3.4 Licence Validity, Recency Requirements & EASA Form 19 Application

3.4 Licence Validity, Recency Requirements & EASA Form 19 Application

Quick Answer: The EASA Part-66 Aircraft Maintenance Licence (AML) is an official state qualification valid for 5 years administratively, renewable by submitting EASA Form 19 to the issuing Competent Authority. However, holding a valid licence does not automatically permit an engineer to certify aircraft. Under Part-66.A.20(b)(2), to legally exercise certification privileges, the holder must maintain recency of experience: at least 6 months of relevant maintenance experience in the preceding 2-year period (or complete 3 months under supervision to restore lapsed currency). Certifying staff must also hold a company certification authorisation from an approved maintenance organisation (Part-145 or Part-CAO) and maintain uncompromised physical and mental fitness. Under Part-66.B.500, authorities will suspend, limit, or revoke licences for falsification, certifying unperformed work, or gross negligence.

In European aviation law, an aircraft maintenance engineer occupies a position of public trust analogous to an airline captain or air traffic controller. To safeguard this trust, EASA enforces strict boundaries separating the administrative validity of the licence document from the active operational privilege of releasing an aircraft to service. Maintenance professionals must manage their licence renewal cycles, track active maintenance hours, and adhere to absolute ethical standards.

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Administrative Licence Validity vs Operational Certification Privileges

A critical distinction in EASA Part-66 is the difference between holding an administrative licence document and exercising active certification privileges:

The Part-66 Licence as an Administrative State Credential

Under Part-66.A.40, an Aircraft Maintenance Licence is issued by the National Aviation Authority (Competent Authority) of an EU Member State and is valid for 5 years. This 5-year period is purely administrative: it confirms that the document is authentic and that the state recognises the engineer's qualifications. When 5 years elapse, the licence does not permanently expire, but its administrative validity lapses until the holder formally applies for renewal.

The Part-145 / Part-CAO Company Certification Authorisation

A Part-66 licence alone does not give an engineer the legal right to sign a Certificate of Release to Service (CRS) on a commercial aircraft. Under Part-145.A.35 and Part-CAO.A.040, the legal release authority is granted through a Company Certification Authorisation (CCA) issued by an approved maintenance organisation. Before issuing this authorisation, the quality department of the Part-145 organisation must verify that the engineer:

1. Holds a valid Part-66 licence with appropriate category and type ratings.
2. Satisfies the statutory 6-month in 2-year maintenance recency requirement.
3. Has completed mandatory human factors, aviation legislation, safety management system (SMS), and electrical wiring interconnect system (EWIS) continuation training within the past 24 months.
4. Demonstrates adequate language proficiency in the technical languages used by the organisation (typically English).
5. Understands the organisation's specific Maintenance Organisation Exposition (MOE) procedures.

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Application and Administrative Renewal: EASA Form 19

The universal administrative gateway for all Part-66 licensing transactions is EASA Form 19 (Application for Issue, Amendment or Renewal of an Aircraft Maintenance Licence).

Statutory Uses of EASA Form 19

An engineer submits EASA Form 19 to their Competent Authority for:

• Initial Issue: First-time grant of a Part-66 AML after completing basic examinations and basic practical experience.
• Amendment: Adding a new licence category or subcategory (e.g., adding Category B2 to an existing B1.1 licence), or endorsing a new aircraft type rating.
• 5-Year Renewal: Extending the administrative validity of the licence for another 5-year cycle.
• Transfer / Duplicate: Transferring licensing records between Member States or replacing a lost or damaged licence.

The 5-Year Administrative Renewal Cycle

To renew a licence under 66.A.40, the holder must submit EASA Form 19 along with their original licence document to the issuing Competent Authority before the 5-year expiration date. The Competent Authority verifies that the information contained on the licence matches official state records, verifies that no outstanding enforcement actions exist, and reissues the licence with a new 5-year validity date. Unlike company authorisations, administrative renewal of the Part-66 licence does not require proof of recent maintenance experience; an engineer who has worked in an office for 10 years can maintain the administrative validity of their Part-66 licence indefinitely by submitting Form 19 every 5 years.

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Recency of Maintenance Experience (Part-66.A.20(b)(2))

While an inactive engineer can keep their licence document valid, they cannot legally certify aircraft maintenance. Under Part-66.A.20(b)(2), strict currency rules govern the right to exercise certification privileges.

The 6-Month in 24-Month Rule

The regulation mandates: The holder of an aircraft maintenance licence may not exercise certification privileges unless in the preceding 2-year (24-month) period they have acquired at least 6 months of maintenance experience in accordance with the privileges granted by the aircraft maintenance licence.

Qualifying Maintenance Activities

Under AMC 66.A.20(b)(2), what counts as "maintenance experience" to maintain the 6-month recency?

• Hands-on maintenance performing scheduled inspections, defect rectifications, or component replacements on operating aircraft.
• Direct supervision of aircraft maintenance personnel in line or base maintenance environments.
• Serving in a maintenance management, technical support engineering, or maintenance planning role directly supporting operating aircraft.
• Delivering approved theoretical or practical aircraft type training in an approved Part-147 maintenance training organisation.

Currency Tip: The 6 months of experience does not need to be continuous; it can be accumulated intermittently across the 24-month rolling window.

Restoring Lapsed Recency: The 3-Month Supervised Maintenance Pathway

If an engineer leaves aircraft maintenance (e.g., working in an unrelated commercial role, prolonged illness, or sabbatical) and accumulates less than 6 months of maintenance experience over the preceding 2 years, their certification privileges lapse immediately. The Part-145 organisation must suspend their company certification authorisation.

To restore lapsed certification privileges, AMC 66.A.20(b)(2) establishes a clear rehabilitation protocol:

1. The engineer cannot certify maintenance independently.
2. The engineer must complete at least 3 months of continuous practical maintenance experience performing tasks relevant to the licence category and type ratings.
3. All tasks during these 3 months must be performed under the direct supervision of an authorised certifying technician who signs the work.
4. Upon successful completion of the 3-month supervised period and assessment by the quality department, the organisation can legally restore the engineer's certification authorisation.

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Physical and Mental Fitness Obligations

Unlike flight crew members who must undergo rigorous Class 1 medical examinations conducted by aeromedical examiners (AMEs), Part-66 certifying staff are not subject to routine mandatory state medical exams, and Part-66 contains no medical-fitness paragraph at all. Do not cite 66.A.20(b)(1) for this — that point requires compliance with Annex I (Part-M), Annex II (Part-145), Annex Vb (Part-ML) and Annex Vd (Part-CAO). The four conditions in 66.A.20(b) are: (1) compliance with those Annexes; (2) 6 months of maintenance experience in the preceding 2 years; (3) adequate competence to certify maintenance on the corresponding aircraft; and (4) the ability to read, write and communicate to an understandable level in the language(s) of the technical documentation.

Personal Responsibility and Fitness to Certify

The fitness duty flows instead from 66.A.20(b)(3) (adequate competence), from the organisation’s obligations under Part-145 and its MOE, and from 66.B.500(7), which requires the competent authority to suspend, limit or revoke a licence where the holder has carried out maintenance or issued a CRS under the adverse influence of alcohol or drugs. In practice this is an absolute personal duty. A certifying engineer must immediately self-ground and decline to sign a release if their faculties are impaired by:

• Alcohol: EASA enforces a strict zero-tolerance approach to alcohol impairment in safety-sensitive maintenance roles.
• Psychoactive Substances and Drugs: Illicit narcotics, prescription sedatives, or over-the-counter medications that induce drowsiness, impair motor coordination, or alter cognitive judgment.
• Acute or Chronic Fatigue: Working excessive shifts, circadian disruption during night maintenance, or inadequate sleep.
• Medical Conditions: Uncorrected vision deterioration, hearing loss, neurological disorders, or severe psychological stress.

Safety Management and Just Culture Interface

Under Part-145.A.202 and Regulation (EU) No 376/2014, maintenance organisations must cultivate a Just Culture. If an engineer steps forward and informs production control that they are unfit to certify due to acute fatigue or personal illness, the organisation cannot punish or discipline the technician. However, an engineer who conceals impairment and certifies work commits a severe regulatory violation.

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Suspension, Limitation, and Revocation of Privileges (Part-66.B.500)

The Competent Authority is empowered with sweeping statutory authority to police licence holders. Under Part-66.B.500, the Competent Authority must suspend, limit, or revoke a Part-66 licence if safety concerns or deliberate malfeasance are discovered.

Non-Compliance Grounds Triggering Enforcement

Part-66.B.500 specifically identifies eight statutory grounds for immediate suspension or revocation:

1. Fraudulent Acquisition: Obtaining the aircraft maintenance licence or company certification authorisation through falsified documents, forged logbooks, or untrue declarations.
2. Failure to Perform and Report: Failing to carry out requested maintenance combined with failing to report that fact to the organisation that ordered the work.
3. Failure to Report Inspection Findings: Failing to carry out required maintenance resulting from an inspection, combined with failing to report the defect to the operator or CAMO.
4. Negligent Maintenance: Demonstrating gross negligence or reckless disregard for maintenance procedures during maintenance tasks.
5. Falsification of Records: Falsifying maintenance records, work cards, or inspection sheets.
6. Certifying Unperformed Work: Issuing a Certificate of Release to Service knowing that the required maintenance was not performed, or without verifying that the maintenance was carried out.
7. Impaired Operation: Carrying out maintenance or issuing a Certificate of Release to Service while under the influence of alcohol, drugs, or psychoactive substances.
8. Certifying Without Compliance: Issuing a certificate of release to service in non-compliance with Annex I (Part-M), Annex II (Part-145) or Annex Vb (Part-ML).

When a licence is revoked under 66.B.500, the sanction is entered into the EASA Central Repository, alerting all other European National Aviation Authorities and preventing the individual from obtaining a licence in another Member State.

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Administrative Validity vs Company Authorisation vs Recency Matrix

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Practical Maintenance Scenario: Returning from Long-Term Management Assignment

An engineer holding a Part-66 Category B1.1 licence with Boeing 777 type ratings served as an airline's ground operations logistics director for 30 consecutive months. During this period, the engineer attended business meetings and managed budgets, performing zero aircraft maintenance.

Regulatory Assessment:

1. Licence Status: The engineer's physical Part-66 licence is still within its 5-year administrative validity window and remains legally valid as a state qualification.
2. Recency Status: Under Part-66.A.20(b)(2), the engineer has accumulated 0 months of maintenance experience in the preceding 24 months, completely failing the 6-month recency requirement. The engineer's certification privileges are legally dormant.
3. Attempted Line Release: If the engineer attempts to sign a Certificate of Release to Service for a transit check on a Boeing 777, the release is legally invalid. Under Part-66.B.500, doing so constitutes issuing a release without regulatory compliance, subjecting the engineer to immediate licence suspension.
4. Restoration Protocol: The airline's Part-145 organisation places the engineer on a 3-month supervised rehabilitation programme. The engineer works under the direct supervision of an active B1.1 certifying engineer for 3 months, logging complex maintenance tasks. The engineer completes recurrent Human Factors, EWIS, and Fuel Tank Safety courses. Once the quality manager audits the 3-month record, the company reissues a formal Certification Authorisation, fully restoring the engineer's legal release privileges.

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Exam Tips & Regulatory Traps

• Licence Validity vs Recency: Memorise the numbers: The licence document is valid for 5 years (renewed via EASA Form 19). Active recency requires 6 months of experience in the preceding 2 years (24 months).
• Regaining Recency: If currency is lost, the required period of supervised maintenance is 3 months, not 6 months or 1 year.
• No Mandatory Routine Medicals: Unlike pilots who need Class 1 medicals, Part-66 sets no medical standard for certifying staff. Do not attribute a fitness clause to 66.A.20(b)(1) — that point is about compliance with Part-M/145/ML/CAO. The enforceable hooks are 66.A.20(b)(3) (adequate competence) and 66.B.500(7) (maintenance or CRS under the adverse influence of alcohol or drugs).
• Form Number Trap: The application form for initial issue, amendment, and 5-year renewal of a Part-66 licence is EASA Form 19 (do not confuse with EASA Form 1 for component release, Form 15 for Airworthiness Review Certificates, or Form 26 for the AML document itself).
• Revocation Grounds (66.B.500): Falsifying records or certifying maintenance known to be unperformed leads to mandatory suspension or revocation.