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147.A.200 requires that approved basic training courses comply with the syllabus and duration requirements of Appendix I to Part 66, covering theoretical knowledge and practical training for the relevant licence category.
What it means in practice
Basic training courses must follow the module structure defined in Part 66 Appendix I. Each course must cover the theoretical knowledge subjects and practical training elements required for the specific Part 66 licence category (A, B1, or B2). The minimum course duration, including both theory and practical hours, is prescribed by the regulation and must be met. The organisation cannot shorten courses below the required duration.
The course must include both theoretical classroom instruction and hands-on practical training. Practical training must be structured to develop the skills specified for each module and must be assessed. Training records must show that each student has completed all required modules and achieved the required standard.
Key requirements
The course syllabus must align with Part 66 Appendix I for the relevant category. Minimum course durations must be met. Both theoretical and practical elements must be included and assessed. The organisation must maintain detailed records of student attendance, progress, and assessment results for each module.
Regulation (EU) 2023/989 introduced flexibility into the course-duration framework: under 147.A.200(g), training hours may be adapted — with justification and competent authority agreement — to reflect new technologies and changes in the syllabus, and under 147.A.200(h) the duration of a conversion course between licence categories or subcategories is determined through a training needs assessment rather than a fixed table. Compressing courses for commercial reasons without that documented justification remains a finding.
Common compliance gaps
Organisations sometimes compress course schedules to accommodate commercial pressures, resulting in insufficient contact hours for certain modules. Practical training elements are particularly vulnerable to being shortened. Another gap is poor traceability between the syllabus requirements and the actual training delivered, making it difficult to demonstrate during audit that all required topics have been covered to the required depth.
Part 147 Training
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