UK CAA vs EASA pilot licences: what changed after Brexit

Brexit split what was a single pilot licensing system into two parallel frameworks. Most UK pilots now hold a UK FCL licence, while EASA remains the standard across EU member states. For many this causes daily confusion — here is what actually changed, what is still compatible, and what you need if you want to fly on both sides of the Channel.

Before Brexit: one system

Prior to 31 December 2020, the UK was an EASA member state. UK pilots held EASA licences issued by the UK CAA under EASA Part-FCL. These licences were valid across all 27 EU member states and a number of non-EU countries that had adopted EASA standards. The CAA acted as the national aviation authority (NAA) issuing EASA-format documents.

What happened on transition day

From 1 January 2021, the UK ceased to be an EASA member state. The CAA created UK FCL — a domestic licensing framework that mirrors EASA Part-FCL almost exactly in technical content but is a separate legal instrument under UK retained aviation law.

All UK-issued EASA licences were automatically converted to UK FCL licences. No action was required by pilots; the CAA sent replacement licence documents over the course of 2021–2022. The ratings, privileges, and qualification dates carried over unchanged.

UK FCL vs EASA FCL: the key differences

For everyday UK-based flying — training, recreational, commercial operations on UK-registered aircraft — UK FCL is all you need. The practical content of the licence is almost indistinguishable from its EASA equivalent.

Flying in Europe with a UK FCL licence

This is where many pilots get caught out. A UK FCL licence does not grant privileges in EU airspace on EU-registered aircraft. To fly commercially in Europe, UK pilots generally need one of three things:

Option 1 — Obtain a separate EASA licence

Apply to an EASA member state NAA for a new EASA licence, typically by converting your UK FCL qualifications. Most member states have a conversion route; the process involves providing your UK licence details, logbook evidence, and in some cases completing an administrative examination. Once issued, the EASA licence is entirely independent of your UK FCL licence.

Option 2 — Fly UK-registered aircraft under UK FCL

UK-registered aircraft (G-prefix) operating in EU airspace can be flown under UK FCL privileges, subject to the rules of the specific EU state being overflown or used for operations. Many general aviation pilots flying their own UK-registered aircraft to Europe continue on their UK FCL without issue under this provision. Confirm the requirements with your operator and the relevant NAA before flying commercially.

Option 3 — Bilateral agreement coverage

The UK has sought bilateral aviation agreements with a number of countries. Coverage varies; check the current status of any specific bilateral with the CAA before relying on it for operations.

Holding both licences

Many professional pilots now hold both a UK FCL licence (issued by the UK CAA) and an EASA licence (issued by an EU member state NAA, typically Ireland, Malta, or a Scandinavian state). This is the cleanest solution for pilots who regularly fly both UK and EU-registered aircraft commercially.

Holding both means maintaining two sets of documentation, two medicals (in practice the same AME often issues both, but they are technically separate certificates), and keeping ratings current on each. Revalidation completed on one licence does not automatically apply to the other, though evidence of the revalidation is typically accepted by both authorities.

Medicals: UK Part-MED vs EASA Part-MED

Medical certificate requirements under UK Part-MED and EASA Part-MED are effectively identical in validity periods and examination standards. However, a UK-issued medical certificate supports UK FCL privileges only, and an EASA-issued medical supports EASA FCL privileges only. Pilots holding both licences need to ensure each is supported by the appropriate medical.

In practice, many AMEs are approved by both the UK CAA and an EASA member state NAA and can issue certificates under both frameworks simultaneously.

What hasn't changed

For most UK-based pilots flying UK-registered aircraft recreationally or domestically, Brexit changed very little in practice. The examination syllabi, training requirements, rating structures, and validity periods are virtually identical between UK FCL and EASA FCL. Ratings earned under one framework are generally recognisable when applying for conversion to the other.