IMC, IR(R) and Instrument Ratings for UK private pilots

The rules and regulations concerning the UK private pilot for flying in clouds have several options, and this note is aimed at any UK private pilot with or seeking an IMC, IR(R) or IR rating. This is published only as a guide and with no warranty or guarantee of accuracy or completeness. You are strongly recommended to double check what is written below.

UK IMC Rating continues indefinitely

The IMC rating applies only in UK airspace (including Isle of Man and Channel Islands), permitting the holder to fly in cloud, make instrument approaches and with reduced visibility for Special VFR transits. It does not permit flight in Airways or IFR in Class A airspace.

The rating is issued for UK PPL licences only, and is now only valid on any non-Part 21* IFR equipped UK registered aircraft. A few of these so-called Permit or Annex II aircraft, which are overseen by the LAA, have been approved for Night and/or IFR flight.

The IMC rating is likely to continue to be available and renewable for some years, although the scope of aircraft it can be used with is now severely limited.

*Part 21 is the new term for EASA aircraft, such as Cessna 172, Piper PA28. Non-Part 21 covers Permit aircraft including home-built and a few other exceptions.

Instrument Rating (Restricted)

An exactly equivalent rating was created for use with EASA licences called “Instrument Rating (Restricted)”, which grants the same privileges in UK airspace as previously enjoyed by IMC rated pilots. All the existing procedures, arrangements and privileges continue as before such as 25 months validity, same revalidation requirements, same course content.

After leaving EASA, the IR(R) continues exactly as before and is issued/valid only with UK issued FCL licences. Instruction and skill tests can only be conducted by UK licence holders.

An EASA IR(R) is valid on both Part 21 and non-Part 21 aircraft.

Around 10% of UK PPLs are thought to have this rating today.

Summary

The key points of this change are that:

1. The Instrument Rating (Restricted) can be added to an UK FCL licence, and can be used on both Part 21 and non-Part 21 aircraft indefinitely.
2. The IMC Rating will continue indefinitely on UK only PPL licences, but became restricted to non-Part 21 aircraft from April 2014.
3. New IR(R) ratings will continue to be issued until at least 8 April 2021, and is expected to be extended indefinitely.

Instrument Rating – The traditional route

UK PPLs may also train for a full Instrument Rating, which gives worldwide privileges to fly in Airways, IFR routes and make instrument approaches to minima. This training option is still available but mostly used in commercial flight training schools. It involves an extensive period of ground school training based on a subset of the commercial ATPL training. There are 7 exams to pass, normally done in two or three tranches. I believe there is only one UK commercial provider of the full IR theory course – CATS at Luton.

The exams must be taken over a period not exceeding 18 months. You must pass all the exams within 6 sittings and not more than 4 attempts for any individual subject. Thereafter, the practical course requires a minimum of 50 hours dual instruction at an ATO (which can include up to 35 hours on an approved flight simulator) followed by a practical skill test. ATO (Approved Training Organisation) commercial training is typically more expensive than at smaller private training organisations, and it can also be more difficult to schedule time at weekends. Training time already spent on an IMC rating or elsewhere does not count.

This compared poorly with the US, where some 30% of private pilots hold full Instrument Ratings. It’s much cheaper and easier to obtain the qualification, which has a single written exam and 40 hours dual flight time which can be given by any qualified/freelance instructor. This has driven many UK based pilots to gain the US licence and instrument rating, flying US registered aircraft around Europe.

Competency Based Instrument Rating (CB-IR)

In October 2013, the European Commission formally agreed new measures and proposed the required legal changes to introduce a new Competency Based training route towards the same Instrument Rating qualification, which were passed by the European Parliament to come in to force in April 2014.

The legislation performs two tasks:

a) Created a new EASA-only qualification, the Enroute Instrument Rating (EIR). This allows pilots to fly in cloud and in the airways during day or night including filing IFR flight plans. Taking off or landing in poor visibility/cloud is not permitted. It is positioned as a stepping stone towards a full Instrument Rating, usable in all EU countries and open to all PPL pilots.

b) Reduced the minimum mandatory training for the Instrument Rating (IR). Those who want an IR will still have to pass the same stringent practical skills test, but the range of content for the theory exams has been reduced by about half. Only 10 hours of practical training need be done at an ATO, the remainder can be done by any suitably qualified Instrument Rated Instructor [IRI]) and also takes account of IFR experience already gained. Many IMC rated pilots are likely to have well over 30 hours instrument flight time logged.

This should make a full IR much more accessible for European pilots, many of whom had instead travelled to the US and trained for a US FAA IR.

For those with an IMC already, some argue that the EIR may make less sense. The 10 hours ATO practical training applies for both the EIR or the IR and the theory knowledge exams are the same for both. The IR is a much more useful rating, so the incremental cost (perhaps a few extra hours at the ATO), would seem to be worthwhile. Others take a view that the combination of IMC+EIR would facilitate Southern European touring, knowing that you could get back to a UK home base in poorer weather conditions.

For those without an IMC/IR(R), including those not based in the UK, then the EIR may be a good stepping stone. If not, then the IMC/IR(R) rating offers a good combination of coping in real IMC and getting back down with an instrument approach – potentially a lifesaver.

Basic Instrument Rating

EASA has been developing a new sub-ICAO rating (so valid only within Europe) called the Basic IR. It is intended to supercede the UK IMC Rating, being available and valid throughout Europe, with the additional privilege to fly in Class A controlled airspace (airways). It is likely to be available from 2021.

There is no minimum number of hours of training – it is all competency based. Training must be given at an ATO, not a DTO. Three modules (Basic Instrument Flying, Instrument Approaches, En-Route) each with their own associated theory exam and a single skill test. Annual revalidation by an examiner.

Existing EASA IR holders

There is little change or impact for existing EASA IR holders. They will still require to revalidate annually as before. However, if they fail to do so, they can simply take a renewal  skill test with an examiner and no longer have to be vetted and signed off by an ATO first.

Implementation

Appropriate training courses and exams have been approved in several EASA countries, and students have qualified for both EIR and IR ratings.

In the UK, an e-Exam system has been introduced for all commercial theory exams (ATPL, CPL and IR) which includes the new CB-IR theory modules. There are several venues and each hold test sessions every month, increasing accessibility. The price and time taken to issues results remains the same.

Several question bank providers including aviationexam.com offer practice questions.

Flight training must be overseen by an ATO (Approved Training Organisation), which includes most of the larger schools who train commercial pilots. A number of smaller flying clubs and schools have transitioned across to full ATO status. This was originally driven by an EASA mandate that all schools would have to do so, a requirement that has now been changed instead to become Declared Training Organisations (DTOs). However, those that have made the transition are in a position to offer the EIR and CB-IR courses if they choose to.

ATOs wanting to provide training for the CB-IR will need to have their course approved by the CAA first. The first approved flight training course became available in June 2014, at Rate One Aviation in Gloucester UK. Other ATOs, including in other countries, have announced their own course approvals and the range continues to expand.

Constraints

Those wishing to attain a full commercial ATPL will still need to pass the full set of 14 ground school ATPL exams. As of today, there is no credit for the subset PPL/IR theory. It is not intended for those seeking a longer term commercial career to take the competency based IR, which is targeted at the private pilot.

An IR qualification is of little use on its own. You will also need access to an IFR capable aircraft. Other factors which should increase the demand for an IR would be:

• low cost approvals for GPS approaches into airports
• more widespread IFR training aircraft approved for GPS approaches available at flying clubs
• avoiding the need for full ATC (rather than AFIS or A/G) control onsite for all instrument approaches

The above points are all commonplace in the US, increasing the utility of General Aviation considerably through lower costs, more frequent use/currency and accessibility.

References

EASA FCL.008 Notice of Proposed Amendment NPA 2011-16 (Sep 2011) and Comment Response Document (issued Oct 2012)

AOPA magazine article on the IMC/IR proposals (October 2011).

I’ve separately covered the basic (non-IMC) JAR-PPL changes in this article

*Last updated 18 Aug 2019