The “Exempted Route” to Completing Commercial Knowledge for Flight Instructors

Many aspiring flight instructors are unaware of a little-known option: undertaking the Commercial Pilot Licence (CPL) theoretical knowledge exams without enrolling in a full groundschool course.

A formal CPL groundschool typically involves 300+ hours of structured tuition and costs several thousands of pounds. For determined PPL holders looking to move into instruction, that can be a significant barrier. The exempted route offers a cost-effective alternative.

Let’s be clear—this path is not for the faint-hearted. Self teaching requires commitment, drive and a slight hint of lunacy. There are many resources currently available open source on the internet to support learning, the knowledge gained through PPL tuition will certainly help, and the CAA kindly provide a full list of the Learning Objectives that are examined. With focussed energy, it is possible to complete the examinations within a 6-9 month window, subject to being able to find a suitable exam sittings.

1. What the Exempted Route Is

For candidates aiming for an FI(A) certificate who do not need a CPL issued, Part-FCL allows you to sit and pass the CPL theoretical knowledge (TK) examinations without first completing an approved CPL TK course.

Those exam passes:

  • Count only for meeting the FI prerequisite.
  • Do not qualify you for CPL licence issue.

CAA guidance (FCL.915.FI) states that aspiring instructors who intend to teach the PPL syllabus must have:

“…passed the CPL theoretical knowledge examination, which may be taken without completing a CPL theoretical knowledge training course and which shall not be valid for the issue of a CPL.” – UK Civil Aviation Authority

In practice: You can meet the FI prerequisites more flexibly and cheaply. If you later decide you want a CPL issued, you must then complete an approved CPL TK course (CAA Form 5004 / ATO certificate) and may need to re-validate or re-sit exams so they are valid for licence issue.

Note: A statutory appeal has been submitted to the CAA challenging the requirement for candidates who already passed the exams to resit them if subsequently completing an approved groundschool to progress a CPL application, on the basis that it adds burden without improving safety.

2. Who This Route Is For

  • PPL(A) holders building towards FI(A) who want to instruct (initially as FI(R), then ab-initio PPL once restrictions are lifted). You must still meet the usual FI experience requirements—hours, cross-country, instrument time, recent SEP flying, and the pre-entry test.
  • Important: Without CPL/ATPL TK passes, an FI(A) may only instruct for the LAPL (and associated ratings). To instruct ab-initio PPL students, you must have CPL-level (or ATPL-level) theoretical knowledge passes.

3. The Exams You’ll Sit (CPL(A) TK)

The CPL(A) theoretical knowledge syllabus includes 13 subjects at CPL level:

  • Air Law
  • Aircraft General Knowledge (Systems & Instrumentation)
  • Mass & Balance
  • Performance
  • Flight Planning & Monitoring
  • Human Performance
  • Meteorology
  • General Navigation
  • Radio Navigation
  • Operational Procedures
  • Principles of Flight
  • VFR Communications

(Full details: CAA Theoretical Knowledge Examinations)

4. How to Book and Sit the Exams (Without CPL Course)

  1. Register via the CAA e-Exams system
  2. Submit SRG1192 Form
    • On the form, for Licence Held, enter: “PPL – Exam Application for FI issue only.”
  3. Follow the exam attempt rules (FCL.025):
    • All exams must be passed within 18 months (from the end of the month of your first attempt).
    • Maximum 6 sittings and 4 attempts per subject.
  4. Validity of passes:
    • For CPL or IR licence issue: passes are valid for 36 months (when taken with a full course).
    • For FI(A) purposes under the exempted route: the results do not expire.
  5. CPL licence issue later:
    • If you later seek a CPL, you must complete an approved CPL TK course and provide the ATO’s course completion certificate (CAA Form 5004).

5. Key Links

Why GPS Denial in the UK Should Concern GA Pilots – And Why Backup Navigation Must Be Practised and Tested

In an age where digital avionics, moving maps, and GNSS (Global Navigation Satellite Systems) have become ubiquitous in General Aviation (GA), it’s tempting to take GPS for granted.

For many private pilots, cross-country flying now involves little more than programming a route into a GPS unit or app and following the magenta line. But what happens when that line disappears?

Over the past few years, the world has seen a marked rise in GPS jamming and spoofing events, particularly in regions near military training areas and strategic infrastructure. While this trend might initially sound like a nuisance for commercial or military operators, it’s something that every GA pilot should treat as a serious threat, not just to convenience, but to safety.

The Reality of GPS Denial in the UK

GPS denial takes two main forms: jamming, which blocks or interferes with satellite signals, and spoofing, where false signals are broadcast to mislead receivers. In the UK, such interference has been increasingly recorded around areas like Salisbury Plain, The Wash, the Scottish Highlands, and the North Sea—areas that often intersect popular GA routes.

While NOTAMs may occasionally warn of jamming exercises, these are not always well-publicised or easily interpreted by the average GA pilot, and their coverage can extend far beyond expected zones. Additionally, there’s growing concern about unintentional interference from consumer devices, illegal jammers, and hostile state actors.

GPS is a passive system, aircraft receive signals but don’t transmit—so there’s no warning when it fails. No buzzing alarms. No flickering screens. You might just notice your aircraft is now flying over an unexpected landmark, and your ‘current position’ is now… nowhere.

Why GA Is Particularly Vulnerable

Unlike commercial operators who often fly with inertial reference systems, dual GNSS receivers, or access to air traffic navigational support, the average GA pilot might be relying entirely on:

  • A single GNSS unit (perhaps embedded in a tablet)
  • A moving map application like SkyDemon, ForeFlight, or Garmin Pilot
  • Minimal recent practice with DR (Dead Reckoning) or VFR chart-based navigation

The combination of these factors makes GA particularly susceptible to spatial disorientation, airspace infringements, and navigational error in the event of GPS loss. This is especially true in marginal visibility, poor weather, or near controlled airspace boundaries.

A Call to Return to Core Navigation Skills

Aviation, at its heart, is a discipline of redundancy and preparation. That’s why we check alternate aerodromes, carry spare fuel, and keep paper charts in our flight bags (don’t we?). But how often do we truly practice fallback navigation techniques?

Pilots should regularly test themselves on:

  • Dead reckoning: Estimating position based on heading, time, and ground speed
  • Map reading: Interpreting visual features and correlating them with a VFR chart
  • Timed legs: Using accurate clocking to confirm position between turning points
  • Diversion planning: Rapidly selecting and flying to an alternate route or aerodrome

Flying a short route with the GPS intentionally turned off, or covered, can be an excellent refresher. Club fly-outs or training days can incorporate this as a challenge or exercise.

Regulatory and Instructional Support

There is growing recognition in the UK CAA and EASA communities that over-reliance on GPS has degraded essential pilotage and navigation skills. Instructors and examiners should take the initiative to:

  • Simulate GPS failure during PPL and post-qualification training flights
  • Emphasise traditional navigation skills during biennial flight reviews
  • Encourage electronic device discipline—i.e., flying with it turned off during sections of a flight

Conclusion: Prepare for When, Not If

GPS is one of the greatest advancements in modern aviation, but it is not invulnerable. As reliance increases, so too does the consequence of its absence. For GA pilots flying in a congested, complex airspace like the UK’s, complacency can lead to disorientation or infringement in minutes.

Treat backup navigation not as an emergency procedure, but as a core competency. If we train as though GPS will fail, we ensure our safety and self-sufficiency when—not if—it does.

Author’s note:

If you’re a GA pilot, challenge yourself this month. Plan and fly a short route entirely using dead reckoning and visual fixes. No GPS, no moving map. You might rediscover both the challenge and satisfaction that comes from truly navigating by air