If no deal is concluded between the EU and the UK, organisations (Part 145) maintaining aircraft might need to take action to maximise continuity and stability for the aviation sector. 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-145 MAINTENANCE OF AIRCRAFT – UK APPROVED

Would my organisation Approval continue to be valid after the UK leaves the EU?

Yes, as a UK-approved Part-145 holder your approval would remain valid after the UK leaves the EU with the same scope of work as you have today. There is no need for a new certificate, as it was issued by the UK CAA (not EASA). The UK CAA would arrange for an updated certificate to be issued the next time you change your approval or when the normal two yearly recommendation is made by the CAA to continue the approval. This would remove the references to EASA.

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Would my organisation continue to be able to certify UK-registered aircraft?

Yes, as a UK-approved Part-145 holder, you would be able to continue to certify UK-registered aircraft as your approval would still be valid after the UK leaves the EU.

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Would my organisation continue to be able to certify EU-registered aircraft?

To continue to certify EU-registered aircraft you would also need to hold an EASA Part 145 approval. Should there be a non-negotiated withdrawal, the European Commission has said that the UK would be considered a third country. From October 2 2018, EASA has said that it will accept third country applications from UK holders of Part 145 approvals. Organisations will need to decide whether, in a non-negotiated withdrawal, they wish to retain both a national and an EASA approval. Further details regarding the EASA application process can be found on this link.

 A UK- Part-145 would be needed to continue to certify UK-registered aircraft. Organisations will need to retain their UK approvals should they wish to access the benefits of any Bilateral Air Safety Agreement the UK has in place with third countries. Having a third country approval from EASA is unlikely to give you access to the benefits of the EU’s current Bilateral Air Safety Agreements.

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My UK based organisation has applied for a Third country approval from EASA, will 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 and 2 and subject to Appendix IV to Part 145. Certifying staff may be qualified in accordance with the national aviation regulations of the state in which the organisation facility is registered. Further details regarding the EASA application process can be found on this link.

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How can my organisation continue to maintain/certify US, Canadian or Brazilian registered aircraft?

Should there be a non-negotiated withdrawal the EU air safety bilateral agreements would cease to be effective in the UK.

The CAA and US’s FAA have agreed a new bilateral that would come into force if no deal is agreed, and this can be found here

The CAA and Transport Canada have also agreed a new bilateral that would come into force if no deal is agreed, details of which can be found here.

New agreements are also being developed directly between the UK and Japan's Civil Aviation Bureau and ANAC of Brazil. The aim of all these agreements is to establish working arrangements which would provide a similar framework as exists today.

 

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How can my organisation continue to maintain/certify non-UK registered aircraft?

Your organisation would need to apply for an EASA-approval if your organisation intends to maintain aircraft registered in the EASA member states.  Other non-European states of registry may accept CAA issued approvals.

You are advised to contact EASA or the State of Registry NAA as soon as possible to discuss the application process in this scenario.

From October 2 2018, EASA has said that it will accept third country applications from UK holders of Part 145 approvals. Organisations will need to decide whether, in a non-negotiated withdrawal, they wish to retain both a national and an EASA approval.

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.

Organisations will need to retain their UK approvals should they wish to access the benefits of any Bilateral Air Safety Agreement the UK has in place with third countries. Having a third country approval from EASA is unlikely to give you access to the benefits of the EU’s current Bilateral Air Safety Agreements.

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If my company has an approval to maintain aircraft registered outside the EASA Member States, would it continue to be valid?

This is a decision for the National Aviation Authority of the state of registry. Please contact as soon as possible the specific NAA directly.

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Would I be able to continue to issue EASA Form-1 certificates under my UK approval?

No – once the UK formally leaves the EU, you would no longer be able to issue EASA- Form 1 certificates. The UK would issue CAA Form 1 certificates independent of the EASA system.

The Form is to be completed in accordance with the existing Instructions and AMC/GM, with the exception that the Authority information in the header and the Form Reference itself (CAA Form 1 rather than EASA Form 1) is changed. 

 A word version of the new UK form is available here: CAA Form 1

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What would the CAA Form 1 look like?

A sample template is available here: CAA Form 1

As can be seen, the technical information remains unchanged. The form is to be completed in accordance with the existing instructions and AMC/GM with the exception that the Authority information in the header and the Form Reference itself (CAA Form 1 rather than EASA Form 1) will change.

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Could I fit a component released under an EASA Form 1 or equivalent to a UK registered aircraft?

Yes, these components could continue to fitted to a UK registered aircraft, but only for a period of up to two years.

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If my company employs Part 66 certifying staff with UK issued Part 66 licences, could they continue to certify under my UK 145 approval?

Yes, they could continue to certify under a UK approval. The UK issued Part 66 licence would remain valid after the UK leaves the EU, and there is currently no need for re-issue of the licence.

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If my company employs Part 66 certifying staff with Non-UK issued Part 66 licences in the UK, could they continue to certify under my UK 145 approval?

Yes, they could continue to certify under the UK approval, but only for a period of up to two years. After that, the engineer would need to obtain a licence from the CAA. The CAA would provide an application process for EU licence holders to apply for a UK licence after the UK leaves the EU.

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PART-145 MAINTENANCE OF COMPONENTS & SPECIALISED SERVICES – UK APPROVED

Would my organisation approval continue to be valid after exit day?

Yes, as a UK-approved Part-145 holder your approval would remain valid post EU exit with the same scope of work as you have today. There would be no need for a new certificate as it was issued by the UK CAA (not EASA). The UK CAA will arrange for an updated certificate to be issued the next time you change your approval or when the normal two-yearly recommendation is made by the CAA to continue the approval. This would remove the references to EASA.

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Would I be able to continue to issue EASA Form-1 certificates under my UK CAA approval?

No – once the UK formally leaves the EU, you would no longer be able to issue EASA-approved Form 1 certificates. The UK would issue Form 1 certificates independent of the EASA system. 

A template of the new UK Form 1 is available here: UK Form 1

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*UPDATE* Would Form 1 certificates issued by CAA approved organisations be accepted by EASA for use on EU-registered aircraft?

You are advised to contact EASA as soon as possible to discuss this scenario. The European Union has adopted legislation that would recognise Form 1s issued by UK organisations before exit day as remaining valid for 9 months from the day after exit day.

Further details regarding EASA Brexit planning can be found on this link. 

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Would Form 1 certificates issued by UK organisations be accepted by third countries?

This is a decision for the National Aviation Authority (NAA) of the state of registry. Please contact the specific NAA directly as soon as possible.

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Could I still use parts released under EASA Form 1 in order to complete maintenance, repairs and/or modifications to components?

Yes, these components could continue to be fitted to a component released under a CAA Form 1 from 29 March 2019 onwards, but only for a period of up to two years.

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PART-145 MAINTENANCE OF AIRCRAFT BY ORGANISATIONS LOCATED OUTSIDE THE UK

Would my organisation be able to certify UK-registered aircraft?

Yes, the CAA is intending to continue to recognise non-UK EASA Part 145 organisations for up to two years. To enable these organisations to release UK registered aircraft during this two-year period, an EASA Part 145 approval will be recognised in UK legislation. There may be some minor changes to the certificate of release to service to recognise the UK legal basis for the release. 

The CAA will be reviewing the situation after the UK leaves the EU.

Please note that UK operators may insist that their maintenance providers have a UK approval as part of the commercial arrangements. This is at the discretion of the operator. Should an organisation wish to apply for a UK approval, however, please review the third country application page on the CAA website for further details.

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My organisation has facilities in the EU and within the UK. Could I accept UK issued Part 66 Licences?

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 and 2 and subject to Appendix IV to Part 145. 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 to contact the relevant NAA as soon as possible to discuss the approval process in this scenario.

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PART-145 MAINTENANCE OF COMPONENTS & SPECIALISED SERVICES BY ORGANISATIONS LOCATED OUTSIDE THE UK

Would my organisation still be able to issue an EASA Form 1 to a product or component that has either been removed from or to be fitted to a UK registered aircraft?

Yes, as the current EASA system allows for components removed from Non-EU aircraft to be maintained and released with an EASA Form 1 providing the component conforms to EASA maintenance/design data.

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