While the CAA will continue to accept and process Part FCL transfer applications under existing EASA transfer arrangements until the UK leaves the EU, the procedures adopted by the receiving NAA and recognised validity of the licence during the transfer process may vary among EU member states. Applicants who require continuity of validity throughout the transfer process are therefore advised to apply at least 3 months prior to Exit Day and should also consider engaging with their intended receiving NAA to identify any potential issues.
If no deal is agreed between the EU and the UK, commercial pilots (Part-FCL) might need to take action to ensure continuity of service. Actions required would depend on individual circumstances and are a matter for each business and individual to consider. This page sets what you need to consider to prepare for such an eventuality.
UK-ISSUED PART-FCL COMMERCIAL PILOT LICENCES
Would I be able to continue operating UK-registered aircraft?
Would I still be able to use my UK-issued Licence, with EASA references on it, when operating UK-registered aircraft?
Yes, it is an ICAO compliant licence and would remain valid for operating UK-registered aircraft. In a no deal scenario, the CAA would provide additional clarification to those involved in ramp inspections by providing a downloadable document online to support EASA format licence documents issued prior to the UK's exit from the EU.
Would I be able to continue operating EU-registered aircraft with a UK Part-FCL licence?
The European Commission has said that it would not recognise UK-issued Part-FCL licences.
To continue operating EU-registered aircraft, you may seek a licence validation from any EASA Competent Authority, which would be valid for aircraft registered in any EASA Member State. You cannot seek this until after the UK has formally withdrawn from the EU.
We recommend that you speak to the relevant NAA as soon as possible about the process for achieving a validation of your UK issued Part-FCL licence.
Alternatively, you may undertake a State of Licence Issue transfer before the UK formally leaves the EU. This means transferring your licence from the UK to another EASA member state.
To transfer a Part FCL to a new State of Licence, a request to transfer your licence and a separate request to transfer your medical records must be submitted to the CAA before the UK leaves the EU. In addition, a request to become the applicant’s new State of Licence must be submitted to the receiving NAA before Exit day. An application cannot be progressed until all three of these requests along with supporting documentation and appropriate fees have been submitted. Applicants should also be aware that some NAAs may not be able to complete transfer requests if there is insufficient time to do so between receiving the transfer request and Brexit taking effect. Individuals considering transferring their licence who have not yet applied should therefore contact the proposed receiving NAA for further advice.
Incomplete applications – those where all three elements have not been received prior to UK leaving the EU – cannot be progressed after Exit Day as the protocol for transferring licences between EU member states would no longer apply to the UK. These applications would therefore be rejected after Exit Day.
*UPDATE*: When is the latest I could apply to transfer my licence to another EASA member state to get my licence in time for the UK's exit from the EU?
While the CAA will continue to accept and process Part FCL transfer applications under existing EASA transfer arrangements until the UK leaves the EU the CAA has no control over the issuance process of other EASA Member States, we therefore recommend that you contact the proposed NAA directly on these matters.
Applicants should also be aware that some NAAs may not be able to complete transfer requests if there is insufficient time to do so between receiving the transfer request and Brexit taking effect. Individuals considering transferring their licence who have not yet applied should therefore contact the proposed receiving NAA for further advice and are advised to submit their transfer application at least 3 months prior to Exit Day. This will not guarantee that the transfer process will be complete by Exit Day, but it will increase the likelihood. For further advice, applicants should contact their intended receiving NAA.
*UPDATE*: If I transfer my licence to another EASA member state, can I be issued with a UK licence after the UK has left the EU?
Yes, this process is under review; the CAA is developing a simplified application and validation procedure for recent holders of UK-issued Part FCLs which will accept applications after Exit Day.
It is expected that this process will take 3-6 months to implement once Exit Day is confirmed, and further details will be released as they become available.
*UPDATE*: I am currently studying in the UK for my Part-FCL exams which are due to conclude before Exit Day. Could I change the state of my licence after this time?
How much does a State of Licence transfer cost?
That is dependent on the NAA you proposed to move to and its associated scheme of charges.
To transfer out from the CAA there is a charge of £45.00 for the processing of a change of State of Licence Issue and a charge of £77.00 pounds for the transfer of medical records.
Payment for the change of State of Licence Issue will be taken on receipt of the form SRG2150.
Payment for the transfer of medical details you will need to complete form SRG1202.
Further information concerning the process can be found on the CAA website under Changing the State of Licence issue.
I am currently studying for my Part-FCL at a UK training organisation. Would EASA recognise this if I receive my licence after the UK leaves the EU?
If you are currently training for your commercial pilot licence to be issued by any NAA other than the UK, we recommend you speak to your NAA as soon as possible about how the training you have undertaken would be recognised.
The European Commission has stated recently that:
Under Regulation (EU) No 1178/2011 and in particular the second point of Appendix 3 of that regulation, a transfer from one (EASA) Approved Training Organisations (ATO) to another is possible. However, there is no exception as regards the requirement that all theoretical training exams must be taken in the same Member State. Consequently, if all the theory exams have been completed before the withdrawal date and if the change to another ATO located in the EU is done before the withdrawal date, the students will retain the credit for those theory exams performed in the UK for the normal duration of 3 years and may thus complete their training in another EU Member State.
Would UK pilots’ medicals remain valid?
Yes. Medical certificates issued before the UK leaves the EU would remain valid, even if issued by a non-UK EASA Aeromedical Examiner (AME) or Aeromedical Centre (AeMC). At the first medical after EU exit and thereafter, medicals would have to be issued by UK AMEs and Aeromedical Centres, both would retain their permissions and approvals under UK law. No action required.
For UK pilot licences, existing medical certificates would retain validity and UK AMEs and Aeromedical Centres would retain their permissions and approvals under UK law. No action required.
I have a licence application currently in progress with the CAA. Will I receive an EASA Part-FCL or a UK Part-FCL?
The CAA will continue to process your application and you will be issued with an EASA Part FCL or a UK Part FCL licence, depending on when your licence is issued. If the licence is issued prior to the date the UK leaves the EU it will be issued in an EASA Part FCL formatted licence. If the licence is issued after the date the UK leaves the EU it will be issued as a UK Part FCL formatted licence. Both licences are fully ICAO compliant and valid for operating UK-Registered aircraft.
*UPDATE*: Once the CAA has completed transfer of my records to my new EASA member state, what happens to my old UK licence?
Once you have been advised by your new NAA that your new Part FCL is ready, you are required to collect it and to surrender your old UK licence to your new NAA. It is not permitted to hold two Part FCL licences from different EU member states. Applicants are therefore advised to complete the transfer process and surrender their old UK Part FCL at the earliest practical opportunity once they have been informed that their transferred licence is ready. It should be noted that retaining the UK- issued licence and medical documentation does not stop the transfer process.
*UPDATE*: What if I wish to submit variation requests to my new NAA or advise of changes to my medical or professional status?
The CAA retains responsibility for oversight of your medical and professional records until your new Part FCL is issued, and therefore changes or variation requests should be sent to the CAA up to this point. Changes to medical status should be advised to the CAA by the transfer applicant’s AME. The CAA will pass on variation information to the receiving NAA, and applicants should check that this has been incorporated in their new Part FCL when it is issued. Applicants are advised to minimise variation requests as far as possible as they may delay the transfer process, and also that some receiving NAAs may require the re-submission of Doc155/Med SOLI transfer paperwork with the variation details incorporated, along with the accompanying fees.
EU-ISSUED PART-FCL COMMERCIAL PILOT LICENCES
Would I be able to continue operating UK-registered aircraft?
Yes, however to continue operating UK-registered aircraft you would require a validation from the UK CAA.
On the day the UK leaves the EU, the CAA would publish on its website a general validation document for all EASA licence holders, required to operate UK-registered aircraft. Individuals who hold an EASA licence at that point will be able to download the document. Additional details will be provided on this microsite closer to the date.
Can I seek a validation after the UK leaves the EU?
Would my UK licence be valid after the UK leaves the EU?
UK-issued national licences remain unaffected by the UK’s withdrawal from the EU. They are issued under the UK’s Air Navigation Order, which is currently in force.
UK-issued EASA Part-FCL licences become UK Part-FCL licences, and would remain valid for operating UK-registered aircraft should no deal be agreed between the UK and the EU.
Would medicals certified by UK Aeromedical Examiners or Aeromedical Centres remain valid?
For EU pilot licences, the European Commission has stated that approvals by CAA-approved AMEs and AeMCs would no longer be considered valid.
Airlines should contact EASA as soon as possible to discuss the consequences of this for their operations and potential mitigations.
From October 2 2018, EASA has said that it will accept third country applications from UK holders of aeromedical centre certificates. Organisations will need to decide whether, in a non-negotiated withdrawal, they wish to retain both a national and an EASA certificate. The CAA intends to continue to recognise current (and valid) EASA certificates for an initial period of up to two years, but no decision has been made about ongoing validity after this period.
NON-EU/UK COMMERCIAL PILOT LICENCES
I have a UK-validation of my third country licence. Would I still be able to operate EU-registered aircraft?
No, you would only be able to operate UK-registered aircraft with your UK validation.
You would need to seek validation from an EASA Member State to continue operating EU-registered aircraft. You should contact EASA or the relevant NAA as soon as possible to discuss this scenario and actions you might need to take prior to the UK's exit from the EU.
I have another EASA member state validation of my third country licence. Would I still be able to operate UK-registered aircraft?
A validation of a third county licence issue by an EASA Member State, would cease to be valid for UK-registered aircraft when the UK leaves the EU.
You would need to seek validation from the UK CAA to continue operating UK-registered aircraft. For more information, see here.