Flight Simulator Qualification... or is it Certification? Approval? Evaluation?
- Daniel de Vries
- 2 days ago
- 12 min read
If you're just here for a run-down of where these terms apply in relation to flight simulators, jump to the bottom section that lists our their uses and meanings. Otherwise, read on!
When it comes to achieving and maintaining an approval for your flight simulation training device (FSTD), be it a full-flight sim (FFS), a fixed-based flight training device (FTD), a Flight & Navigation Procedures Trainer (FNPT) - or any other flavour of training device - there can be some confusion in the terminology used to identify such an approval from a National Aviation Authority (NAA) or Civil Aviation Authority (CAA) - the terms are often used interchangeably.
Approvals can be granted from any number of authorities globally, and here is a small sample of national airworthiness authorities from around the world:
When it comes to the standards that regulators use to manage the fidelity and training effectiveness of simulators, there are really only three (3) major organisations that set the standards:
International Civil Aviation Organisation (ICAO)
Federal Aviation Administration (FAA)
European Union Aviation Safety Agency (EASA)
Whilst the approvals are granted by a body that is not necessarily one of the 'big three' above, they will almost certainly be using a standard that was developed by, derived from, or managed by one of these major aviation organisations.
So, why is this?
Well, first let's start with who each of these bodies are, and their history in the domain:
FAA Standards
The United States Federal Aviation Administration (FAA) originally established the National Simulator Evaluation Program in June of 1980, which was later retitled to become the National Simulator Program (NSP) that we know today. The purpose of establishing the program was to evaluate simulators for use in approved training programs.
The Genesis of Part 60 - A Response to Evolving Needs
The FAA's Part 60 (full designation is 14 CFR Part 60) is one of the flight simulation industry's go-to standard for the management of simulator fidelity and subsequent training device efficacy.
But before we get into that, let's rewind a bit. Before the Part 60, the field of flight simulation in the United States was a bit less structured. As the technology advanced, and simulators became increasingly sophisticated, the FAA recognized the need for standardised evaluation and qualification. It wasn't enough to have a bouncing box that looked like a cockpit; there was a growing need to ensure that these devices accurately replicated the flight experience via a number of specific requirements.
The initial release of Part 60 was, understandably, focused on establishing baseline standards. They defined key performance metrics and testing procedures to ensure that simulators met minimum requirements. They also specifically required sponsors to operate an approved quality assurance program under an approved quality management system. However, as technology continued to evolve, and as such, so did the regulations. In 2008 'Change 1' to the Part 60 was introduced to update appendices A through F.
Over time, Part 60 has been refined and expanded to address new challenges and advancements. From the refining of requirements at specific levels of simulation fidelity to the incorporation of changes to reflect simulation technology developments, the regulations have adapted to keep pace with the industry. In 2016, 'Change 2' of the Part 60 was implemented to update advancements in flight simulation technology and training practices, alongside stricter requirements for visual systems, and more rigorous performance standards, particularly in areas like handling characteristics and system reliability.
This evolution help both keeping up with technology, and ensuring that flight simulation remains a valuable tool for pilot training and safety. By continually refining Part 60, the FAA has helped to build a foundation for a robust and reliable simulation industry.
A Bit of Part 60 History...
From Economic Driver to Regulatory Necessity
Early development of flight simulation was primarily driven by economic factors, not regulation. Devices like the Antoinette Learning Barrel (1909) and the Link Trainer (1927) were designed to develop piloting skills and reduce the expensive time spent training in actual aircraft. Read more on the early history of flight simulators here.
In the beginning, there were virtually no simulator regulations or standards, meaning manufacturers developed devices based on what they believed was appropriate for airline training needs, resulting in dissimilar simulators. Without approved credits for using simulators in training, acquiring them was a hard sell, even though they lowered the overall cost of flight training by letting aircraft assets remain operational.
The influence of regulation began to shift in the mid-1970s.
Around 1975, the FAA established what would later be called the Sim Team. This team designated personnel to evaluate simulators used by airlines, leading to an approval that allowed training to occur in the device.
In 1977, the FAA began a major effort with aircraft manufacturers (like Boeing and Lockheed) to develop tests that ensured simulators faithfully represented the aircraft with high fidelity. This resulted in the FAA authorising simulators to be used for recurrent pilot training, which previously had required the actual aircraft. This process introduced the use of flight test data (known as reference data) as a crucial ingredient when substituting simulation time for actual flight time.
By 1980, the FAA developed the Advanced Simulation Plan, which introduced the idea that motion-enhanced simulation could be substituted for aircraft time, leading to the certification of Phase 3 simulators (equivalent to today's Level C/D) for initial training on large transport category aircraft requiring a type rating.
The Creation and Consolidation of Part 60
The effort to create the current FAA regulations, the Part 60, began in 1997. The rule was designed to consolidate all simulation regulation and guidance into a single place.
The final rule establishing Part 60 was published on October 30, 2006. This new rule consolidated and updated FSTD requirements previously scattered across different parts of the FAA's regulations and advisory circulars.
Part 60 governs the initial and continuing qualification and use of all aircraft FSTDs used to meet training, evaluation, or flight experience requirements for flight crew-member certification or qualification. It applies to both simulator manufacturers and to training centres and flight schools that use them.
The regulations defined different levels for FSTDs:
Full Flight Simulators (FFS) are classified as Level A through Level D.
Flight Training Devices (FTDs) are classified as Level 4 through Level 7.
Key aspects of the new regulation include the definition of Qualification Performance Standards (QPS), which are published in appendices to Part 60. These standards outline the objective and subjective tests required for qualification at various levels.
Implementation Challenges and Modern Application
The implementation of Part 60 faced delays shortly after publication, driven by the desire for international consistency:
The rule establishing Part 60 was originally scheduled to be effective on October 30, 2007.
However, the FAA initiated subsequent rule-making to achieve greater harmonisation with international flight simulation standards. This necessitated a delay.
The effective date for Part 60 and related amendments was thus postponed to May 30, 2008.
Consequently, the compliance date for Part 60 was also pushed back from October 30, 2009, to May 30, 2010.
For FSTDs already qualified prior to the effective date (May 30, 2008), they were generally "grandfathered" and allowed to retain the standards under which they were originally evaluated. However, all sponsors of previously qualified FSTDs had to obtain a Statement of Qualification (SOQ) by May 30, 2014, to remain qualified.
In the years following its implementation, Part 60 has been central to incorporating new safety requirements into pilot training, such as Upset Prevention and Recovery Training (UPRT). To meet new policy changes that began taking effect in 2014 (with final compliance required by March 12, 2019), Part 60 needed revision to address FFS fidelity and the capabilities of the instructor operating station (IOS).
The ongoing rule-making process aims to establish Part 60 standards covering areas like:
FFS fidelity criteria.
Evaluating how an FFS simulates full aerodynamic stalls.
FFS requirements specifically for UPRT.
Part 60 is administered under the National Simulator Program Office (NSPM) (AFS-205). It includes detailed requirements for:
FSTD sponsorship and eligibility.
Mandating a Quality Management System (QMS) for continuing surveillance and analysis of performance, required for sponsors after May 30, 2010.
Objective data requirements, specifying that validation data packages must include aircraft manufacturer's flight test data and relevant data developed thereafter.
Part 60 essentially transformed simulation in the United States from a helpful aid used primarily for economic efficiency into a highly regulated and indispensable component of required training and certification, ensuring the realism and fidelity necessary for modern aviation safety standards.
EASA Standards
The European Unions Aviation Safety Agency (EASA) officially commenced operations and assumed aviation regulatory responsibility from the Joint Aviation Authorities (JAA) on September 28, 2003 for all European Member States.
The Role of the JAA and the Introduction of JAR-FSTD
The Joint Aviation Authorities (JAA) was an associated body of the European Civil Aviation Conference (ECAC) established in 1970 (originally as Joint Airworthiness Authorities). The JAA represented the civil aviation regulatory authorities of various European States who cooperated to develop and implement common safety standards and procedures.
Crucially, the JAA was not a regulatory body; regulation was achieved through the member authorities (National Aviation Authorities or NAAs) applying the harmonised codes, known as Joint Aviation Requirements (JARs), without having the force of law at the source.
Regarding FSTDs
The JAA’s work was extended after 1987 to include areas like licensing, flight operations, maintenance, and certification/design standards for all classes of aircraft.
The initial issue of JAR-FSTD A (Aeroplane Flight Simulation Training Devices) was published in May 2008, effective August 1, 2008.
JAR-FSTD A was an amalgamation of previous standards (JAR-STD 1A, 2A, 3A, and 4A) aimed at harmonising the regulatory processes for qualifying different types of devices (FFS, FTD, FNPT, BITD).
The Transition to EASA
EASA was established in Brussels in 2002 via “Basic Regulation” (EC) 1592/2002, and became fully operational a year later. This transformed the European aviation safety system from the loose cooperation of the JAA into a unified EU body with a strong
mandate to propose rules and issue certificates.
The main functional difference is that EASA is a regulatory authority that uses NAAs to implement its regulations, whereas the JAA relied on NAAs to apply harmonised codes.
EASA legally assumed regulatory responsibility from the JAA for European Member States effective September 28, 2003.
EASA has absorbed most of the functions of the JAA in its member states, taking over all certification and standardisation roles.
The JAA entered a transition phase (JAA T) starting January 1, 2007, and its Liaison Office closed on June 30, 2009, although the training organisation (JAA TO) remains.
In seeking to devise a common code, EASA adopted the work of the JAA.
FSTD Qualification under EASA (CS-FSTD)
The technical requirements for FSTD qualification were transitioned from JAR-FSTD into EASA's Certification Specifications (CS-FSTD). EASA issues CS as the standard means to show compliance with the Essential Requirements for FSTDs.
Aeroplanes - The current version is CS-FSTD(A) Issue 2, published in July 2020.
Helicopters - The initial issue of CS-FSTD(H) was dated June 26, 2012.
The EASA regulatory framework introduced two distinct sets of requirements for FSTDs:
Technical Specifications (CS-FSTD): These documents define the technical ability, performance, and documentation standards for FSTDs.
Organisation Requirements (ORA.FSTD): These detail the requirements for organisations operating FSTDs (FSTD operators), such as the need for a management system, configuration control, and maintaining the device's qualification level.
The FSTD Evaluation Process
The evaluation for an FSTD qualification (which is the level of technical ability of the device) involves subjecting the FSTD to both validation tests and functions and subjective tests.
Qualification Basis - Initial evaluation is based on the applicable CS-FSTD version effective on the date of application. This basis remains applicable for future recurrent qualifications, unless the device is upgraded or recategorised.
Documentation - The results are compiled in the Qualification Test Guide (QTG), which, upon approval by the Competent Authority, becomes the Master QTG (MQTG). The MQTG serves as the reference for subsequent recurrent evaluations.
Data Requirements - For initial qualification of FFSs and FTDs, aeroplane manufacturers’ validation flight test data are preferred. However, for FNPTs and BITDs, generic data packages can be used, assessed for correct trend and magnitude (CT&M). For new aircraft programs, preliminary data may be used for interim qualification, with re-evaluation required upon release of final manufacturer data.
Grandfathering - The system recognises "grandfather rights," allowing an FSTD operator to retain the qualification level granted under a previous JAA Member State regulation, and allowing the FSTD user to retain associated training credits.
Future Evolution and Modern Concepts (CS-FSTD Issue 3)
EASA is continuously developing these standards, evidenced by ongoing revisions and new concepts:
Consolidation: The upcoming CS-FSTD(A) Issue 3 is planned to amalgamate the separate Aeroplane and Helicopter specifications (CS-FSTD(A) and CS-FSTD(H)). This release is currently planned for December 2025.
FSTD Capability Signature (FCS): Issue 3 will introduce the FCS concept. All new devices qualified after the Issue 3 date (December 2025) will need the new system based on the FCS. Legacy devices can voluntarily apply for an Assigned FCS. The Equipment Specifications List (ESL), detailing the device's capability, will be listed on the new FSTD certificates.
Oversight Shift: EASA is transitioning from a resource-intensive, device-centric oversight (where NAAs annually re-qualify each device) to an organization-centric system. NAAs will continue to perform initial device qualification, but certified organizations will conduct internal evaluations for continuous compliance, allowing NAAs to focus on management system audits and device sampling.
Addressing New Technology: EASA's mandate has expanded to include drones and Urban Air Mobility (UAM), necessitating new rules for devices like eVTOLs, although the planned Issue 3 may be applied if applicable. EASA has also introduced guidance for complex training domains like Upset Prevention and Recovery Training (UPRT), which requires evaluation of the motion system response and aerodynamic modelling beyond the validation envelope.
A Simple Analogy
To better understand the terminology used, it's useful to think of them within an analogy. We can think of the development and operation of an FSTD like launching a new type of product in a regulated market:
Evaluation
The detailed, scientific testing and inspection process performed by the regulatory body on the prototype (the FSTD).
Qualification
The resulting label or rating (Level D, FNPT II, etc.) applied to the product, confirming its technical capabilities and adherence to safety standards.
Certification
Represents the legal standards (EASA CS-FSTD(A)/FAA Part 60) that govern the product category, as well as the professional licenses (pilot certificates) the product helps users achieve.
Approval
The final permission granted to the training provider to actively use that specific, qualified simulator for defined training tasks and credits within their official curriculum.
The Brass Tacks
For a simple guide on these terms in relation to flight simulators, have a look at the expandable references below to gain a clear understanding of their use:
Approved / Approval - Approval generally refers to the regulatory permission or acceptance granted for a specific item, such as data, a training organisation, or the use of an FSTD for credit within a training program.
Approved Data
Data collected using good engineering practices and formally accepted for use by the relevant Civil Aviation Authority (CAA).
Approved Training Organisation (ATO)
A flight crew training organisation formally recognized by a CAA (such as EASA or FAA) to deliver training. EASA's specifications apply to approved training organisations operating FSTDs.
Approved Use (FSTD Approval)
This is the declaration of the extent to which an FSTD (which has already achieved technical qualification) may be used by an operator or training organisation for training, testing, or checking tasks, as agreed by the CAA. For FAA regulations, an FFS user must obtain approval from the appropriate Training Program Approval Authority (TPAA) to use any FFS/FTD in an FAA-approved flight training program.
Approved Training Credits
FSTDs that are not considered in FAA/EASA standards do not deliver any approved training credits. Similarly, the regulatory authority approves what training tasks can be carried out based on the FSTD's qualification.
User Approval (EASA)
Prior to conducting any test, an examiner must ensure that the simulator is qualified and has a valid user approval.
Certified / Certification - In relation to FSTDs and pilot training, "certification" most often refers to the overarching regulatory standards documents, the process of licensing pilots, or the technical verification (certification) of the aircraft model itself. Specifically, flight simulators are not certified.
Certification Specification (CS)
EASA sets the technical and regulatory standards for FSTDs through its Certification Specifications (CS), such as CS-FSTD(H) for helicopters and CS-FSTD(A) for aeroplanes.
Aircraft Certification Process
The development and release of aircraft manufacturer data, including engineering simulations, are often linked to the aircraft design, development, and certification process (Type Certification, Part-21).
Pilot/Airman Certification
The FAA governs FSTD use for meeting training, evaluation, or flight experience requirements for flight crew-member certification or qualification
Qualified / Qualification - Qualification is the essential technical status or competence level of the FSTD itself, achieved after rigorous testing and evaluation by the competent authority.
FSTD Qualification
The level of technical ability of a Flight Simulation Training Device (FSTD) as defined in the compliance document. To be recognized, an FSTD must be formally qualified by the National Aviation Authority (NAA).
Levels of Qualification
FSTDs are categorised into distinct levels (e.g., FFS Levels A, B, C, D; FTD Levels 1, 2, 3 [EASA]; FTD Levels 4–7 [FAA]). The training credits allowed are dependent upon the FSTD type and its qualification level.
Achieving Qualification
Qualification is achieved by comparing the FSTD performance against the criteria specified in the Qualification Test Guide (QTG) for the qualification level sought.
Maintenance of Qualification
Both EASA and the FAA prescribe rules governing the initial and continuing qualification of FSTDs. The FSTD qualification remains valid subject to recurrent evaluations.
Statement of Qualification (SOQ)
An FAA document identifying the qualification level, configuration, and limitations to authorisations for use of a specific FFS.
Upgrade/Recategorisation
An upgrade is the improvement of an FSTD to achieve a higher qualification.
Evaluated / Evaluation - Evaluation is the process or activity carried out by the regulatory authority (CAA/EASA/FAA) to determine if the FSTD meets the standards necessary for qualification.
FSTD Evaluation
A detailed appraisal of an FSTD by the competent authority (NAA/CAA) to ascertain whether or not the standard required for a specified qualification level is met.
Process
The FSTD must be subjected to validation tests and functions and subjective tests during the evaluation. Any FSTD submitted for initial evaluation shall be evaluated against the applicable criteria for the qualification levels applied for.
Role of QTG
The Qualification Test Guide (QTG) contains the data needed for efficient review and evaluation before the FSTD can gain a qualification level. The evaluation serves to validate the FSTD test results given in the QTG.
Types of Evaluation
This includes initial evaluation (for initial qualification), upgrade evaluation, recurrent evaluation (for continuing qualification), and special evaluation (e.g., following a change in location or category or major modification).
Subjective Assessment
During evaluation, pilot acceptance is an important consideration, and the FSTD is subjected to subjective testing, often conducted by a suitably qualified evaluator/pilot.
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