The United Kingdom’s departure from the European Union brought with it a significant and still-evolving change to the regulatory landscape for aviation maintenance: the end of UK participation in the EASA regulatory framework. From 1 January 2021, the Civil Aviation Authority (CAA) became the competent authority for aviation safety regulation in the UK, taking over responsibilities that had previously been delegated to EASA.
For those working in or recruiting for aviation maintenance in the UK, understanding the practical consequences of this change is important. This article sets out where things stood as of mid-2025 and what the ongoing implications are for engineers and employers.
The Regulatory Divergence
At the point of the UK’s departure from EASA, the UK essentially adopted the EASA regulatory framework wholesale into UK law — making the regulations substantively identical at that moment. However, since then the UK and EASA have been developing their respective frameworks independently, and divergence has begun to occur in some areas.
The CAA issues its own regulations (UK CAA Civil Aviation Publications and UK Air Navigation Orders) that now govern UK-registered aircraft and UK-approved organisations, while EASA continues to update its framework for EU member states and associated countries. The pace of regulatory divergence has been gradual but is real and needs to be monitored by compliance teams and quality managers in UK maintenance organisations.
Licence Recognition: The Practical Impact
Perhaps the most significant practical consequence of the EASA/CAA split for maintenance engineers has been the change to licence recognition. Prior to Brexit, a Part-66 licence issued by the CAA was automatically recognised across all EASA member states, and EASA licences were automatically valid in the UK. This mutual recognition simplified both the movement of engineers between the UK and EU and the use of internationally qualified engineers in UK operations.
Post-Brexit, this automatic mutual recognition ended. UK CAA Part-66 licences are no longer automatically valid in EASA member states, and EASA Part-66 licences issued by EU/EEA national authorities are no longer automatically valid in the UK.
In practice, the UK CAA has implemented a conversion process for EASA Part-66 licence holders wishing to obtain a UK licence (generally straightforward and not requiring re-examination for most), and EASA member states have similarly provided conversion pathways for UK CAA licence holders. But the process has added friction and cost for engineers working across the UK-EU border.
Impact on the Workforce
The end of freedom of movement has had a broader workforce impact. Prior to Brexit, EU-qualified engineers could work in the UK on the same basis as UK nationals. Post-Brexit, EU nationals require work authorisation under the UK points-based immigration system, and UK nationals working in EU member states require similar authorisation in those countries.
This has reduced the ease with which UK and EU labour markets have been able to move in response to demand and has added administrative complexity to international contract placements. Protec Technical has developed expertise in navigating these arrangements, but the reality is that international deployments are more administratively complex than they were pre-2021.
The Aviation Safety Agreement Negotiations
There have been ongoing discussions between the UK and EU about a bilateral aviation safety agreement that would restore greater regulatory alignment and potentially re-introduce mutual recognition of Part-66 licences. Progress on these negotiations has been gradual, and as of mid-2025, a comprehensive agreement had not been concluded. This remains an important policy area for the UK aviation industry, and its resolution would meaningfully benefit the maintenance workforce.
Practical Steps for Engineers
If you are a UK CAA Part-66 licence holder seeking to work in EASA member states, or an EASA Part-66 holder seeking to work in the UK, the practical first step is to contact the relevant national authority about the conversion or validation process. Protec Technical’s consultants can advise on the specific requirements applicable to your situation.
Contact us for guidance on navigating the post-Brexit regulatory landscape, or follow us on LinkedIn for ongoing commentary on regulatory developments affecting the sector.
