

For those of us flying in business aviation, it has become clear that rest and flight time limitations and the growing pressure of increasingly demanding rosters, are becoming more and more problematic. Pilots routinely face long duty days, extended rotations, minimal rest, and numerous last-minute changes. Often our schedules are already planned close to the limits of the existing regulations.
Several years ago, EASA made a proposal – known as NPA 2017-17 – which aimed to improve the framework by introducing more protective and harmonised rules across Europe. While far from perfect, it addressed key fatigue-related issues and showed potential for being further developed into a new robust FTL framework. However, that proposal is now off the table and has been replaced by a new one: NPA 2024-106(B).
This latest proposal was tabled last autumn for a ‘focused’ stakeholder consultation, held without any (!) pilot representation. Instead, it was significantly influenced by business aviation operators, resulting in a worrying lack of safety mitigations.
The revised proposal also removes some critical safety mitigations which had been proposed back in 2017, while it heavily prioritises operational flexibility, often at the expense of crew wellbeing and – crucially – aviation safety.
Some of the most unsettling changes include:
Perhaps, most concerning, under the new proposal, pilots could legally operate four sectors with an extended duty of up to 14 hours, with an additional 2 hours under Captain's Discretion?
That means, realistically, business aviation pilots could face 16-hour duties without augmented crew support. And all this in *Business Aviation*, where unforeseen circumstances are not uncommon, so this scenario may quickly become more than just theoretical.
Many business aviation pilots are already flying 600 to 700 hours a year, often with long positioning duties added on top. Unlike scheduled operations, Business Aviation frequently involves even more unpredictable delays, last-minute changes, and operational challenges that significantly affect rest and recovery.
We can only question the rationale behind those changes: is it operational flexibility, is it commercial convenience or is it safety-driven? This is not a call to protest. It's a call to be informed.
Being informed is even more important, because EASA had decided to limit its ‘focused’ consultation to recognised stakeholder organisations only, instead of making it a public consultation. That means that individual Business Aviation pilots did not get the opportunity to study the new rules and to submit comments based on their daily operational experience and safety perspective.
Thankfully, the European Cockpit Association, representing airline and business aviation pilots, has submitted detailed critiques highlighting significant safety shortcomings, procedural flaws, and the troubling reduction of previously proposed safety mitigations – while at the same time offering substantial flexibilities to the operators. It now falls on EASA, as a responsible safety authority, to reassess this proposal urgently.