Co-pilot flight time criteria

Canadian Aviation Regulations (CARs) 401.10 and 421.10 used to allow for only 50% of co-pilot time to be credited towards the issuance of a higher class pilot licence. As of April 14, 2014, this regulation and standard have been repealed. 100% of co-pilot flight time may now be used towards the total flight time required for the issuance of a higher class of pilot licence. This now harmonizes Canadian Requirements with ICAO’s equivalent Standard. The following brochure provides additional guidance information for pilots with regard to the applying co-pilot time.

YES a pilot who is qualified on type, and who is acting as first officer, can legally log co-pilot flight time and credit it towards an ATPL.


  1. The aircraft is required to be operated with a co-pilot, according to CARs Part VI or VII and as stated in the Private Operators Certificate or Air Operator's Certificate.


2. The minimum flight crew is 2 pilots, according to the aircraft Type Certificate. Refer to CAR 421.40 Appendix A Type Designators for guidance material.

Required to be Operated with a Co-Pilot

The operational requirement for a co-pilot may be stated in the Air Operations Certificate (AOC) or Private Operator Certificate (POC) that has been approved by Transport Canada's Commercial and Business Aviation (CBA).

If an AOC or POC states that aircraft are required to be operated with a co-pilot, then the operational requirement has been established and approved for the use of a co-pilot. Details on an approved AOC or POC, Operation Specifications (Ops Spec), and Operations Manuals can be provided by the company Operations Manager or the CBA Inspector responsible for the company.

Many companies have an Ops Spec for single pilot IFR which defines the criteria for operations without a co-pilot. The operations manager and chief pilot may be the only employees that have met the single pilot IFR qualifications (1000TT, 100 multi, 50 IFR, 50 on type) and have a Pilot Proficiency Check (PPC) specifically for single pilot IFR. Other pilots employed by that company may not have a single pilot PPC, so a co-pilot is required by law. By way of example, in the case where an aircraft is dispatched in accordance with the ops spec for single pilot IFR, a co-pilot is not required and in fact is not permitted.

In a separate situation, a company may hold the required Ops Spec to fly single pilot IFR, but the Line Captain does not have a single pilot PPC. Therefore a second-in-command is required to legally fly the aircraft according to the CBA approved Operations Manual.

The onus is on the ATPL applicant to provide Flight Crew Licensing with proof that the co-pilot time logged is appropriate to credit towards an ATPL. A letter from the operations manager or chief pilot stating company policy and quoting the company Operations Manual clarifies individual situations.

Minimum Flight Crew of 2 Requirement

The type certificate determines if an aircraft is to be operated with a minimum flight crew of 2. For example, large Boeing Aeroplanes (B737, 747, 757, etc.) are designated as minimum flight crew of 2 on the type certificate. Guidance material regarding minimum crew requirement is found in Section 421.40 of the CARs - Appendix A Aircraft Type Designators. This chart is a guide only and, in the event of a discrepancy, the appropriate Aircraft Type Approval, Aircraft Type Certificate, Flight Permit, Aircraft Flight Manual or Pilot's Operating Manual take precedence.

Note 1: For an initial 2 crew type rating, you must complete ground and flight training on the aircraft type, have 250 hours TT, write SARON and SAMRA or IATRA, and pass a PPC for that type within 12 months preceding the application date.

Note 2: Subpara CAR 421.34(4)(c) refers to flight time calculated in accordance with section 421.10. Since section 421.10 was repealed on April 14, 2014 the requirement is straight forward and should read “100 additional hours cross-country flight time as pilot-in-command or 200 hours as co-pilot or any combination thereof.”

Note 3: Another way to credit co-pilot time is Pilot-in-command Under Supervision (PIC U/S). This program can be instituted by large and small air carriers, allowing co-pilots to credit up to 200 hours co-pilot time as 100 hours PIC U/S. This means that 50% of up to 200 hours co-pilot time can be credited as PIC experience if approved and if completed within 12 months of the application date. You can apply 50 hours PIC U/S cross country night to meet the 25 hour night PIC cross-country requirement.

For further information: 
Transport Canada's response to Aviation Safety Recommendations A15-01 and A15-02 issued by the Transportation Safety Board of Canada (TSB)