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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