In all likelihood, it will be sometime in the second half of 2017 before we will be handing over draft new rules. When you add the time it then takes for EASA, and the European Commission and Parliament to take care of the broader administration, it is easy to see that the (much needed) new rules will not be in law before the FCL opt‐out ends in 2018. This will begin to cause major problems some considerable time before April 2018 as nations realise how much change is going to be needed in order to comply with FCL – and how little had already been done at the local level. There is already talk within Europe of having the current opt‐out extended for another year or so. In reality, this is not going to help much. Work is critically required to determine when a switch to the new system is going to be feasible. We see this as an early priority – and are quite prepared to argue for things to be pushed back until the early to mid‐2020s, if that is what is needed in order to allow everyone enough time to transition without much trouble