EASA PART-M CONTINUING AIRWORTHINESS · Aero Support Group FZCO · Updated 22 October 2026
Responsibilities under Part-M
Under M.A.201 the owner is responsible for the continuing airworthiness of an aircraft. For commercial air transport and other cases set out in the rule, the operator is responsible and must ensure that continuing airworthiness is managed by an approved CAMO. The continuing airworthiness tasks in M.A.301 include:
- pre-flight inspections and the rectification of defects;
- maintenance in accordance with the approved aircraft maintenance programme (M.A.302);
- compliance with airworthiness directives and operational directives;
- management of modifications and repairs;
- maintenance check flights where required.
Records required by M.A.305 must show the status of each of these tasks for the aircraft and its components.
Maintenance programme and airworthiness review
Aircraft maintenance programme (M.A.302). Each aircraft is maintained in accordance with a programme approved by the competent authority, or by the CAMO under an indirect approval procedure. It must be based on the type certificate holder’s instructions for continued airworthiness and reviewed when those instructions or the operation change.
Airworthiness review (M.A.901). The airworthiness review certificate is issued or extended after a review of the aircraft’s records and a physical survey. The review checks that the maintenance programme, ADs, modifications, repairs and life-limited components are all accounted for.
Where continuing airworthiness falls short
- The maintenance programme has not been revised after changes to the manufacturer’s data or the aircraft’s utilisation.
- AD compliance cannot be shown for every applicable directive and component.
- Records of modifications and repairs do not reference approved data.
- Deferred defects are not tracked to closure within their limits.
- Component records for life-limited parts are incomplete after a lease transition.
How ASG supports continuing airworthiness
- Gap analysis of continuing airworthiness arrangements against Part-M, Part-CAMO and the current AMC and GM.
- Aircraft maintenance programme reviews.
- Records audits covering AD status, modifications, repairs and life-limited components.
- Support for aircraft transitions between operators or registers.
- CAME and procedure development for CAMOs.
Conclusion
Continuing airworthiness is proved through records. When the maintenance programme, AD status and component history can be reconciled to the aircraft, airworthiness reviews and authority audits go smoothly. ASG helps organisations reach that point.
Frequently asked questions
The owner, or the operator in commercial air transport and other cases defined in M.A.201. For commercial operations the operator must use an approved CAMO.
Part-ML (Annex Vb) is a simplified set of continuing airworthiness rules for lighter aircraft not used in commercial air transport by licensed air carriers. Part-M applies to other aircraft.
The competent authority, or the CAMO under an indirect approval procedure approved by the authority.
A review of the aircraft’s records and a physical survey, checking that the maintenance programme, ADs, modifications, repairs and life-limited components are accounted for.
Yes. Regulation (EU) 2026/100, applicable from 7 August 2026, amended Part-M, Part-ML, Part-CAMO and Part-CAO.
Key takeaways
- Part-M is Annex I to Regulation (EU) No 1321/2014
- M.A.301 lists the continuing airworthiness tasks
- Aircraft are maintained to an approved maintenance programme (M.A.302)
- Commercial operators must use an approved CAMO
- Regulation (EU) 2026/100 amended Part-M from August 2026
Need a continuing airworthiness review?
Tell us your fleet and arrangements. ASG will review your continuing airworthiness against Part-M and Part-CAMO.
Aero Support Group (ASG) is an aviation safety, quality and compliance consultancy with offices in Dubai and Istanbul and a branch office in London. It prepares airlines, MROs, ground handlers, airports and civil aviation authorities for IOSA and ISAGO audits, EASA and UK CAA Third Country Operator (TCO) authorisation, EASA and FAA Part-145 approval, and ICAO USOAP audits.
Its work also covers Part-CAMO, Part-M and Part-147, Part-IS information security, SMS, QMS and SeMS development, gap analyses, mock audits and corrective action plans, operations manuals and MOEs, emergency response and business continuity planning, DAQCP, IFQP, JIG and IDQP inspection preparation, ACC3, RA3 and KC3 cargo security validation, CEIV Pharma, and SAF and CORSIA compliance.
ASG has completed 1,000+ projects at 500+ airports in 100+ countries. Its consultants have also served as subject matter experts, auditors and advisors for ICAO, IATA Consulting, IATA audit pools (IOSA, ISAGO, IDQP, IFQP), PRISM, ARGUS International and RSM.