CAMO and Part-M: The Continuing Airworthiness Framework

01The regulation map

Continuing airworthiness in the European system is governed by Commission Regulation (EU) No 1321/2014, which recast and repealed Regulation (EC) No 2042/2003. It sits beneath the Basic Regulation, Regulation (EU) 2018/1139, and alongside the initial-airworthiness regulation, Regulation (EU) No 748/2012 (Part-21).

Almost all practical confusion in this area comes from not knowing which Annex you are in. There are eight, and they are not intuitively named.

Part-ML, Part-CAMO and Part-CAO were inserted into 1321/2014 by Commission Implementing Regulation (EU) 2019/1383, applicable from 24 March 2020, with transitional arrangements set by Regulation (EU) 2020/270. Part-T pre-existed them, having been inserted by Regulation (EU) 2015/1536. The practical end of the transition — after which there should be no remaining Part-M Subpart F or Subpart G organisations — is 24 March 2022 per EASA’s own transition guidance.

02Which regime applies to your aircraft

The applicability test is set by Article 3 of the Regulation, not by the Annexes themselves — which is why reading Part-ML to find out whether Part-ML applies to you does not work.

The Part-ML thresholds, from Article 3(2): aeroplanes of 2,730 kg MTOM or less; helicopters of 1,200 kg MTOM or less certified for a maximum of four occupants; other ELA2 aircraft; and non-conventional aircraft within stated mass limits. Note that neither “complex motor-powered aircraft” nor “ELA2” is defined in 1321/2014 — CMPA is defined in Regulation (EU) 2018/1139 and ELA2 in the Part-21 framework under Regulation (EU) No 748/2012. Check both definitions at source before applying a borderline case.

03Who is responsible

M.A.201 allocates responsibility, and the allocation is more nuanced than “the CAMO does it”.

The owner is responsible for the continuing airworthiness of the aircraft and must ensure no flight takes place unless: the aircraft is maintained in an airworthy condition; any operational and emergency equipment fitted is correctly installed and serviceable, or clearly identified as unserviceable; the airworthiness certificate is valid; and maintenance is performed in accordance with the AMP under M.A.302.

Where the aircraft is leased, those responsibilities transfer to the lessee if the lessee is stipulated on the registration document, or as detailed in the leasing contract. This is a sentence worth reading twice if you are on either side of a lease — the drafting of the contract determines who carries the regulatory obligation, not merely the commercial risk.

Beyond that, the allocation depends on what the aircraft is and what it is used for:

Two further allocations are easy to miss. Any person or organisation performing maintenance is responsible for the tasks performed — responsibility for the work does not migrate to the CAMO. And the pre-flight inspection is the responsibility of the pilot-in-command, or of the operator in the case of a licensed air carrier.

04Part-CAMO and what actually changed

Part-CAMO is the standalone approval regime for a Continuing Airworthiness Management Organisation. It replaced the CAMO regime previously located in Part-M Subpart G (M.A.701 to M.A.716).

EASA’s own characterisation of the difference is admirably brief:

Compared with a Part-M Subpart G organisation, the main difference is the introduction of SMS principles.

That single change has substantial practical consequences. CAMO.A.200 requires a management system comprising:

1. Clearly defined lines of responsibility and accountability, including direct safety accountability of the accountable manager.
2. A safety policy describing the organisation’s overall philosophies and principles with regard to safety.
3. Hazard identification, risk evaluation and management of the associated risks, including mitigation and verification of effectiveness.
4. Maintaining personnel trained and competent to perform their tasks.
5. Documentation of all key management-system processes, including personnel awareness and the amendment procedure.
6. A compliance monitoring function, including a feedback system of findings to the accountable manager.

The system must be commensurate with the size of the organisation and the complexity of its activities — a small CAMO is not expected to replicate an airline’s safety department, but it cannot omit the elements.

Alongside the management system, CAMO.A.202 requires an internal safety reporting scheme, and the Part carries the usual provisions on contracting and subcontracting, facilities, record-keeping, occurrence reporting and immediate reaction to a safety problem.

05The four key people

CAMO.A.305 sets the personnel requirements. Four roles carry named regulatory weight, and all nominated persons must have relevant knowledge, background and satisfactory experience in continuing airworthiness management, with direct access to the accountable manager.

A fifth category is not a post-holder but is regulated separately: airworthiness review staff, whose qualifications are set by CAMO.A.310. Only appropriately qualified airworthiness review staff within an organisation holding the airworthiness review privilege may perform reviews and issue or extend an ARC.

06The CAME

The Continuing Airworthiness Management Exposition, required by CAMO.A.300, is the organisation’s controlling document: the description of how it does what it is approved to do. It is not a compliance formality. In practice the CAME determines three things that matter operationally.

• What the organisation may actually do. Privileges exercised outside the exposition are findings, however competent the person exercising them.
• Whether indirect approval of AMP amendments is available. Under M.A.302(c), where a CAMO or CAO manages the aircraft, the AMP and its amendments may be approved through an indirect approval procedure established in the CAME. Without that procedure documented, every amendment goes back to the authority.
• How records are controlled. The exposition carries the record-keeping procedures that M.A.305 obliges the owner or operator to have in a form acceptable to the competent authority.

07The continuing airworthiness tasks

M.A.301 defines what continuing airworthiness management actually consists of. It is a short list and worth knowing verbatim in substance, because it is the checklist an auditor works from:

• Accomplishment of pre-flight inspections.
• Rectification of defects and damage affecting safe operation, taking account of the MEL and configuration deviation list where they exist.
• Accomplishment of all maintenance in accordance with the AMP.
• Release of all maintenance in accordance with Subpart H.
• For complex motor-powered aircraft or aircraft used by licensed air carriers, analysis of the effectiveness of the approved AMP.
• Accomplishment of any applicable airworthiness directive, operational directive with a continuing airworthiness impact, continuing airworthiness requirement established by the Agency, and measures required by the competent authority in immediate reaction to a safety problem.
• Accomplishment of modifications and repairs in accordance with M.A.304.
• Delivering the mass and balance statement reflecting the current configuration to the pilot-in-command or operator.
• Maintenance check flights, when necessary.

The AD obligation is set out separately in M.A.303, in one sentence: any applicable airworthiness directive must be carried out within the requirements of that directive, unless otherwise specified by the Agency. Our airworthiness directives guide covers how applicability is determined and how compliance times work.

Two neighbouring points complete the picture. M.A.305 requires the aircraft continuing airworthiness record system, with retention periods covered in our technical records guide. M.A.306 requires an operator’s technical log system for commercial air transport, commercial specialised operations and commercial ATO/DTO operations — carrying flight information, the current certificate of release to service, the current maintenance statement showing what is next due, and all outstanding deferred defect rectifications. The initial issue of the technical log system, and each subsequent amendment, must be approved by the competent authority.

08The Airworthiness Review Certificate

The ARC is the periodic confirmation that an aircraft’s continuing airworthiness is under control — the recurring counterpart to the certificate of airworthiness, which does not itself expire.

Controlled environment

An aircraft is in a controlled environment where, over the previous 12 months, it has been continuously managed by a single CAMO or CAO, and maintained by organisations approved under Part-145, Part-M Subpart F or Part-CAO. Both limbs must hold.

Who may issue

The competent authority may additionally issue an ARC at the owner’s request, and may revoke one where circumstances reveal a safety threat. M.A.902 separately governs the circumstances in which an ARC becomes invalid.

09Part-ML, Part-CAO and Part-T in brief

Part-ML — proportionate rules for light aircraft

Part-ML is not simply a shorter Part-M. It changes the mechanism in several places:

• Owner-declared maintenance programme. Under ML.A.302 the AMP need not be approved by the competent authority; the owner may declare it, signing a statement accepting full responsibility for its content and for any deviation from design-holder recommendations.
• Minimum Inspection Programme (MIP) as a fallback: annual or 100-hour inspection, whichever comes first, with a one-month or ten-hour tolerance for aeroplanes, covering servicing, structural inspection, pitot-static and transponder functional checks and engine operational checks.
• Wider ARC issue — by an approved maintenance organisation in conjunction with the annual or 100-hour inspection, and by independent Part-66 certifying staff.
• Pilot-owner maintenance under ML.A.803, broadened for non-commercial operations, with the pilot-owner able to issue the CRS for limited tasks.

Part-CAO — one approval, both functions

A Combined Airworthiness Organisation may perform CAMO activities, maintenance organisation activities, or both — but only for aircraft that are not complex motor-powered and not used by a licensed air carrier. It is the single successor to the old Part-M Subpart F maintenance organisation and, for the light sector, Subpart G. The certificate is EASA Form 3-CAO, against Form 14 for a CAMO.

Scope limits apply: aeroplanes above 2,730 kg and helicopters above 1,200 kg (or certified for more than four occupants) require type-specific approval, and a single-person CAO cannot hold privileges for turbine aeroplanes, turbine helicopters, or multi-piston helicopters.

Part-T — third-country registered aircraft

Part-T applies where an EU licensed air carrier dry leases in an aircraft registered in a third country whose regulatory safety oversight has not been delegated to a Member State. The dividing line is precisely whether an ICAO Article 83 bis transfer has taken place:

• No 83 bis transfer → Part-T. The State of Registry retains the airworthiness functions, and Part-T obliges the EU operator to ensure the aircraft is maintained to that State’s requirements, with AD compliance, defect rectification, CRS documentation, pre-flight inspection and record-keeping.
• 83 bis transfer into the EU → the aircraft comes inside the full Part-M or Part-ML regime, not Part-T.

Article 83 bis is covered in more depth in our lease transitions guide.

10The FAA comparison

The FAA does not have a CAMO. Continuing airworthiness responsibility is structured differently, and mapping one system onto the other term-by-term produces errors.

The FAA also offers a progressive inspection route under 91.409(d), requiring supervision by an A&P holding an Inspection Authorization, a repair station or the manufacturer, a current inspection procedures manual, adequate housing and equipment, and current technical data — with a complete inspection of the aircraft within each 12 calendar months.

11Key terms

12Frequently asked questions