Following the UK’s exit from the EU on 31 January, a transition period will apply until 31 December 2020. During this period, the UK and the aviation sector will continue to follow EU law and to participate in the European Aviation Safety Agency (EASA) system. As a result, businesses and individuals operating in the UK should see no change to existing conditions during the transition period, while the longer-term UK-EU relationship on aviation is determined. Please see the homepage for further details.
A fuller outline of the position as the UK enters the transition period is available here.
While the respective positions outlined in the UK Government and EU negotiating mandates indicate what both sides want in terms of future agreements on air transport and aviation safety and security, the conditions that will exist after the end of the transition period are still uncertain. Given this uncertainty, the FAQ information below should not be regarded as exhaustive and will be subject to change.
As the UK-EU negotiations move forward and more information becomes available, the CAA will update these FAQs and notify stakeholders of the updates through the SkyWise alert system. If you haven’t already done so, please subscribe to the EU exit category in the SkyWise system: skywise.caa.co.uk
After the UK’s membership of the EASA system ceases at the end of the transition period and if there is no mutual recognition of safety certificates between the UK and European systems, Approved Training Organisations (ATO) and Declared Training Organisations (DTO) might need to take action. Actions required would depend on individual circumstances and are a matter for each business and individual to consider. This page sets out what you need to consider to prepare for such an eventuality.
UK issued ATO, DTO and RF
After the UK’s membership of the EASA system ceases at the end of the transition period and if there is no mutual recognition of safety certificates between the UK and European systems, existing training organisation approvals and/or declarations would remain valid under UK law.
Where a Competent Authority other than the CAA would be the State of Licence issue, the European Commission’s previous public positions has said that in the absence of agreement for continued mutual recognition of Training Organisation Approvals, EASA may not recognise training courses conducted by UK-issued approved or declared training organisations where training for a licence, rating or certificate is completed after the UK participation in EASA ceases,
Therefore, prior to commencing a course of theoretical knowledge or flight training for a pilot’s licence, rating or certificate we recommend that Heads of Training contact EASA or the appropriate competent authority to establish what training would be recognised.
Could I seek a new a third country approval from EASA before the UK’s participation in EASA ceases?
EASA has stated previously that it would accept third country applications from UK Approved Training Organisations. Organisations would need to decide whether, after the UK’s membership of the EASA system ceases at the end of the transition period and if there is no mutual recognition of safety certificates between the UK and European systems, they would 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.
I am currently training with non-UK Approved ATO (or DTO) for my Part-FCL licence, which will be issued by the UK. Will my training still be recognised?
Yes. your training will be recognised for up to two years after UK participation in EASA ceases if you are training with at an ATO or DTO located outside the UK which had their Approval Certificate issued prior to the end of the transition period and which continued to be valid during the training period.
How will the qualification of Flight Simulator Training Devices (FSTDs) be affected when the transition period ends?
For Flight Simulator Training Device (FSTD) operators planning to use their devices to deliver training to UK CAA Approved Training Organisations from 1 January 2021, there will be new rules, which will mean that:
- Only EASA or EEA Member State FSTD qualification certificates that have been issued prior to 1 January 2021 will be recognised by the CAA, and only up to the due date of their next evaluation;
- EASA or EEA Member State FSTD qualification certificates issued on or after this date will not be recognised by the CAA.
EASA has invited CAA FSTD operators to apply for an EASA qualification certificate using the ‘early applications’ process detailed on their website.
FSTD qualification certificates held by operators who have taken the required steps to complete transition to EASA oversight before the end of 2020, or who are already under the oversight of EASA or another EAA Member State, will be automatically recognised by the CAA until the next recurrent evaluation. After that date a CAA FSTD qualification certificate will be required to allow any CAA Approved Training Organisation (ATO) to conduct accredited training on those FSTDs.
FSTD operators who have applied for EASA qualification certificates but will not transition to EASA oversight before the end of 2020 will have their EASA qualification certificates issued on or after 1 January 2021. Consequently, such qualifications will not be automatically recognised and a CAA FSTD qualification certificate will be required to allow any CAA ATO to conduct accredited training on affected FSTDs from 1 January. FSTD operators will need to maintain an established CAA qualification certificate in parallel with an EASA one.
We recommend that all CAA ATOs conduct a review of the FSTDs they are currently approved to use for training (as detailed on the ATO certificate) because the above changes may affect the CAA qualification status of some or all of these devices from 1 January.
The process that operators of EASA or EAA Member State qualified FSTDs will need to follow to be issued with a CAA FSTD qualification certificate from 1 January will be outlined shortly.
Please contact the CAA FSTD section (firstname.lastname@example.org) or your CAA ATO inspector if you have any questions.
What will FSTD operators need to do ensure that CAA ATOs can conduct approved training on their Flight Simulator Training Devices (FSTDs) when the transition period ends?
FSTD operators with qualification certificates issued by EASA or EEA Member State will need to adopt the following process if they have a requirement to enable CAA ATO’s to conduct accredited training on the affected FSTDs from 1 January:
Prior to the next EASA “recurrent evaluation due” date being reached in 2021, application must be made to the CAA for a recurrent FSTD evaluation, to be conducted in the same timeframe as the 2021 EASA evaluation.
The CAA FSTD Section will then liaise with the operator to schedule and conduct a recurrent evaluation of the FSTD. The resulting evaluation report produced will be annotated to show this as a CAA initial evaluation (only for the first evaluation in 2021).
Assuming the CAA FSTD evaluation team are satisfied with the outcome, a CAA FSTD qualification certificate will then be issued to the operator valid from that date. The CAA will allocate a unique identifier code to the FSTD, similar to the one already allocated by EASA or EEA Member State. The FSTD will then enter the standard CAA FSTD oversight cycle based on the initial issue date shown on the qualification certificate.
A FSTD Compliance Monitoring System (CMS) audit of all operators coming under CAA oversight in 2021 will also be required.
On receipt of all new applications for FSTD recurrent evaluations, the CAA will liaise with operators to schedule the CMS audit, which will be conducted according to established processes. A completed CAA application form SRG2198 will need to be submitted together with payment based on the fees defined in the CAA Scheme of Charges (Personnel Licensing) to cover the CMS audit.
The first CMS audits of operators coming under CAA oversight will be spread over 2021/2022. This will initiate a 24-monthly CAA audit oversight cycle for each operator.