Torsten Moench
· 22.02.2025
The Federal Ministry of Transport is aiming to introduce association licences as a replacement for the existing recreational boating licences in order to increase the diversity of providers, promote competition in the driving licence sector and thus enable potentially lower prices.
We spoke to Dr Steffen Häbich, Head of Special Interest (SPI) in the ADAC's Tourism department, about these plans.
Häbich: In our statement on the proposal of the Federal Ministry of Transport (BMDV), we clearly advocated the retention of the existing official recreational boating licences with suggestions for optimisation in terms of competition and consumer friendliness as the ADAC's preferred solution in line with the survey results mentioned above.
However, we note that the BMDV intends to take a different, new approach in future by replacing recreational boating licences with officially recognised association licences, for perfectly understandable reasons such as reducing bureaucracy and increasing competition. As a consumer association, we would like to play an active and constructive role in shaping this solution, particularly in terms of a high level of quality orientation and the absolutely necessary independence of training and examinations. In our view, these goals can also be achieved with the introduction of association certificates.
Häbich: Possibly greater competition between the issuing associations and the possible establishment of a higher-level "supervisory body" with independent experts, among others, could help to ensure that the examination and therefore also the training content is adapted to developments in recreational boating more quickly than is currently the case due to too many bureaucratic hurdles. This could make the examination requirements more practical and the entry-level qualification even more attractive for newcomers to recreational boating, which we would of course welcome.
Further advantages can result from the simpler implementation of digital solutions, for example when issuing a digital association certificate or in the context of even more efficient and flexible audit organisation and processing.
Häbich: As already mentioned, increased competition could lead to training content being developed in a more consumer-orientated and dynamic way than before. We also see a great opportunity to establish a binding quality seal for training and training centres. This would also allow the scope of training and an even stronger practical orientation to be regulated and made binding. The associations that are allowed to issue officially recognised association certificates could, for example, regulate this via the admission to the examination or the BMDV could make it binding for the issuing associations. In our view, this would be a real improvement for the consumer and could contribute in the medium term to more holders of recreational boating licences actually getting out on the water.
Häbich: Yes, if other associations in addition to DMYV and DSV meet the BMDV's criteria for issuing recognised association licences, which have yet to be specified, there will be more competition.
The DMYV and DSV certainly have an initial competitive advantage due to the existing examination structures and experience of the last few decades. This can be a challenge, especially for "newcomers". We see the greatest competition in the recruitment of suitable examiners. However, this must not lead to a loss of quality in the examinations, which is why we have already suggested considering a joint pool of qualified examiners from all associations.
I hope that the recent very constructive dialogue between the associations and between the associations and the BMDV, which is geared towards the cause and the interests of consumers, will continue despite the potential competition that may arise.
Häbich: The association licences will replace the official recreational boating licences. However, I assume that there will be protection for the SBF licences issued up to that point, and we are definitely in favour of this. In addition, it must be ensured that the international recognition of association licences is guaranteed, as is currently the case with recreational boating licences. The consumer must not be put at a disadvantage here compared to the current situation of obtaining an international certificate of competence (International Certificate of Pleasure Craft / ICC) at the same time as the SBF.
Häbich: As far as we know, the BMDV has not yet taken a closer look at the aforementioned advanced and supplementary certificates of competence. However, in addition to the Recreational Craft Skipper's Licence Ordinance, the new Recreational Craft Skipper's Licence Ordinance, which sets out the framework conditions for these additional certificates, is to be included in the new Recreational Craft Skipper's Licence Ordinance. The regulations relevant to radio licences, on the other hand, are currently not to become part of the Recreational Craft Navigation Ordinance.
Häbich: The BMDV is probably hoping that the competition between the associations will lead to a reduction in examination fees. Whether this will really materialise remains to be seen. If the focus on quality is taken seriously, which I assume it will be, there will certainly be a lower limit, as all associations involved so far want to maintain or achieve a high level of examination organisation and acceptance as well as the independence of training and examinations. I do not expect any major changes in training costs at present, as the examination and training content is not expected to change directly for the time being. However, a higher quality of training could lead to very cheap, less comprehensive courses disappearing from the market. This would certainly be in our interest, as the training should provide licence candidates with a good basis for the later independent and responsible practice of boating.
Häbich: The BMDV would like to regulate "significant changes to recreational boating licences" in the recreational boating ordinance. The legislative process for this new regulation should be finalised by the end of this year. If this is successful, the BMDV's timetable envisages association licences replacing official recreational boating licences from 2028.
Although we consider the relatively tight schedule to be desirable, it is also very ambitious in view of the available resources and the need for further intensive coordination between the BMDV and the associations.