Proposed modular licensing framework for aircraft maintenance engineers - (CD 2309MS)

Closed 12 Oct 2023

Opened 14 Sep 2023

Feedback updated 24 Nov 2023

We asked

The consultation Proposed modular licensing framework for aircraft maintenance engineers (CD 2309MS) was opened for comment from 14 September to 12 October 2023.

We asked people to provide comments on proposed amendments to the Part 66 Manual of Standards (MOS) to provide a modular licensing framework for aircraft maintenance engineers.

About this consultation

Since the introduction of Part 66 of the Civil Aviation Safety Regulations 1998 (CASR), CASA has received submissions from industry stakeholders indicating that the Part 66 licence pathways are too inflexible. Submissions called for a return to the regulation 31 of the Civil Aviation Regulations 1988 (CAR) structure with licence categories that better suit the individual areas of interest and workplace needs.

Prior to this consultation, we consulted with the Part 66 Technical Working Group (TWG) on the technical details of the proposed modular licensing structure and In December 2022 we published a Discussion paper on Part 66 modular licensing framework for aircraft maintenance engineers (DP 2218MS).

Respondents generally supported a modular licence structure based on the existing Part 66 knowledge and experience requirements and using exclusions in order to expedite delivery of the intended benefits and outcomes.

This consultation set out the details of the proposed modular structure, including proposed amendments of the Part 66 MOS, for consideration and comment.

You said

In total, there were 35 respondents to the proposed amendments. Most responses received were from LAMEs and AME/trainees, with 1 respondent identifying as having no industry or organisation affiliation.

Of the respondents who made written submissions, 31 consented to having them made public and 4 requested their submissions be confidential.

Summary of feedback

The majority of respondents supported the proposal in its entirety offering comments such as:

"…a great step forward"

"…positive impact"

"The modular licence will work very well for my current workplace."

"Appreciation goes to CASA for supporting the implementation of these amendments which will support the aircraft maintenance industry which is suffering due to the LAME shortage crisis".

Nine respondents who agreed with the proposals said that 2 years' experience was inadequate for a person obtaining their first AME licence. They suggested minimum times varied from 2∙5 to 3 years. The main reason given was the lack of maintenance practice and the "culture" exposure to lack of maturity.

CASA considers 2 years as an acceptable minimum experience requirement for a modular licence. In all cases, before a licence is granted, applicants are required to satisfactorily complete the relevant maintenance tasks to meet the competency requirements. CASA also notes that this proposal will not change existing minimum age requirements, i.e., an applicant for a licence must be at least 18 years of age at the time of application. The minimum age to be authorised by a Part 145 AMO as a certifying employee, remains at 21 years.

Additionally, the 2 years minimum experience meets the requirements of Annex 1, Operation of Aircraft to the Chicago Convention standard a licence with privileges restricted to either airframe and engine and aircraft systems and components, or avionics systems or components. The 2 year time period is also in line with similar EASA provisions and exceeds the FAA minimum standard.

Four respondents said that removal of exclusions needs to be simplified. CASA is working with the Department of Infrastructure, Transport, Regional Development, Communications and the Arts to receive policy approval to amend the regulations to provide for removal of exclusions using the Part 66 self-study provisions.

Nine respondents said that mapping to the national vocational education and training (NVET) structure is important. CASA is working with MTOs to agree a mapping of the NVET units of competency to the Part 66 licence modules.

One MTO responded saying that Module 11 should be broken into 2 examinations, with the electrical/instrument components examined separately. CASA has considered this in consultation with the TWG and it was decided to leave Module 11 intact to keep the number and the cost of examinations to a minimum and to allow for the expeditious making of the MOS amendments.

One respondent said that "positive sub-ratings" should be used instead of exclusions. CASA advises that positive privilege statements would require extensive redrafting of the regulations and the MOS, which would delay the intended outcomes. CASA will consider this issue with the TWG as a future initiative.

One respondent said we should:

"...stop making changes to an already terrible system. Go back to basics and a known proven method."

CASA advises that reverting to a previous licensing system is not an option contemplated in this proposal.

We did

In view of the high level of support for the proposal, we will progress the proposed amendments to the Part 66 Manual of Standards and the associated implementation arrangements to provide modular licensing pathways via both self-study and Maintenance Traning Organisations (MTOs). We will also work with the Part 66 Technical Working Group and MTOs to finalise the list of competency units that will be required to be completed for each modular licence by applicants using the MTO pathway.

Published responses

View submitted responses where consent has been given to publish the response.


We are seeking your input on proposed changes to the Part 66 Manual of Standards (MOS) that would allow us to introduce ‘modular’ licensing for aircraft engineers.

This is designed to help address the shortage of licensed aircraft maintenance engineers (LAMEs) by making it easier for people to obtain a licence or return to the profession after a long absence. It will also assist foreign licence holders seeking a qualification to work in Australia.

Feedback from the industry was that the Part 66 AME licence pathways were too inflexible compared to the previous CAR 31 five-category process and we should develop a progressive, modular licensing structure.

We propose to introduce the modular system in two phases as part of our General Aviation Workplan.

This consultation is about the first stage.

Stage 1

In stage 1, we propose to amend the Part 66 MOS by the end of 2023 to enable Category B1 (mechanical) and B2 (avionics) licences to be issued with exclusions.

This will allow us to issue licences in modules (similar to the old CAR 31 system) and exclude only certain aircraft systems, based on an applicant’s training.

For example, a person who has only completed basic training (knowledge modules and practical experience) for piston engines could be granted a modular licence to work on piston engines. But the exclusions applied to the licence would mean they couldn’t work on airframes or other aircraft systems without completing the relevant basic training modules and experience.

We will also be able to issue licences with specific exclusions so that a person who has completed all the training for a licence, except for certain aircraft systems, could be issued a licence with those specific exclusions, such as air conditioning or pressurisation systems.

Stage 1 will allow people to get a licence to do certain things sooner than they would be able to if they had to complete the full licence.

To learn more about the proposal and how it will work, read the Summary of proposed change and information sheet. The links are at the bottom of this page.

Stage 2

The second stage will expand exclusion removal options and allow exclusions to be removed by CASA’s self-study training and examination pathway (noting that under the current regulations exclusions may only be removed via the Part 147 approved Maintenance Training Organisation pathway).

People with modular licences or licences with specific exclusions, will be able to expand the scope of their licence by completing the relevant basic training modules and experience, to remove the exclusions according to their career pathway or employer’s needs.

Expansion of exclusion removal pathways to include CASA self-study will mean people in regional areas, where it can be more challenging to access a maintenance training organisation, will have more options.

We will seek input on Stage 2 next year.

Previous consultations

In December 2022 we published a Discussion paper on Part 66 modular licensing framework for aircraft maintenance engineers (DP 2218MS). Feedback from this consultation has been used to shape this proposal.

We have also been working with the Part 66 Technical Working Group (TWG) on the technical details of the proposed modular licensing structure.

Why your views matter

Your feedback will help us to finalise the first stage of the modular licensing framework and implement it before the end of this year.

Please submit your comments using the survey link on this page.

If you are unable to provide feedback via the survey link, please email for advice.

Documents for review

The Related section at the bottom of this page contains all the documents for this consultation. They are:

  • Summary of proposed change on CD 2309MS, which provides background on the proposed standards 
  • Consultation draft - Part 66 Manual of Standards and Part 147 Manual of Standards Amendment Instrument 2023 (No. 1) 
  • Compilation - Part 66 Manual of Standards (MOS) (as amended)
  • Draft information sheet – How the proposed modular licence will work
  • MS Word copy of online consultation for ease of distribution and feedback within your organisation.

What happens next

At the end of the response period, we will:

  • review all comments received
  • make responses publicly available on the consultation hub (unless you request your submission remain confidential)
  • publish a Summary of Consultation which summarises the feedback received and outlines any intended changes and next steps.

Feedback that improves on the proposal will be incorporated.

Post-implementation review

We will monitor and review the new policies in practice on an ongoing basis.


  • CASA Staff
  • Part 147 of CASR Maintenance training organisations
  • Part 145 of CASR approved maintenance organisations (AMO)
  • Regulation 30 of CAR maintenance organisations (CAR 30)
  • Licensed aircraft maintenance engineers (LAME)
  • Aircraft maintenance engineers (AME)
  • Training organisation representative


  • Private operations
  • Aircraft engineer licensing
  • Maintenance training
  • Continuing airworthiness / maintenance