Working towards your frozen ATPL? Check out my best selling Pilot Training Guide on Amazon for how to become a pilot!
Listen to the Pilot Training Guide FREE with Audible here
I had spent most of 2020 from March on furlough and a good proportion of that time not only wondering if I would have a job to return to but worrying about how I was going to pay the bills.
The decision on whether or not to unfreeze my frozen ATPL came down to the fact that I would rather spend the £800 (skills test fee) plus circa 600Euro IAA Initial ATPL application fee from a position of being in employment rather than, should the worst happen- trying to find that sort of cash out of work.
In this blog post, I’ll share some of the pitfalls to avoid when unfreezing your licence.

What is a Frozen ATPL
A frozen ATPL does not really exist. A frozen ATPL is a casual description for when someone has completed pilot training and has a Commercial Pilot Licence (CPL) and Multi-Engine Instrument Rating (MEIR) and has passed all 13 ATPL theoretical exams.
A frozen ATPL can be achieved via the modular pilot training route or integrated route. fATPL requires both theoretical study and practical flight training.
Once a student has completed 1500 flight hours and has achieved at least 75% in each ATPL exam, they can then start the process to unfreeze their frozen ATPL.
How do I unfreeze my ATPL?
You need to have met the requirements from an ATPL including passing all 13 ATPL theoretical exams, flying (>1500 hours total time) and passing an ATPL skills tests.
Theoretical knowledge to unfreeze ATPL
Most likely already completed prior to CPL and MEIR, you need to pass the ATPL theoretical exams with more than 75%. The ATPL exams consist from (taken from the CAA website)
- Air law
- Aircraft general knowledge – airframe/systems/powerplant
- Aircraft general knowledge – instrumentation
- Mass and balance
- Performance
- Flight planning and monitoring
- Human performance
- Meteorology
- General navigation
- Radio navigation
- Operational procedures
- Principles of flight
- Visual flight rules (VFR) communications
- Instrument flight rules (IFR) communications
Flying experience needed to unfreeze ATPL
- 500 hours in multi-pilot operations on aeroplanes
- 500 hours as Pilot in command under supervision (PICUS) or
- 250 hours as Pilot in Command (PIC) or
- 250 hours to include a minimum of 70 hours as PIC and the remainder as PICUS.
- 200 hours of cross-country flight time, of which at least 100 hours should be as PIC or as PIC under supervision
- 75 hours of instrument time, of which not more than 30 hours can be instrument ground time
- 100 hours of night flight as PIC or co-pilot.
Of the 1500 hours of total flight time required, up to 100 hours can be completed in a suitable simulator (FFS or FNPT – but only a maximum of 25 hours may be completed in an FNPT)
Skills test required to unfreeze your ATPL
Once you have the relevant experience and have passed the theoretical knowledge exams, you will need to complete a skills test in a full flight sim. The skills test is actually very similar to your licence proficiency check (if with an airline).
Some of the subtle differences will include the following
- Requirement to show command potential. This is normally completed with an excercise in the air e.g. dealing with a failure
- Raw data ILS approach
- Standard profile including engine failure, single engine approach to go around etc. You will also need to demonstrate a non precision approach.
The next section shares some of the major mistakes to avoid when unfreezing your ATPL.
Mistake #1: Don’t just go with the first quote you get to unfreeze your frozen ATPL
One of the ‘benefits’ of COVID 19 is that sim hire rates have come right down. Back in the day, many airlines used to unfreeze their pilots’ licences during their recurrent sims.
Most of us though are not so fortunate, and if you want to unfreeze your licence, you need to do it yourself or wait until command upgrade.
When looking to unfreeze my licence, I found a lot of goodwill from the many pilots around the globe who were willing to help and share information. Get a few quotes. Through that process, I settled with David @737Sim Guide – check him out on Instagram.
Mistake #2: You don’t have to wait until you have 1500hours ‘flight time’ with frozen ATPL
With a frozen EASA ATPL you can credit up to 100hrs of sim time towards the 1500hr total time requirement. It is worth considering that the 100hr sim time can be made up of a maximum of 25hrs FTD time and the rest Full Flight sim time.
Why the rush? With regulations changing, e.g. Brexit and the fragile nature of airline employment, in particular low hour pilot jobs, the ATPL skill test is much easier to pass when flying regularly and current.
If you are (flying wise) in a good situation, make the most of it. I’ve certainly learned that you never know what can happen tomorrow with all the recent upheaval.
Mistake #3: A lot of people will say there is no point unfreezing as there is no real ‘tangible’ difference between a frozen and unfrozen ATPL
The main difference between a frozen and unfrozen ATPL is that an ATPL is required to command an aircraft over 5700kg or with over nine passenger seats. As a first officer, I would agree that yes, there is no real difference between freezing or unfreezing in day-to-day work (for me on the B737).
During covid 19, with aviation jobs scarce, I have seen specific jobs adverts excluding frozen ATPLs for first officer positions.
Some jobs required a full ATPL. From a job security standpoint (if I can say such a thing during these times!) I would rather have an unfrozen ATPL as the difference between having just a CPL vs an ATPL could make the difference in potential job prospects.
Mistake #4: Not keeping your logbook up to date
Hour wise, the requirements for initial ATPL issue (lifted from the UK CAA website) are:
- 500 hours in multi-pilot operations on aeroplanes
- 500 hours as Pilot in command under supervision (PICUS) or 250 hours as Pilot in Command (PIC) or 250 hours to include a minimum of 70 hours as PIC and the remainder as PICUS.
- 200 hours of cross-country flight time, of which at least 100 hours should be as PIC or as PIC under supervision
- 75 hours of instrument time, of which not more than 30 hours can be instrument ground time
- 100 hours of night flight as PIC or co-pilot.
Of the 1500 hours of total flight time required, up to 100 hours can be completed in a suitable simulator (FFS or FNPT – but only a maximum of 25 hours may be completed in an FNPT).
A lot of the issues come from PICUS hours not being countersigned or entered correctly. With many people using electronic logbooks, there is the real trap of some aviation authorities not accepting electronic signatures.
So you either have to print your electronic logbook and get it countersigned by hand or collect your signatures manually. Trying to correct these signatures at the last minute is a pain as you may not have access to people you flew with previously!?
Mistake #5: Don’t fail and lose your IR during your ATPL skills test
Although unlikely, a significant hazard of unfreezing your licence is that if you hold a valid instrument rating and fail, then you would immediately lose your Instrument Rating!
Failing a sim is catastrophic, so think carefully and don’t breach any contractual requirements if you are unfreezing out of your regular employment sim cycles. Get permissions as appropriate.
Treat the sim with respect and prepare well. The profile is a standard LST profile but with the added requirement of a raw data ILS.
Mistake #6: Not taking advantage of the single-pilot IR cross-credit facility
If you hold a single pilot IR, then provided that you have met the experience requirements necessary (3 single-pilot IFR departures and approaches in the single-engine, single pilot class type), the examiner can sign your licence to keep your single-pilot IR privileges.
The evidence does need to be documented in your logbook. Check with your CAA on what the experience requirements are.
If interested in learning more about Modular Pilot Training, check out my pilot training guide on Amazon.
Listen to the Pilot Training Guide FREE with Audible here
Mistake #7: Make sure you get all your paperwork finalised before leaving the sim centre
Most examiners will help you with this, but make sure you get all the paperwork you need before leaving.
With no malice intended, it can be a pain to chase down paperwork in the weeks after, and the last thing you want is for your ATPL application to be rejected because of a paperwork issue.
I had an excellent experience with David from @737Sim guide from start to finish and would thoroughly recommend him if looking to unfreeze your licence.
My licence is probably the most valuable thing I own, given how much I paid for my modular flight training and how much a frozen ATPL costs – and most importantly the earning power the licence provides.
It was a no brainer to invest in unfreezing my ATPL as one never knows what can happen tomorrow.
Can you get a job with a frozen ATPL?
Yes, you can get a job with a frozen ATPL. Low hour pilot jobs are challenging to come by, but these are some steps you can take at each stage of your pilot training to maximise your chances of getting a job.
During your ATPL theory, try and get the best possible marks and try not to have re-sits during your ATPL exams. The reason for this is that during recruitment, the company you are applying to needs to figure out if you are a training risk or not.
Fail many ATPL exams, and doubts will start to creep into the recruiters’ minds as they try and guess whether or not you will be a training risk.
If you fail an ATPL exam, don’t worry; try and finish as well as you can. Just be aware that there is a surplus of low hour pilots globally, so recruiters looking for low hour pilots can pick and choose from a massive pool.
When choosing where to complete your ATPL exams, it is also essential to make sure you complete your ATPL exams in the state where you will most likely get a job. Ordinarily, you need to make sure you have the right to live and work in the given state.
Having a frozen ATPL in a country where you do not have the right to live and work is not much point as you won’t get a job, and in all likelihood, you will need to pay additional fees to convert your licence back to wherever state you have got the right to live and work in.
Pick carefully where you complete your CPL & MEIR for frozen ATPL
Try and pick a flying school to complete your frozen ATPL with a track record of students getting successful pilot jobs. The best schools are not necessarily the most expensive.
Equally, be careful picking the cheapest training from random schools that do not have excellent standards. When visiting perspective flying schools, ask where students have worked after training and get feedback from recent graduates.
Some flying schools also have links to employment. This may not only be with an airline, but certain schools are part of more extensive operations that perform cargo, flight training or survey flying.
Completing your flying training at these organisations may open the doors later to become an instructor with them or even be employed company as a professional pilot.
MCC course plays a big impact in getting a job with a frozen ATPL
I was in the situation towards the end of pilot training where I was running out of money but wanted to get my MCC certificate. The trap of doing any old cheap MCC means that you may not be sufficiently prepared for airline assessment and type ratings.
A strong MCC like the APS MCC can help bridge the gap into airline pilot employment, and it will flatten the curve when it comes to your type rating.
If you are ready to book right away, make sure you check out VA Airline Training and their APS MCC course.
I would love to hear from you if you have any questions about unfreezing your ATPL – please leave a comment in the section below!

Kudzi Chikohora is a B737 captain with over 3,000 hours of flying in Europe. He holds a Master’s degree in Aerospace Engineering, is a chartered engineer, and is a member of the Royal Aeronautical Society.
Kudzi completed his pilot training via the self-funded modular pilot training route and created kcthepilot.com to share pilot training and aviation content.
Is there a time limit from when you complete your training and obtain an fATPL until when you eventually unfreeze it? I have heard conflicting reports of it being 5 years. Thank you!
Hi everyone,
I have over 3500h as F/O on B737NG and A320, but I never did my ATPL unfreeze, thought it would come naturally with time, but now circumstances have changed and I am looking forward to do it, I am a little puzzled about the criteria to do it, are all items mandatory or are they OR ?
——–
Flying experience needed to unfreeze ATPL
500 hours in multi-pilot operations on aeroplanes
500 hours as Pilot in command under supervision (PICUS) or
250 hours as Pilot in Command (PIC) or
250 hours to include a minimum of 70 hours as PIC and the remainder as PICUS.
200 hours of cross-country flight time, of which at least 100 hours should be as PIC or as PIC under supervision
75 hours of instrument time, of which not more than 30 hours can be instrument ground time
100 hours of night flight as PIC or co-pilot.
Of the 1500 hours of total flight time required, up to 100 hours can be completed in a suitable simulator (FFS or FNPT – but only a maximum of 25 hours may be completed in an FNPT)
———
To summarize I have 3500h TT / 200PIC (total picus and Cessnas) / 50h Double Command, am I eligible?
Thanks for the feedback!
Thanks for reaching out.
Not all mandatory – these items are ‘or’ as you mentioned;
500 hours as Pilot in command under supervision (PICUS) or
250 hours as Pilot in Command (PIC) or
250 hours to include a minimum of 70 hours as PIC and the remainder as PICUS.
Wishing you the best of luck