What to Do If a KIWA EASA Part-66 Type Rating Is Revoked

A revoked aircraft type rating is serious, but it does not necessarily end your Part-66 career. You may be able to challenge the decision, correct the underlying deficiency or apply for reinstatement.

Act promptly and deal with the authority that issued the licence or rating. Do not continue certifying aircraft while the rating is revoked, suspended or otherwise restricted.

Understand what has been revoked

There is an important distinction between:

• the Part-66 Aircraft Maintenance Licence (AML) itself;
• an individual aircraft type rating or type-rating endorsement;
• a licence category or subcategory; and
• a Part-145 organisation’s certification authorisation.

If only a type rating has been revoked, you may still hold a valid Part-66 licence and other aircraft ratings. However, you cannot issue Certificates of Release to Service for the affected aircraft type unless and until the rating is legally restored and your Part-145 employer authorises you to do so. The official EASA Part-66 information provides the regulatory context for aircraft maintenance licences and ratings.

If the entire AML has been revoked or suspended, you must stop exercising all privileges associated with the licence.

A type rating is not the same as a company authorisation. Restoring the rating does not automatically restore your Part-145 authorisation. Your employer may require a new competence assessment, continuation training, recent experience or other internal approval before you return to certification duties.

Read the revocation notice carefully

Obtain and read the official decision from KIWA or the responsible licensing authority. The notice should normally explain:

• which licence, category or rating is affected;
• whether the action is a revocation, suspension, limitation or another enforcement measure;
• the reason for the decision;
• the effective date;
• whether the physical licence must be returned;
• whether you have a right of appeal or review; and
• what evidence is required for reinstatement.

Do not rely solely on information from your employer, a training organisation or an informal email. Request the formal decision and retain copies of every letter, email, form and supporting document. You can also review the UK CAA engineer licensing guidance for general information about licensing responsibilities and regulatory processes.

If the notice is unclear, request written clarification from KIWA before submitting an application or attempting to transfer the licence.

Stop using the rating immediately

Once the revocation takes effect, stop using the rating in any professional capacity. This includes:

• signing Certificates of Release to Service;
• certifying maintenance under a Part-145 authorisation;
• presenting yourself as current on the affected aircraft type;
• relying on the rating to supervise or support certification work; and
• using an electronic or paper copy of the licence that still displays the rating.

Notify your employer’s quality and compliance department. The organisation may need to remove or suspend your authorisation and review work carried out after the enforcement action took effect.

Continuing to certify after revocation can create a separate regulatory problem and may make reinstatement considerably more difficult.

Return the licence if instructed

If the authority has revoked the Part-66 AML itself, follow its instructions for returning the licence without delay.

For example, guidance published by the Hellenic Civil Aviation Authority states that, after receiving official notification of revocation and the reason for it, the engineer must return the licence to HCAA without delay. Similar requirements may apply under the procedures of another competent authority, including KIWA.

Send the licence using a trackable method and retain:

• a copy or scan of the licence;
• proof of postage or delivery;
• the authority’s acknowledgement; and
• the official revocation decision.

Do not assume that retaining the physical licence means that its privileges remain valid. The legal status of the licence is determined by the authority’s decision, not by the document in your possession.

Identify and correct the underlying deficiency

A revoked rating will not normally be restored simply because the holder requests it. You must understand what caused the decision and provide evidence that the deficiency has been fully corrected.

Possible causes include:

• inaccurate or fraudulent training records;
• an invalid or incorrectly issued Certificate of Recognition;
• missing examination or practical-training evidence;
• failure to meet experience or recency requirements;
• an incorrect licence transfer between authorities;
• serious maintenance or certification findings;
• failure to comply with a limitation or restriction; or
• enforcement action connected with a Part-145 organisation.

If the issue concerns training records, contact the approved Part-147 organisation and request a complete, verified training file. If documents are incorrect, ask the organisation to explain the discrepancy and provide corrected evidence where appropriate. You can also use AeroTech Careers’ guide to KIWA EASA licences and OJT approval for related compliance considerations.

Do not alter, replace or recreate records yourself. Submitting documents that are inconsistent with the authority’s records may raise further concerns about their authenticity.

Do not assume that transferring the licence will solve the problem

Some engineers consider transferring their AML to another EASA Member State after enforcement action. This is not a reliable solution.

HCAA has publicly stated that it does not accept:

• transfers of AMLs from the Netherlands, including KIWA-issued licences; or
• transfers of licences subject to a restriction, revocation, suspension or other enforcement action.

As a result, a KIWA licence affected by enforcement action may not be transferable to HCAA. Other authorities may take a similar approach, particularly where the original authority has not confirmed that the deficiencies have been resolved.

A new authority will usually need to verify the licence’s history and status. Omitting the revocation from an application may result in rejection and potentially further enforcement action. Before considering any change of authority, read this guide to choosing an EASA competent authority for a Part-66 licence.

The correct course is normally to resolve the matter with the authority that issued the licence, unless that authority formally directs you otherwise.

Apply for reinstatement where permitted

After a revoked licence has been returned, the engineer may retain the right to request reinstatement, provided that the deficiencies leading to the revocation have been fully rectified.

The exact procedure depends on the competent authority. Under the HCAA process described in its published announcements, the applicant must:

1. Complete and submit Form 19.
2. State that the application is for the “Application to reinstate a Part-66 License”.
3. Include the required supporting documents in PDF format.
4. Attach the official notification of revocation.
5. Provide evidence addressing each deficiency identified in the decision.

Additional documents may include corrected training records, examination results, statements from an approved Part-147 organisation, maintenance experience evidence, identity documents and proof that required corrective actions have been completed.

For a KIWA licence, contact KIWA or the responsible Dutch licensing department for the current reinstatement form and document list. Do not assume that the HCAA Form 19 process is automatically the KIWA process, although the general principle of a formal application supported by evidence of corrective action is similar. Always compare the current authority procedure with the EASA continuing airworthiness rules before preparing your submission.

Consider an appeal or administrative review

If you believe the revocation is factually incorrect, procedurally defective or based on incomplete information, check the appeal deadline immediately. Regulatory decisions often have strict time limits.

An appeal should normally address:

• the specific finding being challenged;
• the evidence supporting your position;
• any procedural error;
• the corrective action already taken; and
• the outcome you are requesting.

Aviation regulatory appeals can have significant consequences. Consider obtaining advice from an aviation lawyer or an experienced Part-66 compliance specialist. An appeal and a reinstatement application are not always mutually exclusive, but confirm the appropriate strategy before submitting documents.

Review the training and rating evidence

Before applying for reinstatement, create a complete file containing:

• the revoked licence and rating details;
• the revocation notice;
• all correspondence with KIWA or another authority;
• the original type-training certificate;
• examination certificates and results;
• practical training or assessment records;
• relevant maintenance experience and logbook evidence;
• employer or Part-145 statements;
• evidence of corrective actions; and
• any appeal or reinstatement forms.

Pay particular attention to Certificates of Recognition. Authorities may reject documents that were issued incorrectly or subsequently cancelled. If your evidence needs organising, the Part 66 Logbook Analysis service can help you review relevant logbook records and identify documentation gaps.

HCAA, for example, has announced that it does not accept Certificates of Recognition issued by AIR-TECH Bildung (DE.147.0014) during 2023 and 2024, because those certificates were cancelled by the German authority, LBA. If your rating depends on one of these certificates, do not submit it as valid evidence. Contact the issuing organisation and the relevant authority to establish what replacement training or assessment is required.

Be careful with UK-issued training evidence

Brexit-related transitional rules can also cause confusion. In certain circumstances, EASA Member States may continue to accept a UK Certificate of Recognition for a Part-66 licence or rating endorsement after the transitional period, provided that:

• the Certificate of Recognition was correctly issued; and
• the application was made within the applicable Part-66 time limits.

The relevant limits can differ. Depending on the applicable provision, they may be up to 10 years for an aircraft licence or rating application and three years for certain rating-endorsement applications.

This does not mean that every UK document remains acceptable indefinitely. Check the issue date, the training organisation’s approval status, the applicable transitional rule and the date on which the EASA application was made.

Do not return to certification until everything is restored

Even after the authority reinstates the rating, further steps are usually required before you can certify in an operational environment.

Your employer may need to:

• reinstate your Part-145 authorisation;
• verify the updated AML;
• review your aircraft-type competence;
• confirm recent experience;
• complete continuation or refresher training; and
• update the organisation’s authorisation and compliance records.

A Part-66 rating provides the regulatory licence privilege. It does not, by itself, give you permission to certify on behalf of a particular Part-145 organisation.

Practical action plan

If your KIWA type rating has been revoked, follow this sequence:

1. Stop using the rating immediately.
2. Obtain the formal revocation decision.
3. Check the appeal and reinstatement deadlines.
4. Notify your employer and suspend the affected authorisation.
5. Return the licence if the authority requires it.
6. Identify the exact deficiency behind the decision.
7. Collect verified evidence proving that it has been corrected.
8. Ask KIWA for the current reinstatement or appeal procedure.
9. Do not attempt an informal transfer to another authority.
10. Resume certification only after both the rating and the company authorisation are valid.

Treat a revocation as a regulatory matter, not merely an administrative inconvenience. Prompt, honest and well-documented cooperation gives you the best chance of restoring the rating and protecting your future as a licensed aircraft maintenance engineer.