The EASA Airworthiness Review Certificate: What Private Owners Need to Know Before Renewal

Meta description: Understand the EASA airworthiness review certificate renewal process, who can issue your ARC, and how to prepare for inspection.

Your ARC expires in a few weeks. You’ve been flying all year, the aircraft feels fine, and now someone needs to confirm it’s still airworthy. But what exactly are they checking? What documents do you need ready? And what happens if they find something wrong? If you’ve been self-managing under Part-ML, the ARC renewal can feel like an exam you didn’t study for. This guide explains what the process involves, what trips owners up, and how to approach it prepared.

What the Airworthiness Review Certificate Actually Is

The Airworthiness Review Certificate is EASA’s mechanism for confirming that an aircraft remains in compliance with its approved maintenance programme and applicable airworthiness requirements. It’s not a one-time certification—it’s a recurring validation that your aircraft continues to meet the conditions under which it was originally certified.

Under EASA Part-ML (which governs continuing airworthiness for most privately operated GA aircraft), the ARC serves as documented evidence that someone qualified has reviewed your aircraft’s airworthiness status within the required timeframe. Without a valid ARC, your aircraft cannot legally fly—even if every component is working perfectly.

The certificate itself states the aircraft registration, the date of issue, and the expiry date. It confirms that on the date of review, the aircraft was found airworthy in accordance with the applicable regulations.

Think of it as the aircraft equivalent of your medical certificate. The aircraft might be healthy, but you need the paperwork to prove someone qualified has checked.

Who Can Issue an ARC and How Long It Lasts

For aircraft operating under Part-ML, an ARC can be issued by:

1. A Continuing Airworthiness Management Organisation (CAMO) — These are organisations approved under Part-CAMO or Part-CAO to manage continuing airworthiness. They can issue ARCs as part of their contracted management of your aircraft.

2. Airworthiness review staff — Under Part-ML.A.903, qualified individuals who hold appropriate airworthiness review authorisation can conduct the review and issue the ARC. These are typically independent engineers or inspectors authorised by your National Aviation Authority (NAA).

3. The competent authority itself — In some cases, your NAA can conduct the airworthiness review directly, though this is less common for routine renewals.

An ARC is valid for 12 months from the date of issue. However, there’s an important nuance: if you complete your airworthiness review within the 90 days before your current ARC expires, the new certificate validity runs from the expiry date of the old one—not from the review date. This prevents you from losing months of validity by renewing early.

The Two-Extension Rule

Here’s where Part-ML differs from the older Part-M framework in an important way.

Under Part-ML.A.901(c), if your aircraft is managed by a CAMO (or CAO with airworthiness review staff privileges), that organisation can extend your ARC twice, each time by 12 months, without requiring a full airworthiness review.

This means a CAMO-managed aircraft could theoretically fly for up to three years on extensions before requiring a complete airworthiness review with physical inspection. The extensions are not automatic—the CAMO must still verify continuing airworthiness status through their management system—but they don’t require the full document review and physical survey that an initial issue or third renewal demands.

Important limitation: If you’re self-managing under Part-ML (not using a CAMO), you cannot extend your own ARC. You must have a full airworthiness review conducted each year by authorised airworthiness review staff or your competent authority.

This is one of the key decision points for owners: CAMO management adds cost but can simplify renewals. Self-management gives you control but requires annual reviews.

What an Airworthiness Review Involves

An airworthiness review has two components: a documentation review and a physical inspection of the aircraft.

Documentation Review

The reviewing staff will examine your aircraft records to verify:

• Maintenance programme compliance — Has all maintenance required by your approved Aircraft Maintenance Programme (AMP) been completed? This includes scheduled inspections (annual, 50-hour, 100-hour, whatever your programme specifies), component life limits, and calendar-based tasks.

• Airworthiness Directives (ADs) — Have all applicable ADs been complied with, either through completion or through an approved alternative means of compliance? The reviewer will check your AD status against the current applicable AD list for your aircraft type, engine, propeller, and installed equipment.

• Service Bulletin status — While most SBs are not mandatory, some become mandatory through ADs or through your maintenance programme. The reviewer may check that you’re tracking these appropriately.

• Weight and balance — Is your current weight and balance report accurate and up to date?

• Modifications and repairs — Have all modifications been approved and documented correctly? Have repairs been signed off with appropriate release certificates?

• Release to service documentation — Are your maintenance entries complete, legible, and signed by appropriately authorised personnel?

• Component documentation — For life-limited or hard-time components, can you demonstrate traceability and remaining life?

Physical Inspection

The physical survey isn’t a full maintenance inspection—it’s a verification that the aircraft condition matches what the documentation claims. The reviewer will check:

• General condition of the airframe, control surfaces, and visible structure
• Evidence of damage, corrosion, or deterioration
• Security of panels, cowlings, and access doors
• Condition of tyres, brakes, and landing gear
• Visible fluid leaks
• Correct placards and markings
• That the aircraft configuration matches the approved data (no undocumented modifications)

The physical inspection typically takes one to three hours depending on aircraft complexity. The reviewer needs reasonable access—clean aircraft, panels accessible, logbooks available.

Common Reasons an ARC Is Refused or Findings Are Raised

ARC reviews don’t always go smoothly. Here are the issues that most commonly cause problems:

Incomplete maintenance records — Missing signatures, illegible entries, maintenance performed but not properly documented. The work might have been done correctly, but if the paperwork doesn’t prove it, the reviewer cannot accept it.

Overdue scheduled maintenance — Tasks in your AMP that have exceeded their interval. This is particularly common with calendar-based items that don’t correlate with flight hours.

AD non-compliance — Either an AD wasn’t completed, wasn’t documented, or the documented compliance doesn’t match current requirements. AD statuses change—repeating inspections get superseded, new ADs get issued. Your AD tracking needs to be current.

Configuration discrepancies — Equipment installed that isn’t on the approved equipment list, or modifications without proper approval documentation.

Component life exceedances — Life-limited parts that have exceeded their approved life, or parts where the documentation can’t establish remaining life.

Physical condition issues — Corrosion, damage, or wear that should have been addressed through maintenance but wasn’t.

When findings are raised, you have options. Minor documentation issues can sometimes be resolved during the review. More significant findings require corrective action before the ARC can be issued. In some cases, you may need to complete maintenance before the aircraft can return to service.

[VERIFY: Part-ML.A.903(a) — confirm current wording on findings resolution requirements]

CAMO-Managed Versus Self-Managed: Which Approach Suits You?

The choice between CAMO management and self-management under Part-ML is fundamentally about how much of the airworthiness management burden you want to carry yourself.

Self-Managing Under Part-ML

You’re responsible for:

• Maintaining your own AMP (or using the Minimum Inspection Programme)
• Tracking all scheduled maintenance, ADs, and component lives
• Arranging annual airworthiness reviews with authorised staff
• Maintaining complete and current aircraft records

Advantages: Lower ongoing cost, direct control over your aircraft’s maintenance management, no dependency on a third party’s administrative processes.

Disadvantages: Annual ARC reviews required (no extension option), all tracking responsibility falls on you, any gaps in your system become your problem at ARC time.

CAMO Management

The CAMO takes contractual responsibility for:

• Monitoring your maintenance programme compliance
• Tracking ADs and scheduling maintenance
• Issuing ARC extensions (up to two consecutive years)
• Maintaining airworthiness status oversight

Advantages: ARC extensions reduce administrative burden, professional oversight catches issues before they become ARC problems, reduced owner workload.

Disadvantages: Ongoing management fees, less direct control, dependent on CAMO’s responsiveness and accuracy.

For owners who fly frequently, track their own maintenance meticulously, and are comfortable with regulatory requirements, self-management works well. For owners who want airworthiness management handled professionally—or who have complex aircraft with extensive tracking requirements—CAMO management may justify the cost.

How Squawkd Helps

Squawkd’s maintenance tracking automatically monitors your AMP compliance, AD status, and component life limits against your actual flight hours and calendar time. When your ARC review approaches, you can generate a complete airworthiness status summary showing exactly what’s been done and what’s coming due—giving your reviewer everything they need in one place.

Frequently Asked Questions

Q: Can I fly my aircraft if my ARC has expired?

No. An aircraft without a valid ARC is not considered airworthy under EASA regulations, regardless of its physical condition or maintenance status. You must complete an airworthiness review and obtain a new ARC before flight. If your ARC lapses, the subsequent review may also require additional verification that no unauthorised flights occurred during the invalid period.

Q: How early can I renew my ARC without losing validity time?

If your airworthiness review is completed within 90 days before your current ARC expiry date, the new ARC validity period starts from your old expiry date rather than the review date. This means renewing up to three months early costs you nothing in terms of validity. Renewing earlier than 90 days out will result in a new 12-month validity starting from the review date.

Q: What’s the difference between an ARC and a Certificate of Airworthiness?

Your Certificate of Airworthiness (CofA) is the original certification that your aircraft meets type design standards—it’s issued once and remains valid indefinitely (for standard CofAs) as long as the aircraft remains airworthy. The ARC is the periodic verification that your aircraft continues to meet airworthiness requirements. Think of the CofA as proving the aircraft was built correctly; the ARC proves it’s been maintained correctly.

Tags: ARC renewal, EASA Part-ML, airworthiness review, continuing airworthiness, aircraft maintenance programme, CAMO management, GA aircraft compliance

Regulatory context: EASA

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