CAR 31 to Part 66: has your licence transitioned?
Before booking exams or arranging requalification, check which licence you actually hold. An engineer who started under CAR 31 may already have a Part 66 licence, even if they have not exercised its privileges for years.
Requalifying as a Part 66 licence holder and obtaining a Part 66 licence using old CAR 31 evidence are different processes. The first step is to establish which applies to you.[1][2]
Start with section VIII of your licence
Look for the statement beside the Roman numeral VIII. On the licence example shown, it reads:
This Licence is issued in accordance with regulations 66.025 and 66.080 of the Civil Aviation Safety Regulations 1998.
The two references identify the Part 66 provisions under which licences and ratings are granted:
| Reference | What it means |
|---|---|
| CASR 66.025 — Grant of licence | Covers the grant of an aircraft engineer licence under Part 66. |
| CASR 66.080 — Grant of rating | Covers the grant of a rating on an aircraft engineer licence, including the applicable training and assessment requirements. |
A licence bearing this statement is a Part 66 licence document, not an old CAR 31 licence document. For someone originally licensed under CAR 31, this is a useful first check that a Part 66 document has been issued.[1]
There is a qualification: these references are not unique to licences issued through the 2011 transition. They identify the licensing system, not the holder’s complete licensing history. Nor does the statement establish recency, remove exclusions or authorise work outside the licence’s privileges.[1]
If the only document you have is your old CAR 31 licence, ask CASA to check your record. Not having a Part 66 document in your files does not establish that the transition never happened. Resolve any missing or conflicting records before deciding that you need a new licence pathway.[2][3]
What happened during the transition?
The transition took effect on 27 June 2011. Under former CASR 202.341, a person holding a CAR 31 aircraft maintenance engineer licence or a CAO 100.66 maintenance authority on 26 June 2011 was taken to have applied for, and to meet the requirements for, the corresponding Part 66 licence categories, subcategories and ratings.
The provision specifically referred to the grant requirements in 66.025 and 66.080 — the same regulations shown in section VIII of the example licence. Former regulations 202.342 and 202.343 separately addressed suspended licences and applications that had not been finally determined.[3]
CASA describes the practical conversion as the reissue of CAR 31 licences during May–June 2011. Because the old category and group-rating structure did not match Part 66, exclusions and inclusions were used to preserve the privileges previously held.
That is why a transitioned licence may show a B1 or B2 category with restrictions. The category heading alone does not tell you everything you can certify.[2]
If you already hold a Part 66 licence
Your next step is to establish what is needed to exercise that licence’s privileges now. Depending on your circumstances, that may involve recency, requalification, exclusion removal, type ratings or an organisation’s certification authorisation.
Under CASR 66.120, maintenance certification and release to service must remain within the applicable privileges, conditions and limitations. The regulation also requires that, within the preceding two years, you have been granted the licence, accumulated at least six months’ experience exercising the relevant privileges, or met a requalification requirement.[1]
For A, B1 and B2 licence holders, MOS 66.A.23 provides alternative requalification arrangements. These include at least 100 days of relevant maintenance as an AME with evidence retained, an MTO assessment and report, or an assessment through an approved maintenance organisation or CAR 30 organisation under its specified procedures. The MTO option includes theory examination and practical assessment.[4]
Requalification addresses an existing licence holder’s recency requirements. It does not convert an untransitioned CAR 31 licence into a Part 66 licence. A gap in recent certification experience is therefore not the same problem as never having obtained a Part 66 licence.[1][4]
If your CAR 31 licence was never transitioned
If CASA confirms that your expired CAR 31 licence was not transitioned and you do not hold a Part 66 licence, the old document can still be valuable evidence. It is not, by itself, authority to certify maintenance today.[1][5]
CASA’s Part 147 guidance expressly addresses “Expired CASA CAR 31 licence (not transitioned)”. Table 6 provides for straight recognition of the privileges recorded on the face of that licence, excluding cancelled or revoked licences. It also allows CAR 31 examination evidence to be mapped against Part 66 knowledge requirements.[5]
This recognition takes place within the MTO’s approved RPL process. It does not reactivate the old licence or guarantee that every requirement for the proposed Part 66 licence has been met.
A CASA-approved Part 147 maintenance training organisation can assess the old licence, examination results and maintenance experience, then identify any remaining training, assessment and experience requirements. The amount of recognition depends on the evidence and the privileges being sought.[5]
A suspension, cancellation or revocation needs separate attention with CASA. It should not be treated as an ordinary expired-licence RPL case.[3][5]
Will you need exams, MEA units or more practical experience?
That depends on what the assessment recognises and what remains outstanding. Have your existing evidence reviewed before you book exams.
Knowledge and examinations
CAR 31 Basics and extension Basics may provide credit towards Part 66 knowledge requirements. The credit depends on the subjects covered and their mapping to the applicable Part 66 syllabus; holding Basics results does not automatically satisfy every module.
CASA’s guidance explains that credit for a whole module requires coverage of all its topics. An incomplete match should not be presented as exemption from the entire module examination. Your assessment needs to identify which knowledge requirements are satisfied and which examinations remain.[5][6]
MEA units of competency
For the MTO training pathway, the required MEA Aeroskills units form part of the licensing requirements. MOS 66.A.25 identifies the relevant units in Appendix IV for category or subcategory licences, and Appendix X for modular licences. Additional optional units apply to certain privileges, including propellers, wooden structures and fabric surfaces.
The MOS also allows the necessary qualifications or units to be recognised through RPL conducted in accordance with the MTO’s course plan and exposition. This does not mean everyone must repeat a full course. Equally, a modular licence should not automatically be described as requiring an entire diploma: the requirements must be matched to the modular scope being sought.[4]
Practical experience and assessment
Your maintenance history also needs to support the proposed licence. Relevant logbooks, schedules of experience, employer records and evidence of work performed can help establish what you have done. Depending on the gaps, further workplace evidence, practical demonstrations, questioning or training may be needed.[5]
The applicable practical-experience requirements still need to be satisfied. Passing the outstanding exams alone does not establish that all licensing requirements have been met.[4]
This article describes the Part 147 MTO/RPL route. Part 66 also provides a self-study pathway with its own examination and documented practical-experience requirements; it is not an exams-only alternative.[7]
CASA RPL and VET RPL are not interchangeable
Both processes recognise prior learning, but they serve different purposes.
In the CASA licensing system, an MTO conducts RPL within the scope of its CASA approval and approved procedures. The assessment establishes what can be recognised towards the relevant Part 66 requirements.[5]
In the vocational education and training system, an RTO assesses prior skills, knowledge and experience against the requirements of the training product. ASQA requires evidence-based, documented RPL decisions made through the organisation’s assessment system. RPL must meet the same assessment standards as other assessment; it is not a guaranteed qualification based on years in the industry.[8]
The assessments may overlap, but recognition of old licence privileges for CASA purposes should not be presented as automatic entitlement to a VET qualification. Where VET units or a qualification are issued, the RTO must satisfy the applicable VET assessment requirements.[5][8]
Neither an RPL report nor a statement of attainment is a Part 66 licence. Certification under Part 66 depends on the licence and its applicable privileges, ratings, limitations, recency requirements and any required organisation authorisation.[1]
What to do next
1. Confirm your licence status
Start with section VIII, then contact CASA if the document or your history is unclear. Ask CASA to confirm whether you hold a Part 66 licence and obtain the recorded categories, subcategories, ratings, exclusions, inclusions and conditions.
A useful question is:
Does CASA hold a Part 66 aircraft engineer licence record for me arising from the CAR 31 transition? If so, please confirm its status and the categories, ratings, exclusions, inclusions and conditions recorded.
Resolve any discrepancy before committing to a new training pathway. Separately, review your recent maintenance and certification experience to establish whether requalification is needed.[1][2][3]
2. Gather your existing evidence
For an MTO assessment, provide the complete old licence and any later licence documents, CAR 31 Basics and extension Basics results, schedules of experience, qualifications and aircraft or system training records. Include logbooks, employer references, company authorisations and evidence of recent maintenance work where available.
These records help the assessor establish both your previous privileges and the knowledge and practical experience supporting them.[5]
3. Agree on the licence scope and obtain a gap report
Tell the MTO which aircraft and systems you intend to work on and which certification privileges you need. A full category or subcategory licence and a modular licence have different requirements; the assessment should be directed at the outcome you are actually seeking.[4]
Ask for a report identifying the recognition granted, the MEA units and knowledge requirements still outstanding, any further practical experience needed, and the training, assessment or exams required to close those gaps. It should also explain any exclusions or limitations expected to remain.[4][5]
4. Complete the outstanding requirements and apply to CASA
Complete the agreed training, assessment, examinations and experience requirements. The MTO reports the applicable training and assessment outcome, and you submit the relevant licence application to CASA.
CASA makes the licensing decision. Completion of the MTO process supports the application; it does not itself issue the licence.[1][7]
How Sigma Aerospace College can help
Sigma Aerospace College’s published CASA approval includes category A1–A4, B1.1–B1.4 and B2 training, B1 and B2 modular licence training, and approved use of RPL.[9]
For a former CAR 31 licence holder, we start with the documents: what licence was issued, what privileges it covered, what examinations and training were completed, and what maintenance experience can be supported.
Send us a copy of your licence, any confirmation from CASA about its status, and the training and experience records you have available. Tell us what you need to certify. That gives us the basis to identify the appropriate assessment and any remaining requirements.
General information only. Individual licence status must be confirmed with CASA, and recognition and training requirements depend on the applicant’s evidence and the scope of the relevant approval.
References
- Civil Aviation Safety Regulations 1998, compilation dated 30 June 2026. Regulations 66.020, 66.025, 66.080 and 66.120; applicable organisation-authorisation provisions. Federal Register of Legislation.
- CASA AC 66-08 v1.3 — Part 66 aircraft engineer licences: privileges, December 2022. Section 4.3.2–4.3.3, conversion from CAR 31 and the use of exclusions and inclusions. CASA.
- Former CASR Subpart 202.CG, including regulations 202.341–202.343, historical compilation dated 1 September 2014. These are historical transition provisions, not a current application pathway. Federal Register of Legislation.
- Part 66 Manual of Standards, compilation dated 3 July 2026. Sections 66.A.23, 66.A.25 and 66.A.30; Appendices IV and X. Federal Register of Legislation.
- CASA AMC/GM Part 147 v3.3 — Maintenance training organisations, December 2025. Section 2, Table 6 and Annex A. CASA.
- Recognition of prior learning (RPL) assessment — CASA Basics. Mapping Basics results to Part 66 knowledge requirements. CASA.
- Apply for a Part 66 licence. MTO and self-study application requirements. CASA.
- ASQA RPL & Credit Transfer Practice Guide, Standard 1.6. ASQA.
- CASA AC 147-02 v8.9 — Approved Part 147 training organisations, June 2026. Section 2.4, Sigma Aerospace College. CASA.
References checked 16 September 2026.
