Legal Interpretations
Condell 2009
Summary
The Question
Does 14 CFR 61.3(a)(1)'s allowance for a pilot license "issued by the country" of operation include a license issued under the law of another European Economic Area state?
Background
An individual asked whether, for a U.S.-registered aircraft operated in a foreign country, mutual license-acceptance agreements among European Economic Area states let a license from any such state count as one issued by that country.
The FAA’s Interpretation
No. The FAA does not read "issued by the country" in 14 CFR 61.3(a)(1) to include a license issued under the law of a European Economic Area state. The rule is expressly limited to a pilot certificate issued by the specific country in which the operation takes place.
- Requester
- Condell
- Issued
- August 20, 2009
- Subject
- Pilot Certification & Privileges
Regulations Cited
Page 1
U.S. Department
of Transportation
Federal Aviation
Administration
AUG 2 0 2009
Mr. Barry S. M. Condell
FinbarCondell@BlueYonder.co.uk
Office of the Chief Counsel 800 Independence Ave., S.W .
Washington, D.C. 20591
This responds to your email to Mr. James Whitlow of April 17, 2009, requesting an interpretation of 14 CFR 61.3(a)(1). Section 61.3(a)(l) provides in pertinent part that when a U.S. registered aircraft "is operated within a foreign country, a current pilot license issued by the country in which the aircraft is operated may be used." You ask whether the use of phrase ''issued by the country" is interpreted by the Federal Aviation Administration (FAA) as also meaning "issued under the law of a Contracting State to the European Economic Area" in the situation where various countries have entered into agreements for "the mutual acceptance of personnel licenses for the exercise of functions in civil aviation?" The answer is that the FAA does not interpret the phase "issued by the country" as including "issued under the law of a Contracting State to the European Economic Area." The rule is expressly limited to a pilot certificate issued by the specific country within which the operation will take place.
This response was prepared by Michael E. Chase, Manager of the Air Traffic and Airmen/Airport Certification Law Branch in the Regulations Division of the Office of Chief Counsel, and coordinated with the General Aviation Division of Flight Standards Service. If you have additional questions regarding this matter, please contact us at your convenience at (202) 267-3073.
Sin~ly, ~/£~~!
Rebecca B. 6l'acPherson
Assistant Chief Counsel for Regulations, AGC-200
Regulations Referenced
Snapshot retrieved August 6, 2026.