7 July 2021
An announcement by the CAA and Department for Transport towards the end of May confirmed that American FAA licence holders resident in the UK have been given until 21 December this year to obtain an equivalent UK Part-FCL licence, if they wish to continue flying in the UK.
This extends the previous deadline of 21 June and applies regardless of the state of registration of the aircraft being flown. The notes on the exemption document suggest further extensions to this deadline are unlikely and will only happen if the conditions of article 71(1) of the UK Basic Regulation apply. Article 71(1) is essentially the old EASA ‘urgent operational need’ provision as retained in UK law and is the mechanism by which the CAA has published the current extension document (ORS4 1490), using the Covid pandemic as the reason the deadline has been extended.
It is hard to know how many people this affects – ending the use of foreign licences by pilots living in Europe has been on the cards for a long time, and I suspect over the years many have already complied, while the UK was still in the EU. Non-FAA ICAO licence holders (for example South African or Canadian) living in the UK have already had to comply some time ago.
However, there probably are a few people who still need to, and now that we are now out of the EU, UK residents holding EASA licences issued after 31 December 2020 are also dragged into the requirement since they are now considered ‘third country’ by the UK. So let us review the requirements for obtaining a UK Part-FCL PPL while holding a foreign one.
The requirements are now in Commission Delegated Regulation (EU) 2020/723, as retained in UK law. This replaced Annex III to the EASA Aircrew Regulation in March 2020. The version in force in the UK can be found along with other retained law at CAA Aircrew regulations.
The regulation makes a distinction between ‘validation’, which is normally limited to a year, and ‘conversion’, which is permanent and results in the issue of a full equivalent UK Part-FCL licence. ‘Conversion’ is perhaps a misnomer since you do not have to surrender the foreign licence, indeed you legally still need it if the aircraft being flown is still registered in the state that issued the foreign licence – you essentially need to be dual qualified.
I will focus on conversion. For permanent UK residents, ‘validation’ is probably not worthwhile and the requirements for conversion are only slightly greater.
It is much more straightforward if you have 100 hours flight time – so if you do not, I would obtain this somehow before converting, otherwise you do not really have any alleviation from the full UK Part-FCL training requirements.
Assuming you have 100 hours, you need to:
In practice I would approach a suitable flying school to guide you through the process. The UK PPL Skills Test is similar to any other ICAO one, but every state has its own local flavour.
For obtaining the UK Part-FCL Instrument Rating, you can use the 2014 conversion process for pilots with a third country IR and 50 or more hours PIC under IFR in aeroplanes (note that is IFR time, not necessarily time in IMC). You must do the UK Skills Test, during which you will be examined orally on UK air law, operational procedures, meteorology, flight planning and performance. There is no requirement for written exams or training prior to the test, but in practice I would suggest you need a flying school that provides IR training to prepare you for the UK test. Like the experience requirement for converting at PPL level, if you do not have 50 hours PIC under IFR, I would find a way to get it, as otherwise the above option is not available.
Holders of EASA licences issued by other EASA member states issued prior to 31 December 2020 are essentially excused all of the above until 31 December 2022 since they can fly G-reg under the provisions of the European Withdrawal Act 2018 and the CAA’s general validation (CAP2017). There is also now a process since April for former UK EASA licence holders (who changed state of licence issue before 31 December 2020) to obtain a UK licence as a paperwork exercise.
A similar process may also be available to holders of EASA licences issued prior to 31 December 2020 who have never had a UK issued licence, which may involve a Skills Test but not much else – this will become more relevant once we are closer to the December 2022 expiry of CAP2017.
For EASA licences issued from 2021 onwards, to obtain a UK licence you need to follow the requirements of Regulation 2020/773, as described earlier, since these are now considered third country licences, along with the FAA and others.