Engineers transferring their Part-66 licence to other Member States:

While the CAA will continue to accept and process Part 66 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 amongst 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, Part 66 licence holders might need to take action to minimise impact on their privileges. 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.

PART-66 AIRCRAFT MAINTENANCE LICENCE – ISSUED BY THE CAA

If I have an EASA Part-66 licence issued by the CAA would it still be valid after the UK leaves the EU?

Yes, CAA issued licences would remain valid. All CAA issued licences would be re-issued in due course to a new UK format, removing EASA references over time. Timescales for this would be advised at a later date but it would likely coincide with the normal licence renewal date.

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My UK based Part 145 organisation has applied for a third country approval from EASA. Would EASA accept UK Part 66 licences to support the approval?

When the UK leaves the EU it would be classified as a third country. Part 145 has provision to use non-EASA licences to support an approval issued in third countries. This is set out in Part 145.A.30 (j) paragraphs 1, 2 and Appendix IV. Certifying staff may be qualified in accordance with the national aviation regulations of the state in which the organisation facility is registered.

You are advised in conjunction with your Part 145 organisation, to contact EASA as soon as possible to discuss the approval process in this scenario.

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If I have an EASA Part-66 Licence issued by the CAA would I be able to continue to work on UK-registered aircraft?

Yes, CAA issued Licences would remain valid for use on aircraft registered in the UK that are maintained by organisations approved by the CAA. All CAA issued Licences would be re-issued to the new UK standard, removing EASA references over time. Timescales for this will be advised at a later date. 

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If I have an EASA Part-66 Licence issued by the CAA would I be able to continue to work on EU-registered aircraft?

No, you would not be able to continue to release EU-registered aircraft to service.

If you wish to continue to release EU-registered aircraft to service you would need to transfer your licence to the National Aviation Authority of another EASA member state before the UK leaves the EU. You are advised to have a discussion with the relevant NAA as soon as possible about their process and timetable for transfers.

While the CAA will continue to accept and process Part 66 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 amongst 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.

Licence holders who transferred their state of licence issue who also wish to maintain aircraft registered in the UK after withdrawal should follow the guidance below for Part 66 licence holders who hold a Part 66 licence issued by another EASA member state.

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If I complete basic or type training at a UK Part-147 approved organisation, would I be able to add these to my UK licence?

Yes, it intended that a Certificate of recognition issued by a UK Part 147 approved organisation would be accepted for inclusion on a UK issued Licence.

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If I complete basic or type training at a Part-147 approved organisation located outside the UK, would I be able to add these to my UK licence?

Yes, it is intended that a Certificate of Recognition issued by a Part 147 approved organisation located outside the UK approved prior to exit day would be accepted for the issue or amendment of a UK issued Licence for up to two years after EU exit.

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I have completed some of the basic training modules for my Part 66 licence. Would I be able to use these examinations when applying for a UK Part 66 licence?

Yes, it is intended that a Certificate of Recognition for Module Examinations issued by either a UK approved or non-UK Part 147 approved organisation would be accepted for the issue or amendment of a UK issued licence (for the Non-UK Part 147 organisation this is limited for up to two years after EU exit).

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I have completed some of the basic training modules for my Part 66 licence. Would I be able to use these examinations when applying for an EU Part 66 licence?

The European Union has adopted legislation which would allow these training module examinations to be used when applying for a EU part 66 licence if completed before 29 March 2019 . Further details can be found on EASA’s website for Brexit.

The EU has also indicated that examinations completed under the CAA between 29 March 2019 and Exit Day may also be allowed when applying for an EU Part-66, but potential applicants are advised to clarify this with their intended receiving NAA. 

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I have a UK Part-66 licence but work outside the UK and Europe on non-UK registered aircraft – what would the impact be?

You would need to contact your local National Aviation Authority in the state where the aircraft you work on are registered. If you work outside the EU and UK on EU-registered aircraft, your UK Part-66 licence would no longer be valid.

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Could I hold another EU NAA and a UK licence concurrently?

At present, under EASA regulations you can only hold one Part 66 licence.

You are advised to discuss with relevant NAAs or EASA their process and timetable for accepting applications for EU member state transfer prior to the UK's exit from the EU.

In a no-deal scenario, after the UK leaves the EU, you would be able to hold both a UK and EASA Part 66 licence concurrently.

The UK CAA would open an application process for engineers who have transferred their licence to another EU member state prior to exit date to allow the restoration of their UK licence. The process for this would be outlined once the UK leaves the EU.

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Could I transfer my licence to another EU member state NAA if UK national limitations are still applied?

Normally all national limitations are required to be removed prior to transfer. The decision to accept a transfer is the responsibility of the receiving EU member state NAA and you are advised to discuss with relevant the NAA or EASA as soon as possible.

The CAA has provided a dedicated application webpage and form to help guide applicants through this process.

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Would the CAA still recognise my Part 66 exams if I have taken them with another EU NAA or Non-UK Part 147 approved organisation.

Yes, these are intended to continue to be recognised, but only for a period of up to two years.

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PART-66 AIRCRAFT MAINTENANCE LICENCE – ISSUED BY ANOTHER EU MEMBER STATE

If I have a Non-UK Part-66 Licence, would I be able to continue to work on UK-registered aircraft?

Yes, it is intended that you would be able to continue to work on UK-registered aircraft for a period of up to two years after EU exit. Personnel working in organisations approved by the CAA who are based in the UK would need to obtain a UK CAA issued Part 66 licence after this point in time.

Individuals working in a UK Part-145 approved organisation located outside the UK may continue to work on UK-registered aircraft providing they fulfil the requirements of Part 145.A.30 (j) paragraphs 1 and 2 and subject to Appendix IV to Part 145.

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If I have completed basic or type training at a UK Part-147 approved organisation, would I be able to add the categories or ratings to my Part 66 licence issued by airworthiness authority of an EASA Member State?

EASA has not set out a process which would accept Certificates of Recognition issued by Part 147 organisations based in the UK. Further details can be found on EASA’s website for Brexit.

You are advised to contact EASA as soon as possible to discuss the application process in this scenario.

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Would another EU NAA recognise and accept UK-issued 147 examination certificates and/or Certificate of Recognition?

EASA has not set out a process which would accept Certificates of Recognition issued by Part 147 organisations based in the UK. Further details can be found on EASA’s website for Brexit.

You are advised to contact EASA / EU NAA as soon as possible to discuss the application process in this scenario.

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How would the UK’s exit from the EU affect the application of Airworthiness Directives for the UK-registered aircraft that I own, operate or manage?

 All EU regulations applicable at the point of UK exit would be retained in UK domestic legislation in a no-deal scenario, including Regulation (EU) No 1321/2014, Part M. This means owners, operators and Continuing Airworthiness Management Organisations (CAMOs) would continue to review and apply applicable Airworthiness Directives to their respective fleets based on requirements for the aircraft and its engines, propellers and equipment as set out in CAP 747 Mandatory Requirements for Airworthiness, Airworthiness Directives issued or adopted by EASA, plus any Airworthiness Directives notified by the State of Design.

You can view CAP 747 here: http://publicapps.caa.co.uk/docs/33/CAP747_21JUL17_BM.pdf

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Some of the regulation references in CAP 747 have been repealed, typically references to Regulation (EU) 216/2008 concerning EASA and non-EASA aircraft. Where can I find the latest information?

The CAA is aware that CAP 747 currently has some out-of-date references and is in the process of updating the document. Reference to superseded or amended regulations should be taken to mean the current version of the applicable regulation in force. The CAA will ensure any mandatory requirements for UK-registered aircraft are reflected within CAP 747 and also made available via the CAA website Airworthiness Directive page. For enquiries relating to ADs, please email ad.unit@caa.co.uk

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