Changing the EASA Part-66 Competent Authority During OJT or Type Training

Changing the competent authority responsible for an EASA Part-66 Aircraft Maintenance Licence during aircraft type training or On-the-Job Training (OJT) requires careful coordination. The training may be valid, but its acceptance depends on the authority that issued the licence, the organisation that approved the training and whether the receiving authority accepts the existing procedures and records.

This is particularly important where an applicant starts training under one EASA licensing authority and later relocates, changes employer or intends to have the licence managed by another authority.

The key principle: the licensing authority controls first-type OJT

OJT is not required to obtain the basic EASA Part-66 licence. It becomes relevant when an applicant seeks the first aircraft type rating in a particular category or subcategory.

Under 66.A.45(c) and Section 6 of Appendix III to Part-66, first-type OJT must be satisfactorily completed and approved for the purpose of adding the rating. The OJT must be approved by the competent authority that issued the Part-66 licence. Applicants should check the current requirements in the EASA Easy Access Rules for Continuing Airworthiness before relying on an existing approval.

This creates an important distinction:

• The maintenance organisation's competent authority supervises the organisation's approval.
• The licensing authority manages the applicant's Part-66 licence and decides whether the OJT is acceptable for rating endorsement.
• These authorities may be the same, but they are not necessarily the same.

Changing the licensing authority while OJT is in progress can therefore affect the approval route, even if the training is being carried out at the same Part-145 organisation.

OJT approval is not automatically transferred

An OJT programme approved or accepted by the original licensing authority does not automatically become approved by a new authority. Before changing authority, the applicant should obtain written confirmation of:

• The status of the existing Part-66 licence application or licence;
• The OJT programme's approval status;
• The aircraft, tasks and maintenance data covered by the programme;
• The organisation responsible for supervising and assessing the OJT;
• Whether the receiving authority will accept completed tasks and assessments; and
• Whether any remaining OJT must be completed under a revised or separately approved procedure.

The receiving authority may accept the completed portion of the OJT, request additional evidence or require the programme to be reviewed and approved again. There is no general entitlement to transfer an incomplete OJT programme without assessment.

For this reason, an applicant should not change authority simply by submitting a new application and continuing the training. The authority responsible for the licence at the point of endorsement must be able to verify that the complete OJT meets the applicable Part-66 requirements.

Applicants should also distinguish an authority transfer from a new licence application. Our guide to transferring an EASA Part-66 AML between authorities explains the wider licensing considerations.

When the Part-145 organisation is located outside the EASA Member States

A particularly important scenario arises where the Part-145 organisation has its principal place of business outside the EASA Member States.

In that case, the competent authority of the maintenance organisation is EASA. However, EASA is not a licensing authority for issuing an individual Part-66 licence. Consequently, the organisation cannot rely on the normal assumption that its OJT procedures can be included in its Maintenance Organisation Exposition (MOE) for direct use by the licensing authority.

The OJT procedures cannot be included in the MOE solely for this purpose because EASA, as the organisation's competent authority in this situation, is not the authority issuing the applicant's Part-66 licence.

A licensing authority may nevertheless approve the OJT procedures directly. Those procedures must be contained in a separate controlled document outside the MOE and must not be treated as an MOE procedure. The licensing authority issuing the licence must decide whether the separate OJT procedure is acceptable for the purposes of Appendix III, Section 6.

This is particularly relevant when an applicant changes from one EASA licensing authority to another during training. The first authority may have accepted the separate OJT documentation, while the second authority may require its own review before accepting the same programme.

Where the licensing and maintenance authorities are different

Where the licensing authority is also the competent authority of the Part-145 organisation, the OJT approval route is usually more direct. The authority can oversee both:

• The organisation's OJT procedure; and
• The applicant's Part-66 licensing requirements.

Where different authorities are involved, acceptance is not automatic. The licensing authority remains responsible for deciding whether the OJT procedure and the resulting evidence are acceptable for licensing purposes.

This principle is reflected in the AMC to Section 6 of Appendix III to Part-66. In practical terms, the applicant must establish acceptance with the licensing authority rather than assume that approval by the Part-145 authority alone is sufficient. The latest regulatory material should be checked against the EASA continuing airworthiness regulations.

Changing authority during type training

Aircraft type training and OJT are related but separate elements.

A type-training course may be delivered by:

• An organisation approved under Part-147;
• A Part-145 organisation using an approved arrangement where permitted; or
• Another organisation or authority arrangement recognised under the applicable Part-66 provisions.

The course approval and the OJT approval should therefore be checked separately when changing authority.

A change of licensing authority does not necessarily invalidate a completed Part-147 type-training course. However, the new licensing authority may still need to verify:

• That the course was approved by the appropriate competent authority;
• That the course covered the correct aircraft type and licence category;
• That the examination and practical elements were completed correctly;
• That the course certificate and supporting records are authentic and traceable; and
• That the course remains acceptable under the licensing authority's procedures.

A Part-147 approval is not the same as approval of an individual's OJT programme. Completing type training does not, by itself, satisfy the first-type OJT requirement. Applicants looking for an approved training provider can use our Part-147 training schools resource.

Special rule for Group 1 airship type training

For Group 1 airships, type-training courses must be directly approved by the competent authority in all cases.

The competent authority must have a procedure to ensure that the syllabus covers all relevant elements contained in the maintenance data issued by the Design Approval Holder (DAH), in accordance with 66.B.130(b).

Accordingly, if the applicant changes licensing authority during Group 1 airship type training, the receiving authority should confirm whether it accepts:

• The original authority's direct course approval;
• The syllabus and its relationship to the DAH maintenance data;
• Any completed examinations or practical training; and
• The remaining training under the receiving authority's approval procedure.

This is not an area where an applicant should rely only on a course certificate or an employer's confirmation.

UK CAA and EASA authority changes

The UK position must be distinguished from the EASA system. The UK CAA Part-66 guidance should be consulted for current UK application and licensing requirements.

Since the UK's withdrawal from the EU aviation system, a UK CAA Part-66 licence is a UK Part-66 licence, not an EASA Part-66 licence. The UK CAA cannot simply be substituted for an EASA Member State authority as though it were another EASA competent authority.

An individual holding an EASA Part-66 licence issued by an EASA Member State, such as the Netherlands, should establish whether the intended change is:

• A transfer or change of EASA licensing authority; or
• A separate application for a UK CAA Part-66 licence or UK recognition route.

The two processes should not be treated as interchangeable. In particular, existing EASA OJT or type-training evidence should be submitted to the relevant authority for confirmation before the applicant assumes that it will support a UK licence application. Our guide to certifying EASA aircraft in the UK after Brexit provides additional context.

Recommended process before changing authority

1. Identify the authority responsible for the licence

Confirm which authority currently issues or manages the Part-66 licence. This is the authority responsible for approving first-type OJT for the licence.

2. Obtain the OJT procedure

Request the exact approved or accepted OJT procedure, including its document number, revision status and approval basis.

If the Part-145 organisation is outside the EASA Member States, confirm that the procedure is held in a separate document and is not incorrectly presented as part of the MOE.

3. Freeze and verify completed evidence

Ensure that completed OJT tasks, assessments, supervisor signatures, dates, aircraft registrations and maintenance references are fully recorded and traceable. The record should clearly show what was completed before the change of authority. Accurate experience records are also important when maintaining a Part-66 application file, so applicants may benefit from our guide to completing a CAP 741 logbook.

4. Contact the receiving licensing authority

Ask the receiving authority, in writing, whether it will accept:

• The existing licence file;
• Completed OJT tasks;
• The current OJT procedure;
• Type-training certificates;
• Examinations and practical assessments; and
• The Part-145 organisation's supervision and assessment arrangements.

5. Obtain a written transition decision

The applicant should receive a clear decision stating whether the OJT may continue under the existing procedure or whether a new approval, revised document or additional assessment is required.

6. Do not complete the final endorsement stage prematurely

The final type-rating application should be made only after the authority responsible for the licence confirms that the complete training and OJT package is acceptable.

Keep your Part-66 experience evidence organised before an authority change. Analyse your logbook today with Part 66 Logbook Analysis.

Common mistakes

The most frequent problems arise when applicants:

• Assume that EASA mutual recognition automatically transfers an incomplete OJT programme;
• Treat Part-147 type training as a substitute for first-type OJT;
• Assume that Part-145 approval alone validates OJT for licensing purposes;
• Continue training after changing authority without written acceptance;
• Rely on an MOE procedure where the organisation is outside the EASA Member States;
• Treat a UK CAA licence application as a direct continuation of an EASA Part-66 application; or
• Submit task records without the underlying approved OJT procedure.

These issues can lead to rejected evidence, duplicated training or delays in type-rating endorsement. For related guidance, read our article on EASA licences and OJT approval in the UK.

Conclusion

Changing the EASA Part-66 competent authority during type training or OJT is possible, but it must be managed as a regulatory transition rather than an administrative change of address.

For first-type OJT, the critical authority is the authority that issued the Part-66 licence. Where that authority changes, the receiving authority must decide whether it accepts the existing OJT procedure and completed evidence. This is especially important when the Part-145 organisation is based outside the EASA Member States, because EASA may be the organisation's competent authority while not being the applicant's licensing authority.

Applicants should obtain written acceptance before changing authority or continuing an incomplete programme. That step can prevent uncertainty over whether completed type training and OJT will ultimately support the Part-66 type-rating application.