Published on February 29th, 2020 | by Mark Dwyer0
Should I Transfer My Flying Licence to Ireland Before Brexit?
Recently I’ve received quite a few emails from Irish pilots who hold UK issued EASA Pilot licences asking if they should transfer their licences to Ireland. In this article, I’ll outline the options available to you and potential outcomes at the end of the transition period. This article is completely apolitical, and I won’t be speculating on what may or may not happen in the political arena between now and the end of any transition period. The focus of this article is primarily on PPL holders (and some newly qualified CPL holders). Commercial pilots currently operating for an airline will most likely be governed by the rules of their employer as to which country issues their licence.
Some terms I’m going to use in this article
Competent Authority – Appointed by each Member State to undertake their responsibilities under the requirements of regulation (EC) 1702/2003. e.g. IAA in Ireland, CAA in UK.
CPL – Commercial Pilot Licence
ICAO – International Civil Aviation Organisation
LAPL – Light Aircraft Pilot Licence
Part-FCL –EU regulation 1178/2011 as amended. The regulation under which Part-FCL or EASA Pilot licences are issued. More commonly referred to as an EASA licence but is often referred to as a Part-FCL licence in official documents
PPL – Private Pilot Licence
SOLI – State Of Licence Issue
What is the current situation?
The United Kingdom officially left the European Union on 31st January 2020. The withdrawal agreement that was negotiated between the UK and EU prior to this allowed for a transition period between 1st February 2020 and 31st December 2020. During this period, the UK remains fully aligned with EU rules and therefore remains a full member of EASA, the European Union Aviation Safety Agency. So, the current situation is that there is no change.
The transition period will allow time for the UK and EU to negotiate their future relationship. This may or may not lead to the UK leaving EASA so let’s look at both options.
If the UK leaves EASA
Following the transition period there is a possibility that the UK will leave EASA. If you hold a UK issued Part-FCL (EASA) PPL it’s important to understand that it is still fully ICAO compliant. The Chicago Convention, provides for worldwide recognition of flight crew licences issued by any member State of the International Civil Aviation Organization (ICAO) provided that:
- the licence meets or exceeds the ICAO licensing Standards of Annex 1 – Personnel Licensing to the Convention on International Civil Aviation; and
- the licence is used on an aircraft which is registered in the State which has issued or validated the licence.
If the licence is to be used on an aircraft which is not registered in the SOLI, the licence holder must obtain a validation of the licence from the aircraft’s State of Registry or alternatively obtain a new licence issued by the State of Registry. This means that, if the UK leaves EASA, you will be restricted to flying UK registered aircraft or will need a validation to fly EI- registered aircraft.
Flying an EASA aircraft with non-ICAO licence?
If you hold a UK issued LAPL, it’s a different situation. The LAPL is non-ICAO compliant and therefore is only recognised within Europe. In this case, the LAPL will revert to a National PPL (NPPL) and will only be recognised outside of the UK where there is an existing validation or acceptance of that licence from the other state. This is the case in Ireland, where UK issued NPPLs are recognised subject to certain conditions.
However, it should be noted that the NPPL does not permit you to fly EASA aircraft outside of the UK so there is certainly a loss of privileges here. In simple terms, you would be restricted to flying permit aircraft (homebuilt and microlight) under IAA Aeronautical Notice P21.
Separately, there is an exemption issued by the UK CAA / Department for Transport that allows NPPL holders to fly EASA aircraft in UK airspace, this exemption looks set to end on 8th April 2020 anyway.
For medicals issued prior to the UK leaving EASA (if that happens), they will remain valid until their validity date for a Part-FCL licence. After that date, you will need to ensure your AME has an EASA approval if you continue to hold an EASA licence. Many UK based AMEs already conduct many medicals for EASA Licence holders outside the UK so have started the process of gaining EASA approval in the event the UK leaves EASA. In any case, the IAA has a full list of EASA aeromedical examiners listed on their website.
If the UK does not leave EASA
In this situation, the situation remains as it is today with no changes. So, the question I’m sure you’re asking is: Why don’t I wait for the UK to leave and then transfer my licence? Well, in order to transfer your licence to another Competent Authority (IAA in this case), you need to hold a current EASA licence. If the UK leaves EASA, your UK issued licence becomes non-EASA and therefore this option will no longer be available to you. There is a process to covert an ICAO licence to a Part-FCL (EASA) licence but this will almost certainly involve a Licence Skills Test (LST).
Why not just switch to Ireland?
Indeed, this would probably be the safest option in that it will ensure you maintain a Part-FCL (EASA) licence however, the decision must be made based on your own circumstances and flying requirements.
Advantages of Converting
- You will maintain your Part-FCL (EASA) licence regardless of the UK position after the transition period
- The IAA will allow any EASA SEP examiners to sign certificates of revalidation by experience (the UK does not allow non-UK examiners to sign revalidation by experience)
Disadvantages of Converting
- There is currently a fee of €250
- You’ll need to complete paperwork and send it to the IAA.
- You’ll also need to complete paperwork for the UK CAA and pay a fee of £45
- The process could take up to 12 weeks. If your rating expires within this timeframe if could complicate the process so, try to revalidate it beforehand if possible.
Hopefully this article answers any questions you may have about transferring your EASA licence to Ireland. If you have any further questions you can email me at email@example.com or ask on the FII Forum.