Part 66 Manual of Standards Amendment Instrument 2026 (No. 1)

Explanatory Statement

Civil Aviation Safety Regulations 1998

Part 66 Manual of Standards Amendment Instrument 2026 (No. 1)

Purpose

The purpose of the Part 66 Manual of Standards Amendment Instrument 2026 (No. 1) (the instrument) is to address the shortage of licenced aircraft maintenance engineers (LAMEs) in Australia by amending the Part 66 Manual of Standards (the Part 66 MOS) to enable CASA to recognise aircraft maintenance licences issued by the United Kingdom and the United States of America.

The instrument substitutes Appendix V with a new Appendix V specifying the United Kingdom and the United States of America as recognised States for the purposes of regulation 66.030 of the Civil Aviation Safety Regulations 1998 (CASR). Regulation 66.030 provides for the Civil Aviation Safety Authority (CASA) to recognise a foreign licence, issued by a recognised State, provided the licence is held by an applicant for an Australian aircraft engineer licence (AEL) at the time of application and is in force.

CASA will closely monitor the operation of the amendments over the first 12 months of operation with a formal review to be conducted after 6 months. In this way, CASA will be able to establish at an early stage whether the amendments are achieving their intended objectives or whether there are any unintended consequences which need to be addressed. If unexpected outcomes are identified, CASA will revisit the amendments and the associated policy settings.

Legislation

Under section 9 of the Civil Aviation Act 1988 (the Act), CASA has the function of conducting the safety regulation of a range of matters, including, under paragraph 9(1)(c), developing and promulgating appropriate, clear and concise aviation safety standards.

Section 98 of the Act empowers the Governor-General to make regulations for the Act and in the interests of the safety of air navigation. Relevantly, the Governor-General has made CASR. Under subsection 98(5A) of the Act, the regulations may empower CASA to issue instruments in relation to, among other matters, the maintenance and airworthiness of aircraft.

Part 66 of CASR, Continuing airworthiness—aircraft engineer licences and ratings, deals with various categories and types of AELs and ratings granted by CASA for:

• the performance of maintenance certification for maintenance carried out on aircraft
• issuing certificates of release to service for aircraft in relation to maintenance carried on aircraft.

For subsection 98(5A) of the Act, regulation 66.015 of CASR empowers CASA to issue a Manual of Standards for Part 66 of CASR, prescribing matters required or permitted to be prescribed by the Part 66 MOS or necessary or convenient to be prescribed for carrying out or giving effect to Part 66. In particular, paragraph 66.015(2)(b) provides that the Part 66 MOS may specify that a specified foreign country is a recognised State.

Under regulation 66.025 of CASR, subject to regulation 11.055, CASA must grant an AEL to an applicant if specified requirements are met. Those requirements include that CASA is satisfied that the applicant meets the requirements in paragraph 66.025(3)(e).

Paragraph 66.025(3)(e) requires that the applicant meets the requirements of sections 66.A.25 and 66.A.30 of the Part 66 MOS for the licence applied for, or is taken, under regulation 66.030, 66.035, 66.040, 66.045, 66.050, 66.055, 66.065 or 66.070, to meet those requirements. Sections 66.A.25 and 66.A.30 of the Part 66 MOS contains basic knowledge and competency requirements and basic practical experience requirements, respectively.

Regulation 66.030 provides for the recognition of foreign licences from recognised States held at the time of application. Subregulation 66.030(1) states that the regulation applies to an applicant for an aircraft engineer licence if:

(a) at the time of making the application for the licence, the applicant holds a foreign licence, that is in force, issued by:

 (i) a recognised State; or

 (ii) a foreign company incorporated or formed in a recognised State; and

(b) the applicant exercised privileges under the foreign licence or under a foreign rating endorsed on the foreign licence; and

(c) CASA determines, in writing, that at least 1 of the privileges exercised was equivalent to a privilege mentioned in the Part 66 Manual of Standards for the licence applied for; and

(d) in the 2 years immediately before the time of making the application, the applicant has:

 (i) exercised the privileges for at least 6 months; or

 (ii) gained at least 6 months additional practical experience; or

 (iii) for an applicant for a category C licence who does not hold, and is not applying for, a category B1 or B2 licence—gained experience that CASA determines, in writing, is relevant to the privileges mentioned in the Part 66 Manual of Standards for the licence applied for.

The applicant is taken to meet the requirements of sections 66.A.25 and 66.A.30 of the Part 66 Manual of Standards for the licence applied for to the extent mentioned in the determination under paragraph (1)(c).

Part 1 of the CASR Dictionary defines aircraft engineer licence as meaning any of the following licences granted under regulation 66.025 or 66.026 of CASR:

(a) subcategory A1;

(b) subcategory A2;

(c) subcategory A3;

(d) subcategory A4;

(e) subcategory B1.1;

(f) subcategory B1.2;

(g) subcategory B1.3;

(h) subcategory B1.4;

(i) category B2;

(j) category C.

Part 3 of the CASR Dictionary defines foreign licence as meaning:

(a) a licence that:

 (i) is granted under a national aviation law of a foreign country, other than a foreign country that is an excluded State; and

 (ii) complies with Annex 1, Personnel Licensing, to the Chicago Convention; and

 (iii) deals with the provision of maintenance services; or

(b) an authorisation that:

 (i) is issued by a foreign company, other than a foreign company incorporated or formed in an excluded State; and

 (ii) deals with the provision of maintenance services; or

(c) a licence mentioned in paragraph (a) and an authorisation mentioned in paragraph (b) that together deal with the provision of maintenance services.

Part 3 of the CASR Dictionary defines recognised State as meaning a foreign country specified as a recognised State in the Part 66 Manual of Standards.

Section 66.A.60 of the Part 66 MOS states that, for the purposes of regulation 66.030 of CASR, recognised States are set out in Appendix V.

Under subsection 33(3) of the Acts Interpretation Act 1901, where an Act confers a power to make, grant or issue any instrument of a legislative or administrative character (including rules, regulations or by-laws), the power shall be construed as including a power exercisable in the like manner and subject to the like conditions (if any) to repeal, rescind, revoke, amend, or vary any such instrument.

Background

Australia currently has a shortage of LAMEs, particularly in regional areas, and there is a need to find, attract and retain more LAMEs in Australia. To address this skills shortage, the Australian Government Aviation White Paper required CASA to implement the following initiative:

Initiative 18 – Streamline training and accreditation pathways for licensed aviation maintenance engineers (LAMEs), including:

 recognition of licences from overseas authorities with similar standards and requirements. CASA already recognises aviation maintenance engineer licences issued by the Civil Aviation Authority of New Zealand. By the end of 2025, CASA will adopt a framework for recognition of licences issued by civil aviation authorities in nations that apply regulations that are equivalent to those applied by CASA. Engineers licensed by these authorities will still be required to pass exams on Australian aviation law to be licensed by CASA.

The intended outcome is to enable LAMEs from those recognised States to gain an Australian AEL that is equivalent to, and based on, recognition of their foreign licence, without having to undergo a formal recognition of prior learning (RPL) assessment by a CASA approved maintenance training organisation (MTO). This more efficient approach would negate the need for applicants to complete all of the basic knowledge training modules and examinations required under Part 66 and the Part 66 MOS, with many likely to only have to complete exams in Australian aviation law.

Part 66 already provides for CASA’s recognition of foreign licences from recognised States held at time of application, to enable a foreign licence holder to gain a Part 66 licence based on their foreign licence. Section 66.A.60 of the Part 66 MOS states that, for the purposes of regulation 66.030 of CASR, recognised States are set out in Appendix V. However, to date, no foreign States have been recognised and listed under this provision in Appendix V of the Part 66 MOS.

In response to Initiative 18, CASA developed a framework to assess foreign States for recognition as a recognised State for the purposes of regulation 66.030 (the assessment framework). Due to the complexity of some foreign licensing and training systems, the listing of recognised States in the Part 66 MOS will occur in a phased approach.

CASA’s initial trial of the assessment framework was to assess States with differing regulations and maintenance personnel licensing and training systems. CASA completed the assessment of the first tranche of foreign States (Singapore, the United Kingdom and the United States of America) according to a draft of the assessment framework. CASA consulted on the draft framework at the same time as it consulted on a draft of this instrument (see below under the heading Consultation) and no substantial adjustments were made to the final framework.

The decision to select Singapore and the United Kingdom as countries to initially assess was due to both States being International Civil Aviation Organization (ICAO) Member States whose maintenance personnel licensing and training systems are based on the European Union Aviation Safety Agency (EASA) Part 66 licensing system, the same licensing system that underpins CASA’s Part 66 licensing system.

The decision to also select the United States of America in the first tranche of countries to be assessed was due to the USA also being an ICAO Member State, whose maintenance personnel licensing and training system, although a non-EASA-based licensing system, is closely aligned to ICAO licensing and training requirements. In addition, the USA’s effective implementation score that measures a Member State’s overall compliance to ICAO standards and recommended practices, was of a high standard across areas including legislation, licensing and airworthiness to support CASA’s decision to recognise the USA as a recognised State.

The assessment framework requires CASA to determine that an assessed foreign State has similar licensing and training standards, and regulatory oversight, when compared to Australian standards and requirements, and that the State complies with Annex 1 to the Convention on International Civil Aviation (the Chicago Convention). Annex 1, Personnel Licensing, contains Standards and Recommended Practices adopted by ICAO as the minimum standards for personnel licensing.

Each State is assessed against specific criteria, including the following:

• the foreign State’s maintenance licensing legislation must be available from an official source in English language to permit CASA to review the legislation
• Governance, regulatory compliance, oversight and enforcement

• the foreign State must be an ICAO Member State and must have acceptable ICAO effective implementation scores from ICAO Universal Safety Oversight Audit Programme (USOAP) audits in the areas of legislation, personnel licensing and airworthiness

• effectiveness of the State’s regulatory safety oversight (i.e., compliance, monitoring and enforcement requirements)

• against licensing training and examination providers

• licensing standards for equivalent licences

• evaluate the foreign State’s licensing requirements against Australian requirements, including requirements for basic knowledge and practical experience

• identify licence types (categories) issued by the foreign State
• licensing standards for training, examination and assessments

• verify that the State’s requirements for delivery of training and conduct of examinations and assessments are acceptable compared to Australian requirements

• identify licence privileges for each type/category of foreign licence issued by the State
• foreign licence – previous licensing standards

• consider if the State had previous licensing standards that were used to issue licences that may still be in force in the State

• foreign State’s foreign licence recognition

• consider if the State issues aircraft maintenance licences based on recognition of another foreign State’s licensing system.

After assessing Singapore, the United Kingdom and the United States against the framework, CASA initially proposed to recognise all 3 States. CASA, therefore, consulted on a draft of the instrument that included all 3 States as recognised States in Appendix V of the Part 66 MOS.

Overview of instrument

The instrument amends the Part 66 MOS in accordance with subsection 33(3) of the Acts Interpretation Act 1901.

The amendments made by Schedule 1 to the instrument amend the Part 66 MOS to substitute Appendix V with a new Appendix V that lists the United Kingdom and the United States of America as recognised States for the purposes of section 66.A.60 of the Part 66 MOS. Section 66.A.60 of the Part 66 MOS states that, for the purposes of regulation 66.030 of CASR, recognised States are set out in Appendix V.

The recognised States are listed by the names by which they are generally known. The United Kingdom is listed as “United Kingdom”, its name in the official list of short names of ICAO Contracting States (available from the ICAO website at <www.icao.int> (search for “Member States”)). “United Kingdom” is also referred to in the name of its national aviation authority, the “UK Civil Aviation Authority”. The United States of America is listed using its full name, which is also used in the definition of FAA in Part 1 of the CASR Dictionary: “the Federal Aviation Administration of the United States of America”.

Regulation 66.030 only deals with recognition of foreign licences issued by recognised States that are held at the time of application for an AEL. Appendix V lists recognised States only for the purposes of regulation 66.030 only, and not regulation 66.035 of CASR, which deals with the recognition of foreign licences from recognised States held before the time of application for an AEL. As at commencement of the instrument, no foreign States have been recognised for the purposes of regulation 66.035.

A note at the end of the new Schedule states that an applicant for an aircraft engineer licence who holds a foreign licence issued by a recognised State may be required by CASA to undertake and pass 1 or more specified knowledge tests. The note gives an example of such a test, being Module 10, Part 3 of Appendix I to the Part 66 MOS, which relates to knowledge of Australian aviation legislation.

Under regulation 11.035 of CASR, CASA may, by written notice, ask an applicant who is an individual to undertake a test of knowledge, skill or competence relevant to the application for the purpose of satisfying itself about a matter mentioned in subregulation 11.055(1A) of CASR. (These are matters such as that CASA may only grant the licence if the person meets relevant criteria and granting it would not be likely to have an adverse effect on the safety of air navigation.) The notice of which particular tests an individual must undertake could be given to the applicant in, or together with, the application form to be filled in by the applicant or during the application process.

The amendments will commence on the day after registration of the instrument.

CASA has assessed the impact that the amendments made by the instrument will have on aviation safety and is satisfied that they will have no adverse impact on aviation safety as to become a recognised State a foreign State must have been assessed by CASA as having acceptable licensing and training standards that comply with Annex 1 to the Chicago Convention.

Content of instrument

Section 1 names the instrument.

Section 2 provides that the instrument commences on the day after it is registered.

Section 3 provides that Schedule 1 of the instrument amends the Part 66 Manual of Standards.

Schedule 1 sets out the amendment to be made to the Part 66 MOS.

Item 1 of Schedule 1 substitutes Appendix V of the Part 66 MOS with a new Appendix V that lists the United Kingdom and the United States of America as recognised States.

The new Appendix V includes 2 notes after the list of recognised States.

The first note states that an applicant for an AEL who holds a foreign licence issued by a recognised State may be required to undertake and pass 1 or more specified knowledge tests. The note gives an example of such a test, being Module 10, Part 3, Appendix I which relates to knowledge of Australian aviation legislation.

The second note states that New Zealand has status under the Trans-Tasman Mutual Recognition Arrangement that is equivalent to that of a recognised State. This note was also included in the previous Appendix V.

Legislation Act 2003 (the LA)

Under paragraph 98(5AA)(a) of the Act, an instrument issued under subsection 98(5A) is a legislative instrument for the LA if it is expressed to apply in relation to a class of persons. The Part 66 MOS is a legislative instrument as it applies to a class of persons, being aircraft engineers.

Paragraph 10(1)(d) of the LA provides that an instrument will be a legislative instrument if it includes a provision that amends or repeals another legislative instrument. This instrument amends the Part 66 MOS and is, therefore, also a legislative instrument and subject to tabling and disallowance in the Parliament under sections 38 and 42 of the LA.

Sunsetting

Part 4 of Chapter 3 of the LA (the sunsetting provisions) does not apply to the instrument or the Part 66 MOS, because they relate to aviation safety and are made under CASR (item 15 of the table in section 12 of the Legislation (Exemptions and Other Matters) Regulation 2015).

The instrument is an amending instrument and, therefore, will be automatically repealed under section 48A of the LA, which will happen before the sunsetting provisions would have repealed the instrument if they had applied.

The amendments to the Part 66 MOS will have enduring operation. Generally speaking, item 15, when invoked, is necessary to ensure that, in the interests of aviation safety, a relevant instrument has enduring effect, certainty and clarity for aviation operators, both domestic and international. The instrument deals with aviation safety matters and is intended to have enduring operation and it therefore would not be appropriate for it to be subject to sunsetting. The exemption from the sunsetting provisions affects parliamentary oversight by not requiring the Part 66 MOS to be remade and subject to further tabling and disallowance in the Parliament under sections 38 and 42 of the LA.

Consultation

Public consultation on the draft instrument was undertaken from 7 May 2025 to 4 June 2025. The consultation also sought feedback on the draft assessment framework.

The draft instrument on which consultation was undertaken would have amended the Part 66 MOS to recognise an initial tranche of 3 States that were assessed using the draft assessment framework: Singapore, the United Kingdom (UK) and the United States of America (USA).

CASA consulted with numerous stakeholder groups, including aircraft maintenance engineers (AME), approved maintenance organisations (AMO), maintenance training organisations (MTO) and others such as pilots, representative organisations and retired aviation professionals.

CASA received 372 responses from individuals across all stakeholder groups. In broad terms, around three quarters of responses expressed some concerns about the proposal.

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.

Separate to the public consultation, CASA held multiple meetings to engage directly with representative organisations to better understand their concerns. After considering all feedback and further analysis regarding which States were most likely to be able to help address Australia’s aircraft maintenance shortages, particularly its regional skills shortages, CASA decided that, given Singapore’s limited general aviation sector, its licence holders were less likely to be able to meet that need and, therefore, that Singapore should not be listed as a recognised State in the Part 66 MOS.

CASA is satisfied that no further consultation is appropriate or reasonably practicable for this instrument for section 17 of the LA.

Sector risk, economic and cost impact

Subsection 9A(1) of the Act states that, in exercising its powers and performing its functions, CASA must regard the safety of air navigation as the most important consideration. Subsection 9A(3) states that, subject to subsection (1), in developing and promulgating aviation safety standards under paragraph 9(1)(c), CASA must:

(a) consider the economic and cost impact on individuals, businesses and the community of the standards; and

(b) take into account the differing risks associated with different industry sectors.

The cost impact of a standard refers to the direct cost (in the sense of price or expense) which a standard would cause individuals, businesses and the community to incur. The economic impact of a standard refers to the impact a standard would have on the production, distribution and use of wealth across the economy, at the level of the individual, relevant businesses in the aviation sector, and the community more broadly. The economic impact of a standard could also include the general financial impact of that standard on different industry sectors.

The economic and cost impact of the instrument has been determined by:

(a) the identification of individuals and businesses affected by the instrument; and

(b) consideration of how the requirements to be imposed on individuals and businesses under the instrument will be different compared to existing requirements; and

(c) a valuation of the impact, in terms of direct costs on individuals and businesses affected by the instrument to comply with the different requirements. This valuation is consistent with the principles of best practice regulation of the Australian Government; and

(d) a valuation of the impact the different requirements would have on the production, distribution and use of wealth across the economy, at the level of the individual, relevant businesses in the aviation sector, and the community more broadly; and

(e) consideration of community impacts, beyond those direct impacts on individuals and businesses affected by the instrument, that are relevant if the instrument were to result in flow-on effects to other aviation businesses, or local non-aviation businesses that experience a change in their activity due to the instrument.

CASA has assessed that the economic and cost impact of the instrument is not significant. The instrument makes minor or machinery changes to an existing instrument and there will be no significant change to the economic or cost impact on individuals, businesses or the community. The Office of Impact Analysis (OIA) has also made an assessment that its impacts are unlikely to be more than minor (see below) and an Impact Analysis (IA) is not required.

The amendments made by the instrument will affect persons who apply for an AEL on the basis of holding a foreign licence issued by a recognised State by making it quicker for them to be granted an AEL, without having to undergo an RPL assessment by an MTO. This more efficient approach would generally negate the need for an applicant to complete all of the basic knowledge training modules and examinations required under Part 66 and the Part 66 MOS, with many applicants who apply for a “full” AEL only needing to complete the exams in Australian aviation law. This is because the majority of an applicant’s knowledge, competencies and practical experience will be taken to be equivalent to Australia’s requirements for the AEL. How much will depend upon the scope of privileges they hold on their particular foreign licence and the kind of AEL they have applied for. This will also have an indirect, positive impact on businesses who employ AEL holders by providing them with a wider pool of AEL holders to carry out maintenance of aircraft.

Impact on categories of operations

These amendments will have a positive effect on all categories of operations as the number of AEL holders available to maintain and certify maintenance performed on aircraft will increase.

Impact on regional and remote communities

The amendments will have a positive impact on regional and remote communities as they will benefit from an anticipated rise in licensed aircraft maintenance engineers whose licence privileges are aligned to the needs of aircraft operators working in these communities.

Office of Impact Analysis

An IA is not required in this case, as the instrument is covered by a standing agreement between CASA and OIA under which an IA is not required for amendments to Manual of Standards as they are minor or machinery in nature (OIA id: OIA23-06250).

Statement of Compatibility with Human Rights

The Statement of Compatibility with Human Rights at Attachment 1 has been prepared in accordance with Part 3 of the Human Rights (Parliamentary Scrutiny) Act 2011.

Making and commencement

The instrument has been made by the Director of Aviation Safety, on behalf of CASA, in accordance with subsection 73(2) of the Act.

The instrument commences on the day after it is registered and is automatically repealed in accordance with section 48A of the LA.

Attachment 1

Statement of Compatibility with Human Rights

Prepared in accordance with Part 3 of the
Human Rights (Parliamentary Scrutiny) Act 2011

Part 66 Manual of Standards Amendment Instrument 2026 (No. 1)

This legislative instrument is compatible with the human rights and freedoms
recognised or declared in the international instruments listed in section 3 of the
Human Rights (Parliamentary Scrutiny) Act 2011.

Overview of the legislative instrument

The purpose of the legislative instrument is to address the shortage of licenced aircraft maintenance engineers in Australia by amending the Part 66 Manual of Standards (the Part 66 MOS) to enable the Civil Aviation Safety Authority (CASA) to recognise aircraft maintenance engineer licences issued by the United Kingdom and the United States of America.

The instrument substitutes Appendix V of the Part 66 MOS with a new Appendix V specifying the United Kingdom and the United States of America as recognised States for the purposes of regulation 66.030 of the Civil Aviation Safety Regulations 1998 (CASR). Regulation 66.030 provides for CASA to recognise a foreign licence, issued by a recognised State, provided the licence is held by an applicant for an Australian aircraft engineer licence (AEL) at the time of application and is in force.

To become a recognised State, a foreign State must have been assessed by CASA as having acceptable licensing and training standards that comply with Annex 1, Personnel licencing, to the Convention on International Civil Aviation. Annex 1 contains Standards and Recommended Practices adopted by the International Civil Aviation Organization as the minimum standards for personnel licensing.

CASA may require an applicant to undertake and pass specified knowledge tests, for example, examinations in Australian aviation law.

Human rights implications

The instrument is compatible with the human rights and freedoms recognised or declared in the international instruments listed in section 3 of the Human Rights (Parliamentary Scrutiny) Act 2011.

The instrument engages in a positive way with the right to work in Article 6 of the International Covenant on Economic, Social and Cultural Rights by enabling holders of aircraft maintenance licences issued by recognised States to obtain work in Australia as a licenced aircraft maintenance engineer (LAME). As there is a skills shortage of LAMEs in Australia, it should not affect the ability of current or future Australian LAMEs to obtain regular work.

The instrument protects the right to life in Article 6 of the International Covenant on Civil and Political Rights by protecting aviation safety by ensuring that Australian aircraft are always maintained by LAMEs who obtained their licence due to meeting the relevant Australian standards and requirements administered by CASA, or licensing and training standards, acceptable to CASA, that are applied by the national aviation authority of a recognised State. Applicants who obtain an Australian AEL due to holding such a foreign licence must still comply with Australian civil aviation safety regulations.

Conclusion

This legislative instrument is compatible with human rights.

Civil Aviation Safety Authority