Part-66 Module 10 after Regulation (EU) 2023/989: what changed and what to study

What changed in Part-66 Module 10 in 2024?

Regulation (EU) 2023/989 replaced Module 10, Aviation Legislation, in Appendix I to Part-66 with effect from 12 June 2024. The module grew from seven sub-modules to ten, gaining independent certifying staff, oversight principles, maintenance beyond current EU regulations and cybersecurity in aviation maintenance, and the essay question in the Module 10 examination was removed. The UK did not adopt the change, so UK candidates still study the seven-heading syllabus and still write an essay.

Below is the change in detail: the dates and transitional rules, a side-by-side table of the old and new sub-module headings with knowledge levels, the new examination format, who is affected and how, and where the UK stands.

What did Regulation (EU) 2023/989 change, and from when?

Commission Implementing Regulation (EU) 2023/989 of 22 May 2023 amended Regulation (EU) No 1321/2014 in two places that matter for basic licence candidates: Annex III (Part-66) Appendix I, the basic knowledge requirements, and Appendix II, the basic examination standard. It also amended Annex IV (Part-147) so that approved training organisations could deliver the new syllabus.

Article 3 gives the dates. The Regulation entered into force twenty days after publication in the Official Journal of 23 May 2023 and applies from 12 June 2024; only Article 1(1), a definition change, and Article 2, corrections to Part-M and Part-ML, applied earlier, from 12 June 2023.

Because a basic course can run for years, the Regulation added three transitional paragraphs to Article 6 of Regulation (EU) No 1321/2014:

• Article 6(4). Any basic training course, or part of one, that commenced before 12 June 2024 shall be finished, including any related examination, before 12 June 2026, and the corresponding certificates of recognition shall also be issued before 12 June 2026.
• Article 6(5). Those certificates are issued under the Regulation as applicable before 12 June 2024.
• Article 6(6). For licence issue or change after 12 June 2024, the competent authority shall accept an applicant’s basic knowledge examination status under the old version as meeting the new requirements.

In plain terms: passes under the old Module 10 remain good, courses that started under the old syllabus had until 12 June 2026 to finish, and since that date every new examination is set against the new Appendix I and II. The two-year finishing window closed in June 2026, so a candidate sitting Module 10 anywhere in the EU today sits the new paper.

What does the new Module 10 syllabus look like against the old one?

The old syllabus is preserved, unamended, in the UK’s assimilated version of the Regulation, which reproduces the EU text as it stood before 2023/989 and gives a convenient reference for the seven headings. The new headings and knowledge levels come from Annex I to Regulation (EU) 2023/989. Level 1 is a familiarisation with the principal elements, level 2 a general knowledge of theoretical and practical aspects with the ability to apply it, level 3 a detailed knowledge, as defined in Appendix I. “Cat. B” in the table covers B1, B2, B2L and B3, which share the same levels.

Old (to 11 June 2024)	New (from 12 June 2024)	Cat. A	Cat. B
10.1 Regulatory framework	10.1 Regulatory framework	1	1
10.2 Certifying staff, maintenance	10.2 Certifying staff, maintenance	2	2
10.3 Approved maintenance organisations	10.3 Approved maintenance organisations	2	2
—	10.4 Independent certifying staff	—	3
10.4 Air operations	10.5 Air operations	1	1
10.5 Certification of aircraft, parts and appliances	10.6 Certification of aircraft, parts, and appliances	2	2
10.6 Continuing airworthiness	10.7 Continuing airworthiness	2	2
—	10.8 Oversight principles in continuing airworthiness	1	1
10.7 Applicable national and international requirements	10.9 Maintenance and certification beyond the current EU regulations (if not superseded by EU requirements)	—	1
—	10.10 Cybersecurity in aviation maintenance	1	1

Four things to notice:

1. Six headings carry over with new numbers. Candidates who learned the old structure need to relearn the numbering, not the substance, for 10.1 to 10.3 and 10.5 to 10.7.
2. Independent certifying staff (10.4) is level 3 for B licences and not examined for category A. It reflects the privileges of licence holders certifying outside an approved organisation under 66.A.20, and it is the deepest requirement in the module.
3. Oversight principles (10.8) brings the authority’s side of the system, Section B of the Annexes, into the licence syllabus for the first time.
4. Cybersecurity in aviation maintenance (10.10) is entirely new at level 1 for all categories.

The sub-topics under each heading are set out in AMC1 to Appendix I to Part-66 in the EASA Easy Access Rules; the Regulation itself gives only the headings and levels.

How did the examination change?

Appendix II to Part-66 sets the examination standard. Before the amendment Module 10 was examined by 32 multiple-choice questions plus one essay for category A, and 40 multiple-choice questions plus one essay for the B categories. The amended Appendix II sets:

Category	Multiple-choice questions	Time	Essay
A	32	40 minutes	None
B1, B2, B2L, B3	44	55 minutes	None

The pass mark remains 75 % under Appendix II point 1.7. Module 7 is now the only basic module that retains essay questions in the EU. For candidates this means more breadth and no free-text answer: every one of the ten headings can appear, and revision has to cover the level 1 topics that used to be safe to skim.

Who is affected?

Licence candidates in EU member states and in the states that apply EASA rules through agreements. Anyone sitting Module 10 since 12 June 2024 sits the new paper; anyone with an older pass keeps it under Article 6(6), subject to the 10-year examination validity in 66.A.25.

Part-147 approved training organisations, which had to update courses and examinations and, under Article 6(4), finish old-syllabus courses and issue their certificates of recognition before 12 June 2026.

Part-145 and CAMO organisations that use a Module 10 course as regulatory training. Many do, because Module 10 is the only structured aviation-legislation syllabus most technicians ever meet. The new headings, oversight principles in particular, align it more closely with what an organisation needs its staff to understand about competent-authority surveillance. But the two remain legally distinct: Module 10 is individual licence knowledge under 66.A.25, examined by a Part-147 organisation or the competent authority; organisational regulatory training is a 145.A.30 competency matter set in the Maintenance Organisation Exposition (MOE). A Module 10 course is a strong foundation for the latter, and this site’s Part-145 regulatory course is the organisational counterpart.

Where does the UK stand?

The UK left the EASA system on 31 December 2020 and did not adopt Regulation (EU) 2023/989. Three public sources confirm the position:

• UK Regulation (EU) No 1321/2014 Annex III Appendix I on legislation.gov.uk, shown as the latest available revised version, still lists Module 10 as 10.1 Regulatory framework to 10.7 Applicable national and international requirements, and Module 9A as 9.1 to 9.9.
• The CAA’s UK Part-66 knowledge requirements page states that for all licences other than category L, Appendix II requires essay questions for Modules 7A, 7B, 9A, 9B and 10.
• The same page states that the UK is unable to accept any EASA Part-147 certificate of recognition dated after 31 December 2022.

So a UK candidate studies seven headings, answers an essay, and cannot use a recent EASA Part-147 certificate for a UK licence. An EU candidate studies ten headings with no essay. A technician who wants both licences needs to know both syllabuses, and a course built on the new EU structure covers the six shared headings but not the UK’s 10.7, which is about national requirements the UK now maintains itself.

Related courses. EASA Part-66 Module 10 — Aviation Legislation follows the ten post-2023/989 sub-modules one to one; Part-145 Regulatory Training — Initial is the organisational counterpart for staff who need Annex II rather than a licence module.