A Matter of an Opinion: Everyone has One

Preparing for EASA’s FCS Framework: What FSTD Operators and ATOs Need to Know

About Opinion No 01/2025

The 19th of May this year was an important date in the evolution of flight training within Europe, with the European Union Aviation Safety Agency (EASA) publishing how they intend to reshape how flight simulation training devices (FSTDs) are qualified and used in pilot training. With Opinion No 01/2025, EASA proposes a forward-looking regulatory update aimed at better aligning device capabilities with training needs. If you’re a flight simulation training device operator (FSTDO) or an Approved Training Organisation (ATO), or even a Training Device Manufacturer (TDM), this affects you directly — and the clock is already ticking.

Here’s what you need to know to stay ahead of the curve.

Why This Opinion Matters

The industry is evolving rapidly with current FTD-type devices providing FFS realism and fidelity, touchscreen cockpits, Virtual Reality (VR) and Mixed Reality (MR) based flight decks, Simulated Air Traffic Control Environments (SATCE) — none of these fit comfortably within the old framework of device qualification based on rigid FSTD “type and level” labels. EASA is answering this challenge by rolling out a new concept: the FSTD Capability Signature (FCS). It’s flexible, it’s detailed, and it’s built for modern training environments.

Timeline for Implementation

Once the European Commission adopts the proposed changes with a decision (which could take anything from 6 to 12 months), the new FCS framework will officially become applicable for all new build devices two years later, after a transition period. That’s your runway to prepare. Within those two years, there are however two critical deadlines you need to be aware of:

• Within 12 months of the decision applicability date, all FSTDs (except BITDs) must have an FSTDO declared Equipment Specification List (ESL) submitted to the competent authority. So, by around early- or mid-2027.

• Within 18 months, national authorities must issue updated qualification certificates using the new format for all FSTDs (except BITDs). So, by around mid- or late-2027.

  
  

Organisations operating FSTDs can also voluntarily transition legacy devices into the new system during the transition period by applying for an assigned FCS, provided certain conditions are met, or requesting a special evaluation which may be attractive to operators with devices that they believe already exceed the assigned FCS - and hence may facilitate more training credits than currently granted.

What’s Changing for FSTD Operators

The transition from FSTD type/level qualifications (like FTD 2 or FFS Level D) to FCS is more than just new paperwork — it’s a fundamental paradigm shift in how devices are evaluated and qualified.

Instead of classifying a device by a generic label, the qualification certificate will now list each of 14 simulation features contained in the 3 main simulation groups (Aircraft, Cueing, Environment) with an associated fidelity level. These levels range from "none" to "specific", reflecting how closely the simulation mirrors the aircraft and the real-world conditions for that feature.

The new qualification certificates are streamlined and now explicitly indicate whether your device is capable of supporting UPRT (Upset Prevention and Recovery Training) and MCC (Multi-Crew Cooperation) training.

Your responsibilities however will now include developing and maintaining an ESL for each device. This is a structured document that outlines the simulator’s configuration, capabilities, validation data, and the basis for each fidelity level. Whether you keep your legacy qualification or adopt FCS, the ESL becomes a required document and part of your simulator’s official qualification.

Additionally, if you choose to transition to the new system, you can request an assigned FCS based on equivalence tables — meaning your device doesn’t need to be re-evaluated, provided its current specs meet certain thresholds.

What’s Changing for Approved Training Organisations (ATOs)

As an ATO, you’ll need to decide whether to update your type rating training programs to align with the FCS framework and training matrices, as will be detailed in Part FCL, especially for type rating and recurrent training for both fixed and rotary wing aircraft FSTDs. These matrices define the minimum device fidelity levels required for specific training tasks. The new system enables greater flexibility, especially in reducing reliance on full-flight simulators (FFSs) where appropriate.

This flexibility only applies if you redesign the program based on instructional system design principles and “task-to-tool” training matrices developed for the FCS. In practice, it means you may be able to use lower-cost or more versatile devices while still meeting regulatory standards.

If you stick with your existing training programs, no immediate changes are required. Legacy devices remain fully usable. However, only FCS-qualified devices are eligible for credit under task-to-tool designed programs.

EASA also clarified rules around other training devices (OTDs). Some use is permitted, but time spent on these devices does not count toward FSTD minimum training hours.

Benefits for Operators and Trainers

This shift brings a host of benefits:

• Device qualification becomes much more transparent and feature-specific.

• Training credit decisions are based on actual simulator capabilities, not outdated arbitrary FSTD types and labels based on FSTD technical specifications.

• Operators can better utilise new technologies like touchscreen interfaces or extended reality.

• Training providers gain flexibility in building programs tailored to learning objectives, not legacy hardware requirements.

• Potential cost savings from reducing the need for expensive FFS time.

  
  

What You’ll Need to Do

If you operate FSTDs:

• Prepare and submit ESLs for each device (except BITDs) within 12 months of applicability.

• Decide whether to transition legacy devices to FCS qualification.

• Familiarise your technical staff with the FCS framework and ESL requirements.

• Monitor equipment updates — major modifications may require new ESL submission and possible reevaluation.

• Prepare for reissuance of qualification certificates by your national authority within 18 months.

  
  

If you’re an ATO:

• Assess whether to redesign your type rating programs using task-to-tool principles.

• Identify which devices (legacy or FCS-qualified) are eligible for each part of your training.

• Work with your FSTDO partners to ensure ESLs match your training needs.

• Update your training manuals and submit revisions for approval if you adopt the FCS framework.

  
  

No Need to Rush — But Don’t Wait Too Long

EASA has built in flexibility so you don’t need to overhaul everything overnight. Legacy FSTDs remain usable. ESL development is gradual. Applying for assigned FCS is optional.

Still, the direction is clear. This new system is more precise, more flexible, and more compatible with modern FSTD capabilities (especially today’s FTDs) and technologies. Early adoption might give you operational and competitive advantages — especially if you’re developing new devices or expanding your training offerings.

How can SIM OPS Help

SIM OPS have been following this topic for a while. For further background, see some of our blogs;

• Rest In Peace (RIP) the FFS?

• Rest in Peace (RIP) the Full Flight Simulator - A Requiem

• What the hell is an FSTD Capability Signature?

• EASA NPA 2020-15 - Reinventing The Wheel?

And have significantly participated in the relevant industry rule-making meetings and consultations. In fact, we will be speaking on this subject at the RAeS Flight Simulation group conference in London in October.

Based on this we can offer training courses to prepare you. If you need help drafting ESLs, or updating manuals, or navigating equivalence tables, we are here to help.