Regulations
Medevac standby and 24/7 availability: the rostering challenges
In medevac, standby is the roster's basic unit: it converts presence into mission capability. How it is credited (how much duty time it consumes, how much of the next flight duty period it eats, when it triggers rest) decides whether a base genuinely covers the night or only covers it on paper.
A medevac base listed as "covered 24/7" can be unable to launch at four in the morning. The entire gap between those two states comes down to how standby duties are built and credited. This article sets out what the European rules say about standby, why they apply to medevac today only by way of national law, what Subpart FTL (B) changes in 2028, and how to build standby duties that hold.
What counts as standby?
The European regulation defines standby as a pre-notified and defined period during which a crew member must be available to receive an assignment for a flight, positioning or other duty, without an intervening rest period. It then distinguishes two forms:
- Airport standby, performed at the airport: in medevac, the crew waiting at the base, next to the aircraft.
- Other standby, at home or in suitable accommodation: the crew can be called, but needs time to reach the aircraft.
Both have to be in the roster, with start and end times notified in advance so that crews can plan their rest. A standby is not a vague "on call": it is a duty with set times, and it is counted.
Airport standby or home standby: what changes?
The two forms have opposite effects on the roster. Airport standby supports the shortest launch times, but it is the most consuming: it counts in full as duty, and the crew starts the mission with the clock already running. Home standby costs less duty time, but adds travel to the launch delay, which rules it out for the most demanding contractual commitments.
The ORO.FTL scheme that governs scheduled and charter operations puts figures on this difference. They do not apply as such to medevac today (see below), but they give the order of magnitude, and the structure that Subpart FTL (B) takes up from 2028.
| Under ORO.FTL (scheduled and charter) | Airport standby | Other standby (home, hotel) |
|---|---|---|
| Counts as duty time | In full | 25 % of the time spent |
| Maximum duration | 16 hours, standby and FDP combined | 16 hours, and 18 hours awake with the FDP |
| Effect on the maximum FDP | Cut by standby time beyond 4 hours | Cut by standby time beyond 6 hours |
| Without an assignment | Followed by a rest period | Followed by a rest period |
The 6-hour threshold rises to 8 hours when the FDP is extended by in-flight rest or split duty. And one relief matters for night cover: when other standby starts between 23:00 and 07:00, the time between 23:00 and 07:00 does not count towards the reduction of the FDP until the crew member is contacted.
How can standby consume a crew that never flew?
This is the segment's classic trap. Take a 16-hour home standby starting at 08:00. If the crew reports for a mission at 18:00, ten hours in, the maximum FDP of the mission is cut by four hours under the scheme above. The crew is available, but no longer for a long mission. And if no call comes, the standby still ends in a rest period, and part of it is added to cumulative duty counters.
In other words, a long standby can:
- count, wholly or partly, towards cumulative duty time and its rolling ceilings;
- reduce the flight duty period still available if a mission is triggered late;
- trigger a rest requirement at its end, whether or not a mission took place.
The result: a crew can be unavailable the next day after a standby night with no flying at all. That cost never shows up in a presence sheet. A tool that computes true availability surfaces it immediately.
Which standby rules apply to medevac?
Today, none of the European figures above apply directly. Article 8(2) of Regulation (EU) No 965/2012 keeps aeroplane emergency medical service (AEMS) under national law and Subpart Q of Regulation (EEC) No 3922/91, and Article 8(3) sends commercial helicopter operations, HEMS included, to national requirements. The Commission notes that Subpart Q does not provide for standby, in-flight rest or split duty. Standby rules therefore come from national law, from the exemptions granted to the operator and from its own agreements, and they vary from one country, sometimes one AOC, to the next. Our medevac rostering guide details that regime.
For aeroplanes, this changes on 15 October 2028. The delegated regulation adopted by the Commission on 8 September 2026 places AEMS and air taxi under a new Subpart FTL (B), whose standby point (ORO.FTL.226) sets the following:
- airport standby counts in full as duty for cumulative duty limits and for rest;
- crews on airport standby get accommodation or a rest facility with control of light and temperature and isolation from noise;
- each operator specifies, in its individual flight time specification scheme approved by its authority, the maximum standby duration, the effect of standby on the maximum daily FDP, the minimum rest after a standby with no assignment, and how other standby counts towards cumulative duty.
Two other provisions concern medevac directly. During an ongoing AEMS mission, the maximum basic daily FDP of a two-pilot crew may be extended by up to two hours when required to complete the mission. And for two-pilot AEMS crews, the 60 duty hours in any 7 consecutive days may be exceeded by up to 30 hours, subject to a risk assessment and mitigation that includes a recovery rest of at least 72 hours with two local nights. The figures for standby itself will come from EASA certification specifications. Helicopters stay under national rules after 2028.
How do you build standby duties that hold?
- Start from the contractual launch time: it dictates which standby type is viable, and therefore everything downstream.
- Think in mission capability: the useful question is "can the crew on duty still fly a long mission right now?", well beyond "is the base covered?".
- Cap individual shift length: very long standbys maximise displayed coverage and minimise real capability towards the end, since every hour beyond the threshold comes off the FDP. Two short shifts often cover better than one long one.
- Plan the relief before you need it: a long mission launched late in a shift leaves the base uncovered at precisely the hour it must stay covered. Relief belongs in the roster, not in improvisation.
- Distribute nights explicitly: night standby falls in the Window of Circadian Low, and Subpart FTL (B) asks operators to avoid duty patterns that seriously disrupt sleep, such as alternating day and night duties.
- Re-verify compliance at every change: an extended shift or a sick call moves the counters of several people at once.
That is exactly what a constraint-based duty generation engine produces, as in SkAI Tech: ON/OFF patterns generated against the applicable rules (regulatory, regional and in-house, configured per operator), and re-generation in minutes when the situation moves. Because medevac standby rules differ from one operator to the next, and will change in 2028, they are configured rather than hard-wired.
Building standby rosters for a medevac base? See what SkAI Tech changes for crew schedulers.
FAQ
Does standby count towards duty time?
Under ORO.FTL, airport standby counts in full and other standby counts for 25 % of its duration. For medevac, it depends today on the national regime and the operator's approved scheme. From 2028, aeroplane AEMS operators will count airport standby in full, and will set out in their scheme how other standby counts. It is the parameter to encode most carefully: getting it wrong produces either pointless overstaffing or a breach discovered after the fact.
Does a standby without a mission require rest?
Yes, under ORO.FTL, airport standby or other standby that does not lead to an assignment is followed by a rest period. Subpart FTL (B) asks each operator to specify that minimum rest in its scheme. That is why a quiet night of standby can still close the next morning.
How do you cover a base 24/7 with a small team?
By optimising shift structure rather than adding headcount: durations matched to the real mission profile, planned relief, and pooling across bases where geography allows. Headcount follows from the coverage target, not the other way round.
What if a mission runs past the end of a shift?
That is part of normal operations in this segment: it belongs in the roster (planned relief, identified reserve crew) rather than being handled as an incident every single time. The two-hour mission extension of Subpart FTL (B) is a margin to monitor, not a planning assumption.
Sources
- Regulation (EU) No 965/2012, Annex III (Part-ORO), Subpart FTL, as consolidated in the EASA Easy Access Rules for Air Operations (revision of March 2026): ORO.FTL.105 points (25) to (27) (definitions of standby, airport standby and other standby), ORO.FTL.225 (standby and duties at the airport), CS FTL.1.225 (standby: duty crediting, maximum duration, reduction of the FDP).
- Regulation (EU) No 965/2012, Article 8: paragraph 2 (derogation for air taxi, EMS and single-pilot operations to national law and Subpart Q of Regulation (EEC) No 3922/91), paragraph 3 (CAT by helicopter subject to national requirements).
- European Commission (2026, 8 September), Commission Delegated Regulation amending Regulation (EU) No 965/2012 as regards the flight and duty time limitations and rest requirements for air taxi, emergency medical services and single-pilot operations, C(2026) 6142 final, transmitted to the Council on 10 September 2026 (document 12992/26 and its annex): recital 4, Subpart FTL (B) points ORO.FTL.111(g), ORO.FTL.206(e), ORO.FTL.211(c) and ORO.FTL.226, application from 15 October 2028. Like any delegated act, it remains subject to scrutiny by the European Parliament and the Council before publication in the Official Journal.
- The national authority texts applicable to the operator, which remain the reference until the new regime applies, and permanently for helicopters.
