Back in the days when the United Kingdom (UK) was a member of the European Union (EU) approved training organisations (ATOs) in the UK could train pilots holding licences issued by any of the 32 EASA states (the EU states plus Iceland, Lichtenstein, Norway and Switzerland). Since Brexit, ATOs approved by the UK CAA can only train pilots who hold, or intend to apply for, licences issued by the UK CAA. Training organisations in the UK that intend to provide training to pilots holding EASA licenses now have to be approved by EASA.
During the transition period when the UK was leaving the EU ATOs in the UK were given the opportunity to apply for EASA approval on the basis of their existing CAA approval. EASA issued certificates to these ATOs at the start of 2021. Many ATOs now hold certificates from both EASA and the UK CAA and can continue to provide training to pilots who hold either UK or EASA licenses.
Those ATOs holding dual approvals will, like many UK businesses, suffer an increased regulatory burden and increased costs. They will be audited separately by EASA and the UK CAA.
There is no fixed fee for holding an EASA approval; instead EASA bills ATOs for the time that inspectors spend on oversight activities. At the time of writing the rate is €247 per hour. The inspectors decide how much time is required and travelling time is billed at the same rate as working time. ATOs approved by EASA can expect an audit every 12 months. The period between audits may be extended once the audit team have confidence in the ATO’s internal compliance monitoring processes.
EASA has been responsible for oversight of ATOs outside the territory of the EASA states since 2013. EASA inspectors have adopted a robust attitude to audits and inspections and have suspended or revoked the certificates of a number of ATOs. The EASA inspectors may interpret some regulations differently to the UK CAA and problems could arise if practices that were found acceptable by UK CAA are not acceptable to EASA.
Alternatives for ATOs
ATOs based outside the EASA states must apply to EASA for approval but ATOs based in the EASA states can provide training at satellite bases in other countries.
Some ATOs previously based in the UK have decided that it is preferable to establish a principal place of business in an EU state rather than apply for approval from EASA. Boeing have a large training centre in the south of England, but training is provided by Boeing Ireland Limited. CAE have multiple locations in the UK but deliver training under their approval from the Danish aviation authority.
Instructors and examiners working in EASA-approved ATOs must hold certificates issued by an EASA state (EASA does not issue certificates or licences). UK CAA have stated that they will accept licences and certificates issued by EASA states for a period after Brexit provided that the licence/certificate was issued prior to March 2021. After this period instructors will need to hold a UK certificate to train UK licence holders and an EASA certificate to train EASA licence holders.
At the time when the UK left the EU all of the technical provisions of European rules were adopted by the UK as national regulation. Regulations that come into effect in Europe after January 2021 are not automatically adopted by the UK. The UK may also introduce changes that have not been proposed in Europe. It may become difficult for ATOs to offer the same courses of training for UK and EASA licence holders, especially for ground school courses.
What does this mean for student pilots?
Student pilots who started training towards a CPL or (frozen) ATPL at a UK ATO before Brexit will qualify for both UK and EASA licences provided that the ATO they attended had applied for EASA approval. Despite the extra fees these pilots would be well advised to apply for both licences when they graduate.
Student pilots at UK ATOs that did not apply for EASA approval will only qualify for UK licences and will be restricted to flying aircraft registered in the UK.
Pilots holding licenses and taking advanced training for additional ratings (e.g., type ratings) need to make sure that they attend an ATO that matches their state of licence issue, a UK ATO for UK licence holders and an EASA ATO for EASA licence holders.
Anyone considering enrolling at an ATO for professional pilot training should decide in advance what type of licence he/she needs. An EASA licence can be used to operate aircraft registered in any of the EASA states and, at the time of writing, can be ‘validated’ to fly UK-registered aircraft. A UK licence cannot be used to operate aircraft registered in the EASA states. Attending an ATO with ‘dual approval’ currently looks like a good option but the potential pilot should be aware that, in the future, there could be a requirement to sit additional exams to qualify for UK and EASA licences (e.g., air law) and some ATOs may find that the burden of maintaining dual approval is too onerous.