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New European CPDLC Mandate — and the exemptions

Regulatory Update

February 5, 2020

1

New European CPDLC Mandate — and the exemptions

A new Single European Sky data link requirement took effect Feb 5, 2020, but most corporate operators are exempt under an amendment to Regulation (EC) No 29/2009.

Data Link Mandates

Europe

An airport control tower silhouetted against an orange sunset with a departing aircraft

Beginning 5 February 2020, a new data link requirement goes into effect in the Single European Sky airspace. This new mandate requires aircraft to be equipped with CPDLC ATN-VDL Mode 2 (Aeronautical Telecommunications Network Very High Frequency Data Link Mode 2).

We have received numerous inquiries about this new mandate and its effect on corporate flight departments. The great news is that most corporate operators are recently exempted from this requirement based on an amendment to Regulation (EC) No 29/2009. This amendment creates several exemption categories. The most common exemption for corporate operators is for aircraft certified for 19 passengers or less and under 100K lbs maximum takeoff gross weight.

A link to the document can be found here: EASA SIB 2020-03 Data Link Exemptions and Flight Plans. We recommend operators are familiar with the document and have it readily available in case of a SAFA ramp inspection.

In order to communicate this exemption on the ICAO International Flight Plan, crews should ensure the proper Block 10 and Block 18 codes are used. EASA Safety Information Bulletin No. 2020-03 highlights the appropriate codes regarding CPDLC ATN VDL Mode 2.

If your aircraft IS equipped with the appropriate ATN VDL Mode 2 data link equipment, be sure the "J1" code is entered in Block 10 on the Flight Plan to communicate compliance accurately.

If your aircraft is NOT equipped and you meet the specifications of one of the exemptions, ICAO Doc 10037 requires communication of this exemption in the following manner:

In Block 10: Enter a "Z" to indicate "other capabilities"

In Block 18: Enter "DAT/CPDLCX"

REFERENCED REGULATIONS

FAA AC 91-70B

NAT Doc 007 Ver 2026.1

ICAO Doc 4444 PANS-ATM

ICAO Annex 11

NAT OPS Bulletin 2025-3

AUTHOR

Scott IPC Instructor Team

The Scott IPC instructor team: retired corporate chief pilots, FAA procedures and safety personnel, and former military aviators who teach international procedures.

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