AC 120-127

U .S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Enhanced Qualification Program Date: 7/31/26 AC No: 120-127 Initiated by: AFS-200 Change:

This advisory circular (AC) provides guidance and recommended practices to certificate holders (CH) operating under Title 14 of the Code of Federal Regulations (14 CFR) parts 121, 141, and 142 on the development and implementation of procedures and training for an Enhanced Qualification Program (EQP).

Note: This is a guidance document. Its content is not legally binding in its own right and will not be relied upon by the Department as a separate basis for enforcement action or other administrative penalty. Conformity with the guidance document is voluntary only. This document is intended only to provide clarity on how operators can voluntarily develop and implement an EQP.

Hugh Thom as Executive Director, Flight Standards Service

ii

CONTENTS Paragraph Page

Chapter 1. General1-1

1.1 Purpose of This Advisory Circular (AC)1-1

1.2 Audience1-1

1.3 Where You Can Find This AC1-1

1.4

Related Regulations1-1

1.5

Background1-1

1.6

What to Consider When Reading This AC1-1

1.7

Terms and Definitions1-1

1.8

AC Feedback Form1-2

C

hapter 2. Definitions2-1

2.1

Eligible Pilot2-1

2.2

Qualified Air Carrier2-1

2.3

Qualified Evaluator2-1

2.4

Qualified Instructor2-1

C

hapter 3. Enhanced Qualification Program (EQP)3-1

3.1

General3-1

3.2

Curriculum3-1

3.3

Title 14 CFR Part 141 or 142 Contract3-1

C

hapter 4. EQP Requirements4-1

4.1

Prerequisites4-1

4.2

Instructors and Evaluators4-1

4.3

Subject Matter Expert (SME) Instructors4-1

4.4

Written Testing4-1

C

hapter 5. Application, Certification, and Inspection5-1

5.1 Applic

ation and Certification5-1

5.2

Certification5-1

5.3

Regular Inspection5-2

iii

Chapter 6. Data Analysis Requirements6-1

6.1 S

ystem for Data Analysis6-1

6.2 C

alibration6-1

6.3 R

eferences6-1

Cha

pter 7. Title 14 CFR Parts 141 and 142 Contracting Rules7-1

7.1 C ontracting With 14 CFR Part 141 Pilot Schools or Part 142

Training Centers7-1

Cha

pter 8. EQP Curriculum Requirements8-1

8.1 G

raduation Certificates8-1

8.2 P

hase I: Pilot Assessment8-1

8.3 P

hase II: Review/Introduction to Air Carrier Concepts8-3

8.4 P

hase III: Non-Air-Carrier-Specific Academic/Practical Training8-3

8.5 P

hase IV: Aircraft-Specific Training8-4

8.6 P

hase V: Air-Carrier-Specific Training8-4

Cha

pter 9. Transferability9-1

9.1 C

redit Transfer9-1

9.2 L

imitations9-1

Tab

le 9-1. EQP Credit Transferability9-2

Appendi

x A. S ample EQP LetterA-1

1-1 CHAPTER 1. GENERAL

1.1 Purpose of This Advisory Circular (AC). This AC provides guidance and recommended practices to certificate holders (CH) operating under Title 14 of the Code of Federal Regulations (14 CFR) parts 121, 141, and 142 on the development and implementation of procedures and training for an Enhanced Qualification Program (EQP).

Note: Conformity with the guidance document is voluntary. This document is intended to provide clarity on how operators can voluntarily develop and implement an EQP. The content in this AC is based on the mandated framework for an EQP provided by Section 372 of the Federal Aviation Administration (FAA) Reauthorization Act of 2024 and the recommendations from the Air Carrier Training Aviation Rulemaking Committee (ACT ARC).1 A qualified 14 CFR part 121 air carrier may voluntarily seek FAA certification for an EQP.

FAA certification of an EQP conveys no additional regulatory benefits or privileges beyond those available to all 14 CFR part 121 air carriers.

1.2 Audience. This AC is applicable to 14 CFR parts 121, 141, and 142 CHs.

1.3 Where You Can Find This AC. You can find this AC on the FAA’s website at https://www.faa.gov/regulations_policies/advisory_circulars and the Dynamic Regulatory System (DRS) at https://drs.faa.gov.

1.4 Related Regulations. Title 14 CFR parts 121, 141, and 142. Each of the regulatory references contained in this AC can be found at https://www.ecfr.gov.

1.5 Background. On May 16, 2024, Congress passed the FAA Reauthorization Act of 2024 (Public Law (PL) 118-63). Section 372 states the Administrator must establish the requirements for a program to be known as the “Enhanced Qualification Program” under which qualified 14 CFR part 121 air carriers are certified by the Administrator to provide enhanced training for eligible pilots seeking to obtain Restricted Airline Transport Pilot (R-ATP) Certificates, either directly by the air carrier or by a certified 14 CFR part 141 or 142 training institution that is under contract with the qualified 14 CFR part 121 air carrier.

1.6 What to Consider When Reading This AC. Title 14 CFR part 121 air carriers may choose to adopt the recommendations in this AC to implement policies, procedures, and training to support an effective EQP.

1.7 Terms and Definitions. Definitions and terms are provided in Chapter 2.

1 Refer to Recommendation 16-8, Enhanced Qualification Program, available at https://www.faa.gov/about/office_o rg/headquarters_offices/avs/offices/afx/afs/afs200/afs280/act_arc/act_arc_reco.

1-2

1.8 AC Feedback Form. For your convenience, the AC Feedback Form is the last page of this AC. Note any deficiencies found, clarifications needed, or suggested improvements regarding the contents of this AC on the Feedback Form.

2-1 CHAPTER 2. DEFINITIONS

2.1 Eligible Pilot. The term “eligible pilot” means a pilot who:

1. Has a current Commercial Pilot Certificate under 14 CFR § 61.123, with airplane category multiengine and instrument ratings under 14 CFR § 61.129; and

2. Meets the pilot assessment requirements as defined in this document for an EQP; and

3. Has completed at least one of the following:

• Has graduated from a U.S. Armed Forces undergraduate pilot training school; or

• Obtained a degree with an aviation major from an institution of higher education (as defined in 14 CFR § 61.1) that has been issued a Letter of Authorization (LOA) by the Administrator under 14 CFR § 61.169; or

• Completed flight and ground training for a Commercial Pilot Certificate in the airplane category and an airplane instrument rating at a certified training institution under 14 CFR part 141.

2.2 Qualified Air Carrier. The term “qualified air carrier” means an air carrier that has been issued a 14 CFR part 119 operating certificate for conducting operations under 14 CFR part 121.

2.3 Qualified Evaluator. The term “qualified evaluator” means an individual who meets the requirements for a training center evaluator under 14 CFR § 142.55 or for a check pilot under 14 CFR § 121.411.

2.4 Qualified Instructor. The term “qualified instructor” means an individual who:

• Is qualified in accordance with the minimum training requirements for an Airline Transport Pilot (ATP) Certification Training Program (CTP) (14 CFR § 121.410(b)(1) through (3));

• If the instructor is a flight instructor, is qualified in accordance with 14 CFR § 121.410(b)(4);

• If the instructor is administering type rating practical tests, is qualified as an appropriate examiner for such rating;

• Received training in Threat and Error Management (TEM), facilitation, and risk mitigation determined appropriate by the Administrator; and

• Meets any other requirement determined appropriate by the Administrator.

3-1 CHAPTER 3. ENHANCED QUALIFICATION PROGRAM (EQP)

3.1 General. An EQP is designed to provide enhanced training for pilots seeking an R-ATP Certificate.

3.1.1 Elements. An EQP includes substantial prerequisites, a rigorous pilot assessment process, and intensive integrated academic and flight training. An EQP is designed to accelerate the development of the knowledge and skills necessary for effective performance in an air carrier line operations environment.

3.1.2 Completion and Limitations. Once an eligible pilot completes an EQP, the pilot should then complete all parts of a 14 CFR part 121 air carrier’s approved initial pilot qualification training program. The initial pilot qualification training may not be reduced or credited for eligible pilots based on completing an EQP, even where training tasks are identical.

3.1.3 Regulatory Variance. Air carriers training under 14 CFR part 121 subpart Y may find additional benefits associated with an EQP. For example, an air carrier could request a regulatory variance from certification and rating criteria in 14 CFR part 61, 63, or 65 under the provisions of 14 CFR §§ 121.903 and 121.919 (including a request for alternatives to the aeronautical experience requirements in 14 CFR § 61.159), based on elements of a certified EQP. A variance would be requested under current regulations and process for an Advanced Qualification Program (AQP) under 14 CFR part 121 subpart Y, and would not be specific to, or dependent on, a certified EQP. A certified EQP alone would not provide the basis for regulatory variance.

Note: For further guidance regarding regulatory variances and the provisions of 14 CFR § 121.903(b), refer to AC 120-54, Advanced Qualification Program.

3.2 Curriculum. An EQP curriculum consists of five phases of training as described in Chapter 8, EQP Curriculum Requirements. To adhere to the curriculum requirements identified in PL 118-63, Section 372, all five phases must be completed in sequential order, and each phase must be fully completed before the eligible pilot enters the subsequent phase of the program. In addition, the FAA requires that all training and testing be performed by only qualified instructors and all evaluations be performed by only qualified evaluators as described in Chapter 4, EQP Requirements.

Note: Phases IV and V may be combined to use air-carrier-specific procedures and callouts for Phase IV aircraft-specific training.

3.3 Title 14 CFR Part 141 or 142 Contract. Air carriers are authorized to contract with 14 CFR part 141 pilot schools or part 142 training centers for the implementation of an EQP as described in Chapter 7, Title 14 CFR Parts 141 and 142 Contracting Rules.

4-1 CHAPTER 4. EQP REQUIREMENTS

4.1 Prerequisites. Only qualified air carriers may request and receive certification for an EQP. An EQP curriculum may be taught either directly by the qualified 14 CFR part 121 air carrier or by a training institution certificated under 14 CFR part 141 or 142 that is under contract with the qualified air carrier. A certified EQP may only be administered to eligible pilots who meet the definition of “eligible pilot” as defined in Chapter 2.

4.2 Instructors and Evaluators.

4.2.1 Instructors and evaluators under the program must meet all qualification requirements, as defined in Chapter 2. All training and testing under a certified EQP must be performed by qualified instructors and evaluators, respectively. Evaluators administering type rating practical tests must be appropriately qualified and approved by the Administrator.

4.2.2 Instructors and evaluators must be trained and qualified in leadership and professional development, Crew Resource Management (CRM), pilot monitoring (PM), decision making, Safety Management Systems (SMS), facilitation, TEM, risk mitigation, and reliable data collection; and must be specifically trained and qualified to instruct in an EQP phase in which the instructor is authorized to instruct.

4.3 Subject Matter Expert (SME) Instructors. The FAA recognizes the EQP contains academic subjects where a SME may be better suited than a qualified instructor to deliver the content. For example, for specialized subjects such as meteorology, human factors, or flight dispatch, the FAA recognizes the value of having a SME deliver this content. Since these subjects emphasize the application of knowledge within an air carrier environment, the FAA requires SMEs to deliver content in an EQP alongside a qualified instructor.

This ensures that the material is both relevant and contextualized for air carrier operations.

4.4 Written Testing. An eligible pilot should achieve a minimum score of 80 percent to successfully pass all written tests administered within an EQP. Air carriers with a certified EQP may establish higher standards if desired. Pilots who fail to meet the minimum score should receive additional training and retake the exam on any topics they did not pass. A review should be conducted correcting all tests to 100 percent to ensure each eligible pilot understands areas missed on the exam.

5-1 CHAPTER 5. APPLICATION, CERTIFICATION, AND INSPECTION

5.1 Application and Certification. Air carriers may elect to pursue and receive EQP certification. Air carriers seeking to obtain certification based on the means of compliance described in this AC must comply with all areas of this AC. FAA certification of an EQP is voluntary and conveys no additional regulatory benefits or privileges beyond those available to all 14 CFR part 121 air carriers.

5.2 Certification. Certification, as defined in this AC, is conveyed via a letter issued by the Principal Operations Inspector (POI) to the air carrier showing that an EQP submitted meets the full intent of all parts of this AC. While EQPs are not, in themselves, approved or accepted air carrier training programs, any training conducted within an EQP used to satisfy a regulatory requirement (e.g., ATP CTP or type rating curriculum) would be approved or accepted under the respective 14 CFR part in which the training is conducted.

5.2.1 Working With an Assigned Inspector. Title 14 CFR part 121 air carriers seeking certification for an EQP should work with their POI. The POI grants certification through a standard letter to the air carrier to retain for their record (see Appendix A, Sample EQP Letter).

5.2.2 Submission Package. An air carrier seeking certification of an EQP should provide at least the following in the submission package:

1. Program entry prerequisites, including eligible pilot requirements.

2. Assessment methodology, including reassessment policy and standards.

3. An EQP curriculum, including:

• Planned hours by topic/module;

• Phases IV and V content (as defined in Chapter 8) demonstrating all required topics/modules are incorporated (or combined Phase IV/Phase V content with all topics/modules incorporated if the air carrier elects this approach);

• Whether Phase IV and/or Phase V will include an FAA Type Rating Practical Test;

• When pilots in an EQP are to undergo the FAA ATP-Multiengine Airplane Knowledge Test; and

• The air carrier’s policy regarding retesting after a failure of the ATP Knowledge Test, as well as any other tests/checks/evaluations, as appropriate.

4. An instructor/evaluator training curriculum that meets all the requirements in Chapter 4 along with other requirements detailed in applicable regulations for the part under which they will train.

5. Data collection methodology and framework.

5-2

5.3 Regular Inspection. The assigned POI is responsible for certification of the submitted EQP curricula and EQP authorizations. The assigned inspector is responsible for conducting all required certification, surveillance, and inspection functions associated with an EQP.

6-1 CHAPTER 6. DATA ANALYSIS REQUIREMENTS

6.1 System for Data Analysis. Qualified 14 CFR part 121 air carriers with a certified EQP must have a system for analyzing data that will enable the air carrier and the Administrator to determine whether the training and evaluation activities are satisfactorily accomplishing the overall objectives of the EQP. The FAA considers an AQP under 14 CFR part 121 to meet this requirement. Air carriers that do not have an AQP may meet this requirement by incorporating the EQP into their SMS processes.

6.2 Calibration. Qualified 14 CFR part 121 air carriers with a certified EQP should have calibration training designed to assist instructors/evaluators in identifying their strengths and weaknesses in assessing an eligible pilot’s performance, and to reduce common rater errors. Calibration training is typically accomplished through group sessions in which instructors/evaluators observe video recordings of an eligible pilot’s performance segments and make independent ratings. Following such sessions, the instructors/evaluators discuss their ratings and the reasons for their differences of opinion to establish consensus and a common frame of reference. In addition, the different instructors/evaluators’ ratings are compared to identify variations from group norms or other standards established with respect to both the numerical ratings assigned to individual event sets and the shifts in ratings provided when observing differing levels of performance. Personalized feedback based on such variations is provided to each instructor/evaluator.

6.3 References. Qualified 14 CFR part 121 air carriers can refer to AC 120-54 for methods to ensure a universal standard, which is already in place at almost all 14 CFR part 121 air carriers.

7-1 CHAPTER 7. TITLE 14 CFR PARTS 141 AND 142 CONTRACTING RULES

7.1 Contracting With 14 CFR Part 141 Pilot Schools or Part 142 Training Centers.

A qualified air carrier electing to contract portions of the EQP to a 14 CFR part 141 pilot school or part 142 training center may do so. However, the qualified air carrier remains responsible for its EQP certification, oversight, content, and currency.