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

Part 66 licence holders may need to take action to minimise impact on their privileges. Actions required will depend on individual circumstances and are a matter for each business and individual. This page sets out what you need to consider.

Update - The UK CAA has developed a flowchart pack to aid Airworthiness organisations in understanding what certification can be accepted once UK participation in EASA and EU institutions ends on 31 December 2020.

Update - UK Regulations can be found on the following link:

https://info.caa.co.uk/uk-regulations/

PART-66 AIRCRAFT MAINTENANCE LICENCE – ISSUED BY THE CAA

UPDATE: If I have a Part-66 licence issued by the CAA, will it still be valid after 31 December 2020?

Yes, CAA issued licences will remain valid. All CAA issued licences will be re-issued in due course to a new UK format which will not have EASA references.  This update will coincide with the normal licence renewal dates or if a licence is submitted for a change.

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

The UK will be classified by EASA 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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UPDATE: If I have a Part-66 Licence issued by the CAA, will I be able to continue to work on UK-registered aircraft?

Yes, CAA-issued licences will remain valid for use on aircraft registered in the UK maintained by organisations approved by the CAA. All CAA-issued licences will be re-issued to the new UK standard, removing EASA references over time. This update will coincide with the normal licence renewal dates or if a licence is submitted for a change.

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UPDATE: If I have a Part-66 Licence issued by the CAA, will I be able to continue to work on EU-registered aircraft?

The UK’s membership of the EASA system ended on 31 December 2020. New arrangements are in place that include recognition of certain safety certificates between the UK and European systems. As a result, you may not be able to continue to release EU-registered aircraft to service.

The UK is classified by EASA as a third country. EU Part 145 has provision to use non-EASA licences to support an approval issued in third countries. This is set out in EU 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.

If you wish to continue to release EU-registered aircraft to service outside the UK or you do not work for a EU Part 145 organisation then you will need to apply for an EU Licence from the National Aviation Authority of an EASA member state. You are advised to have a discussion with the relevant EU NAA as soon as possible about their process and timetable for issuing an EU Licence.

While the CAA will continue to support previous Part 66 state transfer applications under EASA transfer arrangements, the procedures adopted by the receiving EU NAA and recognised validity of the licence during the transfer process may vary between EU member states. Applicants who require continuity of validity throughout the transfer process are therefore advised to immediately contact their intended receiving NAA to identify any potential issues.

Licence holders who transferred their licence to another EU member state previously can now hold both UK and EU licences. The following link to application for reactivation of a UK Licence supports this process.  

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

Yes. The EU/EASA certificates of recognition would continue to be accepted for a period of up to two years in certain circumstances..

The CAA will continue to recognise EU/EASA organsiation approval certificates current and valid on 31 December 2020 initial period of up to two years provided that the licence was issued prior to 31 December 2020. Any new certificate or change to a certificate after this date will not be acceptable within the UK system. Therefore any approval certificate issued after this initial issue or change would not be acceptable for the addition to a UK issued Part 66 Licence.

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If I have completed type training and type ratings with a UK Part-147 approval holder, will I be able to add the types/ratings to my EASA Part 66 licence issued by airworthiness authority of an EASA Member State?

If you have a UK Part-147 issued certificate of recognition (CofR) it may be used to support the issue of a basic licence category or addition of a type rating for UK licence only.

For basic or Type rating CofR issued by a UK Organisation to be added to an EU Part 66 licence issued by an EASA Member State, the training organisation would need to apply and hold an EASA Part-147 approval. However, CofRs issued before 31 Dec 2020 continue to be accepted (refer to EASA FAQ).

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

The EU/EASA Certificates of Recognition (CofR) would continue to be acceptable until 30 December 2022 for inclusion on an UK Part-66 licence in certain circumstances:

  • C of Rs issued prior to 31 Dec 2020 – acceptable.
  • C of Rs issued after 31 Dec 2020 by EU/EASA training organizations whose: 

                o Organisation Approval Certificate (EASA Form 11) was issued before 31 December 2020 – acceptable.

               o Organisation Approval Certificate (EASA Form 11) was issued/amended after 31 December 2020 – NOT acceptable 

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

You should contact the applicable EU NAA to discuss the acceptance of training certificates issued by UK organisations. However CofR’s issued before 31 Dec 2020 by UK Part 147 organisations will continue to be accepted (refer to EASA FAQ).

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

You will need to contact the National Aviation Authority of the state of registration of the aircraft you work on.

If you work outside the EU and UK on EU-registered aircraft, your UK Part-66 licence will no longer be valid for use on those aircraft.

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UPDATE: Can I hold an EU NAA and a UK licence concurrently?

After 31 December 2020, individuals will be able to hold a UK and EASA Part 66 licence concurrently.

Licence holders who transferred their licence to another EU member state previously can now apply via the following link for Reactivation of a UK Licence.

For EU Licence holders who have never held a UK licence, it is possible to apply for  a UK licence via the EU Licence to UK Licence application webpage.

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UPDATE: Can I transfer my licence to an EU member state NAA if UK national limitations are still applied?

Since the 31 December 2020 state transfers between the UK and other EU member states have not been (and continue not to be) possible as the UK has now left the EASA system. There are some outstanding applications for state transfer which the CAA is supporting and the information below may be relevant to.

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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Will 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 the CAA may recognise training examinations and CofRs under certain circumstances.

The CAA will continue to recognise EU/EASA organsiation approval certificates current and valid on 31 December 2020 for a period up to two years, provided that the certificate was issued prior to the 31 December 2020. Any new certificate or change to a certificate after this date will not be acceptable within the UK system. Therefore, any CofR issued after this initial issue or change would not be acceptable for the addition to a UK issued Part 66 licence.

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

Yes.

The CAA will continue to recognise EU/EASA organsiation approval certificates current and valid on 31 December 2020 a period of up to two years, provided that the certificate was issued prior to the 31 December 2020. Any new certificate or change to a certificate after this date will not be acceptable within the UK system. Therefore, any CofR issued after this initial issue or change would not be acceptable for the addition to a UK issued Part 66 licence.

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

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

Yes, they can continue to certify under the UK approval with the following caveats:

UK or Non-EU based

The CAA will continue to recognise EU issued Part 66 licences which are current and valid on 31 December 2020 for an initial period of up to two years provided that they were issued prior to 31 December 2020. Any new licence or change to a licence after this date will not be acceptable in the UK system.

However, the CAA has issued Exemption ORS4 1468 to allow the use of an EU licence issued after 31 December 2020 for a limited period of time whilst the licence holder applies for a UK licence.

All certifying staff will ultimately require a UK Issued Part 66 Licence.

The only circumstance in which a UK issued licence is not required is when UK Part 145.A.30(j) and Appendix IV are applied i.e. where the licence is deemed to be the national licence of the country where the maintenance facility is registered and certifying staff hold national licences allowing for certification under a CAA approval. There are no time limitations applied to these circumstances which is only applicable outside the UK.

EU Based

An EU-issued Part 66 licence may continue to certify G- registered aircraft under the UK Part 145.A.30(j) and Appendix IV, i.e. where the licence is deemed to be the national licence of the country where the maintenance facility is registered, such as a facility within the EU and where the certifying staff hold EU Licences to certify under an CAA approval. There are no time limitations applied to these circumstances.

If you are working for a Part MF/CAO or are independent certifying staff using your EU licence then you can continue to do so as the CAA will continue to recognise EU issued Part 66 licences which are current and valid on 31 December 2020 for a period of up to two years. Any new licence or change to a licence after this date will not be acceptable in the UK system.

However the CAA has issued an Exemption ORS4 1468 to allow the use of an EU licence issued after 31 December 2020 for a limited period while the licence holder applies for a UK licence.

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

CofRs issued before 31 December 2020 by UK Part 147 organisations will continue to be accepted (refer to EASA FAQ).

There is, as of 31 December 2021, no mutual recognition of Part 66 licences or CofR in the UK and European systems. Consequently, you are advised to contact your local EU NAA as soon as possible to discuss the application process in this scenario.

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UPDATE: Will an EU NAA recognise and accept UK-issued 147 examination certificates and/or Certificate of Recognition?

CofRs issued before 31 December 2020 by UK Part 147 organisations will continue to be accepted (refer to EASA FAQ).

After 31 December 2020, there is no mutual recognition of Part 66 licences or Certificates of Recognition between the UK and European systems. Consequently, you are advised to contact your local EU NAA as soon as possible to discuss the application process in this scenario.

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Do I need to remove national limitations from my UK Part 66 Licence prior to a state transfer to another EU Member state?

Since the 31 December 2020 state transfers between the UK and other EU member states has not been possible as the UK has left the EASA system.

For EU Licence holders who have never held a UK licence, please apply for UK licence via the EU Licence to UK Licence application webpage.

Any limitations on an EU licence will be assessed against the UK limitations process and applied accordingly. Any licence limitation which does not conform a similar UK limitation may lead to loss of privileges on the UK licence.

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How does the UK leaving EASA affect the application of Airworthiness Directives for the UK-registered aircraft that I own, operate or manage?

All EU regulations current and valid on 31 December 2020 are retained in UK domestic legislation, including Regulation (EU) No 1321/2014, Part M. This means owners, operators and Continuing Airworthiness Management Organisations (CAMOs) must 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. 

Issue 4 of CAP 747 has been updated to reflect the new UK-EU framework. 

Section 1, Part 1 provides new flowcharts to assist in identifying the applicable mandatory requirements for airworthiness relating to your product. The revision history in CAP 747 provides more details on the changes to the CAP.

You can view CAP 747 here: www.caa.co.uk/CAP747.

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With the UK outside EASA, has the classification of aircraft in CAP 747 changed?

Issue 4 of CAP 747 has been published to reflect the new UK-EU regulatory arrangements.

Each aircraft type is categorised as either:

  • a “Part 21 aircraft”; an aircraft that is included in the scope of Regulation (EU) 2018/1139 (as retained by The European Union (Withdrawal) Act 2018); or
  • a “non-Part 21 aircraft”; an aircraft that is subject to the Air Navigation Order.

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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