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Legal Interpretations

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Entwistle-Jet-CareInternational 2014

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Summary

The Question

May a pilot holding only a United Kingdom airline transport pilot license operate a U.S. civil aircraft within the United Kingdom, including as a salaried pilot of type-certificated aircraft?

Background

Jet-Care International asked whether a pilot holding a UK airline transport pilot license, but no U.S. pilot certificate, may operate a civil aircraft of the United States within UK airspace, and whether this applies to salaried pilots flying type-certificated aircraft.

The FAA’s Interpretation

Yes. 14 CFR 61.3 permits operating a U.S. civil aircraft within a foreign country with a pilot license issued by that country and places no limitation on that use, so it covers salaried pilots of type-certificated aircraft. However, 14 CFR 61.3 and the 1944 Convention on International Civil Aviation prohibit such a pilot from operating the aircraft outside the United Kingdom.

Requester
Entwistle
Organization
Jet-CareInternational
Issued
March 7, 2014
Subject
Pilot Certification & Privileges

Regulations Cited

  • 14 CFR 61.3

Page 1

U.S. Department
o f TronsportoHon
Federal Aviation
Administration
MAR -7 2014
Martin Entwistle
Jet-Care International
3 Saddle Road
Cedar Knolls, NJ 07927
Dear Mr. Entwistle:
Office of the Chief Counsel 800 Independence Ave., S.W.
Washington, D.C. 20591

This letter responds to the request for a legal interpretation that you emailed to my office on November 4, 2013. You have asked whetfier a pilot who holds an airline transport pilot license issued by the United Kingdom may operate a civil aircraft of the United States within the airspace of the United Kingdom without holding a pilot certificate issued by the United States.

Section 61.3 permits a pilot to operate a civil aircraft of the United States without holding a pilot certificate issued by the United States when the aircraft is operated within·a foreign country and the pilot holds a pilot license issued by that country. You have asked whether this section applies to salaried pilots operating type-certificated aircraft. Section 61.3 does not contain any limitation on the use of a foreign pilot license when operating a civil aircraft of the United States within a foreign country. See Legal Interpretation to Ira Curtis (Jan. 28, 1985). We note that, under the scenario that you have presented, § 61.3 and U.S. obligations under the 1944 Convention on International Civil Aviation prohibit a pilot who holds only a pilot license issued by the United Kingdom from operating a civil aircraft of the United States outside the United Kingdom. See Legal Interpretation to Barry Condell, August 20, 2009.

This response was prepared by Anne Moore, an attorney in the International Law, Legislation, and Regulations Division of the Office of the Chief Counsel. If you have any additional questions regarding this matter, please contact my office at (202) 267-3073.

Mark . Bury

Assistant Chief Counsel fi International Law,

Legislation, and Regulations

Regulations Referenced

14 CFR 61.3

Snapshot retrieved August 6, 2026.

Summary

The Question

May a pilot holding only a United Kingdom airline transport pilot license operate a U.S. civil aircraft within the United Kingdom, including as a salaried pilot of type-certificated aircraft?

Background

Jet-Care International asked whether a pilot holding a UK airline transport pilot license, but no U.S. pilot certificate, may operate a civil aircraft of the United States within UK airspace, and whether this applies to salaried pilots flying type-certificated aircraft.

The FAA’s Interpretation

Yes. 14 CFR 61.3 permits operating a U.S. civil aircraft within a foreign country with a pilot license issued by that country and places no limitation on that use, so it covers salaried pilots of type-certificated aircraft. However, 14 CFR 61.3 and the 1944 Convention on International Civil Aviation prohibit such a pilot from operating the aircraft outside the United Kingdom.

Requester
Entwistle
Organization
Jet-CareInternational
Issued
March 7, 2014
Subject
Pilot Certification & Privileges

Regulations Cited

  • 14 CFR 61.3