FAA Part 117 vs EASA ORO.FTL — Which Applies to You?

The short answer

Your operating certificate decides, not your passport. If you fly for a US Part 121 carrier, you operate under FAA Part 117 — even if you're based in Frankfurt and hold a Greek licence. If you fly for an EU operator, you're on EASA ORO.FTL — even if you hold an FAA ATP. The aircraft registration matters less than the air operator certificate.

Pilots flying for non-EU, non-US carriers (Emirates, Qatar, Singapore Airlines, Turkish Airlines) sit on a third system — usually one based loosely on ICAO recommendations, with significant local variations. We'll focus on Part 117 and ORO.FTL here.

Side-by-side at a glance

The two regulations look like fraternal twins. They were both written in the wake of the Colgan 3407 / fatigue research wave around 2010–2014. But on closer reading, they diverge in three areas that matter to working pilots.

1. Cumulative limits

EASA tracks 7, 14 and 28-day cumulative block hours. FAA Part 117 tracks 28-day cumulative flight hours, and rolls in a quarterly limit, but it doesn't enforce a 7-day cap the way EASA does.

Practical effect: a US carrier can roster you with three 6-day-on / 1-day-off cycles and stay legal because the 28-day total works out. A European carrier doing the same pattern will hit the 7-day cap and have to thin the schedule.

This is why European pilots who go to the US often feel the schedule is heavier. The total monthly hours might be similar — but the rest distribution is fundamentally different.

2. Split-duty

EASA explicitly recognises split-duty (ORO.FTL.225) and allows the maximum FDP to be extended by up to 4 hours when an in-duty rest meets the criteria. FAA Part 117 has no equivalent. If you operate a duty with a 4-hour break in the middle in the US, your maximum FDP is the same as if you'd flown straight through.

This is one of the reasons European long-haul ULR operations look different from US ones — the rule supports a different operational pattern.

3. Augmented crew

Both regulations recognise that a 3- or 4-pilot crew can fly longer than a 2-pilot crew because rest is shared. They define rest facility classes — but the classes don't translate directly:

• FAA Class 1 ≈ EASA Class A (separate compartment, lie-flat bed)
• FAA Class 2 ≈ EASA Class B (curtained-off seat, lie-flat or near-flat)
• FAA Class 3 ≈ EASA Class C (cabin seat, recline at least 40°)
• EASA has a Class D for crew rest taken in cabin seats with no recline minimum — FAA does not formally credit this

The maximum FDP additions for each class are similar but not identical. If you fly internationally with augmented crews, the safer practice is to plan to the more restrictive of the two if you cross both jurisdictions in a single rotation.

Where the two rules agree

Don't lose the forest:

• Both define maximum FDP via reporting time and sector count tables.
• Both define the WOCL window 02:00–05:59 (FAA: acclimated time, EASA: base time).
• Both allow commander's discretion as a residual safety valve, with documentation requirements.
• Both require minimum rest after duty (typically 10 to 12 hours, longer if you cross several time zones).
• Both expect the operator to publish a fatigue risk management system (FRMS) on top of the regulation.

The numbers near the centre of the table are practically identical. The differences live in the edge cases — the unusual rosters, the long-haul ULR operations, the cumulative caps that take a month to catch up to you.

Which one applies to you, in 30 seconds

1. Look up your operator's AOC. If issued by the FAA, you're under Part 117. If issued by an EASA member state authority, you're under ORO.FTL. If issued by anyone else, your operator's FTSS will tell you which model it follows.
2. Read the operations manual chapter on flight time limitations. It will reference the regulation and any approved variations.
3. If you fly for two operators (some long-haul augmented crew arrangements, military reservists in civil cockpit) — read both, plan to the stricter, document everything.

Common confusions

"My ATP is FAA, so Part 117 applies." No. Your licence is portable. The regulation is decided by your operator, not your paper.

"I'm flying an N-registered aircraft, so Part 117 applies." Also no. Aircraft registration matters for some things (airworthiness, certain operating rules) but not for FTL. The AOC of the operating company decides.

"The hours in my logbook will count differently under each rule." Block time is block time. Flight time is flight time. The number you write doesn't change. What changes is which buckets it goes into for cumulative limit checks.

Practical lifestyle differences

If you're considering a career move from one to the other, the regulation isn't your top reason — but it's worth knowing what changes:

• FAA → EASA: tighter weekly rest enforcement, more split-duty operations, a longer rest cycle after multi-day rotations
• EASA → FAA: heavier monthly schedules possible, less formal split-duty, more reliance on FAR Part 121 supplementary rules

Where Flight Log fits

The app keeps both engines running and doesn't ask you to choose at install time. When you start a duty period, the app picks up your authority preference (set during onboarding) and applies the matching rule set. Cross-jurisdictional rotations can override the rule for that single duty.

For pilots whose careers genuinely cross both regulators — the niche but growing population of contract pilots, augmented crew on intercontinental positioning, ferry pilots — having one app that respects both ruleboards saves an hour of recalculation per duty.