Can a UK Maintenance Company Complete EASA OJT Without Part-147 Approval?

Yes, in principle. A UK maintenance company can conduct EASA Part-66 on-the-job training (OJT) without holding Part-147 approval, provided the organisation, training programme, supervision and records meet the applicable Part-66 and Part-145 requirements, and the relevant licensing authority accepts the arrangement.

The important distinction is between aircraft type training and OJT. Part-147 approval is generally required for an approved aircraft type training course, but it is not automatically required for an organisation conducting supervised practical OJT.

Because acceptance depends on the approval basis and the authority issuing the licence, applicants should confirm the arrangement before beginning training. The Kiwa EASA licences and OJT approval guide provides further context on how OJT approval can affect UK-based applicants.

What is EASA OJT?

For EASA Part-66 purposes, OJT is supervised maintenance performed on a specific aircraft type within an appropriately approved maintenance organisation.

The trainee must complete a representative range of maintenance tasks under direct supervision. Typically:

• Tasks are performed on an actual aircraft or applicable component.
• Each task is recorded against a job card or equivalent maintenance record.
• The trainee signs the task record and a designated supervisor countersigns it.
• The work is completed under appropriate supervision.
• An independent, appropriately qualified assessor conducts the final assessment.

OJT is not a classroom course or a collection of simulated exercises. It is production maintenance carried out within an approved maintenance environment.

Applicants should compare the proposed programme with the current EASA Easy Access Rules for Continuing Airworthiness, including the applicable Part-66 requirements and associated acceptable means of compliance.

Is Part-147 approval required?

Not necessarily.

Part-147 organisations are entitled to conduct approved aircraft type training courses in accordance with Article 6 of Regulation (EU) No 1321/2014. However, Appendix III to Part-66 allows other organisations, including Part-145 maintenance organisations and manufacturers, to be approved by the relevant competent authority to provide elements of aircraft type training, including:

• The theoretical element of aircraft type training.
• Theoretical examinations.
• The practical element of aircraft type training.
• Practical training and assessment.

This means that a Part-145 organisation may be able to conduct the practical OJT element without also being a Part-147 organisation.

The organisation must have the appropriate maintenance approval, aircraft capability, procedures and competent personnel to support the training. It cannot simply designate normal maintenance activity as OJT.

The regulatory framework should be checked against the latest material published by EASA on continuing airworthiness, because approval requirements and authority guidance may change.

Key approval requirements

For a Part-66 applicant, the first aircraft type rating in a category or subcategory normally requires satisfactory completion of the applicable OJT under point 66.A.45(c) and Appendix III.

The OJT must be acceptable to the competent authority responsible for issuing the Part-66 licence. This is particularly important where the maintenance company is located in the UK but the licence is issued by an EASA Member State or another EASA licensing authority.

The maintenance organisation should also have an approved OJT procedure in its exposition, normally within the relevant MOE section, such as an OJT procedure in MOE Chapter 3.15. The procedure should define:

• The aircraft type and applicable rating.
• The tasks to be completed.
• The supervision arrangements.
• The competence requirements for supervisors and assessors.
• The method for recording completed tasks.
• The final assessment process.
• Controls for discrepancies, incomplete tasks and repeat assessments.

The competent authority responsible for the maintenance organisation must approve the relevant organisational procedures. However, conducting Part-66 licensing training is not, by itself, a standard Part-145 privilege. The procedure cannot therefore be assumed to be valid for every licensing authority. The authority issuing the licence must accept or approve the OJT in accordance with Appendix III.

For UK approval information, organisations should consult the UK CAA Part-145 guidance and confirm precisely which privileges and procedures are included in their approval.

Can this be done in the UK for an EASA licence?

Potentially, yes, but the organisation’s approval status must be checked carefully.

A UK maintenance company may hold:

• UK CAA Part-145 approval only.
• EASA Part-145 approval.
• Dual UK CAA and EASA Part-145 approval.
• Another approval accepted under the applicable regulatory arrangements.

UK CAA Part-145 approval is not automatically equivalent to EASA Part-145 approval following the UK’s departure from the European Union. For EASA Part-66 OJT, the organisation must hold approval acceptable for the intended licensing route and aircraft work.

Before training begins, the applicant should confirm:

1. Which authority issued, or will issue, the Part-66 licence.
2. Whether the UK organisation holds the necessary EASA-approved maintenance capability.
3. Whether the licensing authority has accepted the organisation’s OJT programme and records.

Without those confirmations, completed maintenance tasks may constitute useful practical experience but may not be accepted as the OJT required for the first type rating.

OJT is not required for the basic Part-66 licence

OJT should not be confused with the experience required for the basic licence.

EASA Part-66 basic licensing is normally based on the relevant examinations and practical maintenance experience under point 66.A.30. OJT becomes mandatory when adding the first aircraft type rating in a particular category or subcategory under point 66.A.45 and Appendix III.

The distinction is:

• Basic Part-66 experience: Builds general maintenance competence and supports a basic licence application.
• Theoretical type training: Provides aircraft-type knowledge and supports the type examination.
• Practical type training: Provides structured hands-on training and supports practical assessment.
• OJT or structured OJT: Demonstrates supervised production maintenance on the aircraft type and supports the final assessment for the first type rating.

A company may therefore provide useful Part-66 experience without providing approved OJT. Experience alone does not constitute OJT.

Applicants should also distinguish OJT from the broader experience evidence required for a licence application. For guidance on documenting experience, see our article on completing a CAP 741 logbook.

The relevance of Part-145 maintenance experience

The organisation must maintain an active and relevant maintenance environment. Under 145.A.35(c) and AMC 145.A.35(c), it must ensure that certifying staff and support staff are involved in at least six months of actual relevant aircraft or component maintenance experience during any consecutive two-year period.

This requirement supports continuing competence within the maintenance organisation. It does not approve an OJT programme or replace the Part-66 OJT requirements.

Similarly, where a B2 licence holder is exercising the relevant certification privileges under 66.A.20(a)(3)(ii), the holder must have completed:

• The relevant Category A aircraft task training.
• Six months of documented practical experience covering the scope of the authorisation.

That task training must include appropriate practical and theoretical training for each authorised task. It is a separate competence and authorisation requirement, not a substitute for the OJT required for the first aircraft type rating.

What records should the UK company provide?

A credible OJT package should allow the licensing authority to trace every task from the aircraft maintenance record to the trainee and supervisor.

Records should normally identify:

• Aircraft registration and type.
• Maintenance organisation and approval details.
• Work order or job card reference.
• Task description and ATA chapter, where applicable.
• Date of completion.
• Trainee identity and signature.
• Supervisor identity, approval status and countersignature.
• Any limitations or restrictions.
• Final assessment details.
• The independent assessor’s conclusion.

The task list must represent the scope of the intended rating. A small number of unrelated tasks, office-based technical work or repeated low-complexity activities will not normally demonstrate the required breadth of practical competence.

Where a task involves an independent inspection, the roles and authorisations must be controlled separately from the OJT record. Read who can perform an independent inspection for guidance on competence, authorisation and independence requirements.

Can the UK CAA approve EASA OJT?

The answer depends on the regulatory relationship and the authority issuing the licence.

The UK CAA may approve the maintenance organisation’s UK approval and associated procedures. However, an EASA Part-66 licence is issued under the authority of the relevant EASA Member State or other competent authority responsible for that licence. That licensing authority must be satisfied that the OJT meets Appendix III.

A UK maintenance company should therefore not market its programme simply as “EASA OJT” unless it can identify:

• The Part-145 or other applicable approval supporting the activity.
• The authority that approved the OJT procedure.
• The licence-issuing authority’s acceptance of the arrangement.
• The specific Part-66 rating and aircraft type covered.

Where regulatory interpretations or acceptance remain unclear, the safest approach is to obtain written confirmation from the relevant competent authority before the programme starts.

UK experience, CAP 741 and military service

For applicants pursuing a UK CAA Part-66 licence, practical experience is normally documented through appropriate maintenance records, including CAP 741-style experience logbooks where applicable. Those records demonstrate maintenance experience, but they should not be confused with a completed EASA OJT programme.

Military applicants may also have previous maintenance experience assessed through UK Ministry of Defence recognition pathways. Recognised military experience can support a licensing application, but it does not automatically satisfy the separate OJT requirement for the first aircraft type rating unless the competent authority accepts the evidence under the applicable Part-66 provisions.

For the wider UK licensing process, see our guide to becoming a licensed aircraft maintenance engineer.

Need help checking your Part-66 experience records? Analyse Your Logbook Today! Our Part 66 Logbook Analysis service can help you review your records and identify potential gaps before submitting an application.

Final answer

A UK maintenance company can conduct EASA Part-66 OJT without Part-147 approval, but only where the arrangement is properly controlled and accepted by the relevant authorities.

The company will generally need an appropriate Part-145 approval and aircraft capability, an approved OJT procedure, suitably qualified supervisors and assessors, complete task records, and acceptance by the competent authority responsible for issuing the applicant’s Part-66 licence.

Part-147 approval is principally associated with approved aircraft type training courses. It is not an automatic prerequisite for practical OJT. However, a UK company with only UK approval, no accepted OJT procedure or no agreement from the relevant EASA licensing authority cannot assume that supervised maintenance experience will be accepted as EASA OJT.