BREXIT – A LETTER TO OUR CLIENTS
To all Clients:
As the date of the UK’s withdrawal from the EU is rapidly approaching I wanted to update and reassure you on the current position of Resource Group (RG) on important topics concerning relationships between us and the EU based customers of our UK businesses (RG also has registered companies in Germany, Spain and Switzerland).
Most of our customers are engaged in the transportation sector. On the 7th June 2018 the Government set out its desire to secure liberal aviation market access under a UK-EU framework agreement. The advice we have received from the UK government is that it does not expect a scenario in which the UK leaves the EU without a deal. However, we have a duty to plan for the highly unlikely scenario in which no mutually satisfactory deal can be reached.
Some key planning assumptions for a non-negotiated exit include:
• The UK leaves the EU at 11 pm on 29 March 2019.
• The UK continues to mirror EU aviation regulations for at least a two year period.
• UK issued licences and approvals (issued when the UK was an EASA member) will continue to have validity under UK law but will no longer be recognized by EASA for use on EASA Member State registered aircraft.
Below is our current plan of action for our respective business operations:
EASA Part-147 Aviation Technical Training
In case of a ‘no-deal’ we have already started the third-country EASA application process for our UK based EASA Part-147 approved training business. Our objective and plan is to hold a full EASA approval upon the UK’s EU exit, hence at this time we see no detrimental impact to our EU customers or customers that require our EASA approval as a consequence of BREXIT.
Aviation Resourcing Services and Flight Crew Services (incl. Contractair Ltd, Resource Consulting Limited)
From a technical and licensing perspective, where we employ contract engineers or aircrew in the EU who hold UK CAA issued EASA licences, if a deal looks unlikely we will be writing to them to consider a transfer of State of Licence Issue of their existing licences to that of another Member State. We are currently evaluating various national aviation authorities to understand which could potentially offer the most straightforward solution. We must stress that it will be the responsibility of individuals to complete this but we will support them as best we can from an administrative perspective. What is clear though is that, so long as this process is started and completed prior to the UK’s exit date, it should be relatively straightforward.
Aside from the technical aspects detailed above, we continue to closely monitor the factors affecting cross-border workers (situations where workers are deployed to our clients in the EU and are employed by one of our UK businesses). It is important to remember that quite a large number of EU workers are posted to the UK (as well as vice-versa), hence it is clear that it is in the interests of both the UK and EU to reach a long-term agreement that facilitates mobility through a reciprocal arrangement. The good news is that the draft Withdrawal Agreement issued by the European Commission earlier this year provides for a transition period from March 29, 2019 through to December 31, 2020 during which it is anticipated that the UK will continue to participate in most EU processes and systems related to social security.
We will continue to closely evaluate the progress of the UK’s negotiations with the EU (insofar as it affects our business operations and those of our customers) and your designated account managers will continue to update you with any key developments.
In the meantime, our customers should take comfort and reassurance from the fact that, as a group, we already have a very firm European footprint and it is our objective that the impact of BREXIT on customer operations is minimized.