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

Closes 12 Oct 2023

Opened 14 Sep 2023


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.

Give Us Your Views


  • 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