Share to any workspace or social platform
66.A.40 establishes that the aircraft maintenance licence becomes invalid five years after its last issue or amendment unless the holder renews it with the issuing competent authority, and sets out the renewal process — which, following Regulation (EU) 2023/989, is made using EASA Form 19 either directly or facilitated through the holder's Part-145 or Part-CAO organisation.
What it means in practice
The Part 66 licence document is not open-ended: it becomes invalid five years after its last issue or amendment unless renewed. Renewal is an administrative verification — the holder submits the licence so the competent authority can confirm that the information on the document matches its records — rather than a re-examination. The holder applies using EASA Form 19, and following Regulation (EU) 2023/989 the renewal may be made directly to the competent authority or routed through the Part-145 maintenance organisation or CAO employing the holder, which can submit the licence and form on the holder's behalf.
Renewal of the licence document is a separate matter from the recency needed to use it. The right to exercise certification privileges depends on 66.A.20(b): the holder must have, within the preceding two years, six months of maintenance experience in accordance with the privileges granted, or have met the conditions for the issue of the appropriate privileges. A current licence document without recency does not permit certification, and recency without a valid licence document does not either.
Key requirements
Track the five-year anniversary of the last issue or amendment of the licence and apply for renewal before it passes. If the licence has expired, the holder must apply to the issuing competent authority for re-issue, and the authority will verify its records before restoring validity. The licence is issued, amended, and renewed by the competent authority that originally issued it, regardless of where in the EASA system the holder currently works.
Independently of document renewal, maintain certification recency under 66.A.20(b) — six months of relevant maintenance experience within any two-year period — supported by the employing organisation's competence and authorisation system. Where recency has lapsed, the organisation and the holder must re-establish it before certification privileges are exercised again.
Common compliance gaps
The classic gap is conflating the two clocks: engineers assume that holding a printed licence means they may certify, or conversely that staying in a certifying role removes the need to renew the document. Organisations sometimes fail to monitor either — particularly for engineers in management or non-certifying roles for extended periods. Proactive tracking of both the five-year document renewal date and the 66.A.20(b) recency window through the organisation's competence management system avoids both failure modes.
Part 66 Training
Working towards your Part 66 licence?
Sofema's Part 66 Foundation course walks you through the full licensing framework — categories, modules, experience requirements, and the path to certification.
View Part 66 courseSources
Have a question about this regulation?
Search across all regulation pages and glossary terms.