EASA’s 2028 FSTD Rules Create New Course-Design Options for ATOs

Europe – The European Union Aviation Safety Agency (EASA) has completed the regulatory package supporting a new capability-based framework for the qualification and use of Flight Simulation Training Devices, giving Approved Training Organisations and operators an optional task-to-tool methodology from April 30, 2028. The framework could change simulator demand by allowing suitable type-rating tasks to move from full-flight simulators to other qualified FSTDs where their documented capabilities meet the training requirement, while requiring ATOs to substantiate device selection through course-design and capability evidence.

• Commission Implementing Regulation (EU) 2026/781 was published on April 10, 2026 and becomes applicable on April 30, 2028. EASA followed on July 15 with ED Decisions 2026/006/R, 2026/007/R and 2026/008/R, covering amendments to Aircrew and Air Operations AMC/GM and the introduction of CS-FSTD Issue 1.
• At the centre of the framework is the FSTD Capability Signature, which describes an individual device according to defined simulation features and fidelity levels rather than relying only on an overall qualification category such as FFS Level C or D. EASA states that the approach allows authorities, ATOs and operators to determine training use according to what an FSTD is technically capable of providing.
• Under the optional task-to-tool methodology, an ATO starts with the training task, determines the required fidelity and then selects an FSTD whose FCS or assigned FCS meets the corresponding requirement. Part-FCL Amendment 15 distinguishes between Training and Training to Proficiency requirements, while AMC5 ORA.ATO.125 establishes the course-design process for applying the methodology to aeroplane and helicopter type ratings.
• One of the principal commercial implications concerns multi-pilot aeroplane type ratings. The existing conventional AMC provides for a minimum of 32 hours of FSTD training, normally including at least 16 hours in an FFS operating as a crew. EASA's 2026 explanatory material states that courses designed using the new FCS framework can include less than 16 hours in an FSTD with capability equivalent to an FFS when designed under AMC5 ORA.ATO.125 and the associated instructional systems design process.
• The flexibility is capability-driven rather than a general reduction in simulator training. ATOs using the new methodology must map training tasks to the applicable FCS requirements and ensure each task is completed on an FSTD whose capability is at least equal to the relevant Training to Proficiency requirement.
• EASA's revised framework also creates a formal Equipment Specification List as part of FSTD qualification. Regulation (EU) 2026/781 defines the ESL as the record containing information on the device's qualification basis, installed equipment, capabilities and specifications, increasing the importance of configuration information where an ATO uses simulators supplied by an external operator.
• Other Training Devices can continue to support elements of type-rating instruction where permitted, but the new approach distinguishes those devices from qualified FSTDs. ATOs redesigning a course will therefore need to separate supplementary OTD activity from minimum FSTD requirements rather than treating procedure-training hours as interchangeable with qualified simulator time.
• The framework also accommodates new simulator architectures and technologies. EASA states that the revised standards support devices that do not fit existing simulator categories and technologies including touchscreen and extended-reality solutions, subject to the capability and training requirements applicable to the individual task.
• Helicopter ATOs can also use task-to-tool, although the revised AMC retains safeguards around aircraft training when the FSTD used does not provide the capability equivalent to the specified FFS standard. EASA's explanatory material confirms that the framework applies to both aeroplane and helicopter type-rating training.
• Operators receive a parallel capability-based route for recurrent training through Part-ORO Issue 2, Amendment 30. EASA states that the amended AMC/GM supports the use of FSTDs with FCS or assigned FCS in operator recurrent training, requiring operators to determine which recurrent items fall within the new capability-based pathway before changing simulator allocation.
• ATO and operator nominated persons preparing for 2028 will therefore need to identify which courses will use the conventional methodology and which will be redesigned under task-to-tool, obtain FCS and equipment information for relevant simulators, map training tasks against required fidelity, and align training manuals, course approvals and simulator-provider change-control arrangements with the devices actually being used.
• EASA's current Easy Access Rules for Aircrew remain the November 2025 revision, published on November 26, 2025, and do not yet consolidate Regulation (EU) 2026/781 or the July 2026 ED Decisions. Organisations preparing for the transition therefore need to refer directly to the 2026 regulatory package until a later consolidated edition incorporates the amendments.
• EASA has launched Implementation Support Task IST.0007 ahead of applicability. Planned support includes a general information session on December 15, 2026, an implementation manual targeted for the first quarter of 2027, domain-specific workshops during 2027 and supporting frequently asked questions.
• AFM previously reported on July 21, 2026 that EASA had introduced CS-FSTD Issue 1 and the associated capability-based framework, including 14 simulator features and the optional task-to-tool methodology. AFM also reported on July 14 that CAA International had launched an FCS readiness course ahead of the 2028 regulatory transition.

Source: EASA