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Is my aircraft complex? Which occurrence list applies

Answer five questions about the aircraft and see whether it reports against Annex I, the list for complex motor-powered aircraft, or against section 1, 2 or 3 of Annex V. The rule is quoted word for word below, with 40 common types read from their EASA type certificate data sheets. Free, no sign-in, runs in your browser.

Worked out in your browser from the definition quoted below. Nothing is sent or stored. Take the figures from your aircraft's type certificate data sheet or flight manual, not a brochure: a modification can change the certified mass.

The rule, word for word

The occurrences you must report are listed in Implementing Regulation (EU) 2015/1018, whose annexes were replaced by Implementing Regulation (EU) 2026/1821. Annex I is the list for the operation of manned aircraft. Annex V is the separate list for everything that is not complex, and it opens with the definition that decides:

“Aircraft other-than complex motor-powered aircraft” means any aircraft other than that defined in point (129) in Annex I to Commission Implementing Regulation (EU) 2023/1020; Annex V (a)

Point (129) sits in Annex I, the definitions, of the Air Operations Regulation, (EU) No 965/2012. Implementing Regulation (EU) 2023/1020 added it there, which is why 2026/1821 names that act. It reads, with the indent dashes of the Official Journal shown as bullets:

“complex motor-powered aircraft” shall mean:

(a) an aeroplane:

  • with a maximum certificated take-off mass exceeding 5 700 kg, or
  • certificated for a maximum passenger seating configuration of more than nineteen, or
  • certificated for operation with a minimum crew of at least two pilots, or
  • equipped with (a) turbojet engine(s) or more than one turboprop engine, or

(b) a helicopter certificated:

(i) for a maximum take-off mass exceeding 3 175 kg, or
(ii) for a maximum passenger seating configuration of more than nine, or
(iii) for operation with a minimum crew of at least two pilots, or

(c) a tilt rotor aircraft; 965/2012 Annex I (129)

Any one line is enough. The same words were Article 3(j) of Regulation (EC) No 216/2008, which the 2015 version of the list pointed to, so the test has not changed. Regulation (EU) No 376/2014, the reporting regulation, uses the term without defining it: it asks for "a separate list classifying occurrences applicable to aircraft other than complex motor-powered aircraft" Art 4(5).

Not complex? Then one of three sections of Annex V

SectionHeading in the ruleWhat falls in it
1Manned aircraft other-than complex motor-powered aircraft excluding sailplanes and lighter-than-air vehiclesAeroplanes and helicopters, piston or turbine, that pass none of the tests above
2Sailplanes (gliders)A sailplane is "a heavier-than-air aircraft which is supported in flight by the dynamic reaction of the air against its fixed lifting surfaces, the free flight of which does not depend on an engine, including also hang gliders, paragliders and other comparable craft" Reg (EU) 923/2012 Art 2(117). Powered sailplanes are in it too: the section lists "an engine failure during take-off" of a powered sailplane 2.1(4), and Part-FCL calls a touring motor glider "a specific class of powered sailplanes" Reg (EU) 1178/2011, FCL.010.
3Lighter-than-air vehicles (balloons and airships)"Balloons and ‘airships’ that rely on hot air or on lighter-than-air gases such as helium or hydrogen for their lift" Dir 2009/43/EC, ML10

An organisation that flies both kinds uses both lists, aircraft by aircraft. Technical and maintenance occurrences on complex aircraft are in Annex II; Annex V has its own technical items for the rest. The items themselves, with examples, are in our guide to what must be reported.

Six results that surprise people

  • One turboprop is not complex. A PC-12 at 4 740 kg with nine passengers, a Grand Caravan and a TBM all report against Annex V section 1. The engine test catches only more than one turboprop.
  • Two turboprops are complex at any mass. A BN2T Islander can be certified at 2 994 kg and is complex. The piston BN2B at the same mass is not. A King Air flown under Part-NCO stays complex.
  • Every jet is complex. The Cirrus Vision Jet has one engine, 2 722 kg and one pilot, and it is complex because of that one engine.
  • A twin-engine helicopter can be not complex. For helicopters the engines do not count. An H135 at 3 100 kg reports against Annex V section 1; an EC145 at 3 585 kg against Annex I.
  • On the line is under it. The rule says "exceeding", so an AW109SP at exactly 3 175 kg is not complex. A Bell 429 is 3 175 kg with internal loads and 3 629 kg with an external load; EASA's rating list marks it not complex.
  • Balloons and airships are never complex. A 5 000 kg Ultramagic N-600 and a Zeppelin NT with three engines and 15 passenger seats both report against Annex V section 3.
Turbofans count as turbojets here. The definition says "turbojet engine(s)", and every light jet in the table below has turbofans. The Air Operations Regulation the definition sits in never uses the word turbofan: it calls jets turbojet throughout, for example "all multi-engined turbo-jet powered aeroplanes" in performance class A 965/2012 Annex I (93). EASA reads it the same way: its class and type rating list marks the Vision Jet, Citation Mustang, Phenom 100 and PC-24 as complex, the mark meaning "an aircraft is categorised as complex motor-powered aircraft in accordance with the definition in the Basic Regulation". The Vision Jet has one engine, 2 722 kg and one pilot, so the jet engine is the only reason it can be.

Sources: Regulation (EU) 2026/1821, Regulation (EU) 2023/1020, Regulation (EU) No 965/2012, Regulation (EU) No 376/2014, Regulation (EU) No 923/2012, Regulation (EU) No 1178/2011, Directive 2009/43/EC, 14 CFR 61.1 and EASA's class and type rating lists, all read in November 2026.

Forty common types, from their EASA data sheets

Types that European flying schools, clubs, small operators and HEMS fly, with the figures as the current EASA type certificate data sheet gives them, read on 8 November 2026. Where variants of a type differ, the row names the variant. A data sheet does not show supplemental type certificates or other changes on your own aircraft: check its flight manual.

TypeMax take-off massPassenger seatsMin crewEnginesListData sheet
Trainers and piston singles
Diamond DA20-C1800 kg111 piston, IO-240-BAnnex V section 1
no test met
EASA.IM.A.223 issue 06
Tecnam P2008 JC630 kg; 650 kg with a mass modification111 piston, Rotax 912 S2Annex V section 1
no test met
EASA.A.583 issue 14
Pipistrel Velis Electro
Virus SW 128
600 kg111 electric, E-811Annex V section 1
no test met
EASA.A.573 issue 13
Cessna 172S Skyhawk1 157 kg (1 156.66)4, pilot's seat included11 piston, IO-360-L2AAnnex V section 1
no test met
EASA.IM.A.051 issue 11
Piper PA-28-181 Archer III1 157 kg3; 2 with G3X avionics11 piston, O-360 or IO-360Annex V section 1
no test met
EASA.IM.A.234 issue 8
Diamond DA40 NG1 280 kg; 1 310 kg per Note 8311 piston (diesel), Austro E4Annex V section 1
no test met
EASA.IM.A.022 issue 24
Piston twins
Piper PA-44-180 Seminole1 724 kg312 piston, O-360 or IO-360Annex V section 1
two engines, but piston
EASA.IM.A.232 issue 06
Diamond DA42 NG1 900 kg; up to 2 001 kg with modifications (item 13, Note 12)312 piston (diesel), Austro E4Annex V section 1
two engines, but piston; EASA list: not complex
EASA.A.005 issue 44
Tecnam P2012 Traveller3 600 kg; 3 680 kg with MOD2012/017912 piston, TEO-540-C1A or GTSIO-520-SAnnex V section 1
two engines, but piston
EASA.A.637 issue 14
Britten-Norman Islander, piston
BN2B-20, -21, -26, -27
2 994 kg912 piston, O-540 or IO-540Annex V section 1
same airframe as the BN2T below, piston engines
EASA.IM.A.388 issue 4
Single turboprops
Pilatus PC-12
PC-12/47E and PC-12/47G; earlier models lighter
4 740 kg9, pilots not counted11 turboprop, PT6A-67P or PT6E-67XPAnnex V section 1
one turboprop is not a test; EASA list: not complex
EASA.A.089 issue 11
Cessna 208B Grand Caravan
Section 2.1 of the sheet
3 969 kg (3 968.9)9 positions; 12 in the 14-seat option11 turboprop, PT6A-114 or -114AAnnex V section 1
one turboprop is not a test; EASA list (as 208): not complex
EASA.IM.A.226 issue 15
Daher TBM
TBM700 N, sold as TBM 850 to TBM 980
3 354 kg; 3 454 kg with MOD70-0680-10 (TBM 960, 980)511 turboprop, PT6A-66D or PT6E-66XTAnnex V section 1
one turboprop is not a test; EASA list: not complex
EASA.A.010 issue 22
Twin turboprops
Beechcraft King Air C90GTi4 581 kg13, pilot and co-pilot included12 turboprop, PT6A-135AAnnex I
two turboprops; EASA list: complex
EASA.IM.A.503 issue 9
Beechcraft King Air B200GT5 670 kg (5 669.9)15, crew included12 turboprop, PT6A-52Annex I
two turboprops; EASA list: complex
EASA.IM.A.277 issue 22
Britten-Norman Islander, turbine
BN2T, BN2T-2, -2R, -4R, -4S
BN2T 2 994 or 3 175 kg; the others 3 855 kg; BN2T-4S 4 048 kg with NB-2175912 turboprop, Allison 250-B17Annex I
two turboprops, at any of these masses; EASA list: complex
EASA.IM.A.388 issue 4
De Havilland DHC-6 Twin Otter
Series 400
5 670 kg1912 turboprop, PT6A-34 or -27Annex I
two turboprops, under the mass and seat limits; EASA list: complex
EASA.IM.A.575 issue 6
Dornier 228-2126 400 kg19, plus 2 crew seats12 turboprop, TPE 331Annex I
two turboprops and above 5 700 kg; EASA list: complex
EASA.A.359 issue 08
Light jets
Cirrus Vision Jet
SF50
2 722 kg7 maximum11 turbofan, FJ33-5AAnnex I
jet engine, whatever the mass; EASA list: complex
EASA.IM.A.615 issue 6
Cessna Citation Mustang
510
3 921 kg6, two crew included1 with listed equipment, or 22 turbofan, PW615F-AAnnex I
jet engines; EASA list: complex
EASA.IM.A.502 issue 03
Embraer Phenom 100
EMB-500
4 750 kg; 4 800 or 4 855 kg with modifications61 with listed equipment, or 22 turbofan, PW617F-EAnnex I
jet engines; EASA list: complex
EASA.IM.A.157 issue 09
Pilatus PC-248 005 to 8 500 kg by serial number8 executive; 10 commuter12 turbofan, FJ44-4A-QPMAnnex I
jet engines and above 5 700 kg; the sheet says so itself (Note 12); EASA list: complex
EASA.A.594 issue 08
Single-engine helicopters
Robinson R22 Beta II621 kg111 piston, O-360-J2AAnnex V section 1
no test met; EASA list: not complex
EASA.IM.R.120 issue 8
Guimbal Cabri G2700 kg111 piston, O-360-J2AAnnex V section 1
no test met; EASA list: not complex
EASA.R.145 issue 8
Robinson R44 Raven II1 134 kg311 piston, IO-540-AE1A5Annex V section 1
no test met; EASA list: not complex
EASA.IM.R.121 issue 07
Robinson R661 225 kg; 1 315 kg with external load411 turbine, 250-C300/A1Annex V section 1
no test met; EASA list: not complex
EASA.IM.R.507 issue 4
Bell 5051 669 kg; 2 030 kg with external load411 turboshaft, Arrius 2RAnnex V section 1
no test met; EASA list: not complex
EASA.IM.R.520 issue 4
Airbus H125
AS 350 B3
2 250 kg; 2 370 kg with OP 33695; 6 with the forward two-place seat11 turboshaft, Arriel 2B, 2B1 or 2DAnnex V section 1
no test met; EASA list: not complex
EASA.R.008 issue 19
Twin-engine helicopters
Airbus H135
EC135 P3, P3H, T3, T3H
2 980 kg; P3H and T3H 3 100 kg as alternative mass712 turbine, PW 206B3 or Arrius 2B2Annex V section 1
two engines do not count for helicopters; EASA list: not complex
EASA.R.009 issue 21
Leonardo AW109SP GrandNew3 175 kg712 PW207CAnnex V section 1
exactly 3 175 kg does not exceed the limit; EASA list: not complex
EASA.R.005 issue 26
Bell 4293 175 kg internal load
3 629 kg with external load
712 turbine, PW207D1 or D2Annex V section 1
on the line for internal loads; EASA list: not complex
EASA.IM.R.506 issue 5
Airbus H145 and EC145
MBB-BK117 C-2, D-2, D-3
C-2 3 585 kg; D-2 3 650 kg (alternatives to 3 800 kg); D-3 3 800 kg9; C-2 10 with kit12 turbine, Arriel 1E2 or 2EAnnex I
above 3 175 kg; EASA list: complex
EASA.R.010 issue 22
Leonardo AW1694 600 kg; 4 800 kg with kit or skids10 in the cabin, plus 1 in the cockpit with one pilot1; for NVG 2 pilots, or 1 and a crew member2 PW210A or A1Annex I
above 3 175 kg and more than nine passengers; EASA list: complex
EASA.R.509 issue 15
Leonardo AW1396 400 kg; 6 800 or 7 000 kg with kits151 VFR day; 2 VFR night and IFR2 turboshaft, PT6C-67C or C1Annex I
above 3 175 kg and more than nine passengers; EASA list: complex
EASA.R.006 issue 27
Sailplanes and powered sailplanes
Schleicher ASK 21600 kg2 seats1NoneAnnex V section 2
sailplane
EASA.A.221 issue 06
Schempp-Hirth Duo Discus T700 kg; 750 kg per AV.9, AV.102 seatsNot stated1, SOLO 2350 DAnnex V section 2
non-self-launching powered sailplane
EASA.A.074 issue 06
Grob G 109B850 kg111; six engine models listedAnnex V section 2
self-launching motorglider, a powered sailplane
EASA.A.249 issue 02
Balloons and airships
Cameron Z-105
hot air balloon
952 kgNo number; see the flight manual1None (burners)Annex V section 3
balloon
EASA.IM.BA.013 issue 27
Ultramagic N-600
hot air balloon
5 000 kgNot stated1None (burners)Annex V section 3
balloon, however heavy
EASA.BA.014 issue 34
Zeppelin NT
LZ N07-101
Not stated in the sheet15, plus 2 pilot seats13, IO-360-C1G6Annex V section 3
airship: three engines and 15 passengers do not make it complex; EASA list: not complex
EASA.AS.001 issue 10

Seats are as the data sheet prints them: most give passengers, a few count the pilots, and the row says so where the sheet does. Masses are the maximum take-off mass of the named variant, with the condition where a modification or external load changes it. Where a sheet names only the engine model, the kind shown follows from that model and its fuel or power unit. "EASA list" is EASA's class and type rating list (aeroplanes 12 February 2026 with its Appendix 2, helicopters 4 May 2025, airships 28 July 2025); it agrees with every row it covers. Data sheets: EASA type certificates library.

Questions we hear

Is a single-engine turboprop complex?

Not because of its engine. The definition catches "(a) turbojet engine(s) or more than one turboprop engine". A single turboprop is complex only if it is certified above 5 700 kg, for more than 19 passenger seats or for a minimum crew of two pilots. A PC-12, Caravan or TBM reports against Annex V section 1.

Is a twin-engine helicopter complex?

Not because of its engines. For helicopters only three things count: a maximum take-off mass above 3 175 kg, more than nine passenger seats, or a minimum crew of two pilots. An H135 at 2 980 or 3 100 kg is not complex; an EC145 at 3 585 kg or an H145 at 3 650 kg or more is.

Our light twin turboprop flies under Part-NCO. Which list?

Annex I. Regulation (EU) No 965/2012 lets non-commercial operators and training organisations fly "complex motor-powered aeroplanes with a maximum certificated take-off mass (MCTOM) at or below 5 700 kg, equipped with turboprop engines" under Part-NCO Art 6(8), (9). The aeroplane stays complex, and the occurrence list follows the aircraft.

Is this the same as an FAA complex airplane?

No. In the US rules a complex airplane "has a retractable landing gear, flaps, and a controllable pitch propeller" 14 CFR 61.1, a pilot training term. A single piston aeroplane with retractable gear is not complex motor-powered, and reports against Annex V section 1.

What about microlights and other aircraft outside EASA rules?

Regulation (EU) No 376/2014 applies to occurrences involving civil aircraft to which Regulation (EU) 2018/1139 applies. "Member States may decide to apply this Regulation also to" the others Art 3(2). Ask your authority or your association whether yours did.

The mass sits right on the line. Is it complex?

Not by mass. The rule says "exceeding": an aeroplane certified at exactly 5 700 kg or a helicopter at exactly 3 175 kg is not complex by mass. Where a data sheet gives a higher mass for a modification or for external loads, see the notes in the table. If in doubt, ask your authority and report the occurrence anyway: one that turns out not to be mandatory counts as a voluntary report.

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