Canadian Pilot Flight Time Limits: Auditing Rolling Windows

Executive Summary

Canada's CAR 700.27(1) caps a flight crew member's total flight time at 112 hours in any 28 consecutive days, 300 hours in any 90 consecutive days and 1,000 hours in any 365 consecutive days, with a separate 8 hours in any 24 consecutive hours for single-pilot operations ^[1]. Subsection 2 adds the point that matters most for a personal record: flight time includes "the flight time accumulated from other flight operations" ^[1] and the full flight time of a flight with an augmented crew. Transport Canada's Advisory Circular (AC) 700-047, Issue 05, effective 28 June 2024, explains the arithmetic as the previous 27, 89 and 364 days, not including today, plus the day's flying ^[2].

The question this report addresses is narrower than "what are the limits". A single roster can be accurate and still incomplete. AC 700-047 says the pilot must advise the operator of all flight time, and lists private or military flying among it ^[2]. A personal rolling total is therefore only as good as its inventory of flying sources. The report proposes a source register, a snapshot with exact first and last included dates, and a correction bridge that carries a late change through every affected window.

A synthetic example (Hypothetical Example), not observed pilot data, shows the mechanics. Previous-27-day employer records of 100.0 h plus 4.0 h of separately substantiated private flying would read 107.0 h if a second feed's 3.0 h were added, but that 3.0 h is proven already included, so the supported subtotal is 104.0 h. An illustrative 6.0 h flight on the evaluation date gives 110.0 h for the 28-day accounting. A late 2.0 h correction raises it to 112.0 h and must also raise the 90-day and 365-day totals and every snapshot whose window contains the corrected flight. A 10.0 h augmented flight stays 10.0 h even if 6.0 h was spent at the controls.

Three limits apply to any such display. The CARs and AC sections read do not say how a flight that crosses midnight is allocated to calendar days, so boundary treatment is an assumption to document. Division III excludes Subpart 702 operators and medical evacuation flights ^[2], and an approved fatigue risk management exemption is a further scope question. And flight time is distinct from hours of work under CAR 700.29 ^[3]. Totals reconcile records; they never grant permission to accept a flight. Pilot Logbook, the invitation-only electronic logbook from LANDING.AERO, advertises 28/90/365-day checks; this report explains how to compare any such display with the register by hand and does not claim to have tested it.

Introduction and Background

This report is written for professional pilots who fly under Canada's Division III framework and whose flying does not all pass through one employer's roster: those changing employers, those who also fly privately, and those serving on augmented crews. It examines one deliverable, a personal rolling flight-time record that can be reproduced from raw flight records and dated precisely. It is a record-reconciliation exercise. It does not replace an operator's approved procedures, an authority's determination, or a pilot's own judgment about whether to accept a flight.

The regulatory text is short and the arithmetic is simple. What is hard is completeness. CAR 700.27(1) prohibits an air operator from assigning, and a flight crew member from accepting, flight time that would push the member's total over the listed limits ^[1]. AC 700-047 repeats the dual prohibition ^[2]. Because the pilot is a named party to the prohibition, the pilot's own count matters, and a count built from one roster can miss flying done elsewhere.

Existing references already explain the limits. The tiredpilots.ca rule page walks through the previous-27/89/364-day method and lists what counts ^[4], and the Air Line Pilots Association (ALPA) mobile documentation states that flying beyond the current employer must be included ^[3]. This report adds a worked, dated reconciliation across several record sources, a boundary-assumption log and a correction bridge.

Jurisdiction is named throughout. The binding text discussed is the Canadian Aviation Regulations (CARs), SOR/96-433, administered by Transport Canada. United States and European Union rules appear only as contrast in the data section, and nothing here is licensing-credit advice in any jurisdiction. Pages were read on 8 November 2026, and every "as of" statement refers to that date. Pilots should re-check the current text before relying on any figure.

The Canadian Regime and the Purpose of a Personal Record

Binding rule, guidance and national practice

The first discipline is to separate three layers. The binding rule is CAR 700.27, in Part VII, Division III, headed "Flight Crew Member Fatigue Management". The guidance is AC 700-047, Issue 05, effective 28 June 2024; Transport Canada states that it does not "set minimum standards or change, create, amend or approve deviations" ^[2]. Practice, such as how an operator or a logbook app displays totals, is neither: it is an implementation choice that should be compared with the rule, not assumed to equal it.

Division III was made by SOR/2018-269, registered on 7 December 2018 ^[5] and published in the Canada Gazette, Part II, on 12 December 2018. Its regulatory impact analysis statement describes a regime for air transport services excluding private air operators ^[5]. Subpart 705 operators had two years from publication to comply ^[5], and Subpart 703 and 704 operators had four ^[5]. Transport Canada's overview of the changes gives the same staging as 24 months for major airline operators and 48 months for smaller and regional operators ^[6].

Who is inside the framework

Scope is the first fact to establish before any arithmetic. Division III does not apply to an air operator who operates under Subpart 702 ^[7], nor to an operator conducting a medical evacuation flight ^[7]; the latter fall under a separate Division with its own limits, which this report does not cover. AC 700-047 states that it applies to holders of air operator certificates under Subparts 703, 704 and 705 ^[2].

Exemptions are the second scope question. Transport Canada describes a performance-based alternative in which an operator submits a safety case to obtain an ongoing exemption ^[8], and AC 700-045 states that such exemptions are available to all Part VII air operators ^[9]. That AC also lists provisions that cannot be exempted, including paragraph 700.27(1)(c), the 1,000-hour annual limit ^[9]. A pilot's personal 365-day total therefore keeps its meaning under any such exemption, while the 28-day and 90-day limits may be subject to operator-specific terms. No public list of exemption holders was located, so whether a particular operator relies on one is a question for that operator.

The purpose of this record

The personal record has one job: to let a pilot reproduce, from raw flight entries, the same three numbers an operator would compute, and to see where the pilot's own inputs and the operator's differ. CAR 401.08 already requires a licence holder to maintain a personal log ^[10]. The additional audit fields proposed below are recommendations. They are not a statutory logbook-field list, and no signature or special legal-credit field is implied.

One boundary keeps the scope clean. CAR 700.29 governs hours of work and carries its own separate limits, listed in the data section. Those are assignment limits on flight duty periods and are excluded from the flight-time arithmetic here; ALPA's documentation likewise treats flight time and hours of work as separate cumulative metrics ^[3]. Rest, fatigue and flight duty period questions are also left aside.

Inventorying Flying Sources and Reconciling Overlaps

Start from flown records, not plans

A roster is a plan; a flown record is evidence. The register therefore needs a column that says which each row is, and plans stay out of totals. Canada's definition of flight time is the time "from the moment an aircraft first moves under its own power for the purpose of taking off until the moment it comes to rest at the end of the flight" ^[11]. That is block-to-block time. tiredpilots.ca glosses it as chocks-off to chocks-on and distinguishes it from air time ^[4]. A source that reports air time, wheels-up to wheels-down, cannot be dropped into the register without conversion or a documented note.

Every flying source belongs in the inventory:

• Current employer actual records, as flown, not as rostered.
• Previous employer records that still fall inside a window, which is the usual gap after a job change.
• Other operators, including a second air operator or contract flying.
• Private flying, which AC 700-047 explicitly lists with military flying ^[2].
• Augmented-crew flights, where the full flight counts ^[4].
• Imported feeds, such as a roster import or a second system's export, which can duplicate a flight already held.

The rule's own wording supports this breadth. AC 700-047 says both the operator and the member must include all flight time in the totals ^[2], and tiredpilots.ca reads the rule the same way ^[4]. An imported employer roster therefore cannot be assumed to contain every flight.

Table 1: a source register with synthetic rows (Hypothetical Example)

Table 1 below shows the proposed register using the synthetic example (illustrative, not observed pilot data). Evaluation date is 31 October 2026. Columns beyond flight identity, interval and duration are recommended audit fields.

Table 1 makes three choices visible. First, the duplicate in R3 is resolved by a documented match key, not by a guess; the supported subtotal depends on that proof. Second, R6 shows a plan held in the register but kept out of the totals. Third, R7 records the full supported flight duration, so a 10.0 h flight does not silently become 6.0 h because that was the time at the controls. AC 700-047 says that for augmented crews the flight time counts "not just the time that the flight crew member spends at the flight controls" ^[2].

Duplicate identity

Overlapping sources are the commonest cause of an inflated total, and under-matching is the commonest cause of a deflated one if a pilot over-removes. Neither CAR 700.27 nor the AC prescribes a duplicate-matching key, so any key is the pilot's own, and it should be written down. A workable key combines date, operator, flight number or registration, and off-block time within a stated tolerance. A unique flight identifier helps where a tool provides one; MyFlightbook's comma-separated export, for example, adds a "FlightID" column as the unique identifier ^[12]. Where two rows share most fields but differ in time by more than the tolerance, the register should hold both rows as unresolved rather than choose one.

Deriving the Three Rolling Subtotals With Explicit Dates

The window arithmetic

AC 700-047 explains the calculation by subtracting from each limit the total flight time flown in the previous 27 days, 89 days and 364 days, not including today. Its worked figures include 103.4 hours in the previous 27 days and 986.7 hours in the previous 364 days ^[2]. The tiredpilots.ca page describes the same method ^[4] and calls each limit "a running total over the window ending now" ^[4]. For a personal record, "today" is the evaluation date. The 28-, 90- and 365-day totals are the previous-27/89/364-day subtotals plus the evaluation date's own flying, and the register should show the two parts separately so that a planned or actual amount for today is never mixed into history.

For the evaluation date of 31 October 2026 in the synthetic example, the inclusive windows are:

• 28-day window: 4 October 2026 to 31 October 2026 (previous-27 subtotal covers 4 to 30 October).
• 90-day window: 3 August 2026 to 31 October 2026 (previous-89 subtotal covers 3 August to 30 October).
• 365-day window: 1 November 2025 to 31 October 2026 (previous-364 subtotal covers 1 November 2025 to 30 October 2026).

Each first date is the evaluation date minus 27, 89 or 364 days. Publishing exact first and last included dates with every total is the cheapest guard against an off-by-one error, and it lets a reader or operator reproduce the figure.

Boundary assumptions that must be documented

Two boundary questions are not answered in the sections of the CARs and the AC read for this report. First, we found no provision defining how a flight that crosses midnight is allocated to calendar days. The only time convention found in Division III is that references to a time of day mean local time at the member's location, which concerns acclimatization, not the rolling windows ^[7]. Second, nothing read states whether the window day boundary is UTC or local. Logbook software varies: MyFlightbook states that times must be in UTC for its calculations ^[12], its import documentation specifies UTC date-times ^[13], and its developer blog notes that the date of flight "seems to always be in local time" by default, with an example in which a 6 p.m. local departure is already the next day in UTC ^[14].

The synthetic illustration below (Hypothetical Example) shows why this matters. For this illustration only, restate R1 as covering 3 to 30 October and suppose its 100.0 h includes a 3.5 h flight that departs at 23:10 UTC on 3 October and lands at 02:40 UTC on 4 October. The 28-day window starts on 4 October.

• Departure-date allocation: the flight falls on 3 October, outside the window, so the previous-27 subtotal is 100.0 h minus 3.5 h, or 96.5 h.
• Landing-date allocation: the flight falls on 4 October, inside the window, and the subtotal stays 100.0 h.
• Proportional split: 50 minutes fall on 3 October and 160 minutes on 4 October, so only 2 h 40 min (about 2.7 h) is inside the window, giving about 99.2 h.

All three treatments are arithmetically possible. None is a finding about what the regulation requires, and the register should state which one the pilot assumed, mark the row "boundary unresolved", and carry the question to the operator. The same applies to a local-versus-UTC date difference on any flight near a window edge. A spread of up to 3.5 h on a 112 h limit is large enough to be worth asking about.

Table 2: the correction bridge (Hypothetical Example)

Table 2 below carries the synthetic 28-day figures from a naive sum, through removal of the duplicate, addition of today's flight and the late correction, to the revised snapshot. The 90- and 365-day columns use invented earlier flying (142.5 h from 3 August to 3 October, and a further 410.0 h from 1 November 2025 to 2 August 2026) purely to show propagation.

Table 2 is deliberately mechanical. The supported previous-27 figure is 104.0 h, not 107.0 h, because 3.0 h is proven already included. The 110.0 h figure is a 28-day accounting number for the example only. The correction then moves each window by the same 2.0 h, because a flight on 20 October sits inside all three. Other flight-time totals in the register that were exported, printed or sent before the correction are now stale and should be marked superseded, with the correction date recorded.

The synthetic totals are not an assessment of any assignment. A 28-day total of 112.0 h equals the numeric cap, and what that means for any decision depends on facts a flight-time-only record cannot supply: the specific assignment, the single-pilot 24-hour test, the hours-of-work limits and the operator's approved procedures.

Corrections, Operator Comparison and Their Limits

How a late correction propagates

A corrected flight changes more than the snapshot in which it was spotted. Using the 20 October flight in the example, the corrected row is inside the 28-day window for every evaluation date from 20 October to 16 November 2026, inside the 90-day window until 17 January 2027, and inside the 365-day window until 19 October 2027. Every previously saved snapshot with an evaluation date in those ranges is affected. The correction register should therefore carry, for each change, the original value, the new value, the flight identity, the date of the correction, the evidence and a list of snapshots restated. Without that list, a pilot may hold two exports that disagree and no record of why.

The same rule applies to a removal. If a row later proves to be a duplicate or a roster plan that never flew, the flight is removed from every affected window. Corrections that add flying are particularly easy to lose because a new row is dated in the past: the correction date and the flight date are different fields, and both should appear.

Comparing the evidence with the operator's record

A comparison with an operator's own figure is a clarification exercise. The pilot's register is not a rival to the operator's system; it is a way to ask a precise question. A useful comparison table lists, for the same evaluation date, the operator's figure, the register's figure, the difference and the candidate causes. Typical causes are:

• Missing source: private, military or other-operator flying not in the operator's data.
• Duplicate: a flight counted from two feeds.
• Augmented flight: the full flight duration versus a shorter at-controls figure.
• Boundary rule: a midnight-spanning flight allocated differently.
• Today's treatment: a planned amount for the evaluation date counted or not counted.
• Effective date of a correction: one side has applied a late change and the other has not.

The AC allocates part of this to the pilot, who "must advise the air operator of all flight time". An unresolved difference should therefore be written up as a question with evidence attached, such as the flown record and the match key, and sent to the operator. The register should record the question, the date asked and the answer received. It should not record an assumed answer. A discrepancy that the operator cannot or does not explain remains "unresolved" in the register, with the date.

What a flight-time-only display cannot determine

A rolling flight-time display answers one narrow arithmetic question. It cannot determine:

• Assignment legality: it excludes the single-pilot 24-hour limit unless separately modelled, and the operator's approved procedures.
• Hours of work: CAR 700.29 has its own limits and accrual rules.
• Flight duty period, rest and fatigue: these are outside this arithmetic.
• Exemption terms: an operator's approved exemption may change which provisions apply, though the 365-day limit cannot be exempted.
• Fitness to fly: no flight-time total establishes it.
• Another jurisdiction's credit: Canadian operational flight-time accounting is not an EASA or Federal Aviation Administration (FAA) licensing-credit rule. FAA 14 CFR 61.51 and EASA FCL.050 govern logbook entries for their own purposes ^[15] (Source: eur-lex.europa.eu).

Tools and Methods: Paper, Spreadsheet, Established Logbooks and Pilot Logbook

The comparison landscape

Table 3 below compares what each reference or tool's own page states that is relevant to this problem, and what the page does not state. It reflects documentation read on 8 November 2026. It is a documentation comparison, not a test, and it makes no statement about accuracy or compliance. Vendor claims are attributed as such.

Table 3 shows a consistent pattern. Every reference states the limits or the method; none of the pages read states how a midnight-spanning flight is allocated, and the logbook documentation does not say how a rolling day window treats the current day. That is a statement about documentation, not a defect: the practical consequence is that the pilot should compute at least one total by hand and compare. A conversion or audit service such as AcuLog describes itself as specialized in "auditing, transcribing, and importing pilot flight records" ^[20]. A flight academy's study guide likewise lists MyFlightbook as a free online logbook that can track currency and generate reports (Source: skyeagle.aero). None of these pages establishes that a given product's Canadian totals match an operator's.

Pilot Logbook alongside the paper method

Pilot Logbook is the publisher's own product, so its position is stated plainly. The vendor's page (pilots.landing.aero, read 8 November 2026) describes it as an invitation-only electronic pilot logbook made by a line pilot, with access by invitation and no open sign-up (request an invite on the vendor's page). It advertises that it checks 28-, 90- and 365-day totals and the roster ahead against the Canadian limits, and that flights wait to be logged from an imported roster. An imported roster is a source of planned flights; it is not evidence that every flight a pilot flew is present, so the register logic above still applies. The vendor page does not describe the boundary rules, exemption handling or duplicate logic, and this report does not assert them.

A manual comparison with Pilot Logbook, or with any logbook display, follows the same six steps:

1. Export the logbook flights for the window as a spreadsheet and note the date and time of export.
2. Rebuild the three window totals from the export in a spreadsheet, using the exact first and last dates stated in the snapshot table.
3. Compare the displayed 28-, 90- and 365-day totals with the rebuilt figures at the same evaluation date.
4. Classify any difference by the candidate causes listed earlier, such as today's treatment, boundary allocation or a missing source.
5. Add flying that the app cannot know about, such as other-operator or military flights not yet entered, and remove proven duplicates.
6. Record unresolved items in the correction register and ask the operator only about the specific rows and evidence.

The paper method uses the same steps with a printed register and a calculator. Neither method makes the display a compliance determination, and neither replaces the operator's approved procedures.

Data Analysis and Evidence

The Canadian numbers, with their sources

The numeric core of the Canadian framework is compact. Each figure below is from the consolidated text as read on 8 November 2026.

• 28 consecutive days: 112 hours of flight time, CAR 700.27(1)(a) ^[1].
• 90 consecutive days: 300 hours, CAR 700.27(1)(b) ^[1].
• 365 consecutive days: 1,000 hours, CAR 700.27(1)(c) ^[1].
• Single-pilot operations: 8 hours in 24 consecutive hours, CAR 700.27(1)(d) ^[1].
• Hours of work (a separate rule): 192 hours in 28 days and 2,200 hours in 365 days, CAR 700.29 ^[21].

The window arithmetic is deterministic once the inputs are fixed. For the synthetic example the previous-27 subtotal plus the evaluation date's flying is 104.0 + 6.0 = 110.0 h before the correction and 106.0 + 6.0 = 112.0 h after it, so the headroom against the 112 h figure shrinks from 2.0 h to 0.0 h purely because of a 2.0 h correction. That is why a late correction has to be carried through every snapshot and not only the one where it was found.

A contrast with other jurisdictions

A short contrast shows why windows must not be transplanted. In the United States, 14 CFR 117.23 uses 100 hours in any 672 consecutive hours ^[22] and 1,000 hours in any 365 consecutive calendar day period ^[22], and it counts all flying on behalf of any certificate holder or 91K Program Manager ^[22]; the regulation defines a calendar day as a 24-hour period from 0000 through 2359 ^[23]. In the European Union, ORO.FTL.210 sets 100 hours in any 28 consecutive days (Source: eur-lex.europa.eu), 900 hours in any calendar year (Source: eur-lex.europa.eu) and a limit over any 12 consecutive calendar months (Source: eur-lex.europa.eu), and crew members who work for more than one operator must maintain their individual records of flight and duty times (Source: eur-lex.europa.eu). Different windows, calendar versus rolling bases and definitions of a day mean a Canadian register cannot be exported into another jurisdiction's accounting. Even the definition of flight time is worded differently: the EU describes the time between first moving from the parking place and coming to rest (Source: eur-lex.europa.eu), and 14 CFR 1.1 runs from movement under the aircraft's own power for the purpose of flight until it comes to rest after landing ^[24].

What the evidence does and does not show

The evidence assembled here is regulatory text, guidance and vendor documentation. It includes no pilot-survey data, operator audit statistics or accuracy benchmarks for any logbook product, and none is claimed. Search-demand figures for specialist phrases such as a pilot logbook rolling flight time calculator are not available from the sources used, and broader electronic-logbook interest is a US estimate that does not measure Canadian demand. How often operator and pilot totals differ is an open question that public sources cannot answer.

Implications and Future Directions

The practical implication is a habit: keep one dated register of every flying source, show the exact first and last included dates beside every total, and keep a correction log. For pilots changing employers the first 90 days at a new operator carry most of the risk, because the previous operator's flying still sits inside the 28-, 90- and 365-day windows while the new operator's system starts empty. The AC sections read do not address that gap, which is why the pilot's own inventory matters.

Private flying follows the same logic. A pilot who flies a light aircraft on a day off has produced a row for the register whether or not any operator ever sees it, and national submission practice for reporting it varies by operator and is not specified in the sources read.

Three things would improve the evidence base. Regulator clarification of the day boundary and of midnight-spanning flights would turn documented assumptions into facts. Logbook vendors could document whether rolling day ranges include the current day and how a UTC date split is handled. A published, versioned list of exemption instruments would simplify the scope check. Until then, a dated assumption log is the honest substitute.

Rules also change, and references label currency differently, for example ALPA's "Consolidated through SOR/2025-226" ^[3] alongside a page update stamp of 26 October 2026 ^[3]. A register should record the date it read the text and the stamp it saw, and be re-checked before reliance.

Frequently Asked Questions (FAQs)

What are the Canadian pilot flight time limits, and how do rolling 28-, 90- and 365-day totals work?

The limits are listed in the data section above. The rolling totals are the previous 27, 89 and 364 days, not counting today, plus the day's flying ^[2]. They apply inside Division III, which excludes Subpart 702 and medical evacuation flights.

How do I calculate pilot flight time totals across multiple employers, and track flight time for multiple operators?

Build a source register of every flown record, remove proven duplicates with a documented match key, and sum by window using exact dates. Flight time includes flying for another air operator and any private or military flying ^[2]. Keep each operator's flown records as separate rows in the same register.

Can private flying be combined with commercial flight time limits?

For the Canadian flight-time arithmetic, yes: private or military flying is included ^[2]. Private flying needs its own evidence, such as the aircraft registration and times.

How are augmented-crew flights counted?

The whole flight's flight time counts for every flight crew member ^[2]. Record the full flight duration, not only time at the controls.

What is the difference between flight time limits and duty time limits?

Flight time under CAR 700.27 is separate from hours of work under CAR 700.29, and ALPA's documentation treats them as distinct cumulative metrics ^[3]. A flight-time display does not check duty time.

Is there a pilot logbook rolling flight time calculator for Canada, and what electronic pilot logbook options exist?

Several electronic logbooks document Canadian limit groups or checks, including LogTen ^[16] and PilotBase (Source: intercom.help). Pilot Logbook advertises 28/90/365-day checks (per its vendor page at pilots.landing.aero) and is invitation-only, as described in the Pilot Logbook section above. None of the pages read documents day-boundary handling, so compare a displayed total with a hand-built one.

Conclusion

A personal rolling flight-time record is useful when it can be reproduced. That requires an inventory of every flying source, a documented duplicate key, exact first and last included dates beside each total, today's flying shown separately, and a correction register that restates every affected snapshot. CAR 700.27 supplies the limits and the inclusion principle, and AC 700-047 supplies the previous-27/89/364-day method. The documents read do not settle the day boundary or the treatment of a midnight-spanning flight, so those remain assumptions that belong in the register and, where they matter, in a question to the operator.

The register is a tool for clarifying discrepancies, never permission to accept a flight. Duty time, rest, fatigue, exemption terms and the operator's approved procedures all sit outside a flight-time-only display. Pilots who want to compare a logbook's displayed totals with their own register can do so by hand with paper, a spreadsheet or an electronic logbook.