Frozen ATPL Explained: What It Is and How to Get One

What is a frozen ATPL?

A "frozen ATPL" is the term used for a Commercial Pilot Licence (CPL) holder who has also passed all 14 ATPL theory examinations but does not yet meet the flight experience requirements for a full ATPL.

The ATPL is "frozen" because you've completed the knowledge component, but you need to accumulate the required flight time (1,500 hours total time including specific requirements for multi-pilot, instrument, and night hours) before it can be "unfrozen" into a full ATPL(A).

The 14 EASA ATPL theory subjects

Passing all 14 ATPL theory papers is the most academically demanding part of the pilot training pathway. You must achieve at least 75% in each paper. Papers are valid for 7 years from the date you pass your first paper, so you must obtain the CPL/IR within that window.

• 010 — Air Law
• 021 — Airframe and Systems / Electrics / Powerplant
• 022 — Instrumentation
• 031 — Mass and Balance
• 032 — Performance
• 033 — Flight Planning and Monitoring
• 040 — Human Performance and Limitations
• 050 — Meteorology
• 061 — General Navigation
• 062 — Radio Navigation
• 070 — Operational Procedures
• 081 — Principles of Flight
• 091 — VFR Communications
• 092 — IFR Communications

How do you unfreeze an ATPL?

To unfreeze an ATPL(A) under EASA, you must accumulate:

• 1,500 hours total flight time • 500 hours in multi-pilot operations • 200 hours cross-country • 100 hours at night • 75 hours instrument time (actual or simulated)

For most pilots, this happens naturally in the first 2–4 years of airline flying. Once you meet the requirements, you apply to your national CAA to upgrade your CPL to a full ATPL.

Integrated vs modular route to frozen ATPL

The integrated route takes you from zero hours to a frozen ATPL in one continuous programme (typically 18–24 months, €70,000–€100,000). You stay at one approved ATO throughout.

The modular route builds qualifications step by step: PPL → Night Rating → IR(A) → CPL(A) → MEP → ATPL theory. This typically takes 3–5 years but costs significantly less (€35,000–€60,000 total) and allows you to work between stages.