Simulator Grading Forms: Digital vs Paper for Aviation Training
Simulator grading is the way an instructor or examiner records what they saw in a simulator session and turns it into grades. Neither the EASA nor the FAA texts reviewed here choose between paper and digital forms for it. Both allow electronic records under conditions, so the choice rests on what each format does to in-session note-taking, data quality, instructor comparison and the record trail.
This guide is for heads of training, chief instructors and quality managers at Approved Training Organisations, airline training departments and small companies that sell simulator-based courses. It covers forms completed by people, not automated scoring from simulator flight data. Regulatory facts are as of November 2026. This is not legal or airworthiness advice, and your Competent Authority decides what it accepts.
Key takeaways
- The sources reviewed allow electronic grading records but do not require them, and FAA approval or acceptance of an electronic system, where it applies, is a step to plan, not a feature to buy.
- EASA’s EBT Manual says to observe first, keep notes short and analyze after the session, so a digital form that demands taps while the instructor should be watching can make the data worse.
- Digital forms mainly help with complete entries, one live form version and comparing instructors; paper helps with in-session speed and failing gently; a hybrid is a legitimate design.
- No study comparing paper and digital simulator grading forms turned up, so a side-by-side pilot on your own sessions is better evidence than any brochure.
What do the rules say about paper or electronic grading forms?
The texts reviewed allow both formats. EASA’s AMC1 ORA.GEN.220(b) says records may be kept on paper, electronically or in a combination of both. The FAA’s AC 120-78A accepts electronic records that match paper for integrity, accuracy and accessibility, with FAA approval or acceptance needed for some certificate holders. Neither text names a grading form format.
The table shows what each source says on the paper-or-electronic question and who decides the rest.
| Question | What the sources say | Who decides the rest |
|---|---|---|
| Is electronic allowed? | AMC1 ORA.GEN.220(b): “Records should be kept in paper form or in electronic format or a combination of both.” (quoted) AC 120-78A (June 22, 2016), paragraph 3-1: an electronic record must provide “equivalent or better data integrity, accuracy, and accessibility” (quoted) than a paper one. | Your Competent Authority or FAA office, through your management system or manuals. |
| Must anyone accept the system? | AC 120-78A is not mandatory, but for several certificate holders, including Part 141 and Part 142 training providers, it describes FAA approval or acceptance through OpSpec A025. A draft AC 120-78B is published and changes this for some holders. | Your FAA principal inspector. The EASA AMC text read here is silent on acceptance. |
| What must a grade record hold? | The EBT Manual, version 2.4 (3Q2026) recommends a 1 to 5 grade per competency for evaluation and scenario-based training, and says the operator should allow “not observed”. It is guidance for EBT operators. | The operator’s grading system, as accepted by the authority. Non-EBT courses follow their course approval. |
| Who sees grades, and for how long? | AMC2 and GM2 ORO.FC.231(c) (Issue 2, Amendment 17): access restricted to authorised persons, and an identified retention policy with accountability. No period is stated there. | The operator, with staff representatives agreeing the access policy. |
Two limits apply. The Part-ORA text read here is the initial 2012 issue, so check current amendments. Operators under Part-ORO have their own ORO.GEN.220, which this guide did not retrieve. For retention periods, see the aviation exam records retention and traceability guide.
When does a simulator session need a grade, and when only a note?
In the sequence EASA’s EBT Manual describes, the instructor observes first, records short notes during the session, classifies observations afterward and grades last, after a facilitated debrief. A grading form therefore has two jobs at different times: quick capture while the trainee flies, and structured grading once the instructor can think.
The manual says short hand-written remarks are usually “sufficient and the most effective way to record” (quoted, section 6.1.2). It adds that recording “should not distract the instructor from monitoring the training progress and the trainees” (quoted) and that no detailed analysis should happen during the session. It also warns against using the observable behavior list as a checklist and advises recording behavior above or below the standard, not everything.
That is EBT guidance for operators, but the logic suits any competency-graded course. The CBTA guide to competencies, observable behaviors and grading defines observable behaviors. The consequence is that “digital or paper” is partly a false choice, because capture and grading can use different media.
Pro tip: Test Each Moment Separately. Write down what the instructor uses during the session and what they complete afterward, then trial each on its own. A tool that is excellent for the post-session grade page can still be wrong for the first ten seconds of an abnormal event.
How do digital and paper simulator grading forms compare?
Paper is quick to start and fails gently; digital is better at forcing complete entries, holding one live form version and comparing instructors. The table lists eight criteria and what to verify. Its judgments are reasoned comparisons, not measured results.
| Criterion | Paper | Digital | Verify before deciding |
|---|---|---|---|
| In-session capture | Pen and a note area; no battery or screen light. | Depends on the interface; every tap or menu takes attention from the trainee. | Time an instructor taking notes during a busy scenario. |
| Completeness | Blank fields are possible and found later. | Required fields can block saving, and can also push instructors to guess a grade. | Whether “not observed” is a separate choice from blank. |
| Legibility | Handwriting varies; a reviewer may not be able to read it. | Typed text is readable. | Have a reviewer read a random sample. |
| Form version | Old copies stay in circulation. | One live version; older versions stay tied to old sessions. | Which form version each saved grade used. |
| Comparing instructors | Needs transcription before any analysis. | Analyzable once entered. | Export of competency-level grades by instructor, not only totals. |
| Alteration and audit trail | Strikethroughs, initials and countersignatures are visible on the page. | Needs a locked record, individual log-ins and a change log. | The alteration safeguards in AMC1 ORA.GEN.220(b) and AC 120-78A (see the design rules below). |
| Offline and failure | Works without power or network; can be lost or damaged. | Needs offline mode and sync rules; a device can die mid-session. | What the instructor does when the device fails, and what syncs in which order. |
| Privacy and access | Controlled by who holds the paper; copies are hard to track. | Role-based access, but easy to over-share if left open. | Who can open individual grades, and who can export them. |
The same trade-offs appear on the maintenance side, covered in practical assessment checklists for aviation maintenance tasks. Rank the criteria by what hurts your operation most; a large airline program and a three-instructor school will differ.
Is there evidence that digital grading forms produce better data?
Not for simulators: no study comparing paper and digital simulator grading forms turned up in this research. The nearest evidence is a 2021 systematic review of paper and electronic public health surveys. It found electronic collection often gave good data faster, but the studies were too uneven to combine. Treat it as a hint, not proof.
The review in the Journal of Medical Internet Research included 14 studies, none randomized, from 12 low- and middle-income countries. In one study, 2.2% of fields were missing on paper against 0.7% on electronic forms. The authors wrote that the studies “were not methodologically rigorous enough to combine” (quoted). They also listed implementation problems, among them accidental data loss, power surges and internet problems, which a simulator bay can share. The review says nothing about aircrew or grading.
What should a digital simulator grading form do, and what should it avoid?
A digital form should keep capture light, grade after the session, separate “not observed” from blank, lock signed records with a change log and limit who sees individual grades. It should avoid turning the observable behavior list into a tick-box screen. Each rule below traces to a source or is marked as a design judgment.
- Keep in-session entry to short free text. The EBT Manual favors brief remarks that do not distract the instructor.
- Do not show every observable behavior as a tick box. The manual says the list should link to observed performance, not act as a checklist.
- Offer “not observed” as a grade. The manual says the operator should allow the instructor to grade “not observed” (quoted), and distinguishes it from a competency left blank on purpose.
- Lock the record at sign-off and log every change. AMC1 ORA.GEN.220(b) asks for safeguards against unauthorised alteration, and AC 120-78A asks for individual access codes and auditing.
- Store the form version with each grade. This is a design judgment so old grades stay interpretable when the form changes.
- Restrict individual grades to authorised persons. AMC2 ORO.FC.231(c) asks for an access policy agreed by the parties, and GM2 says it is “preferable to de-identify the data rather than anonymise it” (quoted).
The manual also describes platforms that hold the simulator script, notes, classification and grading page in one place, as an option, not a requirement. If a vendor shows such a flow, check that it does not push the instructor toward a checklist.
Pro tip: Write the Failure Rule Before Go-Live. Decide what an instructor does when the device dies mid-session, who transcribes the paper fallback, and how the paper original is kept and linked to the digital record.
How do you pilot the switch from paper to digital with evidence?
Run both formats side by side on the same sessions for a fixed period, then compare completeness, time to a finished grade, failures and instructor feedback. Set the measures and the gap that would change your decision before you start.
The table lists five measures and how to count each.
| Measure | How to count it | Why it matters |
|---|---|---|
| Blank-field rate | Blank grade fields divided by total grade fields, per format. | Shows whether either format loses data. |
| Time to finished grade | Minutes from session end to a signed grade. | Delay lets memory fade before the grade is set. |
| Grade match | Competency grades that agree when one instructor enters the same session both ways. | Reveals interface effects on the grade itself. |
| Failures | Device, sync or log-in failures, and minutes to recover. | Measures the real cost of going digital. |
| Instructor distraction | A short post-session question: did the form pull your eyes from the trainee? | Checks the in-session requirement directly. |
Here is an illustrative calculation with invented numbers. Suppose 20 sessions are each graded on nine competencies, giving 180 grade fields per format. If paper shows 9 blank fields and digital shows 2, the blank-field rates are 5.0% and 1.1%. Twenty sessions is a small sample, so a gap like this could be chance, which is why you set the decision gap in advance.
What should you do next?
Pick one simulator course and list every field on its paper form. Mark each as captured in the session or completed afterward, and note which are routinely blank. That list becomes your pilot design and your vendor requirements.
Then ask any vendor to demonstrate five things: offline use and what syncs, locked records with a change log, export of competency-level grades by instructor, role-based access, and what happens when a device fails. As of November 2026, SimpliAssess’s published features page lists item banking, test management, analytics and API-first delivery, but does not describe observation forms, grading forms or offline mode. The SimpliTrain pages reviewed name assessments and a certification tracker but do not describe simulator grading forms either.
None of that is a criticism, since these products may serve the knowledge-testing side of your course. It means grading forms need a live demonstration, and a vendor’s page is not a statement that any authority has accepted its system. Ask your Competent Authority or FAA office what it needs to see before you retire paper.
Frequently asked questions
What is simulator grading?
Simulator grading is the recording of an instructor’s or examiner’s observations during a simulator session and the grades derived from them, usually against a competency or task standard. It differs from automated scoring of flight parameters, which this guide does not cover.
Can aviation training organizations use electronic grade sheets instead of paper?
Generally yes, under conditions. EASA’s AMC1 ORA.GEN.220(b) allows records in paper form, electronic format or both. The FAA’s AC 120-78A accepts electronic records that match paper for integrity, accuracy and accessibility, and some certificate holders need FAA approval or acceptance first. Check what your own authority requires before switching.
Do instructors grade during the simulator session or after it?
In the EBT process described in EASA’s EBT Manual, instructors observe and make short notes during the session, classify observations afterward and grade at the end, after a facilitated debrief. Other course types may differ, so check your approved training program.
Is a digital grading form more accurate than paper?
No aviation study found answers that. A 2021 review of electronic and paper public health surveys reported good data from electronic tools in individual studies but called the evidence too uneven to combine. A side-by-side pilot of your own sessions, measuring blank fields and time to a finished grade, gives a better answer for your operation.
What happens if the tablet fails during a simulator session?
The sources reviewed do not prescribe a procedure, so it is your decision. Write a fallback rule in advance: a paper note sheet at hand, a named person who transcribes it, and a way to link the paper original to the digital record.
Who should be able to see individual simulator grades?
Only authorised persons. For EBT data, AMC2 ORO.FC.231(c) says the access and security policy should restrict information to authorised persons, be agreed by the parties involved and align with the organization’s safety policy so data is not used to attribute blame.
