Recognition of foreign aircraft maintenance engineer licences from recognised States - (CD 2508MS)

This consultation sought feedback on a framework that we are developing for recognising foreign States for Part 66 of the Civil Aviation Safety Regulations 1998 (CASR) and an associated amendment to the Part 66 Manual of Standards (MOS).

Under the proposal, once a foreign State is assessed and formally recognised, a licence holder from that country can apply to have their licence recognised by CASA for the grant of an equivalent Australian Part 66 aircraft maintenance engineer licence.

The public consultation opened on 7 May 2025 and closed on 4 June 2025. A summary of the feedback is provided below.

About this consultation

The consultation sought feedback on the proposed framework that we have developed to assess foreign States for recognition for Part 66 of CASR.

Existing legislation in Part 66 of CASR allows CASA to grant a Part 66 licence to an applicant who holds a foreign aircraft maintenance engineer licence issued by a recognised State. CASA has not previously exercised this legislation because there was no framework in place for assessing and recognising a foreign State.

We also asked for feedback on a proposed amendment to the Part 66 MOS to recognise an initial tranche of 3 States that have been assessed according to the proposed framework: Singapore, the United Kingdom (UK) and the United States of America (USA).

The consultation asked respondents to suggest other foreign States they believe should be considered for assessment for recognition for Part 66 of CASR and provide reasons why the States should be considered.

We continue to engage directly with some representative organisations and unions following the formal consultation period to better understand concerns raised during and since the consultation feedback. Feedback through this current process is not specifically identified in this summary of consultation but is acknowledged through initial consultation submissions by these organisations.

CASA received 372 responses to the consultation with engagement from several stakeholder groups. These included aircraft maintenance engineers (301 responses), approved maintenance organisations (14 responses), maintenance training organisations (10 responses) and others such as pilots, representative organisations, unions and retired aviation professionals (47).

Fifty percent of respondents consented to having their written submissions published, with the remaining 50% requesting their submissions remain confidential.

Thirteen percent of the submissions were made on behalf of an organisation and 87% were submitted as the respondent's personal views.

In broad terms, around three quarters of responses expressed some concerns about the proposal and details are expanded below.

We thank everyone who took the time to review the consultation material and share their feedback.

Summary of feedback

Assessment framework

Question 1 asked for feedback on the framework CASA will use to assess a foreign State for recognition.

Respondents that expressed support for the proposed framework described it as well-structured, comprehensive and necessary for industry growth.

Questions were received seeking clarification on the following:

• the assessment methodology
• clearer timelines for recognition decisions
• ongoing monitoring and review mechanisms.

Many respondents highlighted the critical nature of aircraft maintenance for flight safety and the need to preserve Australia's strong safety record. It was suggested to prioritise the following within the proposal:

• ensuring foreign licensing standards match or exceed Australian requirements before recognition
• robust verification processes, such as competency assessments, to confirm foreign-licensed engineers possess equivalent skills and knowledge
• continued monitoring of recognised States to ensure standards are maintained, such as through oversight.

Comments were also received concerning the impacts on local training pathways, the global shortage of skilled aircraft maintenance personnel and changes to the existing licensing framework were also suggested.

Many responses raised safety objections in broad terms but did not include clear rationale, primarily expressing general concerns about 'lowering standards' without any specific examples or evidence.

Proposed amendment to the Part 66 Manual of Standards

Question 2 asked for feedback on the proposed amendments to the Part 66 Manual of Standards (MOS) to specify Singapore, the United Kingdom and the United States of America as recognised States. This is based on an assessment of each State using the proposed framework.

Like question 1, specific feedback that was supportive of the amendments included:

• the framework provides a suitable assessment and basis for recognition of a State for Part 66 of CASR
• CASA is taking the right approach requiring all foreign applicants to complete Australian aviation legislation exams
• the proposals will assist the aviation industry regarding the shortage of licensed aircraft maintenance personnel
• the proposals are overdue, and more countries should be recognised as soon as possible.

Questions were received seeking clarification on the following:

• specific requirements for licence conversion
• assessment procedures for individual applicants
• documentation requirements
• processing timelines and costs.

In addition, feedback suggested the need for:

• thorough individual assessment, even from recognised States
• verification of recency and scope of experience
• English language proficiency requirements
• an understanding of Australian-specific regulations and procedures.

Many responses highlighted the importance of ensuring foreign licence holders understand Australian regulatory differences, maintenance practices, and documentation requirements.

Concerns raised in response to this question included:

• differences in the scope of privileges of the USA's Airframe and Powerplant (A&P) licence compared to our Part 66 licence
• the lack of reciprocal recognition of Australian Part 66 licences by a foreign State and a belief that many States would not agree to reciprocal recognition
• the ability for a licence holder from a non-recognised State to obtain a licence from a recognised State for the purpose of being granted an Australian Part 66 licence
• potential to prioritise foreigners for employment ahead of Australian aircraft maintenance engineers working toward a licence
• adverse effects on local training industry sustainability
• belief that these proposals will not address the global shortage of skilled aircraft maintenance personnel, and that Australia should be responsible for training aircraft maintenance personnel to meet Australia's needs.

Some respondents raised dissatisfaction with some existing aspects of Part 66 licensing and Part 147 training pathways.

Country prioritisation

The consultation asked for feedback on which additional countries CASA should prioritise for possible recognition for Part 66 of CASR. Approximately 35 foreign countries were nominated.

The countries that received the most recommendations were:

• Canada
• European Union Aviation Safety Agency (EASA) states
• South Africa
• New Zealand (which currently has a status under the Trans-Tasman Mutual Recognition Act (TTMRA) arrangement, that is equivalent to that of a recognised State)
• Malaysia
• Germany
• France.

The rationale for these countries included:

• rigorous training standards equivalent to, or exceeding, Australian requirements
• high safety standards or strong safety records
• similar regulatory frameworks
• strong regulatory oversight and enforcement
• strong aviation relationships
• English-speaking workforce.

Some responses also suggested CASA assess all ICAO member States.

Additional comments

We also sought general feedback on how the proposal may impact respondent operations.

Safety-related additional comments included:

• the need for continued monitoring of safety outcomes
• suggestions for tracking safety metrics and incident rates among foreign licence holders
• recognition of the importance of integrating foreign engineers into Australian safety culture and practices
• emphasis on ensuring foreign licence holders understand Australian-specific requirements and procedures.

There were many comments and concerns that related to broader implementation and industry aspects such as the:

• additional workload and CASA's capacity to manage increased applications and assessments
• requirement for standardised assessment procedures and decision-making criteria to ensure consistent outcomes.

Respondents that suggested positive impacts included themes such as addressing skilled labour shortages, supporting aviation businesses to remain competitive internationally, and reduced assessment times and costs.

Maintenance training organisations highlighted potential differences between the provisions in Part 66 of CASR and the organisation's registered training organisation (RTO) obligations under the Australian Skills Quality Authority (ASQA) standards regarding the ability to recognise a licence holder's foreign training qualifications.

We have completed our review of stakeholder feedback regarding the proposal to recognise foreign aircraft maintenance engineer licences from recognised States.

The responses reflected a range of views, both positive and negative, on key elements of the proposal, including:

• the proposed assessment framework for recognising foreign States
• the inclusion of Singapore, the United Kingdom and the United States as recognised States under Part 66 of CASR
• broader concerns related to training, aviation safety, and employment matters.

We also engaged directly with some representative organisations and unions in the weeks and months since consultation closed.

The aim of this engagement was to better understand their concerns. Their concerns predominantly related to:

• training pathways
• the impact on local employment opportunities
• perceived lowering of safety standards.

Concerns raised by industry bodies regarding industrial relations fall outside our regulatory scope. However, we will continue to engage directly with these stakeholders as we work to finalise a policy and/or an implementation decision.

Next steps

We intend to continue to engage with industry bodies and unions over the coming months and ahead of a policy and/or implementation decision.

We expect to be able to provide industry with more information on this proposal in early 2026.