Consultation on changes to UK Regulations recognising physical or electronic format personnel licences and medical certificates

We asked for feedback on a proposal to amend the legislation to permit either physical or electronic form of licence or certificate to be issued.

The consultation ran from 12 May 2025 to 22 June 2025 and stakeholders were encouraged to review the copy of ICAO Annex 1 Chapter 5 and Appendix 4 included with the consultation prior to responding.

We received a total of two hundred and twenty (220) responses to the consultation. Across all licensing and certification areas an average of 69% of respondents supported the proposed amendments, 5% did not support the proposals and 26% indicated the question was not applicable.

Two responses questioned the cost and/or need to consult on this regulatory change.

Thirty-one licensing and twelve medical certificate responses expressed a preference to have the option of both physical and electronic licences, some suggesting a card style format to replace the current paper licence. A small number of responses said the choice of physical or electronic should be the licence holders. The licence form used by other Authorities was mentioned in several responses. 

Multiple responses offered views and feedback on the design of a digital licensing system including use of wallet technology; validation technology; inclusion of photo identification and the ability to sign up in the field.

Confidence concerns surrounding the introduction of an electronic system were shared in feedback. Specific areas of concern were identified as: issues with access to the electronic licence; access to internet or loss of data connection; mobile phone loss or failure; battery charge issues; difficulties associated with rolling out an electronic system; widespread system failures; integration of systems; and GDPR concerns due to the requirement to carry an electronic device.

We acknowledge the responses and thank the responders for their suggestions.

The need to consult with interested parties on the development of rules that could have important social implications is set out in the Basic Regulation. The consultation process is also inherent in UK law and consultation is widely used to support this principle.  

The CAA recognises the importance to licence holders of having physical evidence of achieving licence status. It is not possible to run concurrent systems whereby an individual holds both an electronic and a hard copy licence issued for the same kind of licence.

ICAO Doc 9379 states that issuance of an electronic licence is optional and can be introduced for all licenced aviation personnel or certain groups, however no individual should have both an EPL (electronic personnel licence) and a hard copy for the same kind of licence. Following the introduction of the electronic personnel licence for a specific licence group, issuing both a physical copy and an electronic copy of the licence would leave the UK at variance with the Convention on International Civil Aviation. The UK, being an ICAO signatory state, follows ICAO requirements.

It should be noted that the FAA, EASA, CASA, and Transport Canada are exploring digital licensing. Brazil has introduced an electronic licensing system. China has already introduced a digital licensing system that is ICAO compliant.  

The CAA will ensure that all aspects of GDPR and the Data Protection Act under UK law are complied with. ICAO Doc 9379 requires all signatory states to the Convention on International Civil Aviation to provide appropriate security in accordance with their national legislation.

All feedback, recommendations on the application process/design and functionality of a digital licensing system, and confidence concerns surrounding the introduction of a digital licensing system have been shared with the Customer Experience and Modernisation Programme (Cx&M) team delivering this project, to feed into and inform their work. Further feedback can be sent directly to cx@caa.co.uk. The Cx&M Team will be conducting user research in 2026 on possible designs, and opportunities to take part in this research will be posted on the CAA website.

Conclusion

The CAA considers that the proposal to amend the legislation to permit either physical or electronic form of licence or certificate to be issued, in all areas consulted, is supported by the majority of responses.

We are working with the Department for Transport (DfT) to implement the proposed changes by Q2-Q3 2026.

In some areas, we need to develop appropriate Acceptable Means of Compliance (AMC), Guidance Material (GM) and other CAA publications (CAPs) to support the planned changes to regulation. These will be consulted on prior to the introduction of the Statutory Instrument.