Industry Guidance and Regulations on SATCE

Updated: April 2020

As a new pilot training tool and emerging flight simulation technology, the regulatory framework for Simulated ATC Environment (SATCE) is still maturing.

SATCE is recommended in ICAO guidance and specifications published by ARINC Industry Activities.

SATCE is not currently mandated for pilot training or as part of flight simulation qualification, except by the European Aviation Safety Agency (EASA) for devices used for the Multi-crew Pilot Licence (MPL).

Industry Collaboration

Since 2002, the flight simulation industry has been envisioning and designing automated ATC systems intended for use in flight simulation training devices (FSTDs).

Industry guidance and specification standards for SATCE are still developing, through collaboration between pilot training and flight simulation experts. This activity is expected to continue as SATCE is increasingly adopted and becomes a mainstream pilot training technology delivered as standard on most flight training devices.

ICAO Recommendation

The International Civil Aviation Organisation (ICAO) has published guidance material on SATCE and recommendations for further development by industry. National aviation authorities (NAAs) and other regulatory bodies are considering similar guidance material that will support SATCE gaining wider adoption. It is expected that SATCE will become mandated for both training programme approval and device qualification once the full benefits and training value are demonstrated and proven from early adopters in the industry.


Compliance Statement

QUADRANT INTERACT™ has been designed to meet and exceed the following SATCE industry guidance, specifications and requirements:

  • ARINC Specification 439B (Aug 2020)
  • ICAO Document 9625 Edition 4 (Sept 2015)
  • EASA AMC/GM Part-FCL MPL (Dec 2011)


Industry Initiatives

Quadrant Group has been involved with, and contributed to, several different industry initiatives concerning SATCE.

Quadrant Group has helped lead the FSEMC SATCE Working Group on SATCE since its initial meeting in Jan 2012 and remains committed to this valuable industry initiative. This Working Group, comprising varied members from both flight training and engineering backgrounds, has grown to become the largest industry collaborative effort on SATCE, and is expected to continue to help mature ARINC Standards as the technology develops.

ARINC Specification 439B

ARINC Specification 439B (Aug 2020) ‘Simulated ATC Environments in Flight Simulation Training Devices’, published by ARINC Industry Activities, is arguably the most comprehensive and up-to-date guidance material on SATCE for FSTDs. This document has been used to inform and support other industry guidance, recommendations and requirements, including those from ICAO and EASA.

ARINC Spec 439B provides industry and regulatory organisations with an emerging standard for SATCE, covering topics such as core SATCE functionality, SATCE data, technology, maintenance, training approval and flight simulator device qualification.

Facilitated by the Flight Simulator Engineering Maintenance Conference (FSEMC), the guidance material is the output of the SATCE Working Group comprising experienced pilots, flight instructors and engineers from regulators, major airlines, pilot training organisations, training device manufactures, and SATCE vendors.

ICAO Document 9625 (4th Edition)

In late 2009, ICAO published the third revision to Document 9625 Vol. 1 Part 2 ‘Manual of Criteria for the Qualification of Flight Simulation Training Devices’. With this publication, ICAO signalled the potential future introduction and regulatory requirement for SATCE in FSTDs. At the time, the guidance on SATCE was deliberately vague since a simulated ATC environment had not been evaluated and verified through training.

In late 2015, ICAO published a revision to Doc. 9625 Vol. 1 with its Fourth Edition. The content on SATCE was thoroughly revised, updated and harmonised with ARINC Report 439 reflecting industry’s progress. ‘Guidance for Environment – ATC’ (Attachment O) contains the following commentary, stressing the provisional nature of the guidance and its intention to further update SATCE content over successive editions:

“The features and requirements contained in… this manual concerning simulated ATC environment are not mandatory for either training approval or FSTD qualification at this time. The content of these appendices should be used as guidance to industry for the continued development and refinement of simulated ATC environment in FSTDs and other flight training tools. Further guidance material will be published in subsequent amendments to this manual when sufficient experience has been gathered and requirements further reviewed and matured by industry.”  ICAO Doc 9625 4th Ed, 2015

ICAO Document 9868 PANS-TRG

The Second Edition of ICAO Document 9868, Procedures for Air Navigation Services (PANS) – Training (TRG), updated in 2016, includes guidance in Part II, Attachment A to Chapter 1 titled “Competency-Based Training and Licensing for The Multi-Crew Pilot Licence”. This Attachment includes guidance on the selection of training media (3.10), including a requirement that FSTDs used for MPL Phase 3 “must permit the progressive introduction of a sophisticated flight environment including ATC”.

At the time this guidance was written (First Edition, 2006), the introduction of SATCE was perhaps envisaged exclusively for higher level, full-motion, full-visual, high-fidelity, type-specific flight simulators, whereas more recent industry opinion is that SATCE will be beneficial across all flight simulation and training device levels.

“The Type III FSTD must permit the progressive introduction of a sophisticated flight environment including ATC…” ICAO Doc 9868 2nd Ed, 2016


ATC simulation has been mandated in European Aviation Safety Agency (EASA) Part-FCL for use with MPL training programs. The flight and simulated flight media minimum level requirements specify that ATC simulation is required for MPL Phase 3 (Intermediate) and Phase 4 (Advanced) FSTDs (Annex to ED Decision 2011/016/R, 15 Dec 2011).

EU Commission Regulation No. 1178/2011, laying down technical requirements and administrative procedures related to civil aviation aircrew, was published in November 2011 in the Official Journal of the European Union.

The EASA Aircrew Regulation contains Annex 1 – Part FCL (Flight Crew Licensing) that incorporates the requirements for flight crew licenses, ratings and certificates. The Acceptable Means of Compliance (AMC) and Guidance Material (GM) to Part-FCL were adopted by EASA and published on the Agency’s website in December 2011.

While SATCE systems are being developed and evaluated across the industry, NAAs overseeing MPL courses are managing the requirement by allowing for alternative means of compliance (AMC). This allowance is a practicable short-term resolution, and is expected to be withdrawn by EASA when SATCE systems have become available and have demonstrated training value.

The functional requirements for ATC simulation in EASA Part-FCL MPL are not specified in any detail. However, these are outlined in guidance materials elsewhere, the most detailed of which is ARINC Spec. 439B.

On 16th Dec 2020, EASA published Notice of Proposed Amendment (NPA) 2020-15. The objective was to amend the EU regulatory framework by applying ‘an innovative approach to the capabilities classification of future flight simulation training devices (FSTDs) that ensures harmonisation with the guidance established in Doc 9625 ‘Manual of Criteria for the Qualification of Flight Simulation Training Devices’ by the International Civil Aviation Organization (ICAO)’.

The NPA included proposed amendments of Certification-Standards (CS) CS-FSTD(A) ‘Aeroplane Flight Simulation Training Devices’, which included a technical specification of a SATCE system for FSTDs for the first time. The SATCE technical specifications in NPA 2020-15 are largely harmonised with ARINC Spec. 439B.

The NPA 2020-15 was open for public comment until 21 April 2021.

IATA / IFALPA MPL Guidance (2nd Edition)

IATA’s ‘Guidance Material and Best Practices for MPL Implementation’ was published jointly with IFALPA in July 2015. Section 14 of the document contains revised material on SATCE, recommending that SATCE be adopted for all types of FSTD and all MPL training phases.

The guidance contains the following comment on training benefits: “students in early phases may especially benefit from the introduction of SATCE to help with their knowledge of ICAO standard phraseology as well as building competency and confidence using radio communications, including in busy airspace, and managing task interruption”.


The following documents and online resources may be helpful concerning SATCE (Simulated ATC Environment) for FSTDs:


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