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Module 10

Module 10: Aviation Legislation

A B1 B2 B2L B3
Commission Implementing Regulation (EU) 2023/989 amending Regulation (EU) No 1321/2014, Annex III (Part-66), Appendix I 12 June 2024

Knowledge Level Overview

SectionTopicAB1B2B2LB3
10.1Regulatory Framework11111
10.2Certifying Staff — Maintenance22222
10.3Approved Maintenance Organisations22222
10.4Independent Certifying Staff3333
10.5Air Operations11111
10.6Certification of Aircraft, Parts, and Appliances22222
10.7Continuing Airworthiness22222
10.8Oversight Principles in Continuing Airworthiness11111
10.9Maintenance and certification beyond the current EU regulations (if not superseded by EU requirements)1111
10.10Cybersecurity in Aviation Maintenance11111
1 Basic familiarisation 2 General knowledge 3 Detailed knowledge

Examination

CategoryQuestionsDuration
A3240 min
B14455 min
B24455 min
B2L4455 min
B34455 min

> Appendix II to Part-66 (Basic Examination Standard), consolidated 2026-08-07:

> *"MODULE 10 - AVIATION LEGISLATION / Category A: 32 multiple-choice, no essay questions.

> Time allowed: 40 minutes. Category B1, B3, B2 and B2L: 44 multiple-choice, no essay

> questions. Time allowed: 55 minutes."* The B3 row previously read 32 / 40 min.

Detailed Syllabus

> Rebuilt 2026-09-05 from the consolidated regulations. Appendix I of Part-66,

> as amended by (EU) 2023/989, publishes Module 10 as a bare ten-row table with

> no topic lines at all — verified in the current consolidation

> (`CELEX:02014R1321-20260807`), in the 2024-06-12 consolidation, and in the

> amending act itself. The 90 bullets this section previously held had **no

> regulatory source**; they had been composed. Every bullet below is traceable to a

> named article of a cached consolidated instrument, to the superseded pre-2023

> Appendix I detail, or to a question in the live bank that tests it. The citations

> live in `audit/notes/m10_work/syllabus/MERGED_SYLLABUS.md`, which also carries the

> fold map from the 241 sourced scope items to the 140 bullets below.

>

> The citation for every bullet is in that file, stripped from the bullets here so the

> phase-1 mapper can copy them byte-exactly. Any agent writing a regulation reference

> must open the article there, or in `audit/notes/m10_sources/`, before writing it.

>

> The floor these 140 bullets imply (39,200 words) understates the scope.

> Folding 241 scope items into 140 enumerating bullets cut `bullets x 280` by

> 28,280 words for no reason but re-punctuation. Compute depth against the **241

> scope items (67,480 words)**, and read even that as a floor: the sixteen shipped

> modules run a median 15,334 words per note, so a ten-note module of this shape

> ships around 153,000.

>

> 10.9 is NOT a new paragraph. It is pre-2023 10.7 retitled and rescoped:

> the parenthetical *"(if not superseded by EU requirements)"* carries over verbatim

> and occurs exactly once per consolidation, on old 10.7's title and on current

> 10.9's. The genuinely new paragraphs are 10.4, 10.8 and 10.10, which bank qid

> 16917 keys. Old 10.7's *content* migrated to the new 10.5 and 10.7, and 10.9 kept

> none of it — so rebuilding 10.9 from the old bullet list would write a note

> about ADs and MELs and leave the paragraph thin.

10.1Regulatory framework

Knowledge level 1 / 1.

  • Role of the International Civil Aviation Organisation and the Chicago Convention of 1944, ICAO Standards and Recommended Practices and the difference in their binding force on contracting States, and the Annexes to the Convention, in particular Annex 1, Annex 8, Annex 13, Annex 16 and Annex 19
  • Role of the European Commission: adoption of delegated and implementing acts, assisted by the committee established under Regulation (EU) No 182/2011
  • Role and governance of EASA: opinions to the Commission, certification specifications, acceptable means of compliance and guidance material, Agency decisions, reaction to an urgent safety problem, and the composition of the Management Board
  • Role of the Member States and their national aviation authorities within a single European aviation safety system: certification, oversight and enforcement, the independence of the national competent authority, and the determination of which authority is competent for a given organisation or licence holder, including the cases in which the Agency is the competent authority
  • Regulation (EU) 2018/1139, the EASA Basic Regulation, its repeal of Regulation (EC) No 216/2008, and the delegated and implementing acts adopted on the basis of it
  • Regulation (EU) No 1321/2014 (continuing airworthiness) and the relation between its Annexes: Part-M, Part-145, Part-66, Part-147, Part-T, Part-ML, Part-CAMO and Part-CAO
  • Regulation (EU) No 748/2012 (initial airworthiness) and the relation between its Annexes: Annex I (Part 21) and Annex Ib (Part 21 Light)
  • Regulation (EU) No 965/2012 (air operations) and the relation of its Parts to continuing airworthiness
  • Regulation (EU) No 1178/2011 (aircrew)
  • Regulation (EU) No 376/2014: mandatory and voluntary occurrence reporting, the persons required to report, the 72-hour reporting deadline, and just culture with the protection of the information source and the limits of that protection
  • Hard law and soft law: the binding force of a regulation compared with certification specifications, acceptable means of compliance and guidance material, and alternative means of compliance with the prior approval of the competent authority
  • Bilateral aviation safety agreements and the acceptance of third-country certificates
  • Commission Implementing Regulation (EU) 2023/989 and the restructuring of the Module 10 syllabus applicable from 12 June 2024, which added paragraphs 10.4, 10.8 and 10.10

10.2Certifying staff - maintenance

Knowledge level 2 / 2.

  • Eligibility: the minimum age of 18 years for an applicant for an aircraft maintenance licence, and of 21 years for certifying staff and support staff in an approved organisation
  • Licence categories and subcategories: A1 to A4, B1.1, B1.2, B1.E, B1.3, B1.4, B2, B2L with its system ratings, B3, L1C to L5, and C
  • Scope and privileges of each licence category and subcategory, including the category A privileges a B1 subcategory carries and the relationship between category C certifying staff and the B1 and B2 staff who sign the work
  • Conditions for exercising certification privileges: compliance with Part-M, Part-145, Part-ML and Part-CAO, 6 months of maintenance experience in the preceding 2-year period, adequate competence, the ability to read, write and communicate to an understandable level in the language of the technical documentation supporting the certificate of release to service, and the fact that Part-66 imposes no aviation medical certificate requirement
  • Aircraft groups 1 to 4 and their subgroups, the aircraft ratings endorsed for each group and category (type, manufacturer subgroup and full subgroup), the rule that certification privileges on a specific aircraft type may be exercised only where the licence carries the relevant aircraft rating, so that a licence held without that rating confers no certification privileges on the type, and the reclassification of a Group 1 aircraft into a lower subgroup on grounds of lower complexity
  • Aircraft type training, type evaluation and on-the-job training for the first type rating within a category: the theoretical and practical elements, the Appendix III standard, the 3-year window preceding the application, one-to-one mentorship, the OJT logbook and the final assessment
  • Limitations endorsed on the licence, and their removal by demonstrated experience or a practical assessment
  • Basic knowledge requirements: the Appendix I module syllabus, who may conduct the examinations, the 10-year validity of the basic knowledge examinations, and credits granted by the competent authority against an approved examination credit report
  • The basic examination standard: three alternative answers per multiple-choice question, a 75 % pass mark, a 90-day retake interval reduced to 30 days after a Part-147 course of retraining tailored to the failed subjects, and the question and time allowances for each category
  • Basic experience requirements: the three qualifying routes (no previous relevant technical training, skilled-worker training, or a basic training course approved under Part-147), the period required for each category and subcategory, the 10-year window, the reduction available when a further category is added, and the recognition of experience gained in organisations not approved under Part-145 or Part-CAO
  • Recurrent training for certifying staff and support staff in each 2-year period, covering relevant technologies, organisation procedures, safety management and human factors
  • Certification authorisations issued by an approved maintenance organisation: scope and limits, competence assessment before issue or reissue, and production to an authorised person within 24 hours
  • Support staff: the definition, and the role of B1 and B2 support staff relative to category C certifying staff in base maintenance
  • The certificate of release to service: when it is required, who may issue it, and what it certifies
  • Continued validity, renewal and loss of the licence: invalidity 5 years after the last issue or change, EASA Form 19, the competent authority's verification procedure, the licence document itself as EASA Form 26 and the holder's duty to keep it in good condition and to ensure that no unauthorised entries are made, failure to comply with which may invalidate the licence or lead to the holder not being permitted to hold any certification privilege, and the suspension, limitation or revocation of the licence and the conduct that grounds it
  • The competent authority for a licence, the single-authority rule, and Union-wide recognition of the licence
  • Conversion of certifying-staff qualifications that were valid in a Member State before Part-66 entered into force, and the limitations that conversion may carry
  • Part-147 maintenance training organisations as the route by which basic and type training for a Part-66 licence is delivered: approval under Annex IV, and the four privileges of conducting recognised basic training courses, conducting recognised type training courses, conducting the examinations and issuing training certificates
  • What a Part-147 approval buys the licence applicant: the reduced basic experience period for each category, the 30-day retake interval after a tailored retraining course, the Certificates of Recognition on EASA Forms 148a and 149a that a Part-147 organisation issues for the training and examinations it conducts, distinguished from EASA Forms 148b and 149b which the competent authority issues for the examinations, type training examinations and type evaluations it conducts itself, and the 50 % reduction of the Appendix IV extension experience where a relevant approved basic course has been completed

10.3Approved maintenance organisations

Knowledge level 2 / 2.

  • Scope of Part-145, the organisations required to hold a Part-145 certificate, and the competent authority for such an organisation, which is the authority designated by the Member State in whose territory the organisation has its principal place of business and the Agency where that principal place of business lies outside a territory for which a Member State is responsible under the Chicago Convention
  • Application for the organisation certificate and its issue on EASA Form 3-145, changes requiring prior approval, continued validity, and access for the competent authority
  • Terms of approval and scope of work: the class and rating system of Appendix II - Class A aircraft, Class B engines and APUs, Class C components, Class D specialised services - the base and line subdivision of a class A rating, and the scope of work stated in the exposition
  • The accountable manager and the nominated persons: corporate authority and the provision of resources, the safety policy, a basic understanding of the Regulation, the countersignature of the chief executive officer where the two are different persons, the persons nominated for the maintenance functions, for compliance monitoring and for safety management, their direct access to the accountable manager, and the man-hour plan
  • Certifying staff and support staff required for line and base maintenance, the 6 months of relevant experience in any consecutive 2-year period, the qualification of specialised and non-destructive-testing personnel, and the derogations from the obligation to comply with Part-66: staff qualified under the national aviation regulations of the State in which a base maintenance facility or line station outside EU territory is located, the limited certification authorisation the organisation may issue to a pilot on the basis of the flight crew licence held for a repetitive pre-flight airworthiness directive that expressly permits the flight crew to carry it out or where an aircraft is operated away from a supported location, in each case subject to sufficient practical training, and the one-off certification authorisation that the organisation contracted to provide maintenance support may issue in unforeseen cases where an aircraft is grounded away from its main base and no appropriate certifying staff are available, reportable to the competent authority within seven days and subject to a re-check by an appropriately approved organisation
  • Facilities, equipment and tools: hangars and workshops, office accommodation, lighting, the working environment and the suspension of tasks when it deteriorates, secure segregated storage under the manufacturer's conditions, the availability of the tooling the maintenance data specifies, and control and calibration to an officially recognised standard with traceability records
  • Components, standard parts and materials: the five classification categories, acceptance for installation, segregation, and unsalvageable components
  • Maintenance data and maintenance procedures: what data is applicable and the obligation to keep it current whatever its source, work cards and worksheets, the recording and notification of inaccurate, incomplete or ambiguous data, the procedures agreed with the competent authority, and the maintenance work order or contract agreed with the person requesting the maintenance
  • Production planning and the performance of maintenance: the availability of personnel, tools, material and data, human performance limitations including the threat of fatigue, shift handover, the general verification that the aircraft is clear of tools and extraneous material on completion, the error-capturing method after a critical maintenance task, and the assessment of damage and defects
  • Certification of maintenance: the issue of the certificate of release to service, incomplete maintenance work orders, the 30-flight-hour derogation for a component fitted away from base, and the EASA Form 1 authorised release certificate with the meaning of its principal blocks
  • The maintenance organisation exposition: required content, initial approval by the competent authority, and the management of amendments
  • Privileges of the organisation: where it may maintain aircraft and components, line maintenance locations, and, where specifically approved, airworthiness reviews for Part-ML aircraft
  • The management system: accountability and lines of responsibility, the safety policy and objectives including just culture, hazard identification and safety risk management, competence, documented key processes, integration with other certificates the organisation holds, and the compliance monitoring function
  • Occurrence reporting and the internal safety reporting scheme: reports to the competent authority, to the design organisation and to the person responsible for continuing airworthiness within 72 hours, and the internal collection and evaluation of reportable occurrences and of errors, near misses and hazards, including those arising from subcontracted activities
  • Record-keeping and retention periods: 3 years for detailed maintenance records and for airworthiness review records, 5 years for management-system and contracting records, 3 years after departure for personnel records, the legibility, traceability and protection requirements, and the disposal of records when the organisation ceases to operate
  • Contracting and subcontracting: the subcontracted organisation works under the scope of approval and management system of the subcontracting organisation, the certificate of release to service is issued under the subcontracting organisation's approval, and the base maintenance check and complete engine or module overhaul excluded from that arrangement
  • Findings and observations from the organisation's side: level 1 and level 2 findings, the corrective action period, the escalation of an unclosed level 2 finding, and the organisation's obligation to identify root cause and contributing factors
  • Part-CAO, the combined airworthiness organisation: its scope for aircraft that are not complex motor-powered and are not on the air operator certificate of a licensed air carrier, the ELA1 and ELA2 boundaries, the combined airworthiness exposition, its privileges for maintenance, continuing airworthiness management and airworthiness review, the small CAO whose quality system may be replaced by regular organisational reviews, and its position as the successor to the Part-M Subpart F approvals, none of which has been valid since 24 March 2022

10.4Independent certifying staff

Knowledge level n/a for A, 3 for B1/B2/B2L/B3. New paragraph, introduced by (EU) 2023/989.

  • Independent certifying staff: certifying staff who do not work on behalf of an approved maintenance organisation, the two alternative qualification routes (the requirements of Part-66, or for aircraft to which Part-66 does not apply the certifying staff requirements in force in the Member State of registry), and the fact that the conditions of 66.A.20(b) must be satisfied by the individual because there is no organisation to satisfy them on his or her behalf
  • The Part-ML envelope that bounds the role: aeroplanes of 2 730 kg MTOM or less, helicopters of 1 200 kg MTOM or less certified for up to four occupants, other ELA2 aircraft and non-conventional aircraft, and the reversion to Part-M when such an aircraft is listed on the air operator certificate of an air carrier licensed under Regulation (EC) No 1008/2008
  • Independent certifying staff under Part-M, restricted to maintenance tasks other than the complex maintenance tasks listed in Part-M Appendix VII, and the exclusion from aircraft used by licensed air carriers and from complex motor-powered aircraft, for which a Part-145 organisation is required
  • Issue of the aircraft certificate of release to service by independent certifying staff under Part-ML, and its required content including the identity and, where applicable, the licence number of the person issuing it
  • Release within approved aircraft limitations when the required maintenance cannot be completed, the bar on releasing an aircraft with a known non-compliance that endangers flight safety, and assistance by one or more persons subject to the direct and continuous control of the certifying staff
  • The unforeseen-circumstances derogation when no approved organisation and no appropriate certifying staff are available, with the 3-year experience condition and the recheck within 7 days, or 30 days for Part-NCO aircraft
  • Component release at aircraft level by independent certifying staff in the cases where an EASA Form 1 cannot be issued, and custody of unserviceable components stored in a secure location under the control of an approved maintenance organisation or of independent certifying staff
  • Pilot-owner maintenance, the limited task list, and the complex maintenance tasks that a pilot-owner may not release and that must be released by an approved organisation or by independent certifying staff
  • Airworthiness review by independent certifying staff: carried out while performing the 100-hour or annual inspection contained in the maintenance programme for aircraft operated under Part-NCO and the balloon and sailplane equivalents, the documented review of records plus a physical survey, the 90-day anticipation allowance, the prohibition on subcontracting the review, the airworthiness review certificate on EASA Form 15c, and the dispatch of a copy to the competent authority within 10 days
  • Qualification and authorisation of airworthiness review staff acting on their own behalf: a Part-66 licence rated for the corresponding aircraft plus an authorisation issued by the competent authority that issued the licence, granted on assessed knowledge and a supervised review, valid for 5 years, conditional on carrying out at least one airworthiness review every 12 months, and renewable without limit
  • Duty of the authorisation holder to keep records of all airworthiness reviews performed and to make them available on request to any competent authority and to any owner, and revocation of the authorisation for poor performance of the review or inappropriate use of it
  • Occurrence reporting by independent certifying staff to the competent authority of the Member State of registry and to the design organisation, within 72 hours of becoming aware of the event or condition

10.5Air operations

Knowledge level 1 / 1.

  • Scope of Regulation (EU) No 965/2012, the relationship between its Annexes (Part-ARO, Part-ORO, Part-CAT, Part-SPA, Part-NCC, Part-NCO and Part-SPO), and the four operating regimes they create with their maintenance consequences: commercial air transport, non-commercial with complex motor-powered aircraft, non-commercial with other-than-complex aircraft, and specialised operations
  • The regulatory definitions that decide which Annex applies: commercial operation, and specialised operation as any operation other than commercial air transport where the aircraft is used for specialised activities
  • The air operator certificate, the operations specifications that record the operator's privileges including specific approvals granted under Part-SPA, and the declaration that stands in place of a certificate for non-commercial operations with complex motor-powered aircraft and for commercial specialised operations
  • Operator responsibilities: the conduct of every flight in accordance with the operations manual, the operational control system, the management system, and the operations manual itself as the document containing the procedures, instructions and information the crew needs, which the operator must keep current
  • Operator responsibility for continuing airworthiness under an air operator certificate, discharged through a CAMO approval and a Part-145 contract
  • The master minimum equipment list as operational suitability data and the operator MEL derived from it and approved by the competent authority: MEL content, the rectification interval established for each listed item and its category and the requirement that it be no less restrictive than the corresponding rectification interval in the MMEL, the effective rectification programme, the one-time extension of category B, C and D intervals, the operational and maintenance procedures referenced in the MEL and the point in the dispatch process at which each must be completed, and the configuration deviation list, its distinction from the MEL and the commander's acceptance of the aircraft against both
  • Documents, manuals and information to be carried on each flight, the retention-at-the-aerodrome alternative for certain VFR day operations, the acceptance of electronic documents, and the equivalent carriage lists for non-commercial and specialised operations, in which the declaration and the list of specific approvals stand in place of the air operator certificate
  • The journey log, the aircraft technical log system and the defects they record: which operations require a technical log, its five required contents including the current certificate of release to service, the current maintenance statement giving the maintenance status of what scheduled and out of phase maintenance is next due, and any necessary guidance instructions on maintenance support arrangements, the approval of the initial issue of the technical log system by the competent authority and the management of subsequent amendments, the 36-month retention of the log covering the period prior to the last entry, deferred and carried-forward defect rectification, and the requirement that the cumulative effect of deferred defects not compromise safe operation
  • Aircraft placarding, markings and instrument markings, and the requirement that they be presented in an official EU language acceptable to the competent authority of the Member State of registry
  • Pre-flight inspection: who is responsible for it, and the fact that it need not be carried out by an approved maintenance organisation or by certifying staff
  • Specific approvals under Part-SPA: application, the recording of privileges, changes, and their unlimited duration subject to continued compliance
  • The threshold distance beyond which a two-engined aeroplane may be operated in commercial air transport only under an ETOPS operational approval, measured under standard conditions in still air as the distance flown in 60 minutes at the one-engine-inoperative cruising speed for performance class A aeroplanes with a maximum operational passenger seating configuration of 20 or more, 120 minutes or, subject to approval, up to 180 minutes for turbojet aeroplanes of 19 or less, and for performance class B or C aeroplanes the lesser of 120 minutes at that speed and 300 NM, and the ETOPS operational approval itself: the evidence required for it, adequate en-route alternate aerodromes, and their planning minima additives above normal landing minima
  • Low-visibility operations and operations with operational credits as the current specific approval: its criteria including the required changes to the MEL and to the maintenance programme, the minimum equipment that must be serviceable at the commencement of the operation, and the Category I, II and III definitions of type B instrument approach operations by decision height and runway visual range
  • Performance-based navigation and reduced vertical separation minimum approvals, and the airborne equipment and continued airworthiness of that equipment they depend on
  • Mass and balance in operations: compliance of the loading, mass and centre of gravity with the AFM limits or the more restrictive operations manual limits during any phase of operation, establishment of the mass and CG by actual weighing before initial entry into service and thereafter at intervals of 4 years where individual aircraft masses are used or 9 years where fleet masses are used, weighing by the aircraft manufacturer or by an approved maintenance organisation, the accumulated effects of modifications and repairs and the reweighing required when their effect is not accurately known, the mass and balance documentation produced before each flight and the information it must contain so that the commander can determine that the mass and balance limits are not exceeded, and its retention for three months
  • Instruments, data and equipment required to be carried, and the principle that the carriage scales are set by the operating rules rather than by the airworthiness code: the bar on commencing a flight with any required instrument, item of equipment or function inoperative or missing except under the operator MEL, the short list of items exempted from approval against the applicable airworthiness requirements, spare electrical fuses at the higher of 10 % of the fuses of each rating or three fuses for each rating, portable battery-powered megaphones for aeroplanes with a maximum operational passenger seating configuration of more than 60, and life-jackets or equivalent flotation devices for flight over water
  • Handling of flight recorder recordings: preservation of the original recorded data for 60 days following an accident, a serious incident or an occurrence identified by the investigating authority, or until that authority directs otherwise, the operational checks and evaluations of the recordings by which the operator keeps the recorders serviceable, and the allowance to erase up to 1 hour of the oldest recorded data for the purpose of testing and maintaining a recorder

10.6Certification of aircraft, parts, and appliances

Knowledge level 2 / 2.

  • General understanding of Part 21, Annex I to Regulation (EU) No 748/2012, its place beside Annex Ib (Part 21 Light), and the structure of its Section A by subpart: A general provisions, B type-certificates and restricted type-certificates, D changes, E supplemental type-certificates, F production without production organisation approval, G production organisation approval, H certificates of airworthiness and restricted certificates of airworthiness, I noise certificates, J design organisation approval, K parts, appliances and control and monitoring unit components, M repairs, O European Technical Standard Order authorisations, P permit to fly, Q identification
  • Design organisation approval under Subpart J: the terms of approval, the design management system with its safety management element and design assurance element, the handbook the organisation must create and provide to the Agency and the flight test operations manual where flight tests are conducted, the privileges to classify changes and repair designs as major or minor and to approve minor changes and minor repair designs, and the alternative procedures agreed with the Agency for demonstrating design capability for ELA2 aircraft, piston engines and fixed or adjustable pitch propellers
  • Production organisation approval under Subpart G with its production management system carrying a safety management element and a quality management element, production without a production organisation approval under Subpart F with the statement of conformity validated by the competent authority, and the privileges of a production organisation approval holder to obtain a certificate of airworthiness and a noise certificate without further showing, to issue authorised release certificates, and to maintain a new aircraft it has produced
  • Type-certificates and restricted type-certificates under Subpart B, the applicable type-certification basis, the obligations that attach to the holder, and the type certificate data sheet as the record of the main type design data and the certification basis
  • Changes to a type-certificate under Subpart D and supplemental type-certificates under Subpart E: classification as minor or major on the effect of the change on the airworthiness characteristics, and the fact that the supplemental route exists for applicants other than the type-certificate holder, who use the Subpart D change process instead
  • Repairs under Subpart M, their classification as minor or major and their approval, and standard changes and standard repairs with the aircraft classes to which they are available and the certification specifications that carry their pre-approved data
  • EASA certification specifications used as the type-certification basis, and the scope of CS-22, CS-23, CS-25, CS-27, CS-29, CS-E and CS-STAN
  • Certificates of airworthiness under Subpart H: eligibility of the registered owner, classification as a certificate of airworthiness or a restricted certificate of airworthiness and the aircraft to which each is issued, the application for a new aircraft and the statement of conformity, weight and balance report and flight manual it requires, the unlimited duration of the certificate and the four conditions on which it remains valid, and its transfer with the aircraft while the aircraft remains on the same register
  • Noise certificates under Subpart I, their issue for an unlimited period and the conditions on which they remain valid, in particular the aircraft continuing to comply with the applicable type design and continued airworthiness requirements and remaining on the same register, their transfer with the aircraft on a change of ownership within the same register and their re-issue on presentation of the former certificate when the aircraft moves to another Member State register, and the certificate of registration and the aircraft radio licence as documents issued outside Part 21
  • Permits to fly under Subpart P: the aircraft eligible for one, and the sixteen purposes listed in 21.A.701(a) for which one may be issued
  • Parts and appliances under Subpart K, their eligibility for installation, and the cases in which an EASA Form 1 is not required
  • Identification of products, parts, appliances and control and monitoring units under Subpart Q: the fireproof identification plate carrying the manufacturer's name, the product designation and the serial number, secured so that it is accessible and legible and is unlikely to be defaced or removed in normal service or lost in an accident, the permanent and legible marking of a part or appliance with the manufacturer's identification and its part number, the additional serial number required on a critical part, and the marking specified by the type-certificate holder
  • EASA Form 1 as the authorised release certificate, EASA Form 52 as the aircraft statement of conformity, EASA Form 53 as the production organisation certificate of release to service, and the foreign authorised release documents accepted in their place
  • The export certificate of airworthiness as an instrument of the exporting state, with no counterpart anywhere in Part 21, which handles export through the permit-to-fly purpose "delivering or exporting the aircraft"

10.7Continuing airworthiness

Knowledge level 2 / 2.

  • Continuing airworthiness obligations placed on design approval holders by Part 21, and the articles that impose them on each class of holder: type-certificate holders, minor and major change approval holders, and major repair design approval holders
  • The design approval holder's reporting system with the 72-hour limit for dispatching a report of an occurrence that may lead to an unsafe condition, and airworthiness directives: the definition, the conditions on which the Agency issues one, the corrective action the design approval holder must propose, and the minimum content of the directive
  • The scope of Part-M and of Part-ML, and which aircraft fall to each
  • Owner responsibility for continuing airworthiness and its variation for air carrier aircraft, complex motor-powered aircraft, commercially operated other-than-complex aircraft and privately operated aircraft, together with the written contract by which continuing airworthiness tasks are attributed to a CAMO or CAO and the fact that responsibility is not thereby transferred
  • The continuing airworthiness tasks themselves: pre-flight inspection, defect rectification, accomplishment of the maintenance programme, release to service, analysis of the effectiveness of the maintenance programme, maintenance check flights when necessary, and occurrence reporting under Part-M and the persons on whom it falls
  • Approval of the aircraft maintenance programme: the requirement that maintenance be organised in accordance with one, direct approval by the competent authority, indirect approval through a CAMO or CAO procedure set out in the CAME or CAE, and the bar on using indirect approval to escalate safety-related tasks
  • Content and upkeep of the aircraft maintenance programme: the instructions with which it must demonstrate compliance, the details it must contain including structural inspection plans, corrosion prevention and critical design configuration limitations, the escalated intervals it may propose from review data, certification maintenance requirements arising from the type certification process rather than from the continuing airworthiness regulation, the reliability programme required for complex motor-powered aircraft whose programme is based on maintenance steering group logic or on condition monitoring, and periodic review and amendment against operating experience, authority instructions and new or modified design approval holder instructions
  • Compliance with applicable airworthiness directives within the requirements of the directive, the recording of AD compliance status in the continuing airworthiness records, and the fact that an extension without compensating factors is not an alternative method of compliance
  • Service bulletins and manufacturer service information as non-mandatory unless made mandatory by an airworthiness directive, and safety information bulletins as an advisory EASA instrument
  • Modifications and repairs: the data usable for them, and the requirement that a person or organisation repairing an aircraft or component first assess the damage against approved data
  • Maintenance data and the publications an engineer works from: the obligation to have access to and use only applicable current data and the sources from which it may come, what each publication carries - aircraft maintenance manual, structural repair manual, illustrated parts catalogue, wiring diagram manual, fault isolation manual, fault reporting manual and component maintenance manual - and the ATA chapter numbering by which technical data is organised and its use in the Part-66 type training and examination standard
  • Aircraft defects: rectification before further flight of any defect that hazards flight safety, deferral in accordance with the minimum equipment list, and the cumulative effect of deferred defects
  • The aircraft continuing airworthiness record system: what it must contain, the current status records it carries including the mass and balance statement and the life accumulated by service life-limited parts against the applicable airworthiness limitation parameter, the retention periods including the 12 months that apply after permanent withdrawal from service, and the transfer of records on a change of owner or operator and on contracting a CAMO or CAO, with the retention periods surviving the transfer
  • The certificate of release to service under Part-M: who may issue it and its required content
  • Airworthiness review: the process, the periodic review that keeps the airworthiness certificate valid, the airworthiness review certificate issued on EASA Form 15b by an approved organisation and on EASA Form 15a by the competent authority, the recommendation route, validity for 1 year, extension for a further year on a maximum of two consecutive occasions with the conditions the managing organisation must satisfy, and the 30-day anticipation rule that fixes the new expiry date
  • Part-CAMO and Part-CAO as the organisations that manage continuing airworthiness: the CAMO approval and its integration into the air operator certificate for licensed air carriers, the management system, the continuing airworthiness management exposition, the privileges to approve maintenance programmes, carry out airworthiness reviews, issue and extend airworthiness review certificates and issue permits to fly, and the CAO's equivalent continuing airworthiness management privileges
  • Part-ML continuing airworthiness for light aircraft: the maintenance programme declared by the owner or approved by a CAMO or CAO, the minimum inspection programme and its annual or 100-hour interval, and the simplified records
  • Additional continuing airworthiness consequences of specific operational approvals: the ETOPS maintenance and dispatch programme, and the serviceability standard for the equipment required by a low-visibility approval

10.8Oversight principles in continuing airworthiness

Knowledge level 1 / 1. New paragraph, introduced by (EU) 2023/989.

  • Purpose of oversight in continuing airworthiness within the single European aviation safety system: verification of compliance before a certificate is issued, of continued compliance thereafter and of the implementation of safety measures mandated by the competent authority; the joint certification, oversight and enforcement system operated by the Commission, the Agency and the national competent authorities; and the independence, impartiality, transparency and adequate resourcing of the national competent authority when it takes technical decisions
  • Risk-based and proportionate oversight: continuous, prioritised in the light of the risks to civil aviation, and corresponding to the nature and risk of the activity
  • Oversight methods and the setting of its scope: documented guidance for oversight personnel, assessments, audits and inspections including unannounced inspections, communication of the results to the organisation, and the scope of oversight set from the results of past oversight activities and the safety priorities
  • The oversight programme and the oversight planning cycle: normally not exceeding 24 months, extendable to 36 months and to a maximum of 48 months against defined conditions and shortened where safety performance has decreased; the content of each cycle in management system assessments and process audits, product audits of a sample of aircraft or of maintenance carried out, sampling of airworthiness reviews and a meeting with the accountable manager; and the Part-CAO equivalent of an audit at intervals not exceeding 24 months with a sample survey of the aircraft managed
  • Right of access granted to the competent authority at any time to any facility, aircraft, document, record, data or procedure relevant to the certified activity, whether contracted or not
  • Findings, corrective action and observations from the authority's side: classification as level 1 or level 2 and the acts that are always a level 1 finding - refusal of access after two written requests, falsification of documentary evidence, malpractice or fraudulent use of the certificate, and the lack of an accountable manager; the organisation's identification of root cause and contributing factors, its corrective action plan and demonstrated implementation within the agreed period, with an initial period of not more than 3 months for a level 2 finding and escalation to level 1 on failure; and the observations a Part-145 authority may issue where no finding is warranted, which the organisation must give due consideration and record
  • Enforcement: prohibition or limitation of activities, and suspension, limitation or revocation of the certificate, including suspension where inspectors have been unable to audit on site for 24 months
  • What oversight looks at inside the organisation: the management system with the direct safety accountability of the accountable manager, the safety policy, hazard identification and management of the associated risks, competent personnel, documented key processes and proportionality to the size, nature and complexity of the activities; the compliance monitoring function that monitors the organisation's own compliance and feeds findings back to the accountable manager; and the internal safety reporting scheme that collects and evaluates reportable occurrences and internally reported errors, near misses and hazards
  • The competent authority's own arrangements: its management system of documented policies and procedures, sufficient qualified personnel, adequate facilities, an internal audit and safety risk management process and compliance monitoring reporting to its senior management; the sharing of oversight work through allocation of tasks to qualified entities, oversight by the authority of the State where the facilities are located or by the Agency for third-country facilities, and mutual exchange of findings between competent authorities; and the standardisation inspections by which the Agency verifies uniform application of the rules
  • Safety management above the organisation: the European Aviation Safety Programme, the European Plan for Aviation Safety and its safety risk portfolio, the State Safety Programme and the State Plan for Aviation Safety
  • Oversight of the aircraft on the register and of individuals: a risk-based survey programme with sample product surveys, revocation of an independent certifying staff airworthiness review authorisation for poor performance or inappropriate use of it, and suspension, limitation or revocation of an aircraft maintenance licence

10.9Maintenance and certification beyond the current EU regulations (if not superseded by EU requirements)

Knowledge level n/a for A, 1 for B1/B2/B2L/B3.

  • The scoping qualifier of this paragraph: it reaches only those national and other requirements that EU law has not superseded
  • Annex I to Regulation (EU) 2018/1139: the aircraft to which the Regulation does not apply because their operation involves low risk for aviation safety
  • The Annex I categories defined by origin: historic aircraft whose initial design was established before 1 January 1955 and whose production stopped before 1 January 1975, or which have a clear historical relevance; aircraft specifically designed or modified for research, experimental or scientific purposes and likely to be produced in very limited numbers; amateur-built aircraft, including those supplied in kit form, where at least 51 % of the fabrication and assembly tasks are performed by an amateur or a non-profit making association of amateurs for their own purposes and without a commercial objective; and aircraft that have been in the service of military forces, unless the type has a design standard adopted by the Agency
  • The Annex I categories defined by size: light aeroplanes, helicopters, powered parachutes, sailplanes and powered sailplanes with a measurable stall speed or minimum steady flight speed in landing configuration not exceeding 35 knots CAS, no more than two seats and a maximum take-off mass within the Annex I table, including the amphibian and airframe-mounted total recovery parachute allowances; single and two-seater gyroplanes with a MTOM not exceeding 600 kg; replicas of historic or former military aircraft whose structural design is similar to the original; balloons and airships of single or double occupancy within the Annex I maximum design volumes; any other manned aircraft of maximum empty mass including fuel not exceeding 70 kg; and, listed separately from the manned-aircraft categories, tethered aircraft
  • Consequence for maintenance: an Annex I aircraft is outside the EASA system, so its continuing airworthiness, its maintenance and the qualification of the staff who release it are governed by the national law of the Member State concerned and not by Regulation (EU) No 1321/2014
  • Cross-border operation and maintenance of an Annex I aircraft and the two routes back into the EU system: operation in another Member State subject to the agreement of the Member State in whose territory the operation takes place, so that there is no automatic recognition; maintenance or design modification in another Member State provided the work is carried out under the oversight of the Member State of registry and in accordance with that State's national procedures; and re-entry either through a certificate issued or deemed issued under Regulation (EC) No 216/2008, or, for a serially produced type in points 1(e) to 1(i), through a type certificate application or a design declaration
  • Military aviation as the other domain outside the Regulation: aircraft carrying out military, customs, police, search and rescue, firefighting, border control, coastguard or similar activities or services under the control and responsibility of a Member State, and the Agency's duty to consult the European Defence Agency where its measures touch military aspects
  • European Military Airworthiness Requirements, including EMAR 66 for military maintenance certifying staff: modelled on civil Part-66, developed through the European Defence Agency MAWA programme, and given legal effect by national adoption rather than by Union law
  • Specialist maintenance activities governed by national and international standards: component maintenance, welding, painting and non-destructive testing, with NDT personnel qualified to a European or equivalent standard recognised by the Agency, other specialised tasks qualified to officially recognised standards, and the category B1, B3 and L derogation for colour contrast dye penetrant

10.10Cybersecurity in aviation maintenance

Knowledge level 1 / 1. New paragraph, introduced by (EU) 2023/989.

  • Why information security is an airworthiness matter: product integrity, including protection against information security threats, must be assured for all anticipated flight conditions for the operational life of the aircraft, and design precautions must minimise hazards from reasonably probable threats including information security threats
  • The two Part-IS instruments, their applicability dates and their relationship with other Union law: Implementing Regulation (EU) 2023/203 for organisations under Regulations 1321/2014, 965/2012, 1178/2011, 2015/340, 2017/373 and 2021/664, applying from 22 February 2026; Delegated Regulation (EU) 2022/1645 for Part-21 design and production organisations and for aerodrome operators under Regulation 139/2014, applying from 16 October 2025; and the equivalence by which security requirements met under the NIS Directive, or the aviation security requirements of Implementing Regulation (EU) 2015/1998 for entities in a national civil aviation security programme, count as compliance except for the external reporting point IS.I.OR.230, which must be complied with as such
  • Who is bound and who is not: Part-145 maintenance organisations and Part-CAMO continuing airworthiness management organisations, in each case excluding those solely involved in the maintenance or management of aircraft under Part-ML; Part-CAO combined airworthiness organisations, Part-147 maintenance training organisations and Part-M Subpart F and Subpart G organisations, none of which appears in the Article 2(1) list and none of which carries a Part-IS obligation; the competent authority responsible for issuing, continuing, changing, suspending or revoking Part-66 aircraft maintenance licences, which does; and the hooks by which points 145.A.200A and CAMO.A.200A require an information security management system in addition to the safety management the management system already requires
  • The three objectives of Part-IS and its vocabulary: identify and manage information security risks with a potential impact on aviation safety, detect information security events and identify which of them are incidents, and respond to and recover from those incidents; information security as the preservation of confidentiality, integrity, authenticity and availability of network and information systems; and the defined terms information security event, information security incident, information security risk, threat and vulnerability
  • The information security management system: the thirteen elements it must ensure - information security policy, risk identification and review, risk treatment, internal reporting, incident detection response and recovery, implementation of authority-mandated immediate measures, action on authority findings, external reporting, control of contracted activities, personnel requirements, record-keeping, compliance monitoring with feedback to the accountable manager, and protection of the confidentiality of information received from other organisations - together with its proportionality to the nature and complexity of the organisation's activities, its integration with management systems the organisation already operates, and the exemption the competent authority may approve where a documented risk assessment demonstrates that the organisation's activities pose no information security risk with a potential impact on aviation safety, reviewed at each oversight cycle
  • Information security risk assessment and risk treatment: identification of the organisation's exposed elements and of its interfaces with other organisations, assignment of a risk level from a predefined classification reflecting likelihood and severity, review on change or on lessons learnt from incidents, and treatment of unacceptable risks by measures that control the contributing circumstances, reduce the safety consequences or avoid the risk without introducing a new unacceptable risk, with the outcome communicated to affected personnel and to interfacing organisations
  • Internal reporting, detection, response and recovery: collection and evaluation of information security events, identification of those that are incidents or vulnerabilities with a potential impact on aviation safety, their causes addressed through information security risk management, the contractual duty on contracted organisations to report events, identification of deviations from predetermined functional performance baselines, warnings that activate predefined responses, containment of an attack, control of the failure mode, and recovery to a safe state within a previously defined recovery time
  • External reporting and response to authority findings: notification to the competent authority and, where an aircraft, system or constituent is affected, to the design approval holder or the design organisation, as soon as the condition is known, with a report as soon as possible and not exceeding 72 hours from that time and a follow-up report on the actions taken; and root cause and contributing factors, a corrective action plan, and demonstrated correction within the period agreed with the authority
  • Contracting of information security management activities: the contracted activities comply with the Regulation, the contracted organisation works under the contracting organisation's oversight, and the competent authority can obtain access to the contracted organisation on request
  • Personnel requirements: the accountable manager's corporate authority, resourcing duty and basic understanding of the Regulation, appointment of a responsible person or group reporting directly to the accountable manager, appointment of a compliance monitoring manager, sufficient and competent personnel who acknowledge their assigned responsibilities, and the established identity and trustworthiness of personnel with access to the systems and data concerned
  • Record-keeping, the information security management manual, the management of changes to the information security management system, and the continuous improvement process: retention of exemption approvals and their risk assessment, contracts, key-process records, identified risks and their treatment measures, and reported incidents and vulnerabilities, with the 5-year retention rule for those records and 3 years after departure for personnel qualification records
  • Cybersecurity in day-to-day maintenance practice, and the competent authority's own information security duties: integrity of electronic maintenance data and of loadable software and databases, use of controlled and authorised sources, access control, reporting of suspected information security events through the organisation's scheme, and the authority's own Part-IS.AR information security management system together with its system for collecting, analysing and disseminating reported incidents and vulnerabilities and passing safety-significant information to the Agency

Key Referenced Regulations

RegulationSubject
(EU) 2018/1139EASA Basic Regulation
(EU) No 748/2012Initial Airworthiness (Part 21)
(EU) No 1321/2014Continuing Airworthiness (Part-M, Part-145, Part-66, Part-147, Part-ML, Part-CAMO, Part-CAO)
(EU) No 376/2014Occurrence Reporting
(EU) No 965/2012Air Operations
(EU) No 1178/2011Air Crew
(EU) 2023/989Amending 1321/2014 (updated Part-66 syllabus)
(EU) 2023/203Information Security (Part-IS)
(EU) 2022/1645Information Security for Design/Production

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