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Licensing explained
Frozen ATPL explained: what it is and how it gets unfrozen
A “frozen ATPL” is a CPL/IR with the ATPL theory exams already passed, waiting for the flying experience that turns it into a full Airline Transport Pilot Licence. This page walks through how that conversion works under EASA Part-FCL and for the UK CAA, using the published rules.
By Matthew Dowell, airline training captain and Chief Flight Instructor. Written in a personal capacity: a plain-language summary, not legal text and not approved or endorsed by EASA, the UK CAA or any authority. Your national authority decides your case, and the regulations always take precedence.
Rules checked 27 October 2026 against the sources listed at the foot of this page. The EASA text was read from the online Easy Access Rules, whose page is headed “Revision from August 2023”, so check for later amendments.
What does “frozen ATPL” mean?
The phrase is industry slang. Neither the EASA Part-FCL text nor the UK CAA ATPL(A) page uses it. What people mean by it is a pilot who has done two things:
- passed the ATPL theoretical knowledge examinations (the 13 EASA subjects; see ATPL exams explained), and
- been issued a CPL with an instrument rating, but not yet an ATPL, because the ATPL experience requirement has not been met.
The licence is not a different kind of licence; the pilot simply holds a CPL/IR. The ATPL is issued later, when the remaining requirements below are complete. Most pilots who finish an integrated or modular course end up here: the exams are done, the hours come from airline flying.
How a frozen ATPL becomes an unfrozen one
Under EASA Part-FCL the ATPL(A) has four ingredients. The numbers below are the rule text; the explanation is mine.
| Requirement | What the rule says | Rule |
|---|---|---|
| Prerequisite licence | An MPL; or a CPL(A) and a multi-engine IR for aeroplanes, plus instruction in multi-crew cooperation (MCC). | FCL.510.A(a) |
| Total experience | At least 1,500 hours of flight time in aeroplanes. | FCL.510.A(b) |
| Multi-pilot | Of those, at least 500 hours in multi-pilot operations on aeroplanes. | FCL.510.A(b)(1) |
| Command experience | Either 500 hours as PIC under supervision; or 250 hours as PIC; or 250 hours including at least 70 hours as PIC and the remainder as PIC under supervision. | FCL.510.A(b)(2) |
| Cross-country | 200 hours, at least 100 of them as PIC or PIC under supervision. | FCL.510.A(b)(3) |
| Instrument time | 75 hours, not more than 30 of them instrument ground time. | FCL.510.A(b)(4) |
| Night | 100 hours as PIC or co-pilot. | FCL.510.A(b)(5) |
| Simulator allowance | Up to 100 of the 1,500 hours may be in an FFS and FNPT; no more than 25 of those in an FNPT. | FCL.510.A(b) |
| Timing | The experience must be completed before the ATPL skill test is taken. | FCL.510.A(d) |
| Skill test | A skill test to Appendix 9, performed as PIC of a multi-pilot aeroplane under IFR, in the aeroplane or an adequately qualified FFS of the same type. | FCL.520.A |
| Theory | The ATPL theory examinations must still be valid (see below). | FCL.025(c)(2) |
Credits exist for pilots with other licences: FCL.510.A(c) credits up to 30 hours as PIC for TMG or sailplane time, 50% of the flight-time requirements for helicopter pilots, and 50% of flight engineer time up to 250 hours (which may be set against the 1,500 hours and the 500 multi-pilot hours, but not more than 250 in total against either).
The UK CAA's ATPL(A) page gives the same hours table for the UK licence. It adds that the applicant must be at least 21, hold a Part-MED Class 1 medical certificate, have met the type-rating requirements for the aircraft used in the skill test, and apply for the licence no later than six months after passing the skill test. For military and other credits, see the CAA page directly.
How long does the theory credit last?
This is the point that catches people out. Under FCL.025(c)(2), the completed ATPL theory examinations stay valid for the issue of an ATPL for 7 years from the last validity date of an IR entered in the licence. The UK CAA's ATPL(A) page repeats this. Two separate clocks come before it:
- 18 months to pass the whole set. Counted from the end of the calendar month of your first attempt at any paper (FCL.025(b)(2)). This is about sitting the exams, not about unfreezing.
- 36 months to use the pass for a CPL or IR. FCL.025(c)(1) makes a theory pass valid for the issue of a CPL or IR for 36 months.
The Irish Aviation Authority’s exam FAQ describes how the pieces fit for its candidates: at ATPL level the pass is accepted for a CPL and/or IR for 36 months from the date of the last required pass, and, provided both the CPL and IR are granted within that period, the ATPL-level results are accepted for an ATPL for seven years from the most recent validity date of the IR entered in the CPL. Other authorities apply the same EASA rule; confirm how yours records and checks it.
Read literally, the seven years follow your IR, not the date of the exams. That is a good reason to keep the IR current while you build hours, and to ask your authority to confirm your expiry date in writing rather than working it out yourself.
A note for Irish-licence holders: the IAA says that from 20 February 2026 the “ATPL theoretical knowledge credit” remark no longer appears on newly issued CPLs and MPLs, because it did not update itself when the credit expired. It says the credit itself is unaffected and that confirmation can be provided on request. Your authority may handle this differently.
EASA route versus UK CAA route
| EASA Part-FCL | UK CAA (UK Part-FCL) | |
|---|---|---|
| Hours | 1,500 total, with the sub-totals above | Same figures on the CAA ATPL(A) page |
| Prerequisite | MPL, or CPL(A) + multi-engine IR + MCC | Same |
| Theory validity | 7 years from last validity date of an IR entered in the licence | Same wording. The CAA adds that UK ATPL theory is “banked” for a CPL(A) to ATPL(A) upgrade where a pilot has kept an IR on a third-country licence within the last 7 years. |
| Skill test | Appendix 9, as PIC of a multi-pilot aeroplane under IFR | Same, with a UK CAA-certified examiner |
| Licence application | Through your Member State authority | Within six months of the skill test; minimum age 21; Class 1 medical |
For crossing between systems, EASA’s FAQ on UK-issued ATPLs says that from 1 January 2021 a UK ATPL is no longer valid to operate an aircraft registered in an EASA Member State unless it was transferred before then, and that holders convert under Commission Delegated Regulation (EU) 2020/723 by applying to any Member State authority. For licences from outside the UK and EASA, the UK CAA has a separate page on third-country CPL and ATPL conversion. I have not set out the theory-exam credits for those conversions here, because they depend on the licence and the authority and I have not checked them against the primary text.
What if my theory has expired?
Then the credit does not carry into the ATPL application, and you should expect to sit the ATPL theory again. How you do that (and how much training the training organisation requires first) is for your authority and organisation; FCL.025(b)(5) requires further training before a retake after the limits are used up. See ATPL exam rules by authority for how sittings, attempts and windows compare across countries.
Where the books fit
The ATPL theory is what makes the licence “frozen” in the first place, and it is also what airlines test again at technical interview. The Mastering ATPL series covers each subject with a revision guide and question bank; what order to take the papers helps you plan inside the 18-month window; and the technical interview page shows what an employer may ask years after you passed. The books are study aids and do not replace your training organisation.
Frequently asked questions
What is a frozen ATPL?
“Frozen ATPL” is pilots’ shorthand, not a term in the regulations. It describes a pilot who holds a commercial pilot licence (CPL) with an instrument rating (IR) and has passed the ATPL theory examinations, but who has not yet got the flying experience needed for the ATPL itself. The ATPL theory pass is the part that is “banked”; the licence is issued once the rest is met.
How do you unfreeze an ATPL?
Under EASA Part-FCL (FCL.510.A) you need a CPL(A) with a multi-engine IR and multi-crew cooperation (MCC) instruction, or an MPL; at least 1,500 hours of flight time with the stated minimum sub-totals; a pass in the ATPL skill test (FCL.520.A); and ATPL theory passes that are still within their validity period. The UK CAA page sets out the same structure for the UK ATPL(A).
How many hours do you need for an ATPL?
FCL.510.A(b) and the UK CAA ATPL(A) page both give 1,500 hours of flight time in aeroplanes, including at least 500 hours in multi-pilot operations, 500 hours as PIC under supervision (or 250 hours as PIC, or 250 hours including at least 70 as PIC and the rest as PICUS), 200 hours cross-country, 75 hours instrument time and 100 hours of night flight as PIC or co-pilot. Up to 100 hours may be in an FFS or FNPT, of which at most 25 in an FNPT.
How long does a frozen ATPL last?
The ATPL theory passes stay valid for the issue of an ATPL for 7 years from the last validity date of an IR entered in the licence (FCL.025(c)(2) in the EASA text, and the same wording in the UK CAA's version). If the seven years run out before you have met the requirements, the theory pass can no longer be used for the issue of the ATPL.
Is the 18-month rule the same as the frozen ATPL validity?
No. The 18 months is the window for passing all the ATPL theory papers in the first place, counted from the end of the calendar month of your first attempt (FCL.025(b)(2)). The seven-year period starts after you have passed and run through your IR; they are separate clocks.
Does a UK frozen ATPL work in the EASA system?
Not automatically. EASA's own FAQ says UK-issued ATPLs stopped being valid for aircraft registered in EASA Member States from 1 January 2021 unless transferred before then, and that conversion is done under Delegated Regulation (EU) 2020/723 with any Member State authority. Ask the authority you intend to apply to what it will accept for your theory passes.
Sources
- EASA, Easy Access Rules for Aircrew (Regulation (EU) No 1178/2011): FCL.025, FCL.510.A, FCL.520.A (ATPL(A) prerequisites, experience, crediting, skill test; theory validity). Checked 2026-10-27.
- UK Civil Aviation Authority, Airline transport pilot licence for aeroplanes: ATPL(A) prerequisites, theory subjects and seven-year validity, flight time, skill test, crediting. Checked 2026-10-27.
- UK Civil Aviation Authority, FCL.025 Theoretical knowledge examinations (UK Part-FCL): UK text of the 18-month, attempts, sittings and validity rules. Checked 2026-10-27.
- UK Civil Aviation Authority, Third Country CPL and ATPL licence conversion requirements: Linked from the CAA ATPL page; not summarised here. Checked 2026-10-27.
- EASA, FAQ 127223: UK-issued ATPL conversion: Page shows last updated 07/05/2021. Checked 2026-10-27.
- Irish Aviation Authority, FAQ - Pilot Examinations: Q.4 on validity of ATPL-level passes. Checked 2026-10-27.
- Irish Aviation Authority, FAQs - Pilot Licensing (EUQ.30): ATPL theoretical knowledge credit remark from 20/02/2026. Checked 2026-10-27.
Not legal or regulatory advice. Always confirm with your national authority and approved training organisation.
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