CASA Is Reviewing the CAO 48.1 Pilot Fatigue Rules
CASA's post-implementation review of CAO 48.1 asks commercial pilots and operators how Appendices 1 to 7 and FRMS are working. The discussion paper asks for survey responses by 2 November 2026.
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Updated November 2, 2026
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CASA is in the last day of the public window it set for comment on Australia's commercial pilot fatigue rules. A notice dated 6 October 2026 says the authority is running a post-implementation review of Civil Aviation Order 48.1 Instrument 2019. Discussion paper DP 2614OS, dated October 2026, asks pilots and operators to respond to the associated survey by 2 November 2026.
The review is about how the rules are working for commercial operations. It is not a new fatigue order, and CASA has not published replacement limits in these two documents. The discussion paper says a report on the review, and any future initiatives, is anticipated by late 2026, subject to the feedback received.
What CAO 48.1 already requires
CAO 48.1 commenced on 2 September 2019. CASA says implementation was predominantly achieved by November 2021, with the last amendment in that sequence taking effect on 2 December 2021. The order is the fatigue framework for flight crew members. Appendices 1 to 7 set the commercial-operations settings. CASA defines commercial operations, for this review, as operations that are not private operations. The survey is generally less relevant to pilots who only fly privately.
The discussion paper describes three approaches already in the order.
- Appendix 1 is the basic, more restrictive set of flight time limitations. CASA says those limits sit broadly outside the window of circadian low and do not require the operator to add the enhanced fatigue-management processes that apply to later appendices. The paper treats the fatigue risk of operations that stay inside Appendix 1 as relatively low in probability because the limits are tighter. It also says those limits suit simpler operations.
- Appendices 2 to 6 allow less restrictive limits for different kinds of flying, including passenger transport, freight, charter and aerial work such as agricultural flying and firefighting. Operators on these appendices have enhanced fatigue-management obligations. CASA describes those as procedures to keep monitoring policies, limits and practices, plus fatigue-risk training for pilots. A minor variation can approve limited non-compliance with a specified provision when CASA is satisfied an acceptable level of safety is preserved.
- Appendix 7 is a fatigue risk management system approved for that operator. CASA calls it a performance-based, data-driven system that can set duty limits beyond the prescriptive appendices if the operator shows the processes and mitigations that hold safety at an acceptable level. The paper says FRMS operations include high-capacity airline flying and smaller passenger, freight, charter and emergency-medical operations.
Across all three, the order splits responsibility. CASA says a flight crew licence is conditioned so a pilot does not start a flight, or related tasks, if fatigue is likely to leave them unfit. An operator must not assign a commercial duty if it reasonably believes the pilot is, or is likely to be, unfit to fly because of fatigue.
What the review is actually asking
The 6 October notice says the review is testing whether Appendices 1 to 7 are effective, efficient, and matched to a diverse industry. It names three working questions: whether pilots feel comfortable reporting fatigue, how operators respond to fatigue reports and concerns, and what education and training operators give pilots. The notice says fatigue affects people differently and that the review is looking at system-based controls, not only at prescriptive hour limits.
DP 2614OS is more specific about the survey. It asks about the effectiveness of the scheme, especially the performance-based elements; the efficiency, flexibility and accessibility of the arrangements; rostering practices that may predict higher fatigue risk; and a list of policy issues CASA has already identified. Pilots may answer the questions that match their operation. Operators receive their survey directly from CASA. The public pilot survey and the discussion paper sit on CASA's consultation page for project DP 2614OS.
The paper's own topic list goes beyond hours. It includes operations under Appendices 1 to 6, operations under an FRMS, a just reporting culture, the data CASA would need to judge whether the framework works, international developments, and continuous improvement. On FRMS, the sections flagged for comment include guidance, whether a system can scale to the size of the operator, how CASA oversees approved systems, and first-of-kind operations. On the prescriptive side, the paper discusses enhanced obligations, minor variations, and rostering on particular duties.
None of that is a finding that the current limits are too long or too short. The documents ask for evidence from crews and certificate holders. They do not publish a proposed new flight-duty table.
What changes for crews before any rule change
For a pilot, 2 November is a survey date, not a new roster cap. Today's limits remain whichever appendix the operation already uses. The licence condition not to fly when likely unfit from fatigue is already in the order the paper describes.
For a scheduling or safety manager, the useful sort is the appendix actually on the certificate. Appendix 1 is the tighter prescriptive set. Appendices 2 to 6 add monitoring and training, and a minor variation exists only where CASA has approved it. An FRMS operator is the one being asked about data, oversight and fit. CASA says the comments may shape later options and, if it develops solutions, further consultation. The milestone named in the paper is a report by late 2026. A roster change built on a limit these documents do not contain is not supported by them.
