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How to obtain an FAA license for holders of ICAO CPL with less than 1500 hours

Posted on: 03/17/2023

Today’s article will be dedicated to foreign pilots with special circumstances who want to obtain a commercial or airline pilot FAA license. So, what categories will we be talking about?
  1. The first case is if you are a foreign pilot with an ICAO CPL license (single, multi, or both – doesn’t matter) and you want to obtain a Frozen ATP (as it is called in Europe) or ATP ME or just CPL.
  2. The second case is foreign second pilots (SIC) who, for some reason, do not have in their ICAO license that they are PIC on any category of aircraft. We often see this in Russian licenses when a pilot has only the record “Co-pilot A320” and nothing else.
  3. The third case is foreign pilots from countries that do not confirm pilot licenses issued by the relevant government agency in response to FAA requests. These countries include Iran, Iraq, Pakistan, Russia (from time to time), China, and some other countries. There are also cases when some pilots are not issued confirmation in the country where the license was issued for some other reasons. Sometimes there are cases when a pilot’s license is validated by another country based on another expired license or one that cannot be confirmed.
  4. The fourth case is expired licenses or licenses with expired check periods.
  5. Pilots with an expired medical certificate and the inability to obtain a new one in the country where the license was issued.
In any of these cases, foreign pilots can still obtain an FAA license, but they will need to go through a special process. The process involves obtaining a verification of their foreign license from their home country’s aviation authority, completing the necessary training and exams in the United States, and obtaining a medical certificate from an FAA-approved physician.

1. If you have a commercial pilot license (CPL) issued in an ICAO country, but you have less than 1500 hours

The first case is if you are a foreign pilot with an ICAO CPL (single or multi or both – doesn’t matter) and you want to obtain Frozen ATP (as it is called in Europe) or just ATP ME or just CPL.
First of all, it is important to remember that there is no concept of Frozen ATPL in the US. That means you can take the ATP-CTP course and even pass the ATP ME written test, but you still won’t be able to take the checkride (exam) until you have accumulated 1500 hours and meet all the other requirements of paragraph 61.159 CFR 14. Purely theoretically, if you have passed the ATP test and are just waiting for the required hours – this can be conditionally called a Frozen ATPL or at least the equivalent of the European Frozen ATPL. But this will not allow you to obtain any license, so you will still remain a foreign commercial pilot, and you will have the result of the written test, which is valid for 60 months.
Now that we’ve covered that, let’s go back to the beginning and consider an example – you are a commercial pilot from some ICAO country, you have an instrument rating, and let’s say you have 500-800 hours of flight time (you can take any number less than 1500 for the example). And you want to obtain an FAA CPL or ATP license. As we said earlier, you won’t be able to get an ATPL until you have accumulated 1500 hours. But you can get an FAA CPL.
Unfortunately, the path will not be the easiest, because there is no direct conversion from ICAO CPL to FAA CPL. You can validate your CPL in the US and only get an FAA PPL Foreign base (without an exam, but with a check by an instructor) based on it. How to do this is detailed in our video by our chief pilot, Andrey Borisevich.

Stage 1: PPL foreign base

So, Stage 1 – is to get your Letter of Verification and then PPL FAA Foreign base (based on your ICAO CPL). Check our video “How to request Verification Letter” here.

Stage 2: Instrument rating

Next, after obtaining your PPL Foreign Base (you can actually start preparing for it immediately), you need to undergo training under the abbreviated program for an Instrument Rating. To do this, you need to receive 15 hours of dual instruction with an FAA instructor, pass the IRA (Instrument Rating Airplane) written test, receive an endorsement from the instructor for the checkride, and actually pass the checkride, which can usually be taken with a DPE (independent Designated Pilot Examiner) or an FAA inspector. Note that 15 hours are the minimum requirements under FAA legislation (Part 61.65), but not all students may be able to prepare in just 15 hours. It is quite possible that you will need more time and more flight hours on the aircraft and/or simulator to get the endorsement from the instructor.
By the time of the checkride, you should already have your FAA PPL Foreign Based license so that you can independently perform PIC functions during the checkride with the examiner.
As a result of passing the exam, you will add an Instrument Rating line to your FAA PPL foreign base.
// You may ask, why can’t you validate your Instrument Rating from a foreign license and simply add it to your FAA PPL foreign base? The answer is that you can, but this will not allow you to move on to the next level – FAA CPL. This will only allow you to perform instrument flights with a PPL level license. These are the rules – to move on to the next level, to an independent FAA CPL, you need to pass an Instrument Rating in the USA, not just validate it.

Stage 3: Commercial License

The next step is to complete the CPL program training. You can choose to do either Single Engine or Multi Engine or both, it’s up to you. In any case, the first CPL rating will take 20 hours with an instructor (part 61.129), a written test, an endorsement from the instructor, and a checkride with an examiner. It’s the same process as the instrument rating. At the end of this stage, you will obtain an independent FAA CPL, which is separate from your initial license, and can be used independently of your ICAO license.

How long does it take?

From the beginning to obtaining the CPL, it can take approximately 3-4 months. Below are the stages with their respective timeframes:

  1. Request for validation letter and waiting for Letter of Verification – 45 – 90 days


  2. Instrument rating – 2 – 4 weeks


  3. Commercial training – 2-4 weeks


If circumstances allow, you can complete both trainings and checkrides in one month while staying in the USA. Alternatively, you can make multiple trips if circumstances don’t permit staying in the USA for a continuous month.

How much does it cost?

The approximate cost of the entire process will be comprised of the following components:
  1. Request for validation letter and Letter of Verification – free
  2. Meeting with an examiner to obtain FAA PPL foreign base (in person or via ZOOM) – $300
  3. TSA application – two at $130 each = $260
  4. FAA Medical – $190
  5. Instrument rating training (minimum of 15 hours) – 15*270 = $4,050
  6. Written test IRA – $175
  7. Checkride IR – $1,000 (examiner fee + rent a plane)
  8. Commercial Pilot Single Engine – 20*$270 = $5,400
  9. Written test CPL – $175
  10. Checkride CPL – $1,000 (examiner fee + rent a plane)
Total: $12,550 (CPL Single)
Total: $15,950 (CPL Multi)
Total: $16,830 (CPL SE and ME)


  • If I have completed the entire process and obtained an FAA CPL, but my original license on which all this was based (ICAO CPL) has expired, been revoked, or lost, will I lose my FAA CPL?
Answer: No! Because your CPL was obtained in America by passing the actual exam, and your instrument rating was also obtained independently through an FAA exam, your FAA CPL is completely independent. Regardless of what happens to your original ICAO license, your FAA CPL is with you forever.
  • How do I maintain my CPL? Do I need to do regular check rides, and how do I do that if I don’t live in the USA?

Answer: Yes, to maintain the currency of this license, you will need to undergo a check ride every 24 calendar months with an FAA instructor. The good news is that the check ride does not have to be done on US soil, and it doesn’t have to be on an N-registered aircraft. It can be done on any aircraft with any registration, but the instructor on board must be an active FAA CFI.

  • Is it possible to go through the entire validation process without coming to the USA?

Answer: YES! We have a unique opportunity to issue you an FAA PPL foreign base remotely, through ZOOM. We have a partner examiner who is authorized to conduct remote verification and issuance of the FAA PPL Foreign base license. To do this, you need to request a Letter of Verification through the IACRA portal (see our video or read our article on the website), and then follow the steps outlined by our team.

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