Landing Aero Article
EASA Cruise Relief Logbook Time: Seat Intervals and CRCP
EASA cruise relief logbook time explained: AMC1 FCL.050 seat intervals, the CRCP remark, the 250-hour restricted-rating credit in FCL.510.A(c)(3), and a flight-to-application ledger for 2026.

Summary
- 01Cruise relief co-pilot logging follows the time actually spent in a pilot seat. Keep the aircraft's block duration separate and retain CRCP in the Remarks column.
- 02The 250-hour credit ceiling applies to time flown while exercising restricted type-rating privileges. Record the rating held on each flight date separately from the cruise relief function.
- 03Preserve supported seat intervals and raw logged durations, then calculate application credit separately. Hours above the cap remain in the record.
- 04A roster or operational flight plan alone does not establish seat occupation or rating status. Mark undocumented intervals unresolved and ask the competent authority which evidence it accepts.
- 05National application forms differ. Estonia prints a cruise relief credit line; Ireland and Greece do not. Confirm the receiving authority's form, evidence checklist and signature requirements.
Inside this article
- 01Executive Summary
- 02Introduction and Background
- 03Key Changes in the EASA Framework
- 04Implementation Considerations and Process Changes
- 05Reconciling the Logbook to a National Application Form
- 06Data Analysis and Evidence
- 07Implications and Future Directions
- 08Frequently Asked Questions (FAQs)
- 09Conclusion
Executive Summary
EASA keeps two questions apart that pilots often merge: what a relief pilot may write in a logbook, and what an ATPL(A) applicant may count as credit. The logging rule in AMC1 FCL.050(b)(3) lets a cruise relief co-pilot log flight time as co-pilot "when occupying a pilot's seat" (Source: www.easa.europa.eu) (Source: www.iaa.ie) [1], and the sample logbook instructions require the remark CRCP when the pilot acted as cruise-relief co-pilot (Source: www.easa.europa.eu). That is a record-keeping rule tied to a seat interval (this article's ledger term for the period actually spent in a pilot seat, not a term defined by the AMC), not to the whole block duration of an augmented flight. Flight time itself is defined for the aircraft, from first movement to final rest.
The credit rule is narrower and sits in a different provision. FCL.510.A(c)(3) credits holders of a restricted type rating issued under FCL.720.A(c) for flight time completed while exercising the privileges of that rating, up to a maximum of 250 hours (Source: www.easa.europa.eu). The restricted rating allows cruise relief duty above Flight Level 200 only when two other crew members hold a full type rating. It is not a universal cap on every relief pilot. Whether a given logged hour falls under the cap depends on the rating held on the date of the flight, so the rating era (this article's ledger term for the rating held on the flight date) must be recorded next to the seat interval.
The amendment behind the cap is Commission Implementing Regulation (EU) 2024/2076 of 24 July 2024. EASA's Opinion 05/2023 records that the credit limit was set at 250 hours and not reduced further, for consistency with the flight engineer credit. The October 2026 Easy Access Rules edition, dated 16 October 2026, carries the current text, with a caveat to check later adoptions.
A worksheet that preserves raw durations and computes credit separately solves the mismatch. In a hypothetical example, 320 hours of supported restricted-privilege time against a 250-hour cap yields 250 hours potentially claimable through that route and 70 hours preserved in the record. That is arithmetic, not an eligibility verdict: the other FCL.510.A subrequirements, including 500 hours of multi-pilot operations, are assessed separately, and national forms differ. Estonia's ATPL(A) form, approved 19 September 2025, prints a cruise relief credit line (Source: transpordiamet.ee). Ireland and Greece print no such line, but require signed logbook pages (Source: www.iaa.ie) (Source: hcaa.gov.gr). Gaps in interval evidence, a changed restriction or ambiguous historic entries belong with the competent authority.
Introduction and Background
Long-haul first officers and cruise relief co-pilots accumulate hours in a way that a simple "block time equals logged time" model does not capture. On an augmented flight several pilots share the flight deck seats over a long duration, and each pilot occupies a pilot seat for only part of it. This report examines how EASA's Part-FCL treats that situation for two purposes: the personal logbook and the ATPL(A) experience application. It covers records and application evidence only. Crew rest planning, crew assignment and training syllabi are out of scope.
The jurisdiction is the European Union Aviation Safety Agency (EASA) system under Regulation (EU) No 1178/2011, Annex I (Part-FCL), as published in EASA's Easy Access Rules for Aircrew. As of November 2026, the current edition is the revision dated 16 October 2026, and EASA's own page advises readers to check whether any rule was adopted after that date (Source: www.easa.europa.eu). A pilot licensed by a national authority in an EASA state applies the same Part-FCL text, but the application form, evidence checklist and assessment practice are national. Rules in the United States, Canada and the United Kingdom differ and are referenced here only for contrast, each time with the jurisdiction named.
Three definitions anchor the analysis. FCL.010 defines a cruise relief co-pilot as a pilot who relieves the co-pilot of duties at the controls during the cruise phase of a flight in multi-pilot operations above FL 200 (Source: eur-lex.europa.eu). A co-pilot is a pilot operating other than as pilot-in-command on an aircraft for which more than one pilot is required (Source: eur-lex.europa.eu). A restricted type rating is a separate licence privilege created by FCL.720.A(c), described in the first body section below. The definition of the function and the existence of a rating restriction are different facts, and the ledger proposed in this report records both.
The report draws on the October 2026 Easy Access Rules text, the amending regulation and its rulemaking opinion, four national authority documents, and the public documentation of several logbook tools and independent explainers. Independent publishers already explain the definition and the CRCP remark; Aviator Archive restates that a cruise relief co-pilot relieves the co-pilot at the controls during the cruise [2]. The CRCP remark goes in the Remarks column [2], and cruise relief is not pilot-in-command time [3]. The gap this report fills is the bridge from seat interval to rating era to application credit. It issues no eligibility verdict, and every pilot's rating history is individual.
Key Changes in the EASA Framework
Logging follows the pilot seat, not the sector
AMC1 FCL.050 is acceptable means of compliance material that supports FCL.050, which requires the pilot to keep a reliable record of all flights in a form and manner established by the competent authority (Source: eur-lex.europa.eu). Within it, the general co-pilot rule in (b)(2) allows a licence holder occupying a pilot seat as co-pilot to log all flight time as co-pilot flight time on an aircraft that needs more than one pilot (Source: www.easa.europa.eu). The cruise relief rule in (b)(3) is worded slightly differently: a cruise relief co-pilot may log all flight time as co-pilot when occupying a pilot's seat (Source: www.easa.europa.eu).
The practical consequence is that the logbook entry for a relief pilot depends on an interval during which the pilot occupied a seat. An independent explainer reaches the same reading, stating that under Part-FCL only the hours in a pilot's seat go in the co-pilot column [2]. That is the publisher's interpretation of the rule, and the AMC text reviewed for this report does not prescribe how the interval is measured or evidenced. The Irish Aviation Authority's advisory memorandum PLAM.024 (Revision 01, 24 August 2023) repeats the same cruise relief wording in its own guidance on acceptable logbook formatting (Source: www.iaa.ie).
The distinction matters because the FCL.010 definition of flight time, for aeroplanes, runs from the moment the aircraft first moves for the purpose of taking off until it finally comes to rest (Source: eur-lex.europa.eu), and the logbook instructions use the same boundary. That is a time measured for the flight. The relief pilot's personal co-pilot entry is bounded by the seat occupation. Equating the two overstates the entry whenever the pilot spent part of the sector in a rest position. A generic percentage reduction is no substitute either, since the rule keys on occupation, not on a fraction.
The CRCP remark and the pilot-function record
AMC1 FCL.050(a)(4) lists the pilot function the record must contain, and cruise-relief co-pilot appears in that list separately from PIC, PICUS, co-pilot, dual, FI and FE (Source: www.easa.europa.eu). The sample logbook's instructions for column 12, headed Remarks and Endorsements, say the column is at the holder's discretion but that certain entries should always be made. One of them is the remark 'CRCP' when the pilot acted as cruise-relief co-pilot (Source: www.easa.europa.eu).
EASA's decision that introduced these changes states the purpose in its rationale: to ensure that cruise-relief co-pilot flight time is recorded appropriately (Source: www.easa.europa.eu). Aviator Archive's September 2026 guide lists the CRCP remark among entries it describes as not optional [2] and notes that the AMC speaks of a cruise relief co-pilot and says nothing about a relief captain [2]. That reading is the author's, and relief captain time is outside the CRCP remark as worded.
Two things follow for the ledger. First, the remark is attached to the function (the pilot acted as cruise-relief co-pilot), not to the rating. A pilot holding a full type rating who relieves in the cruise still performs the function that the definition describes, so the remark question is separate from the credit question. Second, the remark is a durable marker that lets an assessor identify relief entries without reading a free-text note. If an export or printout drops the Remarks column, the marker is lost.
The restricted type rating and the 250-hour credit
FCL.720.A(c) creates a type rating with restricted privileges for a multi-pilot aeroplane, which allows holders to act as cruise relief co-pilots above Flight Level 200 (Source: eur-lex.europa.eu), provided two other members of the crew hold a type rating in accordance with FCL.720.A(b) (Source: eur-lex.europa.eu). To remove the restriction, applicants must comply with every one of a list of conditions (Source: eur-lex.europa.eu), beginning with an assessment at an approved training organisation (ATO) that determines the training needs (Source: www.easa.europa.eu).
FCL.510.A(c)(3) then gives holders of that restricted rating a credit toward ATPL(A) experience. The text refers to holders of a restricted type rating issued in accordance with FCL.720.A(c) (Source: eur-lex.europa.eu) and states that they receive credits for flight time completed while exercising the privileges of that rating, up to a maximum of 250 hours (Source: eur-lex.europa.eu). The consolidated EUR-Lex text of Regulation 1178/2011 as at 14 August 2024 carries the same wording.
Three limits on the reading are worth stating:
- Rating, not function: the credit attaches to a restricted type rating and not to the CRCP function as such.
- Date-sensitive: it applies to time flown while exercising the privileges of that rating, so the question is what rating the pilot held on that flight.
- Allocation unstated: the text names a credit of up to 250 hours, and in the passage read it does not say which of the FCL.510.A(b) subrequirements the credited hours feed.
Opinion 05/2023, the rulemaking document behind the amendment, says the limit was set at 250 hours after discussion in the review group (Source: www.easa.europa.eu) and was not reduced further for consistency with the flight engineer provision in point (c)(2) (Source: www.easa.europa.eu). No other stated rationale for the number was found.
The amending act and its timing
The credit provision was introduced by Commission Implementing Regulation (EU) 2024/2076 of 24 July 2024 (Source: eur-lex.europa.eu), which provides that it enters into force on the twentieth day following publication (Source: eur-lex.europa.eu). Its recital on cruise relief co-pilots concerns revising the provisions in both Regulation (EU) No 1178/2011 and Regulation (EU) No 965/2012 (Source: eur-lex.europa.eu).
This is not a rule newly adopted in 2026. The October 2026 edition is relevant because it is the current consolidated reading, and because the same edition carries other recent changes: EASA's page tags the FCL.010 definitions section with a later amending regulation than the FCL.510.A and FCL.720.A sections (Source: www.easa.europa.eu). The tag shows only that the section has been amended since; it does not show what changed. Anyone compiling an application should compare the text in force on the application date with the text in force on each flight date, and ask the authority how transitional cases are handled.
Table 1 below maps each provision to what it governs and what it does not govern.
| Provision | What it governs | What it does not settle |
|---|---|---|
| FCL.050 and AMC1 FCL.050 | Keeping a reliable flight record in the form the competent authority establishes; co-pilot and cruise relief logging while occupying a seat | How seat intervals are measured or evidenced; whether any credit follows |
| AMC1 FCL.050 logbook instructions, column 12 | The CRCP remark when the pilot acted as cruise-relief co-pilot | The rating held on the date; the credit amount |
| FCL.010 definitions | Cruise relief co-pilot, co-pilot, flight time | Whether the pilot held a restricted rating |
| FCL.720.A(c) | Restricted rating: relief duty above FL200 with two fully rated crew | Experience credit; the national form entry |
| FCL.510.A(c)(3) | Credit up to 250 hours for time exercising the restricted privileges | Which subrequirements receive the credit; other pilots' credit |
| FCL.510.A(d) | Experience completed before the ATPL(A) skill test | Treatment of evidence gaps |
The table shows a layered structure. The logbook rules answer what was flown from which seat, the definitions identify the function, the type rating rules identify privileges, and the experience rules identify what counts toward an ATPL(A). A single number in a logbook cannot answer all four questions, which is why the proposed ledger separates them.
- Bound the personal co-pilot entry by actual seat occupation.
- Enter CRCP in the Remarks column on each relief flight.
- Preserve raw durations and the source record alongside the rating era.
- Identify time flown while exercising restricted type-rating privileges.
- Apply the 250-hour maximum to supported restricted-privilege time.
- Ask the receiving authority how declared credit is allocated on its form.
The cap calculation leaves the other ATPL(A) experience subrequirements open; each subtotal needs its own evidence.
Logged duration is a fact about the flight. Credit is a calculation for an application.
Implementation Considerations and Process Changes
Establish the facts before logging
The first step is to determine, for each flight, the role, the rating and the seat interval. The list below sets out the data points that support a defensible entry.
- Jurisdiction and authority: the licensing authority that will assess the application, since forms and evidence expectations are national.
- Role on the flight: cruise relief co-pilot as defined in FCL.010, or another function such as co-pilot or PICUS (a co-pilot performing the duties of a PIC under supervision (Source: eur-lex.europa.eu)). One independent explainer advises checking first whether the second seat was a required crew position [3].
- Rating privileges on the date: a restricted type rating under FCL.720.A(c), or a full type rating, with the date of any restriction removal.
- Seat interval: start and end times in UTC during which the pilot occupied a pilot seat, with the source of each time.
- Aircraft and operation: type, registration and the fact that the operation required more than one pilot.
- Supporting record: the document from which the interval comes, such as an operator electronic record, a signed crew log or a countersigned entry.
An operational flight plan (OFP) or roster shows what was planned and who was rostered. It does not by itself show who sat in a pilot seat for how long, and it does not show whether the pilot held a restricted rating on the date. Those need a separate record. AMC1 FCL.050 permits commercial air transport flights to be recorded in an electronic format maintained by the operator (Source: www.easa.europa.eu), which suggests asking the operator what record it keeps of relief intervals, if any, and whether the pilot can obtain it. The AMC does not say that such a record must exist.
Record qualifying seat intervals
For each flight, enter the interval and compute the logged duration from the interval. Keep the aircraft's block duration in a separate field so that the difference is visible. The logbook instructions require flight time to be measured from first movement to final rest, which is the reference duration for the flight, not for the relief pilot's seat.
The kinds of record that could support an interval include the following, and the authority decides which it accepts:
- Operator electronic record: a computerised record the operator maintains, where one exists and the pilot can obtain it.
- Countersigned crew log: a signed entry made by a crew member who observed the rotation.
- Operator statement: a letter from the operator confirming the rotation times for a flight or period.
- Not sufficient alone: a roster or OFP, which shows plan and assignment but not occupation of a seat.
Where a pilot occupied a seat in more than one interval on the same flight (for example, two rotations), record each interval and sum them. Where the interval is not documented, record the entry as unresolved rather than estimating it. Ireland's PLAM.024 requires entries made as SPIC or PICUS to be certified by the PIC or FI (Source: www.iaa.ie). The memorandum text read states no equivalent certification for cruise relief entries, so the evidence for an interval has to come from elsewhere.
Retain CRCP identification and the rating era
Enter CRCP in the Remarks column on each relief flight, as the sample logbook instructions require. Add a second marker in the ledger for the rating era, for example "RR" for restricted rating and "FR" for full rating, with the date range. The second marker is a ledger convention and not an EASA requirement. Its purpose is to survive a later question about which entries were flown while exercising restricted privileges.
The logbook remarks column is at the holder's discretion except for the required entries, so extra notes in it are permitted. A pilot should confirm with the authority whether additional annotations are welcome or whether the form expects only the standard entry.
Table 2 below is the ledger layout. It is a template with four synthetic rows, all hypothetical, plus the aggregate line for the cap arithmetic. The four rows are an excerpt; the aggregate line stands for the full hypothetical ledger and includes other flights not shown.
(Hypothetical Example) Synthetic flights for a pilot who held a restricted rating until a stated date.
| Flight date / ID | Block duration | Supported seat interval | Relief role | Rating restriction on date | Source record | Logged duration | CRCP remark | Credit claimed | Receiving-form field | Unresolved question |
|---|---|---|---|---|---|---|---|---|---|---|
| 2025-03-04 / FL-A | 11:40 | 03:10 (one rotation) | Cruise relief co-pilot | Restricted (FCL.720.A(c)) | Operator electronic record | 03:10 | Yes | 03:10 toward the 250 h route | Cruise relief credit line, where the form has one | Does the authority accept the operator record? |
| 2025-09-12 / FL-B | 12:05 | 02:50 and 01:05 (two rotations) | Cruise relief co-pilot | Restricted (FCL.720.A(c)) | Countersigned crew log | 03:55 | Yes | 03:55 toward the 250 h route | Same | Are two rotations summed? |
| 2025-11-18 / FL-D | 11:15 | Not documented | Roster shows relief | Restricted | Roster only | Unresolved | Unresolved | None until evidenced | None | Obtain operator statement or exclude |
| 2026-02-20 / FL-C | 10:30 | 03:30 (one rotation) | Cruise relief co-pilot | Full type rating after restriction removed | Operator electronic record | 03:30 | Yes | None under FCL.510.A(c)(3) | Ordinary experience lines | How is full-rating relief time treated on the form? |
| Aggregate (synthetic) | n/a | n/a | n/a | Restricted-era supported time only (excludes full-rating flights such as FL-C and unresolved FL-D) | n/a | 320:00 raw (restricted-era total, includes other flights not shown) | n/a | 250:00 potentially claimable via this route | See form | 70:00 preserved in the record, not deleted |
The ledger demonstrates why the logged duration and the credit differ. Row FL-A shows 11:40 of block duration but 03:10 of supported seat time, so the entry is 03:10 and not 11:40. Row FL-C shows a logged entry with no credit under the restricted-rating route because the privilege no longer applied. Row FL-D shows an entry that cannot be completed without evidence. The aggregate line applies the cap to the sum of supported restricted-privilege time. The 70 hours above the cap are preserved because the record is the evidence; the cap limits a credit calculation, and the text read does not instruct a pilot to remove hours from the logbook.
Keep the raw record and compute credit separately
Logged duration is a fact about the flight. Credit is a calculation for an application. Merging them, for example by capping the logbook entry at 250 hours or applying a flat 50% reduction, destroys evidence and answers a question the rule does not ask. A better approach is a three-step calculation:
- Sum the supported seat intervals flown while exercising the restricted privileges, by date range.
- Apply the 250-hour maximum from FCL.510.A(c)(3) to that sum only.
- Report the result in the receiving form's field, with the uncapped sum available as a supporting figure.
The cap arithmetic can say nothing about the other lines. FCL.510.A(b) requires 500 hours in multi-pilot operations on aeroplanes (Source: eur-lex.europa.eu), 200 hours cross-country with at least 100 as PIC or PIC under supervision, and 75 hours instrument time, plus 100 hours of night flight as PIC or co-pilot, and the PIC requirement has three alternatives. Up to 100 hours of the 1500 may have been completed in an FFS and FNPT. Each subtotal requires its own evidence. The 250-hour figure cannot be used to infer them.
Check that the label survives export
An export check should be run before any presentation to an authority. The steps are:
- Select a relief flight with a CRCP remark and print the page in the layout the authority expects.
- Confirm the Remarks column appears and the text CRCP is present on the printed line.
- Confirm the rating era (or a note referencing it) appears in the export or on an attached sheet.
- Confirm the totals by function match the ledger, and that no automatic rounding has merged intervals.
- Confirm signatures: Ireland requires electronic logbooks to be printed with each page signed as a true record (Source: www.iaa.ie), and Greece asks for each page to be signed as a true copy (Source: hcaa.gov.gr). The standard EASA logbook form carries a pilot certification line that the entries are true.
How common logbook tools document relief time
Table 3 compares what several logbook tools say on their own pages about relief, co-pilot or cruise relief fields. The table records documented constructs only. It makes no claim that any tool does or does not assess licence credit, and every row should be checked against the version in use.
| Tool | Documented relief or co-pilot construct | Documented records and output | What to verify before relying on it |
|---|---|---|---|
| Paper EASA-format logbook | Pilot function columns and a Remarks and Endorsements column | Hand-entered; pilot certification line | Seat interval written in the remarks or in an annex |
| MyFlightbook | Properties for cruise relief as 2nd officer, day and night [4]; a relief or cruise pilot time property [4]; a seat time property for time in a duty position [4] | Property table on the vendor's site; the page does not describe automated licence-credit checks | Whether the property maps to the CRCP remark in the printed layout |
| LogTen (Pilotbase) | A Relief time field, deducted automatically from Total Time when enabled (Source: intercom.help), with quick split buttons (Source: intercom.help) | Vendor help article | That the deducted Total Time matches the entry convention the authority expects |
| Safelog (Dauntless) | User-created fields for relief pilot time and cruise pilot time [5]; a setting that makes a field count toward total flight time [5] | Supplementary totals for EASA and similar formats, per the vendor's help page | Field naming and the total-time setting |
| ForeFlight Logbook (Europe region) | Dedicated Co-Pilot time field options [6]; European terminology including Co-Pilot and PICUS [7] | An FCL.050 report that relies on Category/Class to total experience hours [6] | Whether relief intervals appear; the captured pages do not mention cruise relief |
| Pilot EFB | Separate pilot-function columns; the vendor describes its product as a personal record, not a compliance system [3] | Vendor explainer | Scope of the stated disclaimer |
| Pilot Logbook (invitation-only) | Pilot-flying options and flights imported from a roster; no dedicated CRCP field or automatic cap calculation is asserted here | Per the vendor's product page read on 8 November 2026: OFP PDFs stored with the matched flight, photos and PDFs attachable to a flight, print layouts based on paper logbooks of 14 authorities including EASA, and whole-logbook export | Whether the CRCP text and rating era appear in the chosen EASA layout and export; access is invitation-only per the vendor at pilots.landing.aero (vendor-published; this row reflects vendor claims only) |
The table shows that the tools expose relief time through different constructs: properties, fields that deduct from the total, user-defined fields, or standard columns. Those conventions are not interchangeable. LogTen's documented behaviour of deducting Relief from Total Time, for example, is a statement about that product's totals, and a pilot should confirm that the figure printed for an authority reflects the seat-interval convention described above. The same applies to every tool in the table, including the one published by this site's operator, whose row in Table 3 reflects only its own product page. A saved OFP or roster in any of them is a supporting record. It is not proof of seat occupation, restriction status or credit. Paper remains a valid alternative where the pilot writes the interval and the rating era directly.
- 01Establish the flight facts
Determine the role, rating held on the flight date and seat interval, together with the supporting record.
- 02Record supported intervals
Compute logged duration from seat intervals and keep block duration separate. Record undocumented intervals as unresolved.
- 03Retain CRCP and rating era
Enter CRCP in Remarks and retain the rating era with its date range in the ledger. The rating marker is a ledger convention.
- 04Calculate credit separately
Sum supported restricted-privilege seat intervals, apply the 250-hour maximum and keep the uncapped sum available as a supporting figure.
- 05Check the export and form
Check that CRCP, rating era and totals survive export. Confirm the national form entry and required signatures before submission.
Reconciling the Logbook to a National Application Form
The receiving form is national, so the last step of the ledger is a mapping to the form's field. Four authority documents show how different the forms can be.
Estonia: a cruise relief credit line
The Estonian Transport Administration's ATPL(A) application form OT_243_K1_V39_r1 carries an approval stamp of 19 September 2025 (Source: transpordiamet.ee). In its experience section the form prints a credit sub-line "as cruise relief co-pilot" beneath the 1500-hour total, with a cap of 250 hours printed in a bilingual layout (Source: transpordiamet.ee). It sits beside the credit lines for touring motor glider or sailplane PIC time and for flight engineer time, and a footnote limits the combined flight engineer credit in points (a) and (b) to 250 hours (Source: transpordiamet.ee). The form therefore treats the cruise relief credit as a distinct entry. It is a named national example, not a universal form, and the form has no field for the rating restriction or seat intervals.
The same form requires the experience to be completed before the skill test (Source: transpordiamet.ee), asks that electronic logbooks be signed (Source: transpordiamet.ee) and requires the original signature of the aircraft commander when PICUS time is claimed (Source: transpordiamet.ee). The PICUS rule is a different credit route and is outside this report.
Ireland and Greece: no separate line, signed pages
The Irish Aviation Authority's ATPL(A) application form lists the standard experience lines and requires that presented logbooks comply with PLAM 024 (Source: www.iaa.ie). Electronic logbooks must be printed with every page signed as a true record (Source: www.iaa.ie). The Hellenic Civil Aviation Authority's form PEL-FCL 527 (revision dated 11 September 2023) requires logbooks to comply with FCL.050 (Source: hcaa.gov.gr) and each electronic page to be signed as a true copy (Source: hcaa.gov.gr). Neither form, as read for this report, prints a cruise relief credit line. A pilot who relied on a restricted-rating credit would need to ask how the authority wants it declared.
Sweden: restriction status as a recorded event
The Swedish Transport Agency's form TSL7077 for ATPL(A) type ratings has check-boxes for a CRCP skill test and for its removal (Source: www.transportstyrelsen.se), and sets out the removal conditions (Source: www.transportstyrelsen.se). The form says nothing, in the pages read, about how hours on a restricted rating are counted toward ATPL totals. It does show that the authority treats restriction status as a recorded event, which supports keeping the date of removal in the ledger. For stated PICUS time the agency asks for written verification from a manager such as a chief pilot (Source: www.transportstyrelsen.se), which illustrates one type of employer evidence, though not for cruise relief.
Taken together, the documents show that the mapping from ledger to form needs a conversation, not an assumption. The Estonian form has a line; two others do not. No national form read for this report asks for a seat-interval statement.
Data Analysis and Evidence
The quantitative core of the rule set is small, and each figure comes from an official text. The list below consolidates the numbers, each with its source.
- Restricted-rating credit cap: 250 hours, FCL.510.A(c)(3), October 2026 edition.
- Multi-pilot operations requirement: 500 hours, FCL.510.A(b).
- Altitude boundary: above FL 200 in the CRCP definition and in the restricted rating privilege.
- Crew alongside a restricted-rating CRCP: two other members with a full type rating.
The list shows a pattern: the 250-hour figure appears twice in FCL.510.A(c), and EASA's own rationale connects the two.
The arithmetic for the hypothetical aggregate is simple. Let S be the sum of supported seat intervals flown while exercising restricted privileges. The potentially claimable amount through this route is the smaller of S and 250. With S equal to 320 hours, the claimable amount is 250 hours and the difference of 70 hours stays in the record. With S equal to 180 hours, the claimable amount is 180 hours and there is no excess. The cap is a ceiling on a credit calculation, so a lower sum is not topped up.
Scale helps to read the number. At most 250 hours can come through this route, against a 1500-hour total requirement for the licence: a maximum of one sixth by this route alone. No source read for this report says the credited hours count toward the multi-pilot requirement, the PIC requirement or the night requirement, so those proportions are deliberately not computed. Opinion 05/2023 frames the limit as one on crediting flight time under FCL.510.A, and the receiving authority decides how a declared credit is allocated.
A second quantitative point concerns evidence rather than credit. Of the three national ATPL(A) application forms read (Estonia, Ireland and Greece), one prints a cruise relief credit line and all three require signed logbook pages or signed electronic printouts. The Swedish type-rating form is not an ATPL application and is not counted in that tally. Across all four documents, none, as read, prescribes a seat-interval statement. The sample is small and is not a survey of European authorities. It indicates that evidence expectations are set by the authority and that a pilot should obtain the current checklist before assembling the application.
Implications and Future Directions
For pilots, the main implication is that retrospective repair is harder than contemporaneous recording. A seat interval that was never written down cannot be reconstructed from a roster. Pilots who fly relief regularly can capture the interval after each sector, store the supporting record with the flight, and note the rating era in the ledger when a restriction is removed. Where a historic flight has no interval evidence, the choices are to obtain an operator statement, to log the entry as unresolved, or to exclude the entry from the credit calculation. Which choice an authority accepts is its decision.
For logbook tooling, the documentation reviewed shows several constructs for relief time and none that is described as computing the restricted-rating credit. That is an observation about public documentation, not about functionality, and the right check is a practical one: enter the synthetic rows from Table 2, export, and look at the result. Pilot Logbook's own page documents saved OFPs, per-flight attachments, date-range printing and exports, which help retain and present records. It is invitation-only, and its page does not assert a dedicated CRCP field, an automatic cap calculation, authority approval or signed operator verification. Pilot Logbook is published by this site's operator, so this description rests on the vendor's own product page and is not independent evidence.
For the rules, three open items deserve attention:
- Amendment checks: EASA's page itself warns that rules adopted after 16 October 2026 may not be reflected.
- Full-rating relief time: the text read does not address whether relief time flown with a full rating is treated differently on a national form.
- Interval evidence standards: these are not defined in the AMC text read. The FCL.010 section also carries a later amendment tag than FCL.510.A, which is a reason to re-read definitions on the application date.
Questions worth putting to the competent authority before submission:
- Interval evidence: which records does the authority accept for a seat interval?
- Rating history: how should the date a restriction was removed be evidenced?
- Form entry: where on the current form is restricted-rating credit declared, and how is it allocated across the requirements?
- Historic entries: how are entries made before the amendment, or without a CRCP remark, assessed?
For contrast, other jurisdictions use different tests. In the United States, 14 CFR 61.51(f) lets a person log second-in-command time while occupying a crewmember station in an aircraft that requires more than one pilot by its type certificate, among other conditions [8]. In Canada, Transport Canada states that 100% of co-pilot flight time may be used toward the total flight time required for a higher class of licence and that the onus is on the ATPL applicant to provide proof [9]. The UK CAA's replacement UK AMC1 FCL.050 uses the same co-pilot seat wording as the EASA text [1]. These are separate regimes, and none of them substitutes for the EASA analysis above.
Frequently Asked Questions (FAQs)
Can cruise relief pilots log PIC or co-pilot time under EASA?
Under AMC1 FCL.050(b)(3) a cruise relief co-pilot may log flight time as co-pilot when occupying a pilot's seat (Source: www.iaa.ie). An independent explainer states that cruise relief is co-pilot or relief time, not pilot-in-command time [3]. PICUS is a separate function with its own conditions, and that supervised-command route is covered in a separate report on EASA PICUS evidence.
How is cruise relief pilot flight time logged?
Record the seat interval, compute the logged duration from it, keep the block duration in a separate field, and enter CRCP in the Remarks column. The seat interval and its source go in the ledger.
What does CRCP mean in the remarks?
CRCP is the remark the sample logbook instructions require when the pilot acted as cruise-relief co-pilot. The purpose of the entry is that cruise-relief flight time is recorded appropriately.
What is the FCL.010 definition?
A cruise relief co-pilot is a pilot who relieves the co-pilot of duties at the controls during the cruise phase of a flight in multi-pilot operations above FL 200.
Does EASA cap every relief pilot at 250 hours?
No. The 250-hour credit maximum in FCL.510.A(c)(3) applies to holders of a restricted type rating issued under FCL.720.A(c), for flight time completed while exercising the privileges of that rating. Whether any other cap applies to a pilot with a full rating is a question for the authority.
What does FCL.050 require of the pilot?
FCL.050 requires a reliable record of the details of all flights flown, in the form and manner established by the competent authority, and FCL.045 requires a pilot to present the flight time record on request of an authorised representative of the competent authority. Electronic records should be kept so that they are readily available at the request of the authority.
How does ATPL hour credit for cruise relief work?
FCL.510.A(b) sets the experience requirements, including 500 hours of multi-pilot operations. FCL.510.A(c)(3) adds a separate credit of up to 250 hours for restricted-rating privileges. The allocation of that credit on a given form is the authority's decision, and Estonia's form prints a separate line for it (Source: transpordiamet.ee).
Conclusion
EASA's rules separate recording from crediting. The logbook rule ties cruise relief co-pilot time to occupying a pilot's seat and asks for the remark CRCP. The credit rule applies to time flown while exercising the privileges of a restricted type rating and stops at 250 hours. A logbook duration can therefore differ from the credit claimed for two independent reasons: the entry is bounded by seat occupation and not by block duration, and the credit is bounded by the rating held on the date and by a cap.
The record that answers both questions is a ledger that keeps raw durations, supported seat intervals, the source record, the rating era and the CRCP label, and computes credit in a separate column. The worked example, 320 hours against a cap of 250, leaves 250 hours potentially claimable through that route and 70 preserved. It is conditional and synthetic and leaves every other subrequirement open.
Pilots should verify the rule text in force on each flight date and on the application date, obtain the receiving authority's current form and evidence checklist, and resolve absent interval evidence, changed restrictions or ambiguous historic entries with the competent authority before submitting.
External Sources (9)
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