EASA PICUS Logbook Requirements: ATPL Evidence Guide

Executive Summary

EASA PICUS logbook requirements concern the evidence behind the hours, as well as their recording. EASA is the European Union Aviation Safety Agency; PICUS means pilot-in-command under supervision. A first officer should be able to connect each claimed flight to the supervision basis, actual pilot-in-command (PIC) and certification. A roster's pilot-flying label does not establish that chain. Sweden's authority explains that the actual commander retains responsibility during PICUS, while Latvia expressly requires PICUS hours to be signed by the captain responsible for those flights. (Source: www.transportstyrelsen.se) (Source: www.caa.gov.lv) The Netherlands also asks applicants to make relevant signed PICUS experience identifiable. (Source: www.ilent.nl)

The recommended flight-to-certification worksheet preserves original labels, flight and source identifiers, supervising PIC, certification scope, original/copy status, export location, claimed minutes, supported minutes and unresolved reasons. These are suggested review fields, not a new regulatory schema. Ireland's FAQ says an employer letter is supplementary evidence and excludes uncertified claimed PICUS from licence experience. (Source: www.iaa.ie) A signed source whose remarks disappear from an export presents a different problem from a flight whose supervision basis remains undocumented. CrewLounge's documentation confirms that a printed PIC column can combine several functions, and ForeFlight's comma-separated values (CSV) export excludes signatures and endorsements. (Source: support.crewlounge.aero) ^[1]

For the Airline Transport Pilot Licence, aeroplanes, ATPL(A), 250 hours PIC, 500 hours PIC under supervision, and a 250-hour combined route including at least 70 PIC hours are alternatives presented separately in Norway's official application form. 70 PIC plus 180 PICUS is only one way to meet the combined route. (Source: www.luftfartstilsynet.no) In the report's hypothetical example, a claimed 200-hour PICUS bucket contains 160 supported hours, 25 missing certification and 15 with unresolved supervision. The result is 160 supported and 40 unresolved; no aircraft time is added. With an assumed 70 actual PIC hours, that leaves a 20-hour shortfall against the combined component, without resolving other ATPL requirements.

National submission procedures require a separate check. Switzerland distinguishes applicant-signed extracts and confirmation of hours; Malta describes applicant certification of computerised printouts. (Source: www.bazl.admin.ch) (Source: www.transport.gov.mt) Ireland's hub and FAQ conflict about originals, so current delivery and signature-format advice remains unresolved here. (Source: www.iaa.ie) The report also states its current-EASA-source access limitation. Paper and electronic records, including the publisher's Pilot Logbook, should face the same evidence test before submission.

Introduction and Background

A first officer preparing an Airline Transport Pilot Licence, aeroplanes, ATPL(A) application needs a record that connects a flight to the experience being claimed. Under EASA Part-FCL, FCL.050 requires reliable flight records in the form and manner established by the competent authority. That makes the evidence behind a subtotal part of the applicant's task. (Source: www.easa.europa.eu)

This report examines personal logbooks, supporting records and certification. Its practical question is whether a pilot can substantiate a particular flight as pilot-in-command under supervision, PICUS, when roster labels, logbook columns and signed evidence differ. Existing specialist coverage already discusses conversion problems, including omitted remarks and retention of signed originals. The contribution here is a repeatable flight-to-certification review, with separate supported and unresolved amounts. ^[2]

Several layers must remain separate. The regulation establishes the obligation; acceptable means of compliance, AMC, describe a non-binding compliance method; national authorities specify administrative evidence and submission arrangements. EASA describes AMC as non-binding standards for demonstrating compliance. A suggested spreadsheet field is an analytical aid, not another regulation. (Source: www.easa.europa.eu)

The evidence was researched for 1 November 2026. EASA identifies an October 2026 Aircrew revision, but its complete current compilation was not retrievable in this research session. The August 2023 provisions remain a historical baseline. The retrieved Part-FCL AMC and GM Amendment 13 (ED Decision 2025/002/R) expressly permits applicants for instructor or examiner certificates to log the flight time of a successful assessment of competence as PIC time. That specific amendment check does not establish the current PICUS rules. A targeted current-text check of FCL.010, FCL.050, AMC1 FCL.050 and FCL.510.A remains outstanding; national forms corroborate the experience alternatives but do not establish the current implementing-rule text. The report therefore identifies source dates and administrative uncertainties rather than claiming to have inspected the inaccessible compilation. (Source: www.easa.europa.eu)

The intended readers are first officers assembling their own experience evidence and captains certifying flights they supervised. No individual applicant, operator programme or flight record was assessed. An applicant should obtain an EASA-qualified instructor's or examiner's review of unresolved eligibility questions before filing.

Key Changes

Review the role before accepting the label

The proposed change is to review evidence at flight level before accepting an aggregate. Pilot-in-command, PIC, means the designated commander; EASA's PICUS definition concerns a co-pilot performing PIC duties under that commander's supervision. A pilot flying, PF, marker describes a flying task and cannot by itself demonstrate those conditions. (Source: www.easa.europa.eu)

This distinction is reflected in Sweden's authority guidance: the actual commander retains responsibility while the co-pilot acts as PICUS. For a Swedish applicant, the authority also describes verification that the AMC conditions were followed. These are separate questions from whose hands flew the departure or approach. (Source: www.transportstyrelsen.se)

A useful first pass is to ask:

• Roster label: What did the original system actually say: PF, PICUS, command training or something else?
• Claimed function: What role does the applicant now claim for this specific flight?
• Commander identity: Who was the actual PIC, and which source identifies that person?
• Eligibility basis: Which supervision arrangement applied on that date?
• Certification: Which endorsement covers the flight and claimed duration?

These are recommended questions. A PF-only row should remain unresolved for PICUS until the missing evidence is examined. Likewise, changing an imported tag does not establish that a qualifying supervision arrangement existed.

Match the supervision method to the actual flight

For EASA PICUS logging, AMC1 FCL.050 requires a supervision method acceptable to the competent authority and performance of all PIC duties without intervention being required for safety. The cited PICUS provision applies where more than one pilot is required by type certification or operational requirements, and requires the PIC's countersignature. (Source: www.easa.europa.eu)

The review should reference the arrangement applicable to the aircraft, operation and date. Switzerland's Federal Office of Civil Aviation (FOCA) flight-time guidance expressly describes documenting the supervision method in the operations manual. Latvia's initial ATPL procedure asks for an authority-approved operator PICUS registration form. These national examples explain why a roster label alone leaves a material question unanswered. (Source: www.bazl.admin.ch) (Source: www.caa.gov.lv)

For the applicant's worksheet, retain a reference to the relevant method or confirmation, its effective period, and the records connecting it to the flight. The worksheet need not reproduce an operator's manual. It should let a reviewer locate the basis rather than infer it from an app's terminology.

Connect certification to identifiable entries

The certifying person and the covered flight must match. Latvia explicitly asks for PICUS hours to be signed by the captain responsible for those flights. The Netherlands' Human Environment and Transport Inspectorate (ILT) gives relevant PICUS hours signed by the commander, with licence number, as an example of evidence applicants should make identifiable. These are Latvia-specific and Netherlands-specific administrative statements. (Source: www.caa.gov.lv) (Source: www.ilent.nl)

If a signature covers a range, record its exact scope and the entries included. Where the scope is ambiguous, seek clarification from the actual certifier or receiving authority. Do not invent a signature, attribute certification to another commander, or treat a general employment statement as flight-level evidence.

Ireland's FAQ makes the distinction concrete: an employer or training-organisation letter can supplement a submission but is not acceptable as its primary experience evidence. That Irish statement should not be generalized into a prohibition on every other state's requested employer confirmation. (Source: www.iaa.ie)

Implementation Considerations and Process Changes

Establish a review copy and source trail

The proposed workflow begins with a preserved copy of the logbook and a source index. Give each candidate flight a stable record identifier (ID) and retain the original roster wording. The purpose is to distinguish a correction to an existing flight from creation of a second flight.

This is a practical import concern. MyFlightbook documents a Flight ID for updating existing flights and says imports without that field are treated as new flights. ForeFlight separately warns that importing a CSV containing flights already present creates duplicates. These documented behaviours justify testing a correction workflow before applying it to an entire personal record. ^{[3] [1]}

The initial source index should capture:

• Flight identity: Date, departure and arrival, registration, and the record ID used in the logbook.
• Source identity: Roster version, page, attachment or other reference from which the entry came.
• Original wording: The imported label before any correction or normalization.
• Claimed minutes: The amount the applicant currently includes in PICUS.
• Supporting material: The supervision reference and the entry's certification reference.
• Record status: Signed original, scan of an original, exported copy, or unsigned working entry.

These are suggested review fields. They are not a newly mandated EASA data schema. The Netherlands' practical requirement that submitted records be complete and readable supports maintaining a usable trail, but does not prescribe this worksheet. (Source: www.ilent.nl)

Keep role evidence and totals separate

A useful worksheet stores the applicant's original claim separately from the review result. Overwriting the claimed number destroys the explanation for a difference. Instead, preserve the original amount, enter the currently supported amount, and describe the unresolved balance.

A captain reviewing a row should be able to see the flight identity, the claimed function, the relevant source and the proposed certification scope. The captain should certify only what they can substantiate. If records show a different commander, stop that row's certification review until the identity is reconciled. Latvia's explicit link between PICUS flights and the responsible captain provides a concrete national example. (Source: www.caa.gov.lv)

Recommended review outcomes are:

• Supported: Conditions, identity, duration and certification match the relevant claim.
• Unresolved certification: The applicant has not located certification covering the entry.
• Unresolved supervision: The basis for claiming supervised command experience remains unclear.
• Unresolved identity: The commander or scope of certification does not match the entry.
• Duplicate candidate: Another row may represent the same underlying flight.
• Reviewed correction: The reason, source and date of a justified correction are retained.

An unresolved PICUS claim should not be automatically recategorized as some other valid role. That would answer a different eligibility question without examining its evidence. Ireland's FAQ specifically excludes uncertified claimed PICUS from experience used for licence issue; it does not authorize a spreadsheet to invent a replacement function. (Source: www.iaa.ie)

Flight-to-Certification Review Sheet

The review sheet should be usable by a pilot, a certifying captain and the person checking the application. Each needs to locate the same flight without depending on the display order of an app. PilotAudit's existing recommendation to compare electronic entries with original paper and operator records provides useful context for this cross-reference approach. ^[2]

In addition to the fields above, the recommended worksheet records:

• Supervision basis: Evidence that PIC duties and the applicable supervision conditions were met.
• Supervising PIC: Name or identifier, linked to the flight's original commander record.
• Certification scope: The specific row, flight, page or clearly defined range covered.
• Certification location: Original logbook page, attached certification or other retrievable reference.
• Export location: The page and row where the flight appears in the proposed submission.
• Supported minutes: The reviewed portion of the claimed PICUS amount.
• Unresolved reason: The exact missing or contradictory evidence, with an action owner if useful.

Table 1 applies those fields to synthetic evidence fixtures, all hypothetical examples. The rows illustrate review decisions, not actual pilot records or findings about any operator. Populate date, leg, record ID, original/copy status and export location for every real flight before using the sheet. The national certification examples informing the review are the Dutch identification guidance and Latvian captain-certification requirement. (Source: www.ilent.nl) (Source: www.caa.gov.lv)

The fixtures separate substantive support from presentation readiness. In H-D, an export defect does not erase a retained signed original; it leaves the proposed submission incomplete. In H-C or H-F, a visible signature does not settle which flights or commander it relates to. That difference should remain visible in the review notes.

For each real row, retain both claimed and supported minutes. If a row is partly supported, document exactly how the supported portion was established. Do not estimate a missing certified duration from a page total. The worksheet is a route into evidence review, not a substitute for the authority's decision. Sweden's verification requirement illustrates the importance of establishing compliance beyond the existence of a numerical total. (Source: www.transportstyrelsen.se)

Certification, Corrections and Export Review

Preserve PICUS identity in a PIC-column printout

EASA's logbook instructions enter PIC, student pilot-in-command (SPIC) and PICUS in the PIC function column, with the PICUS/SPIC certification retained in remarks. Consequently, a PIC-column sum can contain experience with different provenance. (Source: www.easa.europa.eu)

The software documentation makes this distinction practical. CrewLounge PILOTLOG has a dedicated PICUS field, while its print documentation says the PIC column can combine PIC, PICUS, SPIC and solo unless the layout separates them. A pilot should inspect the selected layout rather than assume the printed heading reproduces an ATPL category. (Source: support.crewlounge.aero)

The export review should therefore test:

• Identity: Does the export preserve the underlying flight and record reference?
• Function: Can a reviewer distinguish actual PIC from PICUS behind the displayed total?
• Certification: Are the relevant remarks or linked certified pages available?
• Scope: Is it clear which exported entries the endorsement covers?
• Continuity: Do carried totals reconcile to the retained source record?
• Corrections: Can the applicant explain changed or removed rows without losing the source trail?

Compare the proposed portable document format (PDF) file against the source record and any spreadsheet export. FLYLOG documents Excel/CSV downloads and filtered exports. These are different outputs to test, not interchangeable evidence merely because they originate from the same account. ^[4]

Distinguish signatures by purpose

A page signed by the applicant confirms something different from a flight countersigned by its supervising PIC. FLYLOG's documented page-signature option adds the user's own signature. That feature description alone does not demonstrate certification by a supervising captain. ^[4]

National guidance also separates these acts. Switzerland's FOCA describes applicant signatures page by page and confirmation of hours by an approved entity for ordinary electronic-logbook extracts. Malta's FAQ asks the applicant to certify each page of a complete computerized printout as a true record. Neither statement should be substituted for the separate PICUS certification question. (Source: www.bazl.admin.ch) (Source: www.transport.gov.mt)

Table 2 compares documented personal-record methods and the specific test an applicant should perform. Features are vendor descriptions, not evidence that any particular flight or signature is accepted by an EASA competent authority.

The table identifies inspection points rather than a product ranking. A dedicated PICUS field can assist classification; it cannot establish that the supervision conditions occurred. A signature-capable PDF can preserve evidence; it does not by itself establish the competent authority's acceptance of a particular implementation. The Dutch guidance's emphasis on identifiable relevant signed hours is a useful final-output test. (Source: www.ilent.nl)

For corrections, document what changed and why, then recheck certification coverage. Logbook.aero says a signature already added cannot be edited or deleted, illustrating why pilots should understand the product's signed-record workflow before attempting a correction. A correction should never silently imply that the captain certified a different flight or amended duration. (Source: www.logbook.aero)

Data Analysis and Evidence

Select the experience route before testing a shortfall

For EASA ATPL(A), FCL.510.A provides alternative PIC/PIC-under-supervision routes. Norway's official ATPL form presents the alternatives separately, corroborating the accessible EASA provision. 70 hours actual PIC plus 180 hours PICUS is one way to meet the combined route, not a requirement that every applicant must follow. (Source: www.easa.europa.eu) (Source: www.luftfartstilsynet.no)

Table 3 sets out the alternatives in the accessible EASA text and Norwegian form. This is a comparison of the PIC/PICUS component, not the full ATPL eligibility checklist. (Source: www.easa.europa.eu)

The combined alternative does not make 180 hours a universal PICUS minimum. For example, 100 actual PIC plus 150 supported PICUS, a hypothetical calculation, reaches the same combined total. The selected route determines which amounts need to be substantiated; an app's heading does not choose that route for the applicant. Norway's application form explicitly distinguishes PIC and PICUS alternatives. (Source: www.luftfartstilsynet.no)

Other EASA experience requirements remain: the accessible FCL.510.A text specifies 1,500 hours in aeroplanes, including 500 in multi-pilot operations; 200 cross-country hours, including 100 as PIC or PIC under supervision; 75 instrument hours, with no more than 30 instrument-ground hours; and 100 night hours as PIC or co-pilot. The specified experience precedes the skill test. (Source: www.easa.europa.eu)

Finland's Traficom likewise tells applicants to have sufficient experience before the ATPL skill test. A successful PICUS reconciliation therefore resolves only part of the experience review. (Source: traficom.fi)

Reconcile claimed, supported and unresolved hours

Hypothetical Example: a claimed 200-hour PICUS bucket. Assume the review finds 160 hours with matching underlying conditions and certification, 25 hours missing certification, and 15 hours whose supervision basis remains unresolved. These are constructed inputs, not measured applicant data.

The reconciliation is:

• Claimed PICUS: 200 hours, or 12,000 minutes.
• Supported PICUS: 160 hours, or 9,600 minutes.
• Unresolved certification: 25 hours, or 1,500 minutes.
• Unresolved supervision: 15 hours, or 900 minutes.
• Unresolved total: 40 hours, or 2,400 minutes.
• Balance check: 200 = 160 + 25 + 15 hours.

No aircraft time is added by this calculation. It reconciles the support behind a claimed function subtotal. Missing certification remains unresolved; Ireland's FAQ provides a national example of why such claims cannot simply be included as certified licence experience. (Source: www.iaa.ie)

Now assume, separately, 70 hours of substantiated actual PIC and selection of the combined route. The supported amount becomes 230 hours: 70 + 160. The shortfall against that component is 20 hours, while 40 claimed PICUS hours remain unresolved. Those figures answer different questions and should appear separately. Resolving sufficient evidence could change the supported subtotal, but the example establishes no entitlement and says nothing about the remaining ATPL requirements.

There is no measured error rate, product accuracy benchmark or applicant sample behind these fixtures. Their value is reproducibility: another reviewer can inspect the same rows and understand why a claimed amount is supported, held or corrected.

Implications and Future Directions

Establish the receiving authority's current procedure

The final package must suit the applicant's competent authority. Norway accepts relevant electronic-logbook sections printed, signed and dated, supplied as PDF or paper. Malta describes original-logbook inspection or a complete computerized printout with applicant certification on each page. These are distinct national administrative descriptions. (Source: www.luftfartstilsynet.no) (Source: www.transport.gov.mt)

Sweden asks for verification of AMC compliance, described as written management verification. Austria's ATPL application lists completed PICUS programme records or employer PICUS confirmation where necessary. Latvia asks for its specified operator registration evidence and captain-signed PICUS hours. A pilot should identify the receiving authority before deciding which supplementary records to request. (Source: www.transportstyrelsen.se) (Source: www.austrocontrol.at) (Source: www.caa.gov.lv)

Treat Ireland's public-page conflict as an open question

Ireland is an administrative example. The Irish Aviation Authority (IAA) licensing hub says originals are no longer routinely required and reserves the right to request them. Its logbook FAQ still says originals must be sent for licence issue or upgrade. These public instructions conflict; the report cannot resolve the applicant's current delivery route from them alone. (Source: www.iaa.ie)

The publicly indexed PLAM 024, Revision 01, dated 24 August 2023, was retrieved. It addresses electronic logbooks and signed endorsements/countersignatures, but no current individualized IAA confirmation was obtained. Accordingly, this report gives no definitive Ireland-specific signature-format or delivery advice. Acceptance of a scanned signed original must not be inferred to mean acceptance of a newly created electronic countersignature. (Source: www.iaa.ie)

The applicant's final questions should be concrete:

• Submission route: Which current instructions apply to this application and authority?
• Page scope: Which complete records, extracts and carried totals are required?
• Certification format: How must supervising-PIC certification be provided?
• Copy status: Are originals, certified copies or scanned signed pages required or retained?
• Electronic signatures: Is the particular signature method acceptable for this purpose?
• Unresolved entries: What further evidence would allow a specific row to be assessed?

For Ireland, use those questions to reconcile the conflicting public instructions before submitting. Elsewhere, obtain that authority's instructions directly. The same evidence worksheet can travel between formats, but national acceptance is a separate determination.

Frequently Asked Questions (FAQs)

Does PF on a roster prove EASA PICUS?

No. A PF marker does not establish performance of all PIC functions under an acceptable supervision method or supply certification. Retain it as source evidence and investigate the missing conditions. Sweden's explanation that the actual commander retains responsibility is relevant context. (Source: www.transportstyrelsen.se)

Must every claimed PICUS flight have identifiable certification?

The review must connect claimed flights to certification. Latvia expressly requires PICUS hours to be signed by the responsible captain. A signature with unclear flight coverage should remain unresolved rather than being assumed to cover an arbitrary page range. (Source: www.caa.gov.lv)

Does an electronic field or signature feature make the hours eligible?

No. CrewLounge documents a dedicated field and capzlog documents signature indicators. Those describe recording capabilities. The pilot still needs evidence of the underlying conditions and certification, and the receiving authority decides its accepted submission method. (Source: support.crewlounge.aero) (Source: capzlog.aero)

What if the source is signed but the export loses the evidence?

Preserve the signed source and repair the submission's cross-reference or output. ForeFlight's CSV documentation explicitly excludes signatures and endorsements, illustrating why a data file and a certification package may differ. ^[1]

Conclusion

A defensible PICUS subtotal begins with identifiable flights and evidence that supports the claimed role. The review should connect each flight to its supervision basis, actual PIC, certification and exported representation. A roster label or aggregate heading is useful for locating candidates, but the supporting records determine what the applicant can substantiate.

The practical output is a worksheet with three distinct amounts: claimed, supported and unresolved. Retain the original label, preserve the signed source, document corrections, and count each underlying flight once. Where the source is sound but the export loses remarks, repair the presentation. Where identity, supervision or certification remains uncertain, hold the affected amount for review.

The ATPL comparison must then use the selected experience alternative. The separate PIC and PICUS categories in Norway's official form illustrate why an aggregate PIC heading is insufficient for this calculation. A reconciled subtotal establishes neither all ATPL experience nor administrative acceptance. (Source: www.luftfartstilsynet.no)

Finally, confirm the receiving authority's procedure. Ireland's conflicting public instructions remain a specific limitation; the retrieved memorandum does not establish acceptance of every electronic-signature implementation. Apply the same evidence test to paper and electronic records, including Pilot Logbook, and seek qualified review of unresolved eligibility questions before the application is finalized.