A high-level European Commission conference that started on Thursday in Brussels titled “A Social Agenda for Transport” has elicited some damning commentary from the European Cockpit Association (ECA) over what it considers the failure of the airline industry to recognize its social responsibilities to its pilots. In a statement timed to coincide with the start of the conference, the ECA called on the commission to address poor working conditions for pilots, growing unemployment, so-called “social dumping,” a rapid increase of “atypical” employment, social and fiscal engineering and “questionable” company structures.

“When it comes to social issues in European air transport, it is time that we deal with the reality of what actually happens in our sector,” said ECA president Dirk Polloczek, “And let’s admit it: this reality is ugly.”

The reality, claims the ECA, encompasses a regulatory environment that allows for so-called flags of convenience, where airlines can “shop around” around for the most lenient labor and taxation law or oversight regimes. Meanwhile, in what the ECA calls a “race to the bottom,” some airlines have started to pass their responsibilities for social security contributions and taxes onto their employees under so-called “pay to fly” schemes, or “self-sponsored line training” that requires newly trained pilots to buy a package of flight hours to gain flight experience.

The ECA also cited a recent EU-funded study by the University of Ghent showing that one in six European pilots works on an “atypical” basis, through temporary agencies as self-employed pilots, or on a zero-hours contract with no pay guarantee. According to the ECA, airlines use so-called self employment among pilots as a disguise for regular employment, thereby evading their legal social responsibilities. The Ghent University study notes the prevalence of the practice among young pilots and those flying for certain low-fare airlines. Forty percent of 20- to 30-year-old pilots fly as self-employed contractors, according to the study, and seven out of 10 of all self-employed pilots work for low-fare airlines.

“Flags of convenience, bogus self-employment and pay-to-fly are harmful practices that destroy jobs in Europe, carve out tax and social security payments in EU member states, and force other airlines to follow the example if they don’t want to be wiped out of the market,” ECA vice president Jon Horne said at the EU Commission conference on Thursday. “Atypical employment should concern not only the industry, but all European citizens and decision-makers...Whether looking at the ‘place of business’ that determines tax and regulation, employment status, or aircrew ‘home base,’ current rules and loopholes permit unscrupulous operators to present on paper a smokescreen that obscures and bears little relation to what is actually going on. We must move to a situation where an assessment of reality governs how airlines and crews are handled.”

The ECA has called for an immediate ban on pay-to-fly schemes and zero-hours contracts for air crews, and laws ensuring that employers must declare a genuine home base from which pilots derive their legal rights. It also called for the EC to top its “to-do” list with a definitive halt on “bogus” self-employment and other forms of what it calls social engineering. Finally, it said, European law must eliminate flags of convenience by strengthening the “principal place of business” as a reality of establishment, not a choice by the airline.