I know I am nitpicking, but isn't "shall be equipped with X" different from "shall be equipped with X and it must be in operation" ?

This doesn't sound right to me, don't think the regulations specify autopilot on is mandatory. There are times when it's not advisable, like severe turbulence, for one thing.

@Federico - DL is correct, see pdf page 3 here: An automatic altitude-control system should be operative and engaged during level cruise, except when circumstances such as the need to re-trim the aircraft or turbulence require disengagement.

@Federico You are right. There are several parts to the RVSM regulation; 1 part is the equipment specification, which mandates the altitude control system. The second part is the operator approval, which specifies maintenance programmes, training programmes and operating instructions. These are somewhat tailored to the operator (for good reason). Part of the RVSM operator approval is that in the Aircraft Operator Manual it is stipulated that the automatic altitude control system is active in RVSM airspace. Problem is I can't point to any public reference here, the AOMs I have are under NDA.

Flying manually for climb and descent should be fine, though, right?

@GdD There are allowable exceptions; disconnecting the autopilot during turbulence, out-of-trim conditions, TCAS events is perfectly justifiable. Handflying most of the cruise for maintaining skill is not such an exception.

@DeltaLima I understand NDAs, so no worries. Maybe the document linked by ymb1 could be a substitute for what you had in mind?

@DeltaLima So are you are suggesting it was actually dangerous or rather just not 'by the book'

@CptReynolds IIRC automatic altitude capture is required. Typically the target altitude must be set in the Mode Control Panel, so that the Mode S downlink confirms the level-off altitude to Air Traffic Control and their Conflict Alerting systems

@Federico I'll update the text soon

@ymb1 thank you for the link to the Acceptable Means of Compliance. I will use that as it is the defacto standard for achieving operator approval.

@Federico and thank you for using your mod powers to clean up the comments after we made all this mess here. Perhaps leave it for another day or so others can read it, but it should be cleaned up in the end :-)

Wilco. I tend to prefer preserving them in chat rather than deleting, but we'll see.

@Cloud It was not by the book. Whether it was dangerous is subject to discussion; there are many degrees of "dangerous". From many years of reading accidents and incidents reports, I can say that "not being by the book" often is a contributing factor in an accident. Without any doubt I can say that the kind of behaviour described in your question reduces the level of safety.

Oh no... a pilot actually dared to pilot the plane! Sheesh, how can we expect our commercial pilots to be good and proficient if we prohibit them from actually flying once in a while...?

@SnakeDoc Good point, however there are sims and empty aircraft to practise on :)

@DeltaLima Yes, but in theory it would be OK and in line with the AMC to hand fly until, say, 2000ft to go and then engage the AP in time for altitude capture. I‘m not saying it would be a brilliant idea if everyone did that in normal ops, but there shouldn’t be a rule against it, if I read it right?

@SnakeDoc there is nothing wrong with manual flying a commercial aircraft; I am very glad that there are still a few airlines that actually encourage it. But in RVSM airspace the margins are really tight and so the benefits of manual flying there do not outweigh the added risks.

@CptReynolds It may be permitted in some airlines, and not in others. The OPS approval is agreed between the regulator and the airline, there are slight variations. The AMC is an acceptable means of compliance, not the only acceptable means.

You are making some wild accusations here, btw. You first assume the aircraft flew in RVSM airspace and had RVSM approval instead of being allocated a typical 2,000ft clearance. You also assume the aircraft flew above FL290. You also assume the FO didn't have altitude controls on, and just navigated the plane. I also doubt a pilot or FO would willingly and freely tell a passenger (who may or may not be an aviation enthusiast, specialist, official, or just a normal person) that they deliberately violated regulations. So... your "definitive" violation isn't so definitive after all.

@SnakeDoc Please read the last sentence of my answer carefully before telling me I make wild accusations; there is the word if which indicates a condition. The condition is that the cruise flight was fully hand flown, then it was in violation. Have a good day.

It still seems rather suspect - and you're answer is written assuming there was a clear violation all the way down to a little blurb at the end. That is all I was pointing out - perhaps add that snippet at the top of your post stating you're assuming a lot of stuff that you can't possibly know unless OP provides the flight#. Good Day Sir! ;P

Note that the regulation says “should”, not “shall”. In legalese only the later is actually binding (at least in the domains I am more familiar with).

@JanHudec that is because these are EASA's Acceptable Means of Compliance with the regulations; they are not the regulations themselves which are written by the European Commission. The regulations themselves will say some along the lines of "RVSM operations shall be implemented in a safe manner, and approved by EASA". Then EASA publishes AMC to give guidance. They are not necessary the only means of compliance; one may argue a different way of complying with the regulations (it's not an easy way to go, but possible). For that reason the AMC is written with shoulds.

@DeltaLima Can I ask (out of interest) what your profession is? I guess you work in some kind of legislative review / writing position from your comments is all.

I am a systems engineer in air traffic management

But I have had quite a versatile career so far

Out of university I started as a freelancer. I did aircraft performance modelling, software programming, model validation.

I then got a contract to support ADS-B introduction in Europe. I did a lot of performance monitoring, for which I wrote my own software. I then was asked to support international standardisation of ADS-B. I was involved in several air- and ground ADS-B standards, both on the technology layer and the application layer

I was involved in requirement engineering, safety analyses, security analyses and much more. I learned to write technical documents that had legal relevance.

Then I got a contract with a company that develops systems for airport. It was more technical writing

then I got a contract with an aerospace company that was preparing a bid for a big European Air Traffic Management contract. I was supposed to help with the technical solution, but most of my contribution was to get people from 4 different countries and companies to understand each other and work together

I loved it, and so did my customer

They offered me the role of technical lead of the project, should they be awarded the contract

I accepted the offer and was employed for the first time. Two years of negotiation with the customer followed. Lots of technical work, legal work, financial work. I learned a lot. We concluded the negotiation successfully, and then the whole thing was killed at the political level before the real work even started

In parallel I had been doing various other projects. I worked in SESAR, i was a consultant to a Air Traffic Management regulatory body, I adviced an airport on a new surveillance system and a few other things.

But when the big project was killed, I had enough of ATM for a while, and I wanted to work with a team of people to develop my people management skills. There was no big ATM project in the company at that moment that I could do, so I got the role of product manager for a drone detention system. That is my current role.

But I still love Aviation, especially ATM. I will be back in the industry soon, I am working on two ideas for products.

So I am not in a legislative writing role at the moment, but I have some experience in the field.

@DeltaLima Thanks, super interesting. I am a software dev too, nothing as exciting as aviation though, I'm afraid. Although I do intend to start working on an indie video game soon, something more interesting. Your career sounds very rewarding.

@Cloud It's never too late to consider a career in aerospace as a software developer. I don't know where you're located, but we're looking for about 40 more colleagues at the moment, many of them in software development. We're in Darmstadt (Germany), home of the European Space Operations Centre and very close to Langen (Frankfurt) where the German Air Traffic Control has their headquarters. Many great projects to work on here.

@DeltaLima Thanks for the info. I am inside Europe, but not Germany, I will have a look at you guys :)