What is KIWA?
KIWA is the Netherlands’ licencing department and oddly, its emblem is a beaver. This is because one of their many roles alongside Part-66 licence approvals is that they are a water and waste management company.
Historically, they’ve been one of the quickest and cheapest national aviation authorities (NAA) to process your Part-66 EASA licence, along with Greece.
You might assume that KIWA is the National Aviation Authority (NAA) of the Netherlands, however, that's not the case. In many countries, the Part-66 approval is held directly by the national authority.
In the Netherlands, the responsibility lies with the Environment and Transport Inspectorate (ILT) and they have outsourced the Part-66 licensing process to a private company called KIWA.
For those with their licence endorsements being revoked, what actually happened?
The ILT launched an investigation into KIWA after discovering significant issues with how licences were being issued, particularly regarding the substandard on-the-job training (OJT) practices. Tasks were sometimes signed off without the OJT supervisor even being present on shift.
As a result, hundreds of engineers had their first type ratings revoked, and their licences were returned with all endorsements removed. This blanket action affected many engineers who were innocent victims caught in the fallout.
To put it into perspective, this is akin to the DVLA reaching out after five years of you driving, asking for your driving licence back and then returning it as a provisional, with no privileges. It was utter chaos and still is to this day.
This has caused a massive ripple effect across the industry, as many engineers held KIWA-issued licences, which are now considered invalid. To make matters worse, the ILT has started revoking entire licences, claiming that the grounds on which they were initially granted were unapproved.
What about the aircraft certified during this time?
This seems to be a point that the authorities have yet to address adequately. If a licenced engineer certified an aircraft during the period when their licence had been endorsed with the type rating, but the ILT later removed the endorsement, it raises serious questions.
If the ILT’s decision to remove the endorsements means that you didn’t meet the required qualification standards, it would suggest that any aircraft you certified during that time was done so illegally.
What options do you have to obtain an EASA OJT again in the UK?
If you’re working in the UK and looking to regain EASA OJT approval, there are two primary options:
- Relocate to an EASA member state and complete your OJT
While not the easiest option, this route allows you to carry out your OJT within an EASA state. However, it must be stated that there are potential residency issues with this option. If you’re open to working abroad, this might be a practical solution for you, especially if you’re already planning on relocating in the future. - Obtain OJT approval through an EASA National Aviation Authority (NAA)
This option provides a more flexible solution if you can’t or don’t want to work abroad. It allows you to address the OJT issue without leaving the UK, safeguarding your future career prospects. Here’s how:
If you’re working in the UK and hold a blank Dutch or any blank EASA licence. EASA regulations have changed, and since 2023, stricter rules for on-the-job training (OJT) procedures have been implemented. Most UK companies’ OJT schemes no longer meet the required standard.
Your best option is to get your company’s quality department to submit an OJT approval application with the ILT or another NAA of your choosing. This process usually costs between £700-£1000 and can take up to a year to be processed. The application involves two separate inspectors who must agree that your company’s procedures and policies are sufficient before approval is granted .
Why doesn’t my company have EASA OJT training approval anymore?
It’s important to understand that a maintenance organisation is a Part 145 organisation, not a Part 147 training organisation. Therefore, maintenance organisations don’t organically have the authority to carry out training. That responsibility lies with Part 147 organisations.
For this reason, OJT procedures become a grey area, as they require live aircraft for training, which part 147 training organisations typically don’t have. For this reason OJT’s are usually conducted as an exception to the rule by a part 145 and not a part 147.
This is where section 3.15 of the Maintenance Organisation Exposition (MOE) comes into play. This section of your company’s MOE requests direct approval from the authorities to conduct specific training. If the MOE has been accepted by your local authority and they’ve reviewed your company’s OJT procedures, they can approve the process. And this is why your company natively has UK CAA OJT approval .
If your company holds both an EASA MOE and a CAA MOE, you might notice that Section 3.15 is missing or has been removed from the EASA version. This is because, since Brexit, the EASA and CAA have diverged in their requirements, and EASA now implements its own procedures.
Getting approval to carry out EASA OJT is now an NAA-specific task, meaning your company must complete the OJT approval process set out by the particular NAA they wish to build a bridge with.
Should your company have multiple engineers with various blank EASA licences from different states, the company would have to go through this process with every single one.
What changes is the ILT specifically implementing that need to be adjusted to comply?
The issues that the ILT has raised seem to be less about new regulations and more about enforcing rules that had previously been ignored. The main issues they’re finding with OJT applications are as follows:
Supervisors’ approvals: Most supervisors are highly qualified, but companies often fail to show that they are approved by the company. The ILT is requesting that all OJT supervisors be formally approved by the company and that the company have a procedure to demonstrate this approval.
The best way to implement this is to have some sort of in-house training process for OJT supervisors and state their new privileges in their company approval. To comply, companies should include an approval statement for licenced engineers, confirming that they are approved supervisors.
Assessors’ training: Not to be confused with supervisors. This is the person responsible for signing off on your entire OJT application. The assessors must be recently trained and listed on the company’s approval as authorised to carry out OJT final assessments.
Compliance reports: OJT books have often lacked a compliance report explaining how each section of the company’s MOE and OJT book complies with EASA regulations. A good compliance report should detail how the company’s MOE, procedures, and staff meet the necessary requirements.
Task variety: The ILT has found that the number of tasks submitted in OJT applications is often insufficient. According to EASA regulations, 50% of the tasks in the master list (laid out in AMC to Section 6 of Appendix III to Part-66) must be completed. Additionally, the tasks must be diverse, covering removals/installations, inspections, operations testing, and troubleshooting rather than just component replacements.
The easiest way to comply here is to include the entire task list in the OJT book and provide a section for the assessor to check that a varied set of tasks has been covered within each ATA chapter. Once 50% of the tasks are completed, your OJT is done. This needs to be set out within your company’s MOE.
Can I transfer my blank Dutch licence to another authority?
While transferring your Dutch EASA licence to another authority is possible, it’s becoming increasingly difficult. There have been successful transfers, but the new authority will often require an OJT approval to be carried out.
So, even if you transfer, you may end up in the same situation, just with a different NAA.
The only time an NAA will accept an EASA-to-EASA transfer is if you can provide a valid reason, such as:
- Moving to that country to work
- Working or a company that requires the transfer
- Your company has direct OJT approval from a particular NAA, and you wish to submit an OJT through that authority.
Thanks for your input, but I’m going to transfer, anyway. Any advice?
Let’s take the Irish Aviation Authority (IAA) as an example. The IAA has been overwhelmed with transfer requests, and their main concern is that some engineers who are seeking a transfer may have been blocked from progressing their OJT by KIWA for a valid reason.
The IAA doesn’t want to approve engineers who have obtained their licences through non-compliant training schools. For example, some engineers have been known to sit multiple exams over a weekend in European countries like Slovenia. These exams are notoriously difficult, and it’s nearly impossible to pass modules 13, 3, and 4 in the same afternoon if done properly. The IAA will reject any transfer applications where a suspicious number of exams were sat in one go.
If insufficient experience was submitted to the original NAA when the licence was first issued, they may also reject your transfer. Be careful, as in some cases, KIWA may delete your old licence as soon as you apply for the transfer, leaving you in a difficult position.
What’s the process for transferring from EASA-to-EASA?
KIWA will likely be happy to see you go, as they’ve been dealing with a lot of issues. To transfer, you’ll need to fill out two separate applications. One is with the NAA you’re transferring to and the other is with the NAA you’re leaving.
KIWA will charge a small fee (of course!) to forward your documents to the new NAA, and then you’ll be placed in a queue for review. Make sure to include a signed letter from your quality department explaining the reason for the transfer; without it, your application will be rejected.
Once the new NAA reviews your application, including your module certificates and initial experience logs, they’ll issue your new licence. KIWA will then be instructed to destroy your old licence (you can’t hold two EASA licences from different states concurrently).
Congratulations! You’ll now have a different blank piece of paper—minus the beaver. Hopefully, the reason for your transfer was that your company has secured OJT approval with the new NAA, so you can simply submit your OJT. Be aware, however, that they’ll likely want you to do a fresh OJT from the day your company receives its OJT approval. Any tasks carried out before this date will be considered non-compliant.
Conclusion
While this is undoubtedly a challenging time for UK CAA Part-66 licence holders seeking their EASA first types, it’s important to note that progress is being made towards rebuilding ties between EASA and the CAA.
Although a bilateral agreement may never be reached, the outlook is positive, and we’ll eventually see a framework where both sets of licence holders can operate within the same system.
UK training schools will soon all be dual-certified, and we are already seeing courses aimed at covering the differences between CAA and EASA module exams being offered to bridge the gap. Unfortunately, no processes exist for anyone whose modules have expired.
Rest assured, though, the storm will pass, and brighter days lie ahead. Good luck to everyone navigating this process .
