UK CAA After Brexit, Compared with EASA

The one-paragraph answer

From 1 January 2021 the EASA texts on this page treat a UK-certified commercial operator as a third-country operator, and a Part-66 licence previously issued by the UK authorities as no longer valid in the EU. A UK-based maintenance organisation that wants to keep issuing an EASA Form 1, for a component to be fitted on an aircraft registered in an EASA Member State, must hold an EASA Part-145 approval. EASA’s wording for that approval is a third-country Part-145 approval. This page quotes those EASA texts. It does not quote a UK CAP or a UK regulation.

Seen from Cologne: the operator

The third-country operator rules do not name the United Kingdom. They name the operation.

EASA’s Brexit answers apply that rule to a UK operator. The words below are the current text of FAQ 121080 on the Agency’s Brexit page.

FAQ 121080 — UK commercial operators · EASA Brexit frequently asked questions · easa.europa.eu/en/the-agency/faqs/brexit

As of January 1, 2021 the UK certified CAT operators will be considered as Third Country Operators (TCO) and required to hold a valid EASA TCO authorisation in order to be able to conduct commercial air transport operations into, within or out of the territory to which the EU Treaties apply (or to territories of non-EU EASA Member States). TCO authorisations will be issued also under the EASA early applications process.

A UK airline flying commercially into the EU therefore holds an EASA TCO authorisation on this text, as any other third-country operator does under Article 3.

Maintenance: the EASA Form 1

The maintenance sentence in the EASA answers is narrower than “any release into the EASA system”. It is about an EASA Form 1 for a component.

FAQ 121055 — EASA Form 1 after 31 December 2020 · EASA Brexit frequently asked questions · easa.europa.eu/en/the-agency/faqs/brexit

After December 31, 2020, the UK based maintenance organisation must hold an EASA Part 145 approval in order to be able to continue issuing ‘EASA Form 1’ for components which are to be fitted on an aircraft registered in an EASA Member State.

The same set of answers uses the third-country label for a maintenance organisation located in the UK. The sentence is about on-the-job training procedures, and it names the approval:

FAQ 121059 — EASA Third Country Part 145 approval · EASA Brexit frequently asked questions · easa.europa.eu/en/the-agency/faqs/brexit

Finally, as regards the approval by EASA of the maintenance organisations located in the UK the MOE 3.15 procedures for the On the Job Training (first type endorsement) will not be approved by EASA when such a maintenance organisation transfers to an EASA Third Country Part 145 approval. These MOE 3.15 and 3.16 paragraphs are not applicable to EASA Part-145 Third Country approvals.

The Trade and Cooperation Agreement is mentioned once in these answers, and not as a maintenance-release arrangement:

FAQ 123766 — Trade and Cooperation Agreement · EASA Brexit frequently asked questions · easa.europa.eu/en/the-agency/faqs/brexit

The EU-UK Trade and Cooperation Agreement does not currently address activities covered by Regulation (EU) No 1321/2014.

That is the whole of the maintenance claim this page makes. It does not say how a UK approval compares with a US repair-station approval, and it does not say that an EASA Part-145 organisation may release a UK-registered aircraft.

The Part-66 licence

FAQ 121060 — UK Part-66 licences · EASA Brexit frequently asked questions · easa.europa.eu/en/the-agency/faqs/brexit

No. As of January 1, 2021 Part-66 licences previously issued by UK authorities will no longer be valid and recognised in EU. Accordingly, any such a license cannot be transferred to an EASA Member State after December 31, 2020.

The quote speaks to recognition in the EU. It does not say what licence a person needs to release a G-registered aircraft.

What it means for you

Where to read it yourself

The operator quotes were checked against the Easy Access Rules for Third Country Operators, 2026-07-15 revision. Article 3 and TCO.100 in that revision match the lines above; neither point carries an applicable-until or applicable-from tag. The UK-specific sentences were checked against the current text of EASA’s Brexit frequently asked questions, which is the library document brexit (it has no version label) and the public page Brexit — on the consequences of the UK withdrawal from the EASA system. This page does not cite a UK CAP, the Air Navigation Order, or the Official Record Series. For the EASA Parts named in those answers, start from the regulatory map, then Part-145 and Part-66. The next guide in this series is GCAA, GACA and Transport Canada.