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 29 March 2019.
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 You cannot seek this until after the UK has formally withdrawn from the EU.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 29 March 2019. This means transferring your licence from the UK to another EASA member state.
When is the latest I could apply to transfer my licence to another EASA member state to get my licence in time for 29 March 2019?
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.
To enable the CAA time to complete its part in the licence transfer process, the CAA advises that application forms from the NAA need to be submitted to the CAA by January 1 2019. We will endeavour to transfer any application received after this date, but the process may not be completed by 29 March 2019.
If I transfer my licence to another EASA member state, can I be issued with a UK licence after March 29 2019?
I am currently studying in the UK for my Part-FCL exams which are due to conclude after January 1 2019. 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 29 March 2019?
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 30 March 2019 would remain valid, even if issued by a non-UK EASA Aeromedical Examiner (AME) or Aeromedical Centre (AeMC). At the first medical after 29 March 2019 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.
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 29 March 2019, the CAA would publish on its website a general validation document for all EASA licence holders, required to operate UK-registered aircraft. Additional details will be provided on this microsite closer to the date.
Can I seek a validation after March 29 2019?
Would my UK licence be valid after March 29 2019?
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 29 March 2019.
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 on the 29 March 2019. You would need to seek validation from the UK CAA to continue operating UK-registered aircraft. For more information, see here.