EASA FTL for business aviation: the rules that catch crews out
By Arnthor Birgisson, business aviation captain and founder of Galley. Facts checked on 17 October 2026 against the official texts listed under Sources.
This is a guide, not legal advice. Your operator’s approved scheme in the OM-A is what you fly to.
It’s 18:40 and ops are on the phone: “Can you do one more leg?” Most of us then do the arithmetic on the back of the nav log. The arithmetic matters less than the question before it: which flight time rules are you flying under? In business aviation the answer is often not the one people assume. And the rules that cause trouble are rarely the headline numbers. They are the conditions attached to them.
Below are the eight that come up most on bizjet rosters, each with the paragraph it comes from.
1. You may not be on ORO.FTL at all
When people say “EASA FTL” they usually mean Subpart FTL of Annex III to Regulation (EU) No 965/2012: the ORO.FTL rules, with EASA’s certification specifications, CS FTL.1. Article 8(1) applies them to commercial air transport (CAT):
“CAT operations with aeroplanes and helicopters shall be subject to the requirements of Subpart FTL of Annex III.”
The next paragraph takes a large part of business aviation out again. Article 8(2):
“By way of derogation from paragraph 1, air taxi, emergency medical service and single pilot CAT operations by aeroplanes shall be subject to the requirements specified in the national law referred to in Article 8(4) of Regulation (EEC) No 3922/91 and in Subpart Q of Annex III to that Regulation.”
Article 2 defines an air taxi operation as, “for the purpose of flight time and duty time limitations, a non-scheduled on demand commercial air transport operation with an aeroplane with a maximum operational passenger seating configuration (‘MOPSC’) of 19 or less”. CS FTL.1.100 says the same from the other side: the certification specifications cover scheduled and charter flying, “excluding emergency medical service (EMS), air taxi and single pilot operations”.
Most business jets have 19 passenger seats or fewer, so a lot of on-demand charter is air taxi for FTL purposes. It runs on the older EU-OPS Subpart Q plus your state’s national rules, not on ORO.FTL. A VIP airliner with more than 19 passenger seats is not air taxi under that definition.
Non-commercial flying is different again. Under Article 8(4), non-commercial operations with complex motor-powered aeroplanes (a corporate flight department flying its own jet under Part-NCC, for example) follow “the requirements specified in the national law of the Member State in which the operator has its principal place of business”.
So two crews flying the same type out of the same FBO can be on three different rulebooks. Before you trust any number, open chapter 7 of your OM-A, “Flight time limitations” (the chapter AMC3 ORO.MLR.100 gives it), and read which scheme it is built on. Each point below says which rulebook it comes from.
2. Minimum rest is “at least the preceding duty”, not 10 or 12 hours
Under ORO.FTL.235, the familiar figures are floors, not the rule:
- at home base, point (a)(1): “at least as long as the preceding duty period, or 12 hours, whichever is greater”;
- away from home base, point (b): “at least as long as the preceding duty period, or 10 hours, whichever is greater”, including “an 8-hour sleep opportunity in addition to the time for travelling and physiological needs”.
Point (a)(2) lets the operator apply the away-from-base minimum at home base too, if it gives you suitable accommodation there.
A 13-hour-30 duty that ends at the hotel means 13 hours 30 of rest before the next FDP, not 10. EU-OPS Subpart Q has the same structure: at least the preceding duty period, or 12 hours at home base and 10 hours away (OPS 1.1110 points 1.1 and 1.2).
Where this bites in business aviation: the long day that ends with a positioning flight home. That brings us to the next rule.
3. Positioning is duty, and before you operate it is FDP
ORO.FTL.215 has two points:
“(a) positioning after reporting but prior to operating shall be counted as FDP but shall not count as a sector;
(b) all time spent on positioning shall count as duty period.”
So when you report at 06:00 to ride an airline flight to the aircraft, your FDP starts at 06:00, not when you sign for the jet. The airline flight home after your last sector is still duty, so it lengthens the duty period that the next rest has to cover (rule 2). Subpart Q says the same in OPS 1.1105 point 5: all positioning counts as duty (5.1); positioning after reporting but before operating is part of the FDP (5.2); and a positioning sector straight after an operating sector counts towards the minimum rest calculation (5.3).
The positioning leg is the easiest one to leave out of a hand calculation, and it often changes the answer the most.
4. Planned extensions: twice a week, not late in the day, and they cost rest
ORO.FTL.205(d) lets an operator extend the maximum daily FDP by up to 1 hour, “not more than twice in any 7 consecutive days”. The conditions are where crews get caught:
- the rest before and after must each grow by 2 hours, or the rest after by 4 hours (point (d)(1));
- the extension “shall be planned in advance”, and the sectors are limited: 5 if the FDP doesn’t encroach on the window of circadian low (WOCL, 02:00 to 05:59), 4 if it encroaches by 2 hours or less, 2 if by more (point (d)(3));
- the CS FTL.1.205(b) table (as amended by ED Decision 2023/023/R) allows no extension for an FDP that starts between 19:00 and 06:14. From a 13:30 start, 5 sectors are no longer allowed; from 15:30, only 1 or 2 sectors can be extended. The extended maximum is 14:00 for 1 or 2 sectors starting 07:00 to 13:29, then falls by 15 minutes every half hour, to 11:15 for a start between 18:30 and 18:59.
Under Subpart Q the extension is also up to 1 hour, twice in any 7 consecutive days, with extra rest and sector limits (OPS 1.1105 points 2.1 to 2.6), plus a cap that surprises people: “When an FDP with extension starts in the period 22:00 to 04:59 hours the operator will limit the FDP to 11.45 hours” (point 2.7).
A planned extension is not a buffer for delays. EASA’s answer to a question on ORO.FTL.205(d) says that a duty that was not planned with an extension “cannot be changed into a duty with such extension on the day of operation”. Delays are what the next rule is for.
5. Commander’s discretion is for the unforeseen, and it starts from the basic maximum
ORO.FTL.205(f) covers unforeseen circumstances in flight operations that start at or after the reporting time. Point (f)(1)(i):
“the maximum daily FDP which results after applying points (b) and (e) of point ORO.FTL.205 or point ORO.FTL.220 may not be increased by more than 2 hours unless the flight crew has been augmented, in which case the maximum flight duty period may be increased by not more than 3 hours”
Three things follow:
- The 2 hours count from the basic table (or the in-flight rest or split duty maximum: points (b), (e) and ORO.FTL.220), not from a planned extension under point (d). EASA’s FAQ gives the example: when 1 hour has already been added under ORO.FTL.205(d), “then only 1 hour is left for commander’s discretion”.
- The rest after may be reduced, but “can never be less than 10 hours” (point (f)(1)(iii)).
- The commander decides after consulting all crew members on their alertness, and reports to the operator. When the increase or the reduction is more than 1 hour, the operator sends the report, with its comments, to the authority within 28 days (points (f)(3) to (5)). The operator must also have a non-punitive process for the use of discretion (point (f)(6)).
Subpart Q works the same way: OPS 1.1120 allows up to 2 hours (3 with an augmented crew) on the 13-hour maximum basic daily FDP of OPS 1.1105 point 1.3, and the reduced rest never below the OPS 1.1110 point 1.2 minimum.
If someone asks you to “use discretion” for a leg that was on the schedule at 09:00, that is not an unforeseen circumstance, and you can say so.
6. Weekly rest needs two local nights, not only 36 hours
ORO.FTL.235(d) sets the recurrent extended recovery rest at 36 hours including 2 local nights, with no more than 168 hours between the end of one and the start of the next. Twice every month it must be increased to 2 local days.
The definitions in ORO.FTL.105 do the work:
- a local night is “a period of 8 hours falling between 22:00 and 08:00 local time”;
- a local day is “a 24-hour period commencing at 00:00 local time”.
A 36-hour block that starts at 03:00 on Tuesday ends at 15:00 on Wednesday. It holds only one local night (Tuesday 22:00 to Wednesday 06:00, for example): Tuesday 03:00 to 08:00 is only 5 hours. Thirty-six hours, but not a valid weekly rest.
Subpart Q’s weekly rest is also 36 hours including two local nights, at most 168 hours apart (OPS 1.1110 point 2.1), with the same 22:00 to 08:00 local night (OPS 1.1095 point 1.9). One difference: the authority may let the second local night start at 20:00 if the weekly rest lasts at least 40 hours.
On rotations with odd release times, this is the rule crews miss most often.
7. Standby counts, some of it in full
On-call days are normal in business aviation. In ORO.FTL terms most of them are standby, and CS FTL.1.225 decides what they cost you:
- Airport standby counts in full as duty, for the cumulative limits and for rest (ORO.FTL.225(c)). If an FDP starts during it, the maximum FDP is reduced by any standby beyond 4 hours, and airport standby plus the FDP can’t exceed 16 hours (CS FTL.1.225(a)(2)).
- Other standby (at home or in suitable accommodation) lasts at most 16 hours. If it ends after the first 6 hours, the maximum FDP is reduced by the standby time beyond 6 hours (8 hours where the FDP is extended by in-flight rest or split duty). If the standby starts between 23:00 and 07:00, the time between 23:00 and 07:00 doesn’t count towards that reduction until the operator contacts you (CS FTL.1.225(b)(1) and (7) to (9)).
- 25 % of other standby counts as duty for the cumulative limits in ORO.FTL.210 (CS FTL.1.225(b)(3)).
Subpart Q counts airport standby in full towards cumulative duty (OPS 1.1125 point 1.2) and leaves other standby to the national authority (point 2.1). That is one more reason to read your OM-A.
8. The 14-day duty limit, and the ones Subpart Q doesn’t have
ORO.FTL.210 sets the cumulative limits:
| Limit | ORO.FTL.210 | EU-OPS Subpart Q (OPS 1.1100) |
|---|---|---|
| Duty, 7 consecutive days | 60 h | 60 h |
| Duty, 14 consecutive days | 110 h | none |
| Duty, 28 consecutive days | 190 h | 190 h |
| Flight time, 28 consecutive days | 100 h | 100 h (block) |
| Flight time, calendar year | 900 h | 900 h (block) |
| Flight time, 12 consecutive calendar months | 1,000 h | none |
Most crews watch 60 hours in 7 days. Fewer watch 110 in 14, and two busy weeks that each look fine can break it: two weeks of 58 hours make 116. Positioning and airport standby count as duty here too (rules 3 and 7), and your national rules may add limits that neither table shows.
Quick reference
| Rule | Where it comes from |
|---|---|
| Which scheme applies (CAT, air taxi, NCC) | Reg. (EU) 965/2012 Art. 2, Art. 8(1), 8(2), 8(4); CS FTL.1.100 |
| Minimum rest = preceding duty, or 12 h at home base / 10 h away | ORO.FTL.235(a), (b); OPS 1.1110 points 1.1, 1.2 |
| Positioning before operating = FDP; all positioning = duty | ORO.FTL.215; OPS 1.1105 point 5 |
| Extension +1 h, twice in 7 days, extra rest, sector limits, none from 19:00 to 06:14 | ORO.FTL.205(d); CS FTL.1.205(b); OPS 1.1105 point 2 |
| Commander’s discretion +2 h (+3 h augmented) from the basic maximum, rest ≥ 10 h | ORO.FTL.205(f); OPS 1.1120 |
| Weekly rest 36 h incl. 2 local nights, ≤ 168 h apart | ORO.FTL.235(d), ORO.FTL.105; OPS 1.1110 point 2.1 |
| Standby | ORO.FTL.225, CS FTL.1.225; OPS 1.1125 |
| Cumulative limits | ORO.FTL.210; OPS 1.1100 |
Check your own roster
I built the FTL check in Galley because checking every roster change by hand is how mistakes get through. Galley reads your roster from Leon, Schedaero, Avianis, a crew calendar link or a roster PDF, and checks each duty against EASA ORO.FTL, EU-OPS Subpart Q, the UK rules, FAA Part 117 or Part 135, or your operator’s OM-A scheme. Each finding names the paragraph it comes from. Each scheme also lists what Galley doesn’t check yet: for EASA, cabin crew reporting earlier than flight crew (ORO.FTL.205(c)) and the operator procedure that keeps home standby plus FDP within 18 hours awake (CS FTL.1.225(b)(2)).
If your operator connects Galley to Leon, you see Leon’s FTL figures in Galley, not a second calculation. Either way the check is advisory: your operator’s approved scheme and your own judgement come first.
Related
Sources
- Regulation (EU) No 965/2012, consolidated version of 25 May 2026: Article 2 (air taxi operation), Article 8; Annex III, Subpart FTL: ORO.FTL.105, ORO.FTL.205(d) and (f), ORO.FTL.210, ORO.FTL.215, ORO.FTL.225, ORO.FTL.235. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02012R0965-20260525
- EASA Easy Access Rules for Air Operations (March 2026): CS FTL.1.100; CS FTL.1.205(b) (ED Decision 2023/023/R); CS FTL.1.225 (ED Decision 2014/002/R); AMC3 ORO.MLR.100 (contents of the operations manual). https://www.easa.europa.eu/en/document-library/easy-access-rules/easy-access-rules-air-operations
- EASA FAQ: commander’s discretion ORO.FTL.205(f), see also ORO.FTL.205(d): EASA’s FAQs are its understanding, not legally binding. https://www.easa.europa.eu/en/faq/47599
- EASA FAQ: changing planned duties on the day of operation (ORO.FTL.205). https://www.easa.europa.eu/en/faq/47583
- EU-OPS Subpart Q: Annex III to Regulation (EEC) No 3922/91, as replaced by Regulation (EC) No 1899/2006 and Regulation (EC) No 8/2008: OPS 1.1095 (definitions), 1.1100, 1.1105, 1.1110, 1.1120, 1.1125. https://eur-lex.europa.eu/eli/reg/2008/8/oj
Changes
- 17 October 2026: Facts checked against the texts above.