPC) flight also takes place with a flight instructor
- Step 8: Examiner. Once all of the above steps have been successfully completed, an appointment must be made on site in the USA with an FAA examiner. The examiner no longer carries out an examination, but verifies whether all the necessary documents and requirements for the issue of the licence have been met. If this is the case, he will issue a "Temporary Certificate" and some time later you will receive the official FAA licence plastic card by post.
Option 2: Validation
An FAA licence "recognition" based on an existing EASA ICAO licence is also called "validation" or "14 CFR §61.75 licence". These regulations specify how a pilot with a foreign licence can obtain a validation for an FAA Private Pilot Licence. Unlike a "conversion", this is not a fully-fledged US licence, but is only valid in conjunction with the EASA licence (which should be completely sufficient for most pilots).
Validation is only possible for a private pilot licence (incl. instrument rating). To be able to fly a CPL or ATPL, however, you need a full FAA licence or can then do the conversion described above. (You can of course also go through validation with an EASA CPL, but then you will only receive this for the PPL, i.e. you will not be allowed to fly commercially with the N-registered aircraft in EASA space).
The FAA PPL obtained in this way is valid for as long as the EASA PPL is valid, so it is bound to it! This is the big difference to the independent FAA licence obtained through a conversion.
The validation process is simpler than a conversion. No theory test is required for the validation of a PPL and no flights or flight reviews with flight instructors in the USA are required (but a flight review with a certified FAA flight instructor as described below). Basically, the validation is a purely administrative act. There is one restriction: A theory test must very well be passed for the instrument rating.
The individual steps for validation are
- Step 1: Registration on IACRA (Integrated Airman Certification and Rating Application): https://iacra.faa.gov - the account is required for everything to do with the licence
- Step 2: Log in to IACRA -> new application -> verification of foreign licence and complete everything there. The FAA then contacts the relevant aviation authority of the country issuing the EASA licence (e.g. the LBA for Germany) and requests a copy of the EASA licence and the EASA medical. As soon as this has been received, you will receive a "Letter of Authentication (LoA)" via the IACRA system, which is valid for 6 months.
- Step 3: Register for the theoretical exam
No examination is required for the validation of the PPL! This is only necessary for a possible IR. If you want to validate your IR, the code "IFP" applies, which stands for "Instrument Rating Foreign Pilot via Non-BASA".
Log in to the following website: Login - Talogyregister there and sign up for the IFP at one of the test centres listed. For the IR test, I can recommend the "FAA Knowledge Prep" book by Gleim Aviation. - Step 4: Once you have passed the theory, you apply for the licence via IACRA: .->new application-> Type of application: Pilot->certification: private pilot. You will receive an FTN (File Transfer Number) with your application, which you will need for the rest of the process.
- Step 5: In the USA on site(!): here you must contact a local FSDO (Flight Standards District Office) and make an appointment with an FSDO inspector or a Designate Pilot Examiner (DPE). The DPE will then check all documents such as passport, verification letter, EASA Medical, Instrument Rating Knowledge Test Report (i.e. the result of the theory test) and FTN number.
All details about the process can be found here: https://www.fliegen-usa.de/formalitaeten/anerkennung-validation/
If everything is in order, the examiner will issue a "Temporary Certificate" and some time later you will receive the official FAA licence plastic card by post.
Even if you then hold the licence in your hands, you are not allowed to fly until the following things have been done. These can be done in your home country, but it must be an FAA-certified examiner.
- For the PPL: A flight review (1 hour flight training and 1 hour ground training)...success is confirmed by an "endorsement" in the logbook. FR61.56 applies: https://www.law.cornell.edu/cfr/text/14/61.56
Such a flight review must be repeated once every 24 months (i.e. similar to the revalidation of the EASA PPL). The corresponding test flights can also be combined here.
- For the IR: IFR Proficiency Check according to FR61.57: https://www.law.cornell.edu/cfr/text/14/61.57
"The instrument proficiency check must consist of at least the following areas of operation: (i) Air traffic control clearances and procedures.
(ii) Flight by reference to instruments; (iii) Navigation systems; (iv) Instrument approach procedures; (v) Emergency operations; and (vi) Postflight procedures."
In contrast to the EASA-IR, which has to be renewed every year, the FAA-IR is permanently valid after the IFR Proficiency Check and the check only has to be done once. However, the following conditions apply in order to keep this rating "current" (i.e. permanently valid):
Within the last 6 calendar months you must:
- Complete six (6) instrument approaches.
- Carry out a holding procedure.
- Perform interception and navigation of courses using instrument navigation techniques.
- Fly at least one missed approach (performed or simulated)
Radiotelephony
Whether conversion or validation: A "Radio Operator Permit Limited Use" is required from the FCC to fly an "N-registered" aircraft or, more precisely, to operate a radio station outside the USA. Information and application can be found here: Obtaining a Licence | Federal Communications Commission
Further links
https://www.faa.gov/licenses_certificates/airmen_certification/foreign_license_verification
https://basic6aviation.com/questions_page.html
https://www.fliegen-usa.de/ausbildung/umschreibung-easa-in-us-lizenzen
https://www.fliegen-usa.de/formalitaeten/anerkennung-validation
FAA Test Prep Online: Instrument Rating - Gleim Aviation
Ownership of an N-registered aircraft
If you buy such an aircraft, there are other things to consider in addition to the licence. The owner must be a US trust, as described above (if you are not a US citizen). In addition, insurance is required, the aircraft itself needs a "Radio Station Authorisation" from the FCC and much more. We have summarised all the necessary information in a separate article on buying an aircraft in the Pilot Hub.