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  • How to Declare Your Own Aircraft Maintenance Programme Under EASA Part-ML

    How to Declare Your Own Aircraft Maintenance Programme Under EASA Part-ML

    How to Declare Your Own Aircraft Maintenance Programme Under EASA Part-ML

    Meta description: Learn how to declare your own AMP under EASA Part-ML without a CAMO. Covers mandatory items, permitted deviations, and annual review requirements.

    You own a Cessna 172 or a Piper PA-28 in Europe. You fly privately, keep good records, and wonder why you need to pay a CAMO several hundred euros a year to manage paperwork you could handle yourself. Good news: you probably don’t. Since Part-ML came into force, owners of ELA1 and ELA2 aircraft operating non-commercially can declare their own Aircraft Maintenance Programme without any external approval. But “can” isn’t the same as “should know how.” This guide walks you through exactly what’s required.

    What Is an Aircraft Maintenance Programme and Why Does It Matter?

    An Aircraft Maintenance Programme is the document that defines every recurring maintenance task for your specific aircraft. It tells you what needs to be done, when it needs to be done, and what regulatory requirements drive each task.

    Without an AMP, there’s no structured way to ensure your aircraft remains airworthy. The Annual Review of Airworthiness (ARA) reviewer will check that one exists and that you’re complying with it. If you can’t produce a valid AMP, you won’t get your Airworthiness Review Certificate (ARC) renewed.

    The AMP covers three categories of tasks:

    1. Manufacturer-specified maintenance — the scheduled inspections and component replacements from your aircraft, engine, and propeller maintenance manuals
    2. Mandatory requirements — repetitive Airworthiness Directives and Airworthiness Limitations from the Type Certificate holder
    3. Additional tasks — anything you add based on operational experience, modifications installed, or specific equipment fitted

    For a typical ELA1 aircraft, the AMP might be ten pages. For a complex ELA2 twin, it could be forty. Either way, it’s the backbone of your continuing airworthiness management.

    Declaring vs. Approving: The Part-ML Distinction That Matters

    Here’s where Part-ML created genuine flexibility for private owners. Under the older Part-M framework, every AMP required approval from a CAMO or, in some cases, the competent authority. That meant paying someone else to review and stamp your programme.

    Part-ML changed this for non-commercial operations of ELA1 and ELA2 aircraft. Under ML.A.302, you have two options:

    Option 1: Approved AMP
    You contract a CAMO to develop and approve your AMP. They take responsibility for its content and compliance. You pay for the privilege.

    Option 2: Declared AMP (owner-declared)
    You develop your own AMP using an approved template as a basis, sign a declaration that it meets Part-ML requirements, and take full responsibility for its content. No external approval needed.

    The declaration route under ML.A.302(d) is specifically designed for owners who want to self-manage. You’re not asking permission. You’re stating that your AMP complies with the regulation and accepting the consequences if it doesn’t.

    The catch? “Owner-declared” doesn’t mean “owner-invented.” You must base your AMP on either:

    • The minimum inspection programme from Part-ML Appendix VII, or

    • A template published or accepted by your competent authority, or

    • The manufacturer’s recommended maintenance programme

    Most owners start with their national authority’s template (the UK CAA, EASA, and many NAAs publish these) and adapt it to their specific aircraft configuration.

    Mandatory Items: What You Cannot Omit or Defer

    Owner flexibility has hard limits. Certain items must appear in every AMP regardless of whether it’s declared or approved:

    Repetitive Airworthiness Directives
    Any AD that requires recurring inspections or actions must be incorporated into your AMP with the correct intervals. If AD 2019-0124 requires inspection of a fuel tank vent every 100 hours, that task must appear in your AMP at that interval or more frequently. You cannot extend AD intervals. Ever.

    Check your aircraft’s AD status using EASA’s Safety Publications Tool and cross-reference with any national ADs from your state of registry.

    Airworthiness Limitations (ALIs)
    These come from the Type Certificate holder and appear in Chapter 4 of the aircraft maintenance manual or in a separate Airworthiness Limitations document. ALIs include life-limited parts (replace the landing gear attach bolts at 12,000 hours regardless of condition) and mandatory inspection intervals.

    ALIs are not recommendations. They’re certification requirements. Under ML.A.302(c)(1), your AMP must include all ALIs without modification.

    Certification Maintenance Requirements (CMRs)
    Less common on GA aircraft, but if your type has CMRs defined in the Type Certificate Data Sheet, they’re mandatory inclusions.

    Modifications and Repairs
    If your aircraft carries an STC or has had a major repair, check whether that modification introduced its own maintenance requirements. An autopilot STC might require annual inspection of servo mounting bolts. A composite repair might require periodic NDT. These go in your AMP.

    The point: your declared AMP gives you flexibility on manufacturer-recommended tasks, not on regulatory requirements. Know the difference.

    Where You Have Flexibility: Deviating from Manufacturer Schedules

    Part-ML permits owners to adjust manufacturer-recommended maintenance intervals under specific conditions. This is codified in ML.A.302(c) and represents a genuine departure from the Part-M approach.

    Here’s what you can do:

    Extend or reduce inspection intervals
    If the manufacturer recommends a 100-hour inspection but you fly 30 hours a year, you might choose to perform it annually instead. Part-ML permits this provided you justify the deviation and it doesn’t conflict with mandatory requirements.

    Adjust task groupings
    Rather than following the manufacturer’s exact inspection schedule, you can reorganise tasks into a programme that suits your operation — perhaps combining items into a single annual inspection rather than spreading them across multiple calendar intervals.

    Omit non-applicable tasks
    If your aircraft doesn’t have a specific optional system fitted (no oxygen system, no de-icing equipment), you don’t include the related maintenance tasks.

    The critical phrase in ML.A.302(d) is that deviations are made “under the owner’s responsibility.” This isn’t bureaucratic boilerplate. It means:

    • You must document your reasoning

    • You accept liability if a deviation contributes to an incident

    • An ARA reviewer can question your decisions and refuse to issue an ARC if the justification is inadequate

    Practically speaking, conservative deviations (aligning to annual inspection when you fly well under 100 hours) are rarely challenged. Aggressive extensions without supporting data or experience will raise eyebrows.

    [VERIFY: ML.A.302(d) wording on deviation justification — confirm current AMC/GM guidance]

    The Annual Review Requirement Under ML.A.302(c)(9)

    Your AMP isn’t a document you create once and forget. ML.A.302(c)(9) requires an annual review of the AMP to ensure it remains current and effective.

    What does this review involve?

    AD currency check
    Have any new repetitive ADs been issued since your last review? If yes, incorporate them.

    Service Bulletin review
    Has the manufacturer issued any SBs that affect scheduled maintenance? While SBs aren’t mandatory, you should assess whether any affect airworthiness sufficiently to warrant inclusion.

    Effectiveness assessment
    Has your maintenance programme caught problems before they became failures? If you’ve had recurring discrepancies (persistent corrosion, repeated brake wear), should task intervals be shortened?

    Configuration changes
    Have you installed any new equipment or modifications that introduce maintenance requirements?

    Document the review. A simple signed statement with the date, a summary of changes made (or “no changes required”), and references to any new ADs incorporated is sufficient. Keep it with your aircraft records.

    This annual review typically happens before your ARC renewal. The ARA reviewer will expect to see evidence that it’s been done.

    How Squawkd Helps

    Squawkd tracks your AMP tasks alongside flight hours and calendar time, alerting you before items come due rather than after. When annual review time arrives, you can generate a current status report showing compliance across all tracked requirements — exactly what an ARA reviewer wants to see.

    Frequently Asked Questions

    Q: Can I use the manufacturer’s maintenance schedule directly as my AMP?

    You can base your AMP on the manufacturer’s schedule, but you need to supplement it with repetitive ADs and any requirements from installed modifications that aren’t covered. The manufacturer’s schedule alone won’t include ADs issued after publication or equipment you’ve added via STC. Most owners find it easier to start with a competent authority template and incorporate manufacturer task intervals rather than using the manufacturer document directly.

    Q: What happens if an ARA reviewer disagrees with a deviation I’ve made?

    The reviewer can refuse to issue an ARC if they believe your AMP doesn’t meet Part-ML requirements. In practice, they’ll usually discuss concerns with you first. If you’ve documented your reasoning clearly and it’s technically sound, you can defend your position. If you can’t justify a deviation, expect to revise your AMP and potentially perform overdue maintenance before the ARC is issued.

    Q: Do I need to notify my competent authority when I declare my AMP?

    Under Part-ML, a declared AMP doesn’t require submission to or approval from the authority. However, you must keep the AMP available for inspection. Some national authorities request that you send them a copy for their records — check your NAA’s specific requirements. The declaration itself (stating your AMP complies with Part-ML) should be retained with your aircraft records.

    Tags: EASA Part-ML, aircraft maintenance programme, owner-declared AMP, ELA1, ELA2, continuing airworthiness, ARC renewal

    Regulatory context: EASA

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

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

    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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  • EASA Airworthiness Review Certificate: The Complete Guide for Private Owners

    EASA Airworthiness Review Certificate: The Complete Guide for Private Owners

    EASA Airworthiness Review Certificate: The Complete Guide for Private Owners

    Meta description: Learn what the EASA airworthiness review certificate covers, how the ARC renewal process works, and what documents you need to prepare.

    Your ARC expires in eight weeks. You know the aircraft needs a review before you can legally fly it again, but the specifics are hazy. What exactly will the reviewing engineer inspect? Which documents do you need to have ready? And what happens if something in your maintenance records doesn’t add up? This guide covers exactly what private owners need to know about the EASA airworthiness review certificate—no padding, just the information you need to prepare properly.

    What the Airworthiness Review Certificate Actually Is

    The Airworthiness Review Certificate is the document that confirms your aircraft remains in compliance with its type design and is safe to operate. Without a valid ARC, your aircraft cannot fly under EASA regulations—full stop. It’s the regulatory mechanism that forces a periodic verification of your aircraft’s continuing airworthiness status.

    The ARC is governed primarily by Part-ML for aircraft used in non-commercial operations (which covers most private owners), specifically ML.A.901 through ML.A.905. For aircraft under Part-M (typically commercial or more complex operations), the equivalent requirements sit in M.A.901 and related sections.

    The certificate itself is EASA Form 15c for Part-ML aircraft. It states the aircraft registration, the date of issue, the expiry date, and confirms that at the time of review, the aircraft was found airworthy in accordance with the applicable requirements.

    One critical point: the ARC is not a maintenance release. It doesn’t replace the Certificate of Release to Service after maintenance work. It’s a separate, higher-level confirmation that looks at the complete airworthiness picture—maintenance records, modifications, ADs, life-limited components, and the physical condition of the aircraft.

    Who Can Issue an ARC and How Long It Lasts

    For private owners operating under Part-ML, two routes exist for ARC issuance and renewal:

    Route 1: CAMO or CAO
    A Continuing Airworthiness Management Organisation (CAMO) or Combined Airworthiness Organisation (CAO) with the appropriate privilege can issue and renew your ARC. They take responsibility for verifying the complete airworthiness status.

    Route 2: Appropriately Qualified Personnel
    Under Part-ML, certain licensed engineers can conduct airworthiness reviews and issue or extend ARCs. Specifically, ML.A.903 permits licensed certifying staff holding a Part-66 licence with appropriate type rating, or personnel specifically authorised by the competent authority, to perform this function for ELA1 and ELA2 aircraft. [VERIFY: ML.A.903(1) — confirm current scope of personnel privileges for ARC issuance]

    The validity period is straightforward: 12 months from the date of issue. The expiry date is printed on the certificate. Flying with an expired ARC means flying an aircraft that is not legally airworthy under EASA rules.

    The Two-Extension Rule

    Here’s where many owners get confused. An ARC can be extended twice—each extension adding 12 months—without requiring a full airworthiness review, provided certain conditions are met. After two extensions, a full review is mandatory.

    The conditions for extension under ML.A.901(c) include:

    • The aircraft has been maintained by an appropriately approved organisation or certifying staff

    • No airworthiness issues have been identified that would affect the aircraft’s continued airworthiness

    • The person extending the ARC has verified the maintenance records and confirmed compliance

    This means your ARC can theoretically cover three years (initial issue plus two extensions) before requiring another full physical inspection and documentation review. However, each extension still requires someone qualified to verify the records and confirm no issues exist. It’s not automatic.

    Practical tip: Many owners use the extension option to align ARC renewals with annual inspections or seasonal maintenance schedules. But don’t rely on extensions to avoid proper reviews—they exist for flexibility, not as a shortcut.

    What the ARC Engineer Actually Checks

    The airworthiness review is a two-part process: documentation review and physical survey. Understanding what’s checked helps you prepare properly.

    Documentation Review

    The reviewing engineer or organisation must verify:

    Maintenance records: Complete and continuous records showing all maintenance performed, including scheduled maintenance per your Aircraft Maintenance Programme (AMP), unscheduled maintenance, defect rectification, and component replacements.

    Airworthiness Directives: Evidence that all applicable ADs have been complied with. This means cross-referencing the current AD status for your aircraft type, engine, propeller, and any appliances against your maintenance records.

    Type Certificate and modifications: Confirmation that the aircraft conforms to its type design. Any modifications or repairs must be properly documented and approved (STC, EASA minor modification, etc.).

    Life-limited components: Verification that all components with life limits (calendar, hours, or cycles) are within limits and properly tracked.

    Weight and balance: Current weight and balance report reflecting the actual aircraft configuration.

    Flight manual: Correct and current version for your aircraft.

    Aircraft Maintenance Programme: Valid, current AMP appropriate for your aircraft and approved or declared in accordance with Part-ML.

    Certificate of Registration and CoA: Valid and matching the aircraft.

    Noise and emissions certificates: Where applicable.

    Physical Survey

    The physical inspection is not a full annual inspection—it’s a survey to verify the aircraft’s general condition matches what the paperwork suggests. The engineer will typically check:

    • General external condition: corrosion, damage, missing panels, security of fairings
    • Landing gear condition and tyre wear
    • Engine compartment: leaks, security, general condition
    • Propeller: damage, erosion, security
    • Control surfaces: freedom of movement, security, condition
    • Cockpit: instruments readable, placards present, required equipment installed
    • Safety equipment: fire extinguisher, first aid kit (where required), ELT status

    The physical survey must identify any obvious defects and verify the aircraft hasn’t been operated beyond limitations or with unresolved defects.

    Grounds for ARC Refusal or Suspension

    An ARC will be refused or suspended if the aircraft fails to meet airworthiness requirements. Common reasons include:

    Incomplete or inconsistent records: Gaps in the maintenance documentation, missing logbook entries, or records that don’t add up. If the engineer cannot verify continuous airworthiness, they cannot issue the ARC.

    Outstanding Airworthiness Directives: Non-compliance with mandatory ADs—especially repetitive ADs with expired intervals—is an automatic failure.

    Exceeded life limits: Any life-limited component found beyond its approved limit stops the process immediately.

    Unresolved defects: Known defects that haven’t been properly deferred or rectified.

    Invalid or expired AMP: Operating without a valid maintenance programme, or with one that doesn’t match your actual operations.

    Physical condition issues: Significant corrosion, obvious damage, or safety-critical defects found during the physical survey.

    Modifications without approval: Unapproved modifications or alterations to the aircraft.

    If the ARC is refused, you cannot fly the aircraft until the deficiencies are corrected and a new review confirms compliance. If your ARC is suspended (say, due to a newly discovered issue), the same applies—no flight operations until resolved.

    CAMO vs. Self-Managing Under Part-ML: What’s the Difference?

    Private owners under Part-ML have a choice: contract with a CAMO to manage continuing airworthiness, or self-manage.

    With a CAMO:
    The CAMO takes responsibility for managing your aircraft’s continuing airworthiness. They track maintenance due dates, AD compliance, life-limited components, and coordinate the ARC process. They can issue and renew your ARC directly. The owner still has legal obligations, but the CAMO handles the administrative complexity. This suits owners who want hands-off management or who operate more complex aircraft.

    Self-managing:
    You, as the owner, are responsible for ensuring continuing airworthiness. You must have a valid AMP (either the TCDS minimum inspection programme or a custom programme declared to your NAA), track all maintenance requirements, ensure AD compliance, and arrange for a qualified person to conduct airworthiness reviews. The owner declares their AMP under Part-ML rather than having it approved by a CAMO.

    Self-management works well for owners who are engaged with their aircraft’s maintenance and keep meticulous records. It requires more personal involvement but gives direct control over scheduling and costs.

    The ARC process itself is similar in both cases—the same documentation and physical survey requirements apply. The difference is who manages the ongoing tracking and who takes administrative responsibility for the airworthiness status between reviews.

    How Squawkd Helps

    Squawkd’s aircraft management tools track your ARC expiry alongside all your other airworthiness items—ADs, life-limited components, and scheduled maintenance tasks. When your ARC review approaches, you can pull the complete documentation package the reviewing engineer needs directly from the platform, eliminating last-minute scrambles through logbooks.

    Frequently Asked Questions

    Q: Can I fly while waiting for my ARC renewal appointment?
    No. Once your ARC expires, the aircraft is not legally airworthy under EASA regulations. You cannot fly it—even to reposition for the review—until a new ARC is issued or the existing one is extended. Plan your renewal timing so you’re not grounded waiting for an available slot.

    Q: What if my ARC engineer finds a minor discrepancy during the review?
    Minor discrepancies don’t necessarily mean automatic refusal. If an issue can be quickly resolved (a missing signature, a minor paperwork correction), many engineers will allow you to fix it during the review process. However, airworthiness-affecting issues must be resolved before the ARC can be issued. The engineer cannot sign off on an aircraft that doesn’t meet requirements, regardless of how inconvenient the timing.

    Q: Do I need a new ARC if I change my aircraft’s registration to another EASA state?
    Generally, yes. When you transfer registration between EASA member states, the receiving state’s competent authority will require verification of airworthiness status. This typically involves a new airworthiness review and ARC issuance under the new state’s oversight. The specific process varies by NAA, so contact the receiving state’s authority early in your transfer planning.

    Tags: EASA airworthiness review certificate, ARC renewal, Part-ML, continuing airworthiness, aircraft maintenance programme, private owner maintenance, CAMO

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  • Owner Assisted Maintenance Under Part-ML: What Private Owners Can Actually Do

    Owner Assisted Maintenance Under Part-ML: What Private Owners Can Actually Do

    Owner Assisted Maintenance Under Part-ML: What Private Owners Can Actually Do

    Meta description: Owner assisted maintenance under Part-ML lets you work on your own aircraft legally. Here’s exactly what EASA allows and how to stay compliant.

    You bought an aircraft to fly it, not to watch it sit in a hangar waiting for an engineer’s schedule to clear. Part-ML opened real possibilities for private owners to perform certain maintenance tasks themselves—but the regulation is precise about what qualifies, who signs what off, and how you document it. Get this wrong and your aircraft’s airworthiness is compromised, not just on paper but potentially at your next ramp check. This guide covers exactly what owner assisted maintenance means under Part-ML, where the boundaries sit, and how to execute it without creating compliance headaches.

    What Part-ML Actually Says About Owner Assisted Maintenance

    Part-ML (Annex Vb to Regulation (EU) 2018/1139) governs continuing airworthiness for aircraft not used in commercial air transport. ML.A.803 specifically addresses pilot-owner maintenance, but the term “owner assisted maintenance” describes a related but distinct concept that trips up many owners.

    Pilot-owner maintenance under ML.A.803 allows the owner to perform limited maintenance tasks and release the aircraft to service themselves—no engineer required. Owner assisted maintenance is different: you’re working under the supervision of a licensed engineer who retains responsibility and ultimately releases the aircraft.

    The distinction matters for three reasons:

    1. Task scope. Pilot-owner maintenance is restricted to the task list in Appendix II to Part-ML. Owner assisted work, supervised by a certifying engineer, can extend beyond that list.

    2. Release authority. Under pilot-owner privileges, you sign the release. Under assisted maintenance, the supervising engineer signs.

    3. Record requirements. Both require documentation, but the chain of accountability differs.

    The regulation intentionally created flexibility here. EASA recognised that many private owners have genuine mechanical competence but lack formal licensing. Owner assisted maintenance provides a legal pathway to use that competence while maintaining the oversight structure that keeps aircraft safe.

    Which Tasks You Can Perform Yourself

    Appendix II to Part-ML lists the specific tasks a pilot-owner can perform independently without engineer supervision. These include:

    • Replacement of landing gear tyres, doors, seats, cowlings, and fairings
    • Simple fabric repairs not requiring rib stitching
    • Servicing of batteries, filters, and landing gear shock struts
    • Replacement of spark plugs, hoses, and elastic shock cords
    • Component replacements designed for rapid removal (safety wire, split pins, cotter keys)
    • Servicing operations such as lubrication, topping up fluids, and tyre pressure checks
    • Inspections and operational checks that don’t require disassembly beyond normal access covers

    These tasks share common characteristics: they’re maintenance items with established procedures, limited complexity, and low risk of consequential damage if performed incorrectly.

    For anything outside Appendix II, you have two options. First, you can simply hand the aircraft to a Part-145 organisation or independent certifying engineer and let them handle everything. Second—and this is where owner assisted maintenance becomes valuable—you can perform the work under an engineer’s direct supervision, with the engineer retaining release authority.

    The second option saves money without compromising airworthiness. You’re providing labour under expert oversight, reducing the engineer’s billable hours while they ensure the work meets standards.

    The Supervision Requirement: What “Assisted” Actually Means

    Owner assisted maintenance isn’t a loophole to perform major work and then ask an engineer to rubber-stamp it afterwards. The supervising engineer must be involved before, during, and after the work.

    Before the task: The engineer reviews the procedure, confirms the owner understands the steps, and ensures proper tooling and parts are available. This might happen in person or via detailed communication, depending on task complexity.

    During the task: The level of direct supervision varies. For straightforward work, the engineer might check in at key stages. For anything involving flight controls, engine internals, or structural components, expect continuous oversight.

    After the task: The engineer inspects the completed work, confirms compliance with the applicable maintenance data, and releases the aircraft. Their signature on the release confirms they accept responsibility for the work performed under their supervision.

    If an engineer is unwilling to supervise a particular task, that’s information worth respecting. Their licence is on the line. Push-back usually indicates either task complexity beyond reasonable assisted maintenance scope or concerns about the owner’s capability on that specific job.

    Some CAAs have issued additional guidance on supervision standards.

    Documentation Requirements You Cannot Skip

    Maintenance records under Part-ML aren’t optional paperwork—they’re the legal evidence that your aircraft is airworthy. ML.A.305 specifies what you must retain:

    Aircraft continuing airworthiness records must include the aircraft total time, current status of ADs, current inspection status, and details of modifications and repairs.

    Maintenance records must document the date, a description of the work, applicable maintenance data used, the person who performed the work, and the person who released it. For owner assisted maintenance, both names appear: yours as the person who did the work, the engineer’s as the person who supervised and released.

    The release to service entry must clearly state what was done, reference the applicable procedures or instructions, and confirm the aircraft is approved for return to service. ML.A.801 covers release requirements in detail.

    Sloppy records create real problems. A ramp inspection that finds maintenance entries without clear release authority can ground your aircraft on the spot. Worse, a maintenance-related incident with poor records history shifts liability in directions you don’t want.

    Keep your records current, organised, and accessible. If your system involves paper logbooks scattered across your hangar, office, and flight bag, you’re creating risk.

    Common Mistakes That Create Compliance Problems

    Having worked with owners navigating Part-ML, certain patterns emerge repeatedly:

    Performing tasks outside Appendix II and self-releasing. This is straightforward non-compliance. The task list exists for a reason. If the job isn’t listed, you don’t have pilot-owner release authority regardless of your skill level.

    Failing to use approved maintenance data. You can’t just watch a YouTube video and call it compliant. Maintenance must be performed in accordance with instructions from the type certificate holder, the aircraft manufacturer’s maintenance manual, or approved supplementary data. ML.A.302 is specific about data requirements.

    Incomplete record entries. “Changed oil” with a date and signature isn’t sufficient. The entry must reference the maintenance data used, oil type and quantity, and confirm return to service.

    Treating AMP optional items as truly optional. If your Aircraft Maintenance Programme includes a task, it’s not optional at that point—it’s your compliance schedule. You can propose AMP amendments through the proper process, but you can’t simply skip inconvenient tasks.

    Mixing up EASA and FAA standards. Owners with dual experience sometimes apply Part 91 Preventive Maintenance logic to Part-ML aircraft. The frameworks don’t align, and what’s legal under FAR 43 Appendix A doesn’t automatically transfer.

    Working With Engineers: Making Assisted Maintenance Practical

    Finding an engineer willing to supervise owner assisted maintenance requires trust in both directions. The engineer needs confidence that you’ll follow instructions, not cut corners, and accept their decision on what qualifies as owner-appropriate work.

    Build this relationship gradually. Start with straightforward Appendix II tasks performed independently, then discuss assisted work as they observe your competence. Many engineers prefer owners who ask questions over owners who assume.

    Agree on communication expectations upfront. Some engineers want photo documentation at each stage. Others prefer periodic check-ins. Clarify this before starting work, not after you’ve reassembled something incorrectly.

    Expect to pay for supervision time even when you’re doing the physical work. The engineer is reviewing procedures, monitoring your progress, and accepting liability for the release. That’s valuable, and pricing it appropriately keeps good engineers in the owner-assisted maintenance market.

    How Squawkd Helps

    Squawkd maintains your continuing airworthiness records in a format that satisfies ML.A.305 documentation requirements, tracking task status, inspection schedules, and release history. For co-ownership situations, it ensures every owner and any supervising engineers work from the same current maintenance status—eliminating the scattered logbook problem that creates compliance gaps.

    Frequently Asked Questions

    Can I change my aircraft’s brake pads under pilot-owner maintenance?
    Yes. Replacement of brake pads (including discs on certain types) appears in Appendix II to Part-ML as an approved pilot-owner task, provided you follow the aircraft maintenance manual procedures and document the work correctly.

    What happens if I perform a task outside the Appendix II list without engineer supervision?
    The release to service is invalid. Technically, your aircraft isn’t airworthy, regardless of whether the physical work was done correctly. A subsequent inspection revealing this creates immediate grounding and potential enforcement action.

    Does my engineer need to be physically present for all assisted maintenance?
    Part-ML doesn’t mandate continuous physical presence for every task, but the supervising engineer determines what level of oversight they require to accept release responsibility. For any work affecting flight safety systems, expect them on site.

    Tags: owner assisted maintenance, Part-ML, pilot-owner maintenance, EASA aircraft ownership, continuing airworthiness, ML.A.803, private aircraft maintenance