
Type rating theory exams: what your platform needs
A type rating exam is the written knowledge test a pilot must pass, organised by the Approved Training Organisation (ATO), before being rated on a specific aircraft type. Under EASA Part-FCL, the rule for multi-pilot aircraft sets only a few hard conditions: the exam is written, multiple-choice, at least 100 questions, spread across the main syllabus subjects. As of October 2026, the rule text read for this post leaves the rest to your approved program and your competent authority.
This post is for heads of training, exam officers and quality managers at ATOs that run type rating courses, and for small companies that sell them. It turns the rule text into a list of what an exam platform has to support, and it marks what no software can settle for you. It covers EASA Part-FCL in depth and the FAA only briefly. It is not legal or airworthiness advice.
Every rule below was read from EASA’s Easy Access Rules, the UK CAA or the FAA, and exact wording is marked (quoted). Authorities differ by country and the rules change, so check your competent authority before you configure anything. No source read for this post approves or certifies exam software.
Key takeaways
- EASA’s FCL.725(b) makes the ATO responsible for organising the type rating theory exam, unlike ATPL, CPL and instrument rating exams, where the competent authority selects the questions.
- For multi-pilot aircraft the exam must be written, with at least 100 multiple-choice questions distributed appropriately across the main subjects of the syllabus.
- The rule text read does not state a pass mark, an attempt limit or a retention period, so those are set in your approved training program or by your authority.
- Your platform needs a blueprint check, paper version history, a stored cut score with an approver, and dates that track the 6-month skill test window.
- Whether a “written” exam may be delivered on screen is not settled by the text read, so get your authority’s answer in writing.
What is a type rating exam, and who sets it?
A type rating exam is the theory test inside a type rating course. Under Part-FCL, FCL.725 makes the ATO organise it. The competent authority does not select the questions, as it does for ATPL theory. That puts the question bank, the paper, the exam room and the records with your organization.
FCL.725 has three parts that matter here. Paragraph (a) says “An applicant for a class or type rating shall complete a training course at an ATO.” (quoted) and requires the course to include the mandatory training elements defined in the operational suitability data (OSD) established under Part-21. Paragraph (b) covers the theory exam. Paragraph (c) covers the skill test, set out in Appendix 9 to Part-FCL.
The exam itself is described like this: “The applicant for a class or type rating shall pass a theoretical knowledge examination organised by the ATO to demonstrate the level of theoretical knowledge required for the safe operation of the applicable aircraft class or type.” (quoted) The source is EASA’s Easy Access Rules for Aircrew, Subpart H, in the August 2023 revision. EASA now lists a newer revision that was not read page by page, so check the current text.
How is it different from ATPL theory exams?
ATPL, MPL, CPL and instrument rating theory exams are run by the authority. ARA.FCL.300(b)(1) says “Examinations shall be done in written or computer-based form.” (quoted), and (b)(2) says the competent authority selects the questions from the European Central Question Bank. The same ARA.FCL.300 text does not mention type ratings.
So the ATPL exam setup that many aviation providers know does not transfer. For a type rating exam, the ATO owns the whole chain. Our overview of what regulators expect from online assessment in aviation training places this exam among the others.
What does Part-FCL require of a type rating exam?
FCL.725(b) sets the exam format by aircraft category. Multi-pilot aircraft need a written multiple-choice exam of at least 100 questions. Single-pilot multi-engine aircraft need a written exam whose length depends on complexity. Single-engine aircraft are checked verbally by the examiner during the skill test. The table lists the three main cases.
| Aircraft category | Exam format under FCL.725(b) | Question count in the text | What it means for the platform |
|---|---|---|---|
| Multi-pilot aircraft | Written, multiple-choice, “distributed appropriately across the main subjects of the syllabus” (quoted) | At least 100 | Scored paper with a verifiable count and subject spread |
| Single-pilot multi-engine aircraft | Written, multiple-choice | Depends on the complexity of the aircraft | Your approved program fixes the number |
| Single-engine aircraft | Verbal, by the examiner during the skill test | None stated | No scored paper; at most an examiner’s record |
FCL.725(b) also has formats for single-pilot high performance aeroplanes and sea aeroplanes. They are not covered here, so read the full text if you train on those. Paragraph (d) adds that a pilot who holds a type rating for one form of operation is considered to have met the theory requirement when adding the other form on the same type (paraphrased).
What does the rule text leave open?
The text read leaves open the pass mark, the number of attempts, the time allowed, the source of the questions, the retention period for results and whether “written” includes on-screen delivery. None of these appears in FCL.725(b). The UK CAA’s page on the multi-pilot type rating exam shows the same gap: it gives the 100-question rule and says the pass mark is not stated on the page, pointing readers to its CAP 804. The UK CAA applies UK rules, not EASA’s.
Do not borrow a number from a neighboring rule. EASA’s Flight Examiner Manual for one class rating says the pass mark “should be 75 %” (quoted, module 4.2, version V2021.1). That guidance is for a class rating exam, not a type rating. A pass mark for your type rating exam comes from your approved training program or your authority.
Can an ATO deliver the type rating exam on a computer?
The text read does not say. FCL.725(b)(1) uses the word “written”, while ARA.FCL.300(b)(1) for authority-run exams says “written or computer-based”. The sources read do not confirm on-screen delivery for type rating exams either way. Ask your competent authority and keep its reply.
The difference in wording is the reason to ask rather than assume. An answer that comes from a colleague at another ATO is not evidence for your own approval, because your authority oversees your organization. Put the question in writing: describe the delivery setting, the identity check and the supervision, and ask whether the setup is acceptable for the FCL.725(b) exam.
Pro tip: Ask One Narrow Question. Instead of asking “is online testing allowed?”, send your authority the exact paper layout, the room and supervision setup and the record you will keep, then ask if that setup meets FCL.725(b). A specific question gets a specific answer you can file.
What does your platform need to support a type rating exam?
Your platform needs to prove the paper is built to the blueprint, show which version was sat, hold the cut score with its approver, and track dates against the skill test window. Some duties are software features, and others are procedures that software only records. The table maps each rule point to a requirement. The mapping is this post’s own reading, not an official list.
| Rule point | Requirement for your platform | Feature or procedure |
|---|---|---|
| FCL.725(b): organised by the ATO | Bank, papers and results held by the ATO, with roles so that people who teach cannot edit a live paper | Feature: role-based access |
| FCL.725(a): OSD training elements | Items tagged by aircraft type, variant and syllabus subject, with a change log when your syllabus changes | Feature: tags and item versions |
| FCL.725(b)(1): 100 or more, spread across subjects | Paper assembled from a blueprint, with an automatic count and a subject distribution report | Feature: blueprint-based draw |
| FCL.725(b)(2) and (b)(3): other formats | A scored paper where required, and a simple examiner record where the check is verbal | Feature plus procedure |
| No pass mark in the text | Cut score stored per paper version, with approver and date, taken from your approved program | Feature: stored setting |
| FCL.725(c): skill test window | Course start date, exam date and a computed skill test deadline, with reminders | Feature: dates and alerts |
| FCL.725(d): other form of operation | A recorded decision when a candidate is exempt from the exam because of a prior rating | Procedure, recorded |
| Records for your authority | Per sitting: candidate, paper version, item IDs, answers, times and identity check, kept for the period your authority sets | Feature plus procedure |
Identity checks, supervision and the exam room are procedures that your exposition or program describes. The platform records them but cannot perform them. Our posts on exam security settings and on secure delivery of Part-66 module exams go through the room and settings side, from the maintenance perspective.
How do you build and check a 100-question type rating exam paper?
Start from a blueprint that lists the syllabus subjects and the number of items each contributes, then draw items to that plan and check the count before release. The worked example below is illustrative. The subject names and weights are placeholders, not an official syllabus and not the OSD content for any aircraft type.
| Illustrative subject area | Items per paper | Minimum pool if retakes must not repeat items |
|---|---|---|
| Aircraft general and structure | 10 | 20 |
| Powerplant and APU | 14 | 28 |
| Fuel and hydraulics | 12 | 24 |
| Electrical systems | 12 | 24 |
| Flight controls and landing gear | 14 | 28 |
| Avionics and automation | 14 | 28 |
| Performance and limitations | 12 | 24 |
| Normal, abnormal and emergency procedures | 12 | 24 |
| Total | 100 | 200 |
The third column is arithmetic, not a rule. If your policy bars items from a failed first attempt in the retake, each subject needs at least twice its paper quota, so this blueprint needs 200 items in the live pool. FCL.725(b) sets no attempt policy, so the choice is yours. Our guide to building an item bank covers the fields each item should carry.
Pro tip: Build Spare Items Into the Paper. The text says “at least 100”. If review after a sitting finds one faulty item and you withdraw it from scoring, a 100-question paper drops to 99. Decide before release whether to assemble a few extra scored items, and write down how a withdrawn item is handled. Ask your authority if you are unsure.
How do you track the 6-month skill test window?
FCL.725(c) says the applicant passes the skill test within 6 months after the training course starts, and within 6 months before applying for the rating. Your platform should hold the course start date and compute the deadline.
The rule text is “within a period of 6 months after commencement of the class or type rating training course” (quoted, from the original 2011 text of Regulation (EU) No 1178/2011; the Easy Access Rules text read says the same in other words). A calendar-month reading gives a simple example. A course starts on 2 March 2026, so the skill test must be passed by 2 September 2026. If the theory exam is passed on 20 March, the record should still show 2 September as the deadline.
That is one reading. Your authority may count the days differently, and a break in training or a retake changes the plan, so store the rule version you used and let a person approve exceptions. Because the window is a hard date, set reminders at intervals your team will actually act on, such as at 3 months and 1 month before the deadline.
How does the FAA handle type rating theory?
The FAA rule read sets no separate written type rating exam like FCL.725(b). Under 14 CFR 61.63(d), an additional aircraft type rating requires a practical test at the airline transport pilot certification level and an instructor’s endorsement. The same paragraph lists conditions in which no additional knowledge test is needed (paraphrased from the text on the Legal Information Institute site).
On this reading, knowledge is assessed inside the practical test. The FAA’s Airline Transport Pilot and Type Rating for Airplane Category ACS, code FAA-S-ACS-11A, April 2024 and effective May 31, 2024, lists each task with knowledge, risk management and skill elements. A US training provider may still run its own knowledge checks as part of an approved program, but the sources read do not require a scored theory paper.
If you serve both systems, keep two item tag sets: syllabus subjects for EASA courses and ACS task elements for FAA preparation. Keep each aircraft type’s content separate, because a shared item is only safe if both syllabi cover it.
What should you do next?
Write down your own answers to the open points: pass mark, attempts, time, retention and delivery mode. Then take that list to your competent authority together with your proposed exam setup, and keep the reply with the exam procedure. Build the blueprint and the retake pool before you configure any software.
When you compare platforms, ask each vendor to show four things on your own sample paper: the blueprint count check, the version history of a paper, the stored cut score with its approver, and date alerts for the skill test window. SimpliAssess’s features page lists item banking, tag management, test management, examinee management, scheduling, and analytics and reporting, but it does not describe aviation use, question types or security controls, so ask for those directly. SimpliTrain’s question bank page describes draw rules by topic and difficulty, multi-tag filtering, QTI import and export and version control for questions in published exams. It does not describe type rating exams, so make the same four requests there.
Frequently asked questions
Is the type rating theory exam written?
For multi-pilot aircraft, yes. FCL.725(b)(1) says it shall be written, multiple-choice and at least 100 questions, distributed appropriately across the main subjects of the syllabus. Single-pilot multi-engine aircraft also use a written exam. For single-engine aircraft, the examiner checks theory verbally during the skill test. Check your competent authority for your category.
Who sets the type rating exam questions?
The ATO organises the exam under FCL.725(b). The text read does not have the competent authority select the questions for type ratings, whereas ARA.FCL.300 does for ATPL, MPL, CPL and instrument rating exams. In practice, your own bank and syllabus, built to your approved training program, supply the questions.
What is the pass mark for a type rating exam?
The FCL.725(b) text read does not state one, and the UK CAA page on the multi-pilot exam says the same and points to CAP 804. Do not assume 75 percent. That figure appears in EASA examiner guidance for a class rating exam. Take the pass mark from your approved training program or ask your authority.
Can the type rating exam be taken on a computer?
The sources read do not say. FCL.725(b)(1) says “written”, and ARA.FCL.300(b)(1) says “written or computer-based” for authority-run exams. Ask your competent authority whether your on-screen setup, with its identity and supervision arrangements, is acceptable, and keep the answer in writing with your exam procedure.
Do I need the theory exam again to add single-pilot or multi-pilot privileges?
Under FCL.725(d), a pilot who already holds a type rating on the aircraft type, with privileges for either single-pilot or multi-pilot operation, is considered to have fulfilled the theoretical requirements when adding the other form of operation on the same type (paraphrased). Record that decision in the candidate’s file.
Does the FAA require a written exam for a type rating?
14 CFR 61.63(d) requires a practical test at the airline transport pilot certification level for an additional type rating, and says no additional knowledge test is needed where its conditions apply. The FAA’s ACS for airline transport pilot and type rating tasks lists knowledge elements assessed in that test. Confirm your situation with your FAA contact.


