Bridging UK-EU regulation differences
The UK is a ‘third country’ that has retained EU regulations including aviation regulations which continue to apply under UK law from 1 Jan 21. Those retained EU rules are changing; for example UK Part-SFCL.
This webpage highlights interactions between UK and EU as related to gliding..
Glossary
ANO is the Air Navigation Order.
EASA is the European Aviation Safety Agency.
ICAO is the International Civil Aviation Organisation.
Part-FCL is the Flight Crew Licensing rules.
Part-SFCL is the Sailplane Flight Crew Licensing rules.
Part-21 aeroplane – formerly known as an EASA aeroplane, eg a Robin DR400.
Part-21 sailplane – formerly known as an EASA sailplane, eg a Discus, DG400 (a self-launcher) or a Grob109b (a TMG).
Permission to travel
The EU has brought in new changes at the border, which will affect any UK travellers visiting countries in the European Schengen area. These changes, which are called the ‘entry-exit system’ (EES) will begin from 12 October 2025. The new checks will be introduced in all 29 Schengen countries, including popular holiday destinations Spain, France and Italy. This does not include Ireland or Cyprus.
EES will affect all non-EU passport holders, including those who hold British passports. But if you have an EU passport, the EES rules will not apply to you. From the end of 2026, the Etias visa waiver will also be launched, meaning the cost of entry to Europe will be €20 (£17).
Pilot licencing – UK pilots flying outside the UK
Flying outside the UK using a UK issued SPL: The UK SPL + Class 2 medical certificate is ICAO compliant. That means pilots holding a UK SPL + Class 2 medical certificate may fly UK registered sailplanes in the EU without the national regulators permission.
UK issued flight crew licence holders should be aware that they have no privileges to operate aircraft on the register of an EASA Member State. EU regulation requires validation of a UK SPL to fly an EASA state registered sailplane in the EU.
Validation guidance based on experience:
France: The French DGAC is responsible for issuing SPL validations. When a third country SPL holding pilot is flying a French/EU registered glider, an SPL validation is required. The French DGAC validation form is available here. The fee is 80 Euros. In that case, UK CAA advises that the DGAC will contact CAA to confirm that the UK issued SPL is valid etc. To enable UK CAA to release the information to the DGAC, the SPL holder will need to complete SRG1160. The DGAC turn around the initial application within 48 hours. The minimum turnaround time at CAA from receipt of the SRG1160 is 10 working days. The BGA recommends that pilots who need to validate their UK SPL give themselves a month to complete the process.
Germany: The German federal state aviation authorities are responsible for issuing SPL validations. LBA recent advice to the BGA is that pilots should contact the aviation authority of the federal state in which they intend to operate. The contact addresses of the state aviation authorities can be found under the following link: https://www.lba.de/DE/Presse/Landesluftfahrtbehoerden/Landesluftfahrtbeh%C3%B6rden_node.html
Spain: The validation of a UK SPL with the Spanish authority (AESA) requires a min. experience of 100 hours PIC and is valid for a maximum of 28 days within the calendar year. A Spanish gliding club can act as an intermediary. The steps are: Complete form F-DLA-VAL-05P, pay a fee, provide copies of passport and Class 2 medical and logbook.
South Africa: The validation of a UK SPL with the S African authorities requires UK CAA input. There is a form to complete, a fee, and copies of passport and Class 2 medical and logbook are required. Those visiting Soaring Safari at Bloemfontein are walked through the process (2025).
Instructing in third countries. It is recommended that a UK issued SPL holder intending to instruct in a third country confirms that instructing is permitted with the licence and privileges held by the pilot.
Using a PMD in the UK when flying a non-UK registered sailplane. Whilst the CAA does not limit the PMD’s applicability to UK registered aircraft, it will always remain up to the state of registry to decide on the licensing and medical requirements to operate aircraft on their registry.
Pilot licencing – non UK pilots
Visiting licence holders flying in the UK should read this CAA information, which explains that for VFR recreational flying, an ICAO compliant licence is valid for recreational flying of any aircraft in UK airspace. We have summarised the detail below.
ICAO SPL holders wishing to fly a sailplane in the UK that is registered in the EU state that issued their licence
An EASA ICAO compliant licence holder may fly an aircraft in the UK that is registered in the EU state that issued their licence. No permission is required from the UK CAA.
ICAO SPL holders wishing to fly G-registered sailplanes in the UK on a temporary basis, i.e. for up to 28 days per calendar year:
UK CAA permission is required and must be retained. Your International Civil Aviation Organisation (ICAO) licence/certificate needs to be validated for a limited duration. You will need to make a “declaration” following one of the processes below. You need to follow the declaration process below before flying in UK airspace. Pilots should try and declare as early as possible in the calendar year should they want to use the full 28 days permitted.
You will need to:
- Be in current flying practice on the class or type of aircraft you wish to fly in UK airspace.
- Be flying purely for pleasure, private flying, not receiving remuneration. The flight can only be conducted in non-complex motor-powered aircraft, and do not allow fo flight instruction or examination.
- Meet the requirements of, complete and submit forms SRG2141and SRG2142.
- Please note there is a fee associated with SRG2142, more information can be found in the related information section at the bottom of this page.
You must, for each application:
- Hold a valid Licence/Certificate (that is a licence that is not subject to suspension, limitation or other enforcement action by the issuing authority).
- Hold a valid, current rating relevant to the aircraft to be operated, and the privileges to be exercised, demonstrable by reference to appropriate logbook and licence evidence.
- Hold at least a valid Class 2 Medical issued by the issuing authority.
- Hold an “English proficient” endorsement on their ICAO licence, to meet the minimum level 4 proficiency, or have their proficiency confirmed by a UK Civil Aviation Authority (CAA) Approved Language Proficiency Assessment Centre if no such endorsement applies or the candidate wishes to be credited with proficiency levels 5 or 6 (Form CAA5003 applies).
- Complete an acclimatisation flight which is a check flight conducted with a qualified UK instructor, the aim of the flight is to demonstrate that you are safe to fly the aircraft in UK airspace.
You must keep the declaration you have made to the CAA. Once you have received email confirmation from the CAA, you can fly in UK airspace. Please note the expiry date of your declaration is stated on your confirmation email from the CAA.
ICAO SPL holders wishing to obtain a UK Part SFCL SPL
Pre-requisite: The licence holder must be able to show a minimum of 100 hours flight time in Sailplanes and hold at least a UK CAA pilot medical declaration.
Theoretical knowledge examinations: Complete theoretical knowledge examinations for UK CAA SPL in Air Law and Human Performance at a ATO/DTO or Gliding Club.
Flight Training: Training as required at an ATO/DTO/Gliding Club to be at UK SPL Skill Test Standard.
Skill Test: Pass the UK SPL Skill Test in accordance with SFCL.145 with an FE(S).
Please note. In accordance with the regulations. Any application with less than 100 hours flight time will require all UK SPL theoretical knowledge exams to be undertaken, complete the minimum flight time under instruction requirements defined in SFCL.130 (subject to credits being determined on a case-by-case basis by the training organisation) and complete a skill test.
Pilots wanting FRTOL privileges transferred from their EASA licence should follow the guidance at Third Country Licence conversion requirements from 1 January 2023 | UK Civil Aviation Authority
Before application to the CAA to issue the UK SPL, the CAA will need to verify the applicant’s ICAO licence with the relevant authority via our existing verification process. Verification process is available via the following link Verification of a third country ICAO licence | UK Civil Aviation Authority. Verifications are valid for 6 months.
Following completion of the skill test, the applicant is to apply to the CAA directly using the CAA’s own (non-BGA) SPL Initial Issue Application Form completed by the Head of Training. This is because at present the CAA are the only agency who can process ICAO conversions.
To ensure that you have the required forms in good time, the gliding club is to notify the BGA/CAA when the theoretical knowledge exams are to be sat. This is a temporary measure whilst the full ICAO SPL conversion processes are brought into place by the end of the year.
Licencing fees payable by the applicant will be as per ORS5 No. 430: CAA Scheme of Charges: Personnel Licensing | UK Civil Aviation Authority. Unfortunately, as ICAO conversions are currently only by a direct application to the CAA, the reduced fees that are normally available via the BGA are unavailable for applicants.
Moving aircraft into and out of the UK
Temporarily moving a glider or other gliding equipment into the EU, eg for expeditions, competitions, etc. Where a privately owned glider is moved across the UK/EU border in a trailer towed by a private vehicle and the intent is to return the glider across the EU/UK border (for example visiting the EU for a holiday, competition, etc), the temporary export and subsequent re-import may be declared by conduct, where the act of crossing the border counts as your declaration. You do not need to fill out any forms.
There is a significant amount of experience of crossing the EU border from the UK using declaration by conduct, ie crossing and returning.
Eire customs has described the requirement for crossing from the UK into the EU with a glider towed by a car as an oral declaration accompanied by an inventory to support the oral declaration. The C108 form provides an inventory should that be required. Users should check if the port of arrival/departure allows for an oral declaration.
There is experience of a Spanish port, Santander, demanding a Carnet (which is for most prohibitively expensive). The Istanbul Convention (signed by the UK and EU countries inc Spain) Annex C, Chapter III Miscellaneous provisions, Article 5 and 6 identifies why a means of transport (a sailplane and a trailer) shall be granted with temporary admission without a customs document or security being required.
Temporarily moving a glider into the EU for repair
– The background
The UK-EU Trade and Co-operation Agreement (TCA) allows goods to temporarily move between GB and the EU for repair without incurring customs duty on import, regardless of their origin.
Outward Processing is a procedure that allows goods to be temporarily exported from the UK for repair or processing, and then re-imported to the UK without payment of UK customs duty or import VAT. Further info on Outward Processing and the conditions that need to be met for the relief can be found at:
https://www.gov.uk/guidance/using-outward-processing-to-process-or-repair-your-goods
https://www.gov.uk/guidance/apply-to-pay-less-duty-on-goods-you-export-to-process-or-repair
– Practical guidance
Practical guidance based on experience of refinishing a UK-based glider in the EU is available here.
VAT on used aircraft imported into the UK by a private owner. When purchasing goods in EU (for later import to GB) from a private user of the same goods, the EU seller is likely to have incurred irrecoverable VAT. For the later sale, no VAT would be due on a private sale in the EU, but (now we have left the single market) import VAT will be due on arrival to GB, subject to any import reliefs that may apply.
In a similar scenario but where the goods were bought from a VAT registered business in the EU, a purchaser intending to import those goods to GB would be advised to check if the seller is zero-rating the supply to them, as an export from the EU. Import VAT would be due in GB, on the same basis as described above.
Goods in free circulation in N Ireland at 31 December 2020 are classified as being in free circulation in EU and not in GB. Goods being moved from Ireland to GB are imports.
Maintenance or repair by organisations without a UK CAA approval
Following the UK’s exit from the EU and EASA, maintained, repaired or overhauled parts with EASA Form 1’s from maintenance companies that do not hold UK approvals are not approved for use on UK registered aircraft.
The UK CAA has decided to continue to allow maintained components released using an EASA Form 1 to be fitted on UK registered aircraft if that aircraft falls within the scope of Part ML, if the component has been maintained by its original manufacturer and if the component cannot be obtained from alternative acceptable sources. Examples include Tost release hooks.
The CAA exemption can be viewed here.
Continued acceptance of EASA references on aircraft documents
The CAA will continue to accept references, including EASA form numbers, to any EU regulation which are cited on documents carried by UK-registered aircraft. This includes Certificates of Airworthiness (CofA), Airworthiness Review Certificates (ARC) and Noise Certificates. These will remain valid until they are renewed, whereby they will be replaced with CAA references and form numbers.
Other links
CAA Official Record Series exemptions
– Back to Laws and Rules webpage