Part-66 Licence Privileges: The 6-Month, 2-Year Recency Rule You Can't Ignore

To use the privileges of an EASA Part-66 aircraft maintenance licence, you must have had 6 months of maintenance experience within the preceding 2 years, consistent with those privileges, or have met the provisions for the issue of the relevant privileges (66.A.20(b)(2)). Fall short, and the licence remains valid, but you cannot certify or act as support staff. Licence validity itself is a separate, 5-year matter under 66.A.40.

Who this applies to, and a UK caveat

The rule concerns holders of Part-66 licences issued by EU Member States (and, according to EASA's FAQ, Switzerland, Norway, Iceland and Liechtenstein). The FAQ adds that a licence issued by a country outside the EASA Member States cannot be rendered valid as a Part-66 licence and is not mutually recognised in the European system. Since Brexit, the UK has operated its own CAA licensing regime, which is not covered in this article's sources; UK-issued licences and their rules should be checked with the CAA.

Everything below is taken from Annex III (Part-66) to Regulation (EU) No 1321/2014, consolidated to 22 February 2026, and EASA's continuing airworthiness FAQ.

The rule in full context

66.A.20(b) sets four cumulative conditions on exercising privileges. The recency test is the second; the others are compliance with Part-M, Part-145, Part-ML and Part-CAO as applicable, adequate competence on the aircraft concerned, and the ability to read, write and communicate in the language of the technical documentation and procedures.

EASA's FAQ explains the purpose plainly: compliance with 66.A.20(b)(2) ensures privileges are exercised by people with sufficient recent experience, and if you no longer meet it, you lose the right to exercise certifying or support-staff privileges. It does not touch licence validity.

Which privileges are at stake

• Category A: certificates of release to service after minor scheduled line maintenance and simple defect rectification, within the tasks on the certification authorisation, and only for work the holder personally performed.
• B1: maintenance on structure, power plant and mechanical and electrical systems, plus avionics work needing only simple tests; includes the corresponding A subcategory.
• B2: avionics and electrical systems, and electrical and avionics tasks within power plant and mechanical systems; does not include any A subcategory.
• B3: piston-engine non-pressurised aeroplanes of 2,000 kg MTOM and below.
• L: sailplanes, powered sailplanes, ELA1 aeroplanes, balloons and airships, by subcategory.
• C: base maintenance release of the aircraft in its entirety.

Typical situations that trigger the rule

• A career break, such as parental leave or time out of the industry, that leaves less than 6 months of hands-on experience in the rolling 2-year window.
• A move into planning, technical records or quality, where the work is valuable but may not be maintenance experience in line with the licence privileges.
• A switch of aircraft type or structure after which the experience gained no longer matches the rating you want to use.
• Independent certifying staff with an irregular workload, who need a record to show recency to owners and authorities.

An illustration of the window, with an important caveat: an engineer certified for 4 months in spring 2025 and for 3 months in spring 2026. Looking back 2 years from 5 October 2026, both periods sit inside the window, giving 7 months (4 + 3) on a simple reading. The detailed counting method, including possible reductions the FAQ mentions for independent certifying staff and what counts as a similar aircraft, sits in AMC and GM to Part-66, which this base does not contain. Use the arithmetic only to understand the rolling window.

Regaining privileges if you fall short

The rule offers an alternative to the 6 months: having met “the provision for the issue of the appropriate privileges” within the 2 years. EASA's FAQ reads this against 66.A.45:

In every case, “demonstrate” means having a record, such as a logbook, according to the FAQ.

Adding a first type rating: training, OJT and the 3-year clocks

Engineers returning to work often combine recency with a new type. 66.A.45(b) requires the relevant category B1, B2 or C type training under Appendix III for any type rating. 66.A.45(c) adds, for licences other than category C, on-the-job training for the first type rating in each category or subcategory.

1. Theoretical and practical type training must each be started and completed within the 3 years before applying for the endorsement (Appendix III, point 1).
2. The OJT task list and programme must be accepted by the licensing authority before starting (Appendix III, 6.1(a)).
3. Prerequisite: a category A, B or L5 licence, or completed theoretical type training plus at least 50% of the basic experience requirement (6.1(c)).
4. The OJT is completed within the 3 years before applying for the first type rating, with at least half the tasks after the theoretical training (6.1(d)).
5. Each task is signed by the applicant against a real job card and countersigned by the mentor; the OJT logbook records tasks, registrations, locations and mentors (6.1(f), 6.2).
6. A final assessment of at least one working day follows the mentors' signed recommendation (6.3).

EASA's FAQ warns against taking type training long before you hold a licence: if gaining the basic knowledge and experience takes longer than 3 years, the type training certificate may expire before you can use it. It also says OJT is done on the type sought, with only a limited number of near-identical tasks accepted on other types when justified to the authority.

Students and new applicants: the dates that matter

Two transitional points in Article 6 of the regulation are worth noting. Any basic training course, or part of one, that started before 12 June 2024 had to be finished, including its examinations, before 12 June 2026, with certificates of recognition issued by that date. For licences issued or changed after 12 June 2024, competent authorities accept basic examination status gained under the earlier version of the regulation.

For first licences, the 10-year limits also apply: basic knowledge examinations passed within the 10 years before the application (66.A.25(c)) and experience acquired within the 10 years preceding it (66.A.30(f)). You can test your own timeline in the Part-66 knowledge base with a question such as “If I passed all my Part-66 exam modules for a B1 licence years ago but never finished gathering my experience, do my exam results eventually expire?”

This article explains EU rules; your status is determined by the competent authority that issued your licence. Sources: EUR-Lex and EASA's FAQ. UK CAA rules and the AMC/GM to Part-66 are outside the knowledge base.