The UK-EU trade deal, announced on 24 December 2020, includes agreements on air transport and aviation safety which are due to come into effect at 23.00 GMT on 31 December 2020 when the UK ceases to take part in the EU Aviation Safety Agency (EASA) and other EU institutions.

While the agreements involve some elements of continuity, they do not constitute a replication of the UK’s regulatory arrangements as part of the EASA/EU framework and many sections of the aviation and aerospace industries will face changes after 31 December, as this microsite sets out.

We will study the detail of the new agreements and will update relevant pages of the microsite as information becomes clearer about how the new arrangements will work in practice. We will 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            

This section of the CAA microsite has been tailored for a GA audience. 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.ukFor the vast majority of UK Private Pilot License holders, you will continue to be legally valid for the operation of UK- registered aircraft from 1st January 2021. The CAA will continue to issue and reissue pilots’ licences when they are lost damaged, when details needs to be changed or pilots’ privileges updates as we do now. Over time this would this include removing references to EASA.


CAA UK-EU transition webinar: General Aviation

Following the live webinars hosted on Thursday 26 and Friday 27 November 2020, please find the video recording of the session here.

A Q&A of all outstanding questions not answered in the live session has been included on this page.

Airworthiness

CS-LSA currently imposes a 600 kg day VFR only limitation to LSA aircraft. Might this be relaxed in future? – to include night VFR, for example, or with a greater weight limit (Switzerland for example allows 650 kg MTOW for home built LSA’s).

The day VFR limitation is listed in both the certification specification (CS-LSA) and the approved flight conditions. There is no intention to revise CS-LSA upper MTOW limit at the present time. It could be possible to change these limitations in the future if it had enough support. Please refer to CAP1985: UK General Aviation opportunities after leaving EASA – a consultation

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If I have transferred my UK issued part 66 AML to an EASA AML. Will I be able to regain my UK part 66 AML based on the fact that the initial AML issue was from 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, 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 had previously transferred their licence to another EU member state to allow the restoration of their UK licence. The process for this would be outlined at the end of the transition period.The UK CAA would open an application process for engineers who had previously transferred their licence to another EU member state to allow the restoration of their UK licence. The process for this would be outlined at the end of the transition period.

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From the 1st January, will existing part 145 maintenance facilities based in the UK be allowed to continue maintaining all EASA registered aircraft or solely G Registered aircraft?

To continue to certify EU-registered aircraft you would also need to hold an EASA Part 145 approval. The European Commission has said previously 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 they wish to retain both a national and an EASA approval. Further details regarding the EASA application process can be found on this link.

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What will happen to aircraft who need minor repairs when flying in member EU states. Will there be any ability to use EASA certified mechanics for small repairs.

The text of the regulation allows, in unforeseen circumstances, the owner to authorise a person with proper qualifications and experience to maintain and release the aircraft. The owner is responsible for getting the maintenance rechecked within seven days and keeping all the records of the maintenance and the qualifications of the person who did the maintenance. If a continuing airworthiness management organisation is involved, the owner must inform them within seven days (or 30-Days in certain circumstances). The full regulation is in Part-145.A.50 (f), M.A.801 (c) or ML.A.801 (c)

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Will Part -ML be reviewed to consider amending the requirement for 100 hour checks as pseudo annual checks? Flying school aircraft are flying 600+ hours/year and require a 100 hour check after 3 weeks at peak times

There is already provision within Part-CAO for the organisation to apply to the CAA to an alternative to the Minimum Inspection programme within Part-ML (CAO.A.17). Further guidance is in preparation

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As a non UK citizen, will I be able to keep my aircraft on the UK register and in the affirmative, can it be maintained by an EASA certified workshop on the continent after the EU exit

You may keep your aircraft on the UK register subject to to the eligibility criteria here: https://www.caa.co.uk/Aircraft-register/Registration-information/How-to-register-an-aircraft/How-to-register-an-aircraft/ The workshop performing the maintenance would need to hold a UK Maintenance Organisation Approval.

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We have an ongoing application to EASA for flight conditions on a PtF aircraft. If this is not issued prior to 31 December 2020 will we need to restart the process with the CAA?

If the UK is the State of Design of the Aircraft you will need to restart the process. If the aircraft state of design is an EASA member state it is a matter for EASA.

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When working under Part CAO can an individual with an EASA 66 licence be authorised to be an ARC signatory on G reg aircraft after 31 December 2020?

Yes. 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, it is intended that you would be able to continue to work on UK-registered aircraft for up to two years after the end of the transition period unless your licence changes or expires (whichever occurs soonest). 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.

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Will an EASA issued Form 1 continue to be valid in the UK?

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

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It is possible to fly and train in N-Reg aircraft within UK today using a UK issued licence, without needing special permission from DfT or an FAA licence? Will this be possible as before, and will similar arrangements also apply for EASA registered aircraft (since they would be considered as third country aircraft in the UK)?

From the 1 January 2021, holders of UK CAA issued Examiners Certificate, you may not be able to conduct Skill Tests or Proficiency Checks for EASA Member State licence holders. Examiners should contact the license issuing Member State of the licence that the pilot for Skill Test or Proficiency Check holds to confirm if they can conduct the Skill Test or Proficiency Check.

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Can a EU part 66 holder apply now for a UK licences and hold both ?

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 end of the transition period. 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, 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 had previously transferred their licence to another EU member state to allow the restoration of their UK licence. The process for this would be outlined at the end of the transition period.

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Licensing

 

EASA FCL training courses in EU country - will EU training organisations issue UK licences or will a UK PPL revalidation be required ?

The Withdrawal Act allows the UK CAA to accept a licence, rating, certificate and approval issued by an EASA Member State before the 1 January 2021. 

Flight training for the issue of a licence, rating or certificate conducted at an ATO or DTO within an EASA Member State will therefore, be accepted for this period for the issue of a UK Part-FCL licence, rating or certificate.

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You state that persons holding an EASA licence will only be able to fly a UK reg aircraft for two years. The ANO Schedule 8 allows an ICAO licence holder to operate any UK Reg Annex 1 aircraft. After 1 January 2021 if there are no EASA G Reg aircraft why will Schedule 8 not apply?

Aircraft referred to as EASA Aircraft will be called UK Part 21 aircraft from the 1 January 2021. To fly a UK (G) registered aircraft certificated under UK Part 21 the pilot must hold a UK Part-FCL licence or a validated ICAO compliant licence or an EASA Part-FCL licence issued by an EASA Member State.

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I have to convert my UK EASA ATPL to EASA, as l will be operating a Maltese registered jet. However, l am also a current UK FI and Flight Examiner. Can l continue to examine and instruct in the UK? I also have a stand-alone UK ATPL. Can l use this for instructing and examining?

According to the guidance from EASA to Member States from the 1 January 2021, UK issued Part-FCL licences will not be accepted to operate EASA aircraft registered in EASA Member States. The CAA published a reminder (SW 2020/268) to pilots recently that if they need to transfer the State of Licence issue then they should do so as quickly as possible.

The guidance from EASA to Member States indicates that if the transfer has commenced prior to the 1 January 2021, Member States should continue to process the application.

For those who hold Instructor and Examiner Certificates on their UK licence they will need to contact the EASA Member State that they are transferring to, to see if they will endorse their EASA Part-FCL licence with an Instructor and Examiner Certificate.

If you want to instruct and examiner on Part 21 aircraft for UK Part-FCL licence holder, you will need to reinstate your UK Part-FCL licence past January 2021, as the UK “standalone” licence/rating/certificate is only valid for non Part 21 G reg aircraft.

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I have EASA licences for fixed and rotary and I understand that these will migrate into UK licenses. I do a bulk of my rotary flying in Mallorca. Is it now best that I get a EASA helicopter license also?

According to the guidance from EASA to Member States from the 1 January 2021, UK issued Part-FCL licences will not be accepted to operate EASA Aircraft registered in EASA Member States. The CAA published a reminder (SW 2020/268) to pilots recently that if they need to transfer the State of Licence issue then they should do so as quickly as possible. The guidance from EASA to Member States indicates that if the transfer has commenced prior to the 1 January 2021 the Member States should continue to process the application.

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If you have SOLI'ed out but the process is being delayed due to COVID lockdown in Ireland, will the CAA be flexible if the EASA license isn't issued until 2021?

According to the guidance from EASA to Member States from the 1 January 2021, UK issued Part-FCL licences will not be accepted to operate EASA Aircraft registered in EASA Member States. The CAA published a reminder (SW 2020/268) to pilots recently that if they need to transfer the State of Licence issue then they should do so as qucikly as possible. The guidance from EASA to Member States indicates that if the transfer has commenced prior to the 1 January 2021 the Member States should continue to process the application.

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I’m an FE, can I deliver a PC to a pilot with an Italian licence?

From the 1 January 2021, holders of UK CAA issued Examiners Certificate, you may not be able to conduct Skill Tests or Proficiency Checks for EASA Member State licence holders. Examiners should contact the license issuing Member State of the licence that the pilot for Skill Test or Proficiency Check holds to confirm if they can conduct the Skill Test or Proficiency Check.

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Will the IR(R) become a UK IMC licence on 1 January 2021?

The Instrument Meteorological Conditions (IMC) Rating, is endorsed onto UK national PPLs*. The same rating is endorsed onto UK Part-FCL licences* but is called the Instrument Rating (Restricted). Initially from the 1 January 2021, there are no plans to change this arrangement.
*With exception to the UK NPPL(A) and Part-FCL LAPL.

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How will a UK CAA PPL licence that has not been changed to a JARS or EASA licence be revalidated?

From the 1 January 2021, there will be no change to UK CAA national private pilot licences which are issued for the lifetime of the licence holder. The ratings endorsed are maintained as per the Schedule 8 of the ANO 2016.

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If you have an expired SEP on an EASA PPL now and do not intend to renew until 2021 with a DTO, is anything required to be done or just renew as normal?

From the 1 January 2021, there will be no change to the requirements for the renewal of a class rating. However, if you hold an EASA Part-FCL licence issued by an EASA Member State and intend to renew the rating with a UK Flight Examiner, from the 1 January 2021 this may not be accepted by the issuing Member State.

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If I completed the required training and test, would the CAA issue an EASA PPL (A) right up until 31 December 2020?

From the 1 January 2021, the CAA will issue UK Part-FCL licences. All UK Part-FCL licences will be considered third country licences by EASA and the Member States.

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Will an NPPL and a LAPL have the same geographic constraints after 1 January 2021?

Both the NPPL and LAPL are not issued in accordance with the standards and recommended practices of the Annex 1 to the Chicago Convention, this is often referred to as a sub-ICAO licence. The UK had agreements with some countries which allowed holders of UK NPPLs to operate UK (G) registered aircraft in European Airspace. Although, the LAPL is issued in accordance with the EASA Aircrew Regulation and was accepted across all EASA Member States. From the 1 January 2021, the UK Part-FCL LAPL will no longer be accepted, the CAA and the DfT will be working with EASA and the individual Member States to re-establish those agreements to allow both NPPL and LAPL holders to fly outside of UK airspace.

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When typically going for dual approval as an EASA and UK ATO, would this mean holding 2 different ATO manuals or would this all be done on the same manuals?

According to the guidance from EASA to Member States, direct oversight of third country ATOs by EASA from the 1 January 2021, may require specific manuals for each regulatory approval.

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Will training organisations that currently hold EASA approvals, and who are based in the USA be able to continue to carry out skills test etc for type rating/renewal/revalidation from 1 January 2021?

The Withdrawal Act allows the UK CAA to accept a licence, rating, certificate and approval issued by an EASA Member State before the 1 January 2021, for a period of 2 years or up to the next revalidation or renewal of the privileges.

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If your currently training for a LAPL and was intending to train in Spain, next spring, can you still do that?

If you have not completed the course and passed the Skill Test by 1 January 2021, this should still be OK, but you will need to check a couple of things.

Which EASA Member State or the UK the training organisation has either declared or is approved by? 

Which EASA Member State or the UK will be the state of licence issue? This is usually dependent on which state you have gained your Medical Certificate through.

If the competent authority of the ATO or DTO is within an EASA Member State or has direct oversight from EASA, then this will be accepted by the EASA Member States and the UK for licence issue for a period of 2 years.

If the competent authority is the UK CAA then this may not be accepted by other EASA Member States for licence issue.   training organisation has either declared or is approved by?  If this is an EASA Member State then this will be acceptable, if this is the UK CAA then this may not be accepted by other EASA Member States for licence issue. This will also depend which state issues the licence.

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Will microlights pilots who have NPPLs still be able to fly 3-axis m/lights into Europe from the UK?

From the 1 January 2021, holders of a UK NPPL or UK Part-FCL LAPL cannot fly outside of UK airspace. Aircraft with a Permit to Fly may not be able to fly outside of UK airspace. The UK CAA and DfT will be working with EASA and the individual Member States in the coming months to resolve these issues.

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I have a non-UK EASA PPL. How - and how soon - can I obtain a UK PPL based on that, i.e not having to do any more exams or tests?

The terms for licence holders returning to the UK or seeking to gain a UK Part-FCL licence after changing state of licence issue will soon be published on the CAA website. In the meantime, the Withdrawal Act allows the UK CAA to accept a licence, rating, certificate and approval issued by an EASA Member State before the 1 January 2021, for a period of 2 years. 

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For those of us who have transferred our licences (SOLI), when will you publish guidance on obtaining a UK licence? We are now only 5 weeks from 1 January 2021.

The terms for licence holders returning to the UK or seeking to gain a UK Part-FCL licence after changing state of licence issue will soon be published on the CAA website. In the meantime, the Withdrawal Act allows the UK CAA to accept a licence, rating, certificate and approval issued by an EASA Member State before the 1 January 2021, for a period of 2 years or up to the next re validation or renewal.

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Will a UK Part-FCL LAPL continue to be “upgradeable” to an ICAO-Compliant UK PPL (i.e. to allow flight in Europe in due course).

Yes, the UK Part-FCL LAPL to UK Part-FCL PPL course in FCL.210.A/H(b) will still be available.

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Will an aerobatic rating be required by a pilot with a UK licence to fly aerobatics in a UK registered aircraft?

After the 1 January 2021, for holders of a UK Part-FCL or UK Part-SFCL licence to be able to conduct aerobatics the requirement to hold an aerobatic rating will still apply. For holders of UK national licences there is no requirement to hold an aerobatic rating.

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The slides mention "pop across the channel" for a day trip. What about a longer tour through several EU states? Will that be able to proceed more or less as at present? If not, what extra requirement will apply?

You must hold a valid licence*, rating and at least a Class 2 Medical Certificate. The UK (G) registered aircraft requires a valid Certificate of Airworthiness or Permit to Fly. Valid aircraft Insurance that covers operation in European airspace/countries. If the aircraft has a Permit to Fly, then you will need to confirm that each country you plan to fly to will allow UK Permit to Fly aircraft. You will need to check the entry and customs requirements for each country you plan to visit. *If you hold a UK NPPL or LAPL, then at present you may not be able to fly outside of UK airspace.

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My plan was to undertake and complete a CBIR rating in the first half of 2021. Is that possible and what UK rating would result? Then what is the validity of that rating for IR flight across the EU?

The CBM IR will continue to be available after the 1 January 2021. The CBM IR gives the holder ICAO compliant Instrument privileges, so you will still be able to use the rating when operating UK (G) Registered aircraft in UK and other countries airspace. If you hold a licence issued by an EASA Member State and planned to conduct your training at an ATO holding a UK approval certificate, then this course may not be accepted by the EASA Member State.

 

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SPO

Aerial filming for live broadcast and aerial LIDAR photography on SPO. Will our SPO still be valid in EU?

No. A SPO declaration made to the UK CAA will no longer be recognised by European Member States. If an operator would like to conduct operations within a particular EU state, they would need to contact that particular country’s National Aviation Authority or EASA directly.

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I am an operator of a non-UK registered aircraft conducting Aerial Survey, Flying Training, Aerial Photography, Display Flying, Banner Towing, Parachute Dropping or other specialised operations. Do I need to obtain a UK permit to continue these activities beyond 31 December 2020?

Following the EU Exit transition period which finishes on 31 December 2020, operators of non-UK registered aircraft flying for commercial purposes in the UK must apply for a Foreign Carrier Permit.  A Foreign Carrier Permit is usually issued for a 12 month period.  An example of this would be a German registered Parachute aircraft where previously this aircraft would be allowed to conduct parachute operations, the operator must now obtain a Foreign Carrier Permit to continue parachuting operations after 31 December 2020. The Foreign Carrier Permit is issued under Article 252 of the Air Navigation Order 2016 (as amended).

The application form is available on the CAA website – CPG3202Issue01 - Application for a Foreign Registered Aircraft Permit under Article 223 of the ANO 2009 (caa.co.uk)

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General Aviation guidance by aircraft type.

Aerodromes

Licensed Aerodromes with a UK national licence issued by the CAA will be unaffected. No action is required.

The Government has also reaffirmed that a blanket approval will be in place until 30 June 2022 to enable the continuation of international flights at aerodromes/airfields that do not have a permanent Customs & Excise presence and designation. This 18-month approval will enable operators sufficient time to apply for individual permissions.

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Balloons

On the basis that 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, the current Balloon rules for operating in the UK that are in place will remain and will not be replaced.

EASA have established a simple and proportionate rule set for balloons and have structured them into one document. This document is called the EASA Balloon Rule Book and it contains the rules for balloon air operations (Part-BOP), requirements for balloon flight crew licensing (Part-BFCL), continuing airworthiness (Part-ML) and initial airworthiness (CS-31GB, CS-31HB, CS-31TGB).  The edition containing these rules was published in September 2020 by the European Commission (Regulation (EU) 2018/395). We will retain this rule book as the UK Balloon Rule Book after Transition.

All balloon operations on EASA Part-21 balloons, commercial or private are regulated by this rule book. (Note: Annex I balloons are covered under the provisions of the Air Navigation Order (ANO) 2016.)

Click here to find more information on our Guidance for Balloon Operators webpage.

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Gyroplane

Amateur Built Gyroplanes

The current version of EU Regulation (EC) 216/2008 identifies that all amateur built gyroplanes are the responsibility of the national airworthiness authority.

Amateur built gyroplanes, and modifications to such machines, are mostly dealt with by the Light Aircraft Association (LAA) under the existing terms of their approval. Whilst machines and modifications that fall outside these terms of approval should be dealt with by the CAA (UK), it may in certain circumstances be possible to agree and individually delegate investigation and approval to the LAA.

Therefore the regulations and requirements for Amateur Built Gyroplanes as set out on the CAA webpage remain unchanged post the transition period.

Commercially Manufactured Gyroplanes

Commercially manufactured gyroplanes with a MTOW above 560 kg are the responsibility of the European Aviation Safety Agency (EASA).

On the basis that 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, operators of commercially manufactured gyroplanes above 560 kg might need to take action to ensure continued authority to fly. That said, we believe the vast majority of UK registered commercially built gyroplanes have been certificated at or below this mass, so like the amateur built machines will be unaffected. Actions required for any aircraft above 560 kg would depend on individual circumstances and are a matter for each business and individual to consider.

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

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Ex-Military and Historic Aircraft

Aircraft designed for military purposes may be granted Permits-to-Fly by the CAA subject to demonstration of acceptable airworthiness in accordance with CAA procedures and requirements. This policy will therefore not change post the Transition period and when the UK leaves the EU.

Ex-military aircraft may be maintained in accordance with British Civil Airworthiness Requirements (BCAR) Section A8-23/24 and A8-25.

Operators of specific ex-military aircraft must comply with the operational requirements in CAP632 www.caa.co.uk/cap632

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Microlights

Regulation (EU) 2018/1139 excludes Microlights from European Aviation Safety Agency (EASA) Regulations and so they remain subject to national rules. You will need a UK national licence to fly a microlight in UK airspace.

Therefore the regulations and requirements for Microlights set out on the CAA webpage remain unchanged post the transition period.

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