CAR 31 to Part 66: what if your old licence does not show as transitioned?
There is a persistent industry myth that an old CAR 31 aircraft maintenance engineer licence can simply be “requalified” if it was never grandfathered into CASR Part 66.
That is not the right description of the pathway.
The clear position is this:
If CASA’s licence record does not show that your CAR 31 licence was transitioned/reissued as a Part 66 aircraft engineer licence, you should not treat the old CAR 31 document as a live licence. It is legacy evidence. The practical pathway is a Part 147 MTO recognition of prior learning, gap training and assessment pathway, leading to the relevant MEA units, required Part 66 knowledge examinations, and a new/current Part 66 licence application.
This article explains what happened during the transition, what current CAR 31 holders can and cannot do, and what steps to take now.
The short answer
If you held a CAR 31 licence at the transition date and CASA’s record shows that it became a Part 66 licence, you are dealing with a Part 66 licence. You may still need to manage exclusions, inclusions, ratings, organisation authorisations and recency/requalification.
If CASA’s record does not show a current Part 66 licence, the old CAR 31 licence is not enough to certify maintenance or issue a certificate of release to service today. It can, however, be used as strong evidence in a Part 147 MTO recognition of prior learning process.
That process is not “just exams”. It normally involves:
- Verification of the old CAR 31 licence and its face privileges.
- Mapping of the old privileges, CAR 31 Basics, extension basics, SOE and experience evidence.
- RPL against the relevant Part 66 outcome.
- Completion of gap training and assessment.
- Completion, recognition or reporting of the required MEA units of competency.
- Completion or recognition of the required Part 66 knowledge examinations, including modular exams where the modular pathway is used.
- A Part 66 licence application to CASA.
How the CAR 31 to Part 66 transition actually happened
The transition was not an informal “grandfathering” arrangement. It was built into the transitional provisions of the Civil Aviation Safety Regulations.
Under former CASR regulation 202.341, the transition applied to a person who, on 26 June 2011, held either:
- an aircraft maintenance engineer licence granted under regulation 31 of the Civil Aviation Regulations 1988; or
- a CAO 100.66 maintenance authority.
On 27 June 2011, that person was taken to have applied for, and to meet the requirements for, the relevant Part 66 aircraft engineer licence categories, subcategories and ratings that related to the aircraft and maintenance covered by the old CAR 31 licence or CAO 100.66 authority. See former CASR 202.341, PDF pp. 475–476.
CASA’s own privileges advisory circular describes the practical conversion this way:
“In May-June 2011 (the licence conversion period), all aircraft maintenance engineer licences previously issued under the CAR 31 licensing system were re-issued by CASA as a Part 66 licence.”
CASA then explains why exclusions were used: CAR 31 had a different category/group structure from Part 66, so exclusions were applied to ensure old and new privileges matched rather than giving people privileges they did not previously hold. See CASA AC 66-08 v1.3, p. 27. (Civil Aviation Safety Authority)
This means many former CAR 31 engineers were not simply given a clean, unrestricted B1 or B2 licence. They were issued Part 66 privileges that reflected the old CAR 31 scope, usually through a combination of categories, subcategories, type ratings, exclusions and inclusions.
What happened to engineers who were licensed at the transition date?
For ordinary current licence holders at the transition date, CASA’s process was to reissue the old CAR 31 licence as a Part 66 licence.
For suspended licences and pending applications, the transitional rules were more specific. For example, former CASR 202.342 dealt with licences suspended on 26 June 2011, and former CASR 202.343 dealt with applications made before 27 June 2011 that were not finally determined by CASA. See former CASR 202.342–202.343, PDF pp. 476–477.
There was also a later transitional application mechanism under former CASR 202.344 for certain applications made on or after 27 June 2011. That mechanism expressly ceased and expired at the end of 26 June 2015. See former CASR 202.344, PDF pp. 477–479.
So the practical rule is:
If you held a CAR 31 licence at the transition date, CASA should generally have a Part 66 record for you. If there is no Part 66 record, the issue must be verified with CASA. If CASA confirms there is no current Part 66 licence, you are not dealing with requalification of a live licence. You are dealing with a new/current Part 66 pathway using the CAR 31 material as RPL evidence.
Can you use an old CAR 31 licence today?
Not by itself.
Current CASR 66.120 says a licensed aircraft maintenance engineer may perform maintenance certification or issue a certificate of release to service only in accordance with the privileges, conditions and limitations of their aircraft engineer licence and endorsed ratings. It also requires recent grant, recent exercise of privileges, or requalification within the previous two years. (Federal Register of Legislation)
The current Part 66 MOS defines a Part 66 licence as an aircraft engineer licence issued under Part 66 of CASR. It also defines an old CAR 31 AME licence separately as an AME licence under regulation 31 of CAR 1988 as in force immediately before 27 June 2011. (Federal Register of Legislation)
That distinction matters.
A physical CAR 31 licence document is not the same thing as a current Part 66 licence record.
The operational question is not “do you have an old CAR 31 piece of paper?” The question is:
Does CASA’s current record show that you hold a Part 66 aircraft engineer licence, with the relevant category, subcategory, rating, inclusion, exclusion status and recency?
If the answer is no, do not use the old CAR 31 licence to certify maintenance or issue CRS.
What if CASA’s record shows you do have a Part 66 licence?
Then the issue is different.
You are not trying to revive CAR 31. You are dealing with a current Part 66 licence that may require:
- recency or requalification;
- exclusion removal;
- type rating action;
- organisation authorisation; or
- evidence of recent exercise of privileges.
The Part 66 MOS requalification provision applies to an existing licence holder. For A, B1 and B2 licence holders, MOS 66.A.23 includes pathways such as 100 days of relevant AME maintenance evidence, an MTO report, or an AMO/CAR 30 assessment process. See Part 66 MOS 66.A.23. (Federal Register of Legislation)
That is the correct use of the word requalification.
Requalification is for a current Part 66 licence holder who has a recency problem. It is not a mechanism to resurrect an old CAR 31 licence that CASA does not show as a current Part 66 licence.
What if CASA’s record does not show a Part 66 licence?
If CASA confirms there is no current Part 66 record, the pathway is not “requalify CAR 31”.
The pathway is:
Part 147 MTO RPL → gap training and assessment → MEA units and Part 66 exams → CASA Part 66 application.
CASA’s current Part 147 AMC/GM expressly recognises the category “Expired CASA CAR 31 licence (not transitioned)” in its RPL procedure table. The stated process is:
“Straight recognition of privilege as detailed on the face of the expired licence, excluding cancelled or revoked licences.”
The same table says the MTO may grant knowledge by mapping CASR Part 66 knowledge requirements to CAR 31 knowledge examined, and that CASA can advise whether a licence has been cancelled or revoked. See CASA AMC/GM Part 147 v3.3, Table 6, PDF pp. 10–11. (Civil Aviation Safety Authority)
That is the critical point.
CASA is not saying the untransitioned CAR 31 licence is live. CASA is saying it may be used in an approved MTO RPL process.
Does this mean you only need to sit exams?
No.
For an untransitioned CAR 31 holder, exams are only one part of the pathway.
A current Part 66 outcome requires both:
- Knowledge evidence, usually through Part 66 module examinations or accepted mapped knowledge credit; and
- Competency/practical evidence, usually through relevant MEA units of competency, RPL assessment, gap training and documented experience.
Part 66 MOS 66.A.25 requires applicants to demonstrate the relevant Part 66 knowledge by examination conducted by CASA or an MTO. For modular licences, the applicant must demonstrate knowledge of the applicable modules or sub-modules under Appendix I Part 2A. See Part 66 MOS 66.A.25(b)–(c). (Federal Register of Legislation)
The same MOS section says that, if the applicant was trained by an MTO, the applicant must hold the required units of competency in Appendix IV for a full category/subcategory outcome, or Appendix X for a modular licence outcome. See Part 66 MOS 66.A.25(eb)–(ec). (Federal Register of Legislation)
It also says a person may be taken to hold the necessary qualifications or units of competency if an MTO has conducted an RPL assessment in accordance with the MTO’s course plan and exposition. See Part 66 MOS 66.A.25(g). (Federal Register of Legislation)
So the right answer is:
No, you do not “just sit exams”. You need the required knowledge, competency and experience evidence for the Part 66 outcome being sought. For the MTO pathway, that means MEA units, Part 66 exams or mapped credits, and any required gap training and assessment.
Do you need MEA units?
For the Part 147 MTO pathway, yes.
The Part 66 MOS uses MEA units of competency as part of the licence evidence structure. The MOS defines MEA as “manufacturing and engineering assessment” and notes that MEA is part of the code assigned to the nationally endorsed Australian training package. (Federal Register of Legislation)
The MOS also says a person is taken to hold, or have obtained, a unit of competency if an MTO assesses the person as competent and gives them a statement of attainment or similar document. See Part 66 MOS 66.6. (Federal Register of Legislation)
CASA’s Part 147 AMC/GM is direct on this point:
“The only competencies that a Part 147 MTO can currently report to CASA for the grant of a category A, B1 or B2 licence, or category B1 or B2 modular licence, are those units of competency specified for each licence and listed in Appendix IV and Appendix X respectively, of Part 66 MOS, or those determined by CASA to be equivalent competencies.”
CASA then lists the MEA Aeroskills qualifications recognised for Part 66 outcomes:
- MEA20518 Certificate II in Aircraft Line Maintenance — Category A outcome.
- MEA50219 Diploma of Aeroskills (Mechanical) — Category B1 outcome.
- MEA50118 Diploma of Aeroskills (Avionics) — Category B2 outcome.
See CASA AMC/GM Part 147 v3.3, PDF pp. 11–12. (Civil Aviation Safety Authority)
For a modular licence, the required units are not simply “the whole diploma”. They are the relevant Appendix X units for the chosen modular scope, plus any optional units required for the privileges being sought.
CASA RPL vs ASQA/VET RPL: same words, different function
This is where a lot of confusion starts.
CASA / Part 66 / Part 147 RPL
In the aircraft engineer licensing context, RPL is used to recognise prior knowledge, competency, training, experience or privileges against a Part 66 outcome.
CASA AC 66-08 defines RPL as prior learning that has delivered knowledge or competency by a theoretical or practical element at least equivalent to what would otherwise be required. It also notes that passing examinations, holding units of competency, and holding prerequisite qualifications or units of competency may be achieved by means of RPL. See CASA AC 66-08 v1.3, p. 6. (Civil Aviation Safety Authority)
CASA’s Part 147 AMC/GM says that, where an MTO has CASA approval for an RPL control procedure within its exposition, the MTO may conduct RPL assessments as authorised by that exposition. The evidence may include certificates, diplomas, references, duty statements, company approvals, samples of work, workplace review, recorded practical experience and documentation. The MTO may also require written assignments, oral or written questions, observations, practical demonstrations, interviews or examinations. See CASA AMC/GM Part 147 v3.3, PDF p. 10. (Civil Aviation Safety Authority)
ASQA / VET RPL
ASQA/VET RPL is broader. It is an assessment process within the vocational education and training system.
The 2025 Outcome Standards for Registered Training Organisations define recognition of prior learning as an assessment process involving assessment of an individual’s relevant prior learning and experience, including formal and informal learning, to determine the extent to which the individual meets the requirements of the training product. See the Outcome Standards Instrument 2025, section 4.
Standard 1.6 requires RTOs to support students to seek RPL and to base RPL decisions on evidence of prior skills, learning and experience, with decisions documented and made in a way that is fair, transparent and consistent.
ASQA’s RPL practice guide also warns against treating RPL as an easy, quick or guaranteed pathway to qualifications, and says RPL systems must apply the same rigour as the organisation’s assessment system. (ASQA)
The practical distinction
For aircraft engineers:
ASQA/VET RPL can support the issuing of MEA units of competency.
CASA/Part 147 RPL supports a Part 66 licensing pathway.
Neither one, by itself, gives you permission to certify maintenance or issue CRS.
The authority to certify comes from the Part 66 licence, the endorsed ratings, the licence conditions and exclusions, the applicable maintenance organisation authorisation, and current recency/requalification status.
What should an old CAR 31 holder do now?
Step 1 — Verify the CASA licence record
Do not rely only on an old paper licence.
Ask CASA, or use the applicable CASA licence verification process available to you or your organisation, to confirm:
- whether there is a current Part 66 aircraft engineer licence record;
- the licence category or subcategory;
- any type ratings;
- exclusions;
- inclusions;
- conditions;
- suspension or cancellation history; and
- whether recency/requalification is required.
The question to ask is:
“Does CASA hold a Part 66 aircraft engineer licence record for me arising from the CAR 31 transition, and if so, what categories, subcategories, ratings, exclusions, inclusions and conditions are recorded?”
Step 2 — If a Part 66 record exists, deal with the Part 66 issue
If CASA confirms that you hold a Part 66 licence, the old CAR 31 discussion is mostly historical. You need to work through the current Part 66 requirements for:
- recency;
- requalification;
- exclusion removal;
- rating privileges;
- type training;
- organisation authorisation; and
- evidence of recent exercise of privileges.
Step 3 — If no Part 66 record exists, stop treating CAR 31 as a licence
If CASA confirms that there is no current Part 66 licence, the old CAR 31 licence is not a live certification authority.
It becomes evidence.
The next step is a Part 147 MTO assessment.
Step 4 — Submit the CAR 31 evidence package to a CASA-approved Part 147 MTO
The evidence package should include, where available:
- copy of the CAR 31 licence face;
- category and group ratings;
- type ratings;
- CAR 31 Basics;
- extension basics;
- SOE evidence;
- employer letters;
- old company authorisations;
- recent maintenance history;
- logbooks;
- training records;
- aircraft type or system training records;
- evidence of certification privileges previously exercised;
- evidence of current aircraft maintenance employment or recent hands-on maintenance exposure.
CASA’s Part 147 AMC/GM specifically recognises recorded practical experience, workplace review, company approvals, references, samples of work and documentation/reports/journals as examples of RPL evidence. (Civil Aviation Safety Authority)
Step 5 — Receive a gap report
The MTO should map the evidence to the target Part 66 outcome.
For a former CAR 31 holder, the most practical target may be a modular B1 or B2 outcome, depending on the old privileges and the current work being performed.
The gap report should identify:
- the target licence outcome;
- recognised CAR 31 privileges;
- knowledge credits from CAR 31 Basics or extension basics;
- MEA units already satisfied by RPL;
- MEA units still requiring assessment;
- Part 66 module or modular examinations still required;
- practical experience evidence still required;
- any limitation, exclusion or staged pathway required.
Step 6 — Complete gap training, assessment and exams
The engineer then completes the missing components.
That may include:
- MEA unit assessment;
- practical demonstrations;
- oral questioning;
- workplace evidence collection;
- Part 66 module exams;
- modular licence exams;
- practical experience logbook evidence;
- additional system training;
- optional units for propellers, fabric or wooden structures where relevant.
Step 7 — Apply to CASA for the Part 66 licence outcome
A person may apply to CASA for an aircraft engineer licence under CASR 66.020. The application must include documents evidencing the relevant qualifications and experience. CASA grants the licence only if satisfied the applicant meets the applicable Part 66 MOS requirements, including 66.A.25 and 66.A.30, or is otherwise taken to meet those requirements under the regulations. (Federal Register of Legislation)
Common misconceptions
“I still have my CAR 31 licence, so I can certify.”
Not unless CASA’s current record shows a Part 66 licence and you meet the current privilege, limitation, authorisation and recency requirements.
“I can requalify my CAR 31 licence.”
Not as a stand-alone pathway. Requalification applies to an existing Part 66 licence holder. If there is no Part 66 licence record, the pathway is RPL/gap training toward a Part 66 outcome.
“RPL means I will not need exams.”
No. RPL may reduce or remove some training and assessment requirements where evidence is sufficient. It may also identify missing knowledge that must be examined. CASA’s Part 147 AMC/GM expressly allows MTOs to require additional assessment, including examinations. (Civil Aviation Safety Authority)
“MEA units are just paperwork.”
No. Under the MTO pathway, MEA units of competency are the competency evidence structure that CASA recognises for Part 66 outcomes. For full licences, the relevant Appendix IV units apply. For modular licences, the relevant Appendix X units apply. (Federal Register of Legislation)
“If I had CAR 31 Basics, I automatically meet Part 66.”
No. CASA says CAR 31 Basics may be mapped to Part 66 knowledge requirements, but the result depends on the mapping and the licence outcome being sought. For an expired CAR 31 licence not transitioned, CASA’s current guidance treats the licence as RPL evidence, not as a current licence. (Civil Aviation Safety Authority)
Where Sigma Aerospace College fits
Sigma Aerospace College is listed in CASA AC 147-02 as approved for Category A1–A4, B1.1–B1.4 and B2 category training, and for B1/B2 modular licence outcomes. CASA AC 147-02 also states:
“Approved to train and assess for Modular licence outcomes.”
and:
“RPL has been approved for use by Sigma Aerospace College.”
See CASA AC 147-02 v8.8, pp. 20–21. (Civil Aviation Safety Authority) (Civil Aviation Safety Authority)
For an old CAR 31 holder, the starting point is not a generic exam list. The starting point is a document-based assessment of the old licence, old knowledge evidence, practical experience and target Part 66 outcome.
The correct pathway is:
Verify the CASA record → confirm whether a Part 66 licence exists → if not, complete MTO RPL and gap assessment → complete required MEA units and Part 66 exams → apply for the current Part 66 licence outcome.
Bottom line
If CASA’s current record shows that your CAR 31 licence was transitioned to Part 66, you are dealing with a Part 66 licence and the next issue is recency, exclusions, ratings or authorisation.
If CASA’s current record does not show that your CAR 31 licence was transitioned to Part 66, you should not use the old CAR 31 licence as authority to certify maintenance or issue CRS.
The pathway is not “requalify CAR 31”.
The pathway is:
Part 147 MTO RPL + gap training + required MEA units + required Part 66 exams + CASA Part 66 application.
That is the clean, auditable and regulator-aligned way to bring legacy CAR 31 evidence into the current Part 66 system.
References
- Civil Aviation Safety Regulations 1998 — former Subpart 202.CG transitional provisions for Part 66
Key references: former CASR 202.341, 202.342, 202.343 and 202.344. See PDF pp. 475–479.
https://www.legislation.gov.au/F1998B00220/2014-09-01/2014-09-01/text/1/pdf/4 - CASA AC 66-08 v1.3 — Part 66 aircraft engineer licences: privileges
Key references: RPL definition at p. 6; CAR 31 to Part 66 conversion process at p. 27; exclusion removal at pp. 29–30.
https://www.casa.gov.au/part-66-aircraft-engineer-licences-privileges - Civil Aviation Safety Regulations 1998 — current Part 66
Key references: CASR 66.020, 66.025, 66.026 and 66.120.
https://www.legislation.gov.au/F1998B00220/latest/text - Part 66 Manual of Standards — current compilation
Key references: definitions in 66.5; unit of competency rule in 66.6; transitional privileges in 66.A.21; requalification in 66.A.23; basic knowledge and competency requirements in 66.A.25; practical experience requirements in 66.A.30; Appendix IV and Appendix X.
https://www.legislation.gov.au/F2011L00280/latest/text - CASA AMC/GM Part 147 v3.3 — Maintenance training organisations
Key references: RPL principles and evidence requirements at PDF p. 10; “Expired CASA CAR 31 licence (not transitioned)” in Table 6 at PDF pp. 10–11; MEA units and recognised Aeroskills qualifications at PDF pp. 11–12.
https://www.casa.gov.au/part-147-maintenance-training-organisations-amc-gm - CASA AC 147-02 v8.8 — Approved Part 147 training organisations
Key references: Sigma Aerospace College approvals for category and modular licence outcomes at PDF pp. 20–21.
https://www.casa.gov.au/sites/default/files/2023-10/advisory-circular-147-02-approved-part-147-training-organisations.pdf - National Vocational Education and Training Regulator (Outcome Standards for Registered Training Organisations) Instrument 2025
Key references: RPL definition in section 4; RPL performance indicators in Standard 1.6.
https://www.legislation.gov.au/F2025L00354/asmade/text - ASQA RPL & Credit Transfer Practice Guide
Key references: Standard 1.6 guidance and known RPL risks.
https://www.asqa.gov.au/for-providers/standards-for-RTOs/practice-guides/quality-area-1-training-and-assessment/RPL-and-credit-transfer-practice-guide