Does an EASA training certificate count in a UK Part-145 organisation, and vice versa?

UK CAA vs EASA training after Brexit — Part-145?

It depends which certificate. Safety training including human factors, fuel tank safety and EWIS certificates involve no state recognition on either side: the receiving organisation’s exposition decides. Part-66 basic examination certificates are the opposite — they are authority documents, and the UK stopped accepting EASA Part-147 ones dated after 31 December 2022.

Two documents that look alike in a training file run on different machinery: one is an input to an organisation’s competency procedure, the other to a state’s licensing process.

What kind of document are you actually holding?

There are three, and only the middle one involves an authority recognising a foreign document.

1. Organisation training certificates. Safety training including human factors, fuel tank safety Phase 1 and Phase 2, EWIS by target group, and the 2-year continuation cycle. They evidence that an organisation has met 145.A.30(e) and 145.A.35(d) for a named person. No authority issues or recognises them.
2. Part-66 examination documents. Certificates of recognition for basic modules, basic course certificates, type rating certificates. They feed a licence application, and the licensing authority decides what counts.
3. Organisation approvals. The Part-145 certificate itself — governed by each side’s approval system, not by the UK–EU aviation safety annex.

Does an EASA human factors certificate count in the UK?

There is no border to cross: the rule never asks where the training came from. The competency duty is written as an outcome:

“(e) The organisation shall establish and control the competency of the personnel involved in any maintenance, airworthiness reviews, safety management and compliance monitoring in accordance with a procedure and to a standard agreed with the competent authority.” — 145.A.30(e)

UK 145.A.30(e) reproduces that wording with the CAA as the competent authority, carried into UK Regulation (EU) No 1321/2014 by SI 2023/588, in force since 1 July 2024. Both sides run the same sentence.

AMC4 145.A.30(e) then says who may deliver it, and is deliberately open:

“(d) Safety training may be conducted by the maintenance organisation itself, independent trainers, or any training organisations acceptable to the competent authority.

(e) The safety training procedures should be specified in the MOE.” — AMC4 145.A.30(e)(d) and (e)

Acceptance is therefore not a property of the certificate but of the receiving organisation’s procedure, agreed with its authority and written into its exposition. A certificate from a provider in Ireland, Estonia or the UK is accepted in a UK Part-145 organisation on the same terms as one from next door: does the syllabus match what the Maintenance Organisation Exposition (MOE) says the job function needs, and does the MOE allow that kind of provider?

Do fuel tank safety and EWIS certificates travel the same way?

The reverse direction works identically: the EU text of AMC4 145.A.30(e) is the text quoted above. Fuel tank safety and EWIS follow the same route through AMC5 145.A.30(e), which points to Appendix IV to AMC5 145.A.30(e) and to AMC 20-22, and neither has an authority recognition step of its own. Our guide on whether online training is accepted sets out how a receiving organisation makes that judgement.

“No recognition step” is not “no checking”. The organisation must still satisfy itself that the syllabus covered what its procedure requires — after the SMS amendments described in the UK SMS guide, that includes safety risk management, safety culture and the safety programme, not human factors theory alone.

Why is a Part-66 certificate of recognition different?

Here the document is an authority document, and the UK position is published:

“The UK is unable to accept any EASA Part 147 Certificate of Recognition dated after 31st December 2022. The end of the Withdrawal Agreement on this date, removed the legal basis for these certificates in the UK, therefore the CAA has no legal power to accept any certificated dated after this date.” — UK CAA, UK Part-66 engineer knowledge requirements

The same page sets out what survives:

“Basic module and basic course certificates will continue to be accepted up to 10 years after their issue date, when issued before 31st December 2022. Type rating certificates will continue to be accepted up to 3 years after their issue date, when issued before 31st December 2022. Any certificate dated after 31st December 2022, must have been issued by a UK Part 147 Maintenance Training Organisation which can be found located internationally.” — UK CAA, UK Part-66 engineer knowledge requirements

Note the last clause: a UK Part-147 organisation may sit anywhere in the world. The cut-off is about the approval held, not geography.

The EU rule is written the same way round. 66.A.25(b) allows only two conductors of a basic knowledge examination:

“The basic knowledge examinations shall comply with the standard set out in Appendix II […] and shall be conducted by either of the following: (1) a training organisation approved in accordance with Annex IV (Part-147); (2) the competent authority” — 66.A.25(b)

A Part-147 organisation can sit outside the Union and still hold that approval: under 147.1, where the principal place of business is in a third country the competent authority is the Agency. What does not work is treating an approval under one system as an approval under the other. For examinations from elsewhere, the route is the credit provision:

“(d) The applicant may apply to the competent authority for full or partial credits for the basic knowledge requirements for: […] (2) any other national technical training and examination considered by the competent authority as equivalent to the corresponding basic knowledge requirements of this Annex.” — 66.A.25(d)

That is a case-by-case decision for the licensing competent authority, and harder than it was: since Regulation (EU) 2023/989 the two Module 10 syllabi are no longer the same document. The EU examines ten sub-modules, 10.1 to 10.10, while UK Appendix I still runs 10.1 to 10.7, and the UK’s Appendix II still requires essays for Modules 7A, 7B, 9A, 9B and 10. Our Module 10 guide has the detail.

Does the Trade and Cooperation Agreement fix any of this?

Not for training. The agreement’s aviation safety title lists nine possible areas of cooperation; two matter here:

“1. The Parties may cooperate in the following areas: […] (d) maintenance organisation certificates and monitoring of maintenance organisations; (e) personnel licensing and training; […] 2. The scope of this Title shall be established by way of Annexes covering each area of cooperation set out in paragraph 1.” — Trade and Cooperation Agreement, Article 445

“May cooperate” is the operative phrase. The scope is whatever the Annexes cover, and only one Annex to that title exists in the agreement as signed — Annex 30, whose scope article limits it to points (a), (b) and (c) of Article 445(1): airworthiness, environmental, and design and production certificates. Points (d) and (e) are absent. EASA’s page, dated 9 August 2021, puts it plainly:

“Aviation Safety is covered by Part Two, Heading Two, Title II of the Agreement. The application of the agreement is currently limited to airworthiness and environment certification, covered by Annex 30 to the Agreement.” — EASA, EU-UK Trade and Cooperation Agreement page

That sentence is five years old, so check for a later change: Article 454 lets the Specialised Committee on Aviation Safety amend Annex 30 and adopt further Annexes at any time.

The CAA’s European Union bilateral page calls the same annex by its drafting name, “ANNEX AVSAF-1 AIRWORTHINESS AND ENVIRONMENT CERTIFICATION”, and every item it lists is a design or production item: type certificates, STCs, changes and repairs, TSO authorisations, production organisation approvals, Form 1 and Form 52. Maintenance approvals do not appear.

One article does recognise licences across the border — read its limiting words:

“Certificates of airworthiness, certificates of competency and licences issued […] by one Party and still in force shall be recognised as valid by the other Party […] for the purpose of operating air services under this Title” — Trade and Cooperation Agreement, Article 434(2)

That is an air services provision, not a maintenance one. As things stand the agreement recognises neither training nor licensing — and need not for the first pile, which never depended on it.

Which document travels, and who decides?

Document	EASA certificate in a UK organisation	UK certificate in an EASA organisation	Who decides
Safety training including human factors, 145.A.30(e)	No recognition step; usable if the MOE covers the provider and syllabus	Same	The organisation, under its agreed procedure
Fuel tank safety Phase 1 and Phase 2	Same route, via AMC5 145.A.30(e) and Appendix IV	Same	The organisation, through its MOE
EWIS by target group, AMC 20-22	Same route, via AMC5 145.A.30(e)	Same	The organisation, through its MOE
Part-66 certificate of recognition, basic module or type rating	Not accepted if dated after 31 December 2022; earlier basic module certificates run 10 years from issue, type ratings 3 years	Basic knowledge examinations must come from a Part-147 organisation approved under Annex IV or the authority; else the 66.A.25(d) credit route	The licensing authority
Part-145 organisation approval	Outside the scope of Annex 30	Outside the scope of Annex 30	EASA or the CAA as competent authority

How should you organise a mixed training file?

Sort by pile, not by date. Organisation training certificates belong to the MOE and are audited against your own procedure; Part-66 documents belong to the individual and are audited by the licensing authority. Keeping them in one folder is how people end up asking whether the CAA “accepts” a human factors certificate — a question the rule never asks.

Check the issue date on every Part-66 document you inherited. An EASA-side basic module certificate dated 2023 or later has no route into a UK licence.

Make certificates self-describing. Clause served, syllabus reference, assessment method, date, issuer. That is what lets an organisation on either side map a course to its own procedure without guessing.

Related courses. Part-145 Safety Training including Human Factors — Initial follows the GM1 145.A.30(e) syllabus behind both versions of 145.A.30(e), so one certificate serves either MOE. Part-66 Module 10 — Aviation Legislation covers the EASA Module 10 syllabus as amended by Regulation (EU) 2023/989; it is knowledge training, and the examination still has to come from the sources named in 66.A.25(b).