Airworthiness Reviews and the ARC
The Part-M airworthiness review and the ARC: Form 15b or a recommendation, validity and extension, and the documented review and physical survey.
Dionysis Kefalas11 min readFor CAMO and Part-145 staff
Part 4 of 8 in EASA Continuing Airworthiness Show parts
- 1Continuing Airworthiness: Part-M and Part-CAMO
- 2Aircraft Maintenance Programme under Part-M
- 3EASA Reliability Programmes and Monitoring
- 4Airworthiness Reviews and the ARC
- 5CAMO and CAO Continuing Airworthiness Bodies
- 6Part-M: Release to Service and Records
- 7EASA Airworthiness Directives: AD Compliance Explained
- 8LLP Back-to-Birth Records and Component Tracking (M.A.305)
Quotes checked on against EASA Easy Access Rules for Continuing Airworthiness (Regulation (EU) No 1321/2014) — 2 Sep 2025 revision.
On this page
The certificate in the aircraft file
The certificate in the aircraft file is the airworthiness review certificate. Some files hold a recommendation instead, and the certificate is not there yet. The maintenance programme is one of the records that review reads. This page is how that certificate is issued, how long it lasts, and what the reviewer has to see.
The review and the certificate
M.A.901 is the paperwork around the review. The review that keeps the airworthiness certificate valid is the one in M.A.903, in the section below.
(a)To ensure the validity of the airworthiness certificate, an aircraft shall periodically undergo an airworthiness review in accordance with point M.A.903.
(b)The satisfactory completion of an airworthiness review shall result in: (1) an airworthiness review certificate (ARC) issued in accordance with Appendix III (EASA Form 15b), if the following conditions are met: (i) the continuing airworthiness of the aircraft has been continuously managed in accordance with point M.A.201 of this Annex or point ML.A.201 of Annex Vb, as applicable, since the issue of the former ARC; (ii) the aircraft has been maintained in accordance with this Regulation, since the issue of the former ARC; (iii) the airworthiness certificate has been issued in accordance with Regulation (EU) No 748/2012 and is not revoked or surrendered at the time of the review; (2) a recommendation for the issuance of an ARC to the competent authority, if the conditions in point (1) are not met.
(c)An organisation approved to carry out airworthiness reviews in accordance with point CAMO.A.125(e) of Annex Vc (Part-CAMO) or point CAO.A.095(c)(1) of Annex Vd (Part-CAO) may carry out an airworthiness review of an aircraft included in its scope of work.
(d)When the airworthiness review is carried out by the organisation specified in point (c), the ARC or the recommendation shall be signed by the airworthiness review staff who carried out the airworthiness review.
(e)The person or organisation responsible for the continuing airworthiness of the aircraft in accordance with point M.A.201 shall, upon request and where necessary for those purposes, ensure that the organisation or the competent authority carrying out the airworthiness review or the assessment of an ARC recommendation: (1) has the required aircraft documentation and records; (2) has suitable accommodation at the appropriate location for its personnel; (3) has access to the aircraft; (4) has the assistance of appropriate certifying staff.
(f)By derogation from point M.A.902(a), the airworthiness review may be carried out 90 days or less before the expiry date of the ARC, without loss of continuity of the airworthiness review pattern.
(g)The airworthiness review shall not be subcontracted.
(h)An ARC shall not be issued if there is evidence or there are indications that the aircraft is not airworthy.
(i)A copy of any ARC issued or extended for an aircraft shall be sent to the competent authority of the Member State of registry of the aircraft concerned within 10 days of the issuance or extension.
(j)Without prejudice to point (b) of point M.B.901, for aircraft of 2 730 kg MTOM and below the competent authority may carry out the airworthiness review and issue an ARC itself, if requested by the owner.
(k)Upon surrender or revocation, the ARC shall be returned to the competent authority of the Member State of registry, when so requested by the respective authority.
Quoted word for word from Regulation (EU) No 1321/2014, Easy Access Rules for Continuing Airworthiness, 2 Sep 2025 revision.
Point (a) sends you to that later section. The rest of M.A.901 is what the organisation does with the result.
Point (b) is the fork. When (b)(1) is met, issue Form 15b. When it is not, send a recommendation and do not issue the certificate yourself.
The organisation in (c) may carry out the review, inside its scope. The person who did the work signs, under (d). When the reviewer asks for the file, a place to work, the aircraft, or certifying staff, (e) is the call on the person who manages the aircraft.
Point (f) is the diary: 90 days or less before the ARC expires, and the pattern of validity stays. Do not subcontract the review (g). Do not issue the certificate if the aircraft is not airworthy (h). The copy to the authority of registry goes within 10 days (i).
Point (j) is aircraft of 2 730 kg MTOM and below, and only if the owner asks the authority to do the review. Point (k) is handing the certificate back after surrender or revocation, when that authority asks.
How long the certificate lasts, and who may extend it
How long the certificate lasts, and who may sign another year onto it without a new review, is M.A.902.
(a)An ARC shall be valid for 1 year and its validity may be extended for another year for a maximum of two consecutive extensions. The extension of the validity of the ARC shall begin on: (1) the previous expiry date, if: (i) the extension is carried out within 30 days before the expiry date of the ARC; (ii) the extension is carried out after the expiry date of the ARC; (2) the date on which the extension is carried out, if it is carried out more than 30 days before the expiry date of the ARC.
(b)The ARC shall only be extended by the organisation managing the continuing airworthiness of the aircraft, subject to the following conditions: (1) the continuing airworthiness of the aircraft has been continuously managed by that organisation since the issue of the ARC; (2) the aircraft has been maintained since the issue of the ARC by a maintenance organisation approved in accordance with Annex II (Part-145) or Annex Vd (Part-CAO), as applicable; (3) the organisation managing the continuing airworthiness of the aircraft has no evidence or reason to believe that the aircraft is not airworthy. The maintenance referred to in the first paragraph, point (2), may include pilot-owner maintenance tasks carried out and released to service either by the pilot-owner or by independent certifying staff.
(c)An ARC shall become invalid if: (1) it is expired, suspended, surrendered or revoked; (2) the airworthiness certificate is suspended, surrendered or revoked.
(d)An aircraft shall not fly if the ARC is invalid or if the continuing airworthiness of the aircraft or any component installed on the aircraft does not meet the applicable requirements of this Annex.
Quoted word for word from Regulation (EU) No 1321/2014, Easy Access Rules for Continuing Airworthiness, 2 Sep 2025 revision.
The certificate runs for 1 year. The organisation that has managed the aircraft since it was issued may extend it, for a maximum of two consecutive extensions, and only when (b) is met. Pilot-owner maintenance can still sit inside the maintenance (b) is checking.
A records clerk meets the date rule in (a) like this. An extension within 30 days before expiry, or after expiry, starts on the old expiry date. An extension earlier than that starts on the day it is done, so the days between that day and the old expiry are given up.
Point (c) is when the certificate in the file has stopped counting. Point (d) is when the aircraft does not fly.
What the review has to establish
M.A.901 does not list the checks. The organisation does them under M.A.903.
(a)An airworthiness review is a process that comprises all the tasks and activities for evaluating the airworthiness status of an aircraft based on a documented review of the related aircraft continuing airworthiness records and a physical survey.
(b)Through the documented review of the aircraft, the airworthiness review staff shall be satisfied that: (1) the total in-service life accumulated in the applicable parameter of the aircraft, engine(s), propeller(s), life-limited parts and time-controlled components has been properly recorded; (2) the flight manual is applicable to the aircraft configuration and is kept up to date; (3) the maintenance due on the aircraft according to the AMP, as specified in point M.A.302, has been carried out; (4) known defects have been rectified or, when applicable, deferred in accordance with point M.A.403; (5) the applicable airworthiness directives and the measures mandated by the competent authority have been complied with and properly entered into the aircraft continuing airworthiness record system; (6) the modifications and repairs applied to the aircraft have been entered into the aircraft continuing airworthiness record system and comply with point M.A.304; (7) the life-limited parts and time-controlled components installed on the aircraft are properly identified, entered into the aircraft continuing airworthiness record system and have not exceeded their limitation; (8) if applicable, the current mass and balance statement reflects the current configuration of the aircraft and is valid; (9) the aircraft complies with the applicable type design; (10) if issued, the aircraft holds a valid airworthiness certificate in compliance with Section A, Subpart H, of Annex I (Part 21) or, as applicable, Section A, Subpart H, of Annex Ib (Part 21 Light) to Regulation (EU) No 748/2012; (11) if issued, the aircraft holds a valid noise certificate corresponding to the current configuration of the aircraft in compliance with Section A, Subpart I, of Annex I (Part 21) or, as applicable, Section A, Subpart I, of Annex Ib (Part 21 Light) to Regulation (EU) No 748/2012; (12) maintenance has been released in accordance with any of the following: (i) the applicable requirements of this Regulation, for the period during which the aircraft is within the scope of this Regulation; (ii) the appropriate airworthiness requirements of the State which was responsible for the oversight of the aircraft for the period during which the aircraft was not within the scope of this Regulation. If there is evidence or reason to believe that maintenance in the period referred to in the first paragraph, point (ii), has been inadequate, the airworthiness review staff shall ensure that appropriate actions are taken.
(c)Through the physical survey of the aircraft, the airworthiness review staff shall be satisfied that: (1) the required markings and placards are properly installed and meet the requirements set out in point 21.A.175 of Annex I (Part 21) or, as applicable, point 21L.A.144(a) of Annex Ib (Part 21 Light) to Regulation (EU) No 748/2012; (2) the aircraft complies with its approved flight manual; (3) the aircraft configuration complies with the documentation; (4) no evident defect can be found that has not been addressed in accordance with point M.A.403; (5) no inconsistencies can be found between the aircraft and the documented review of records as referred to in point (b).
(d)For the physical survey, airworthiness review staff not qualified as certifying staff on the specific aircraft subject to the airworthiness review shall be assisted by such qualified personnel.
(e)The airworthiness review shall be planned and carried out in such a manner that the time elapsed between the review of the aircraft continuing airworthiness records and their corresponding verification during physical survey shall be as short as possible.
(f)If for any reason an airworthiness review cannot be completed, the organisation carrying out the airworthiness review shall inform the competent authority of the Member State of registry as soon as possible.
(g)The ARC and the recommendation shall not be issued until all actions to eliminate the detected non-compliance have been implemented.
(h)The details and the outcome of an airworthiness review shall be recorded in an airworthiness review report.
Quoted word for word from Regulation (EU) No 1321/2014, Easy Access Rules for Continuing Airworthiness, 2 Sep 2025 revision.
Do both. Point (a) is a documented review of the records and a physical survey. One does not stand in for the other.
Use (b) and (c) as written. Do not turn them into a shorter list. Airworthiness directives are item (5) of the documented review.
Keep the survey close to the records review. That gap is (e). If the review cannot be finished, report it under (f) as soon as possible. That point sets no hour count.
Do not issue the ARC, or the recommendation, while a finding from the review is still open (g). Put the outcome in the airworthiness review report (h).
Airworthiness review staff
The person who signs has to be qualified for the role they are in. That is M.A.904.
(a)Airworthiness review staff acting on behalf of the competent authority shall be qualified in accordance with point M.B.901(c).
(b)Airworthiness review staff acting on behalf of an organisation referred to in Annex Vc (Part-CAMO) or Annex Vd (Part CAO) shall be qualified in accordance with Annex Vc (Part-CAMO) or Annex Vd (Part-CAO) respectively.
Quoted word for word from Regulation (EU) No 1321/2014, Easy Access Rules for Continuing Airworthiness, 2 Sep 2025 revision.
Staff acting for the authority follow (a). Staff acting for an organisation follow (b), under the annex that point names for them. Do not swap them.
Aircraft under Part-ML
Aircraft under Annex Vb (Part-ML) are reviewed under that annex. The points on this page are Annex I (Part-M).
Next
The maintenance, the release and the records the review reads are in Maintenance, Release to Service and Records. The organisation that may carry out the review is covered with the CAMO or CAO.
Where to read it yourself
The points quoted on this page are M.A.901, M.A.902, M.A.903 and M.A.904 of Annex I (Part-M) to Regulation (EU) No 1321/2014, consolidated with the AMC and GM in the EASA Easy Access Rules for Continuing Airworthiness, free to download. Every citation in this guide was checked against the 2025-09-02 revision.
Educational content, not regulatory compliance advice. Verify against the current regulation text before relying on it.
In this series
Related
- EASA Continuing Airworthiness Explained: Part-M, Part-CAMO and Who Keeps an Aircraft AirworthyGuide · 16 min
- The Aircraft Maintenance Programme (AMP) under Part-MGuide · 8 min
- Reliability Programmes and Reliability MonitoringGuide · 3 min
- The CAMO and CAO: Continuing Airworthiness Management OrganisationsGuide · 5 min
- Maintenance, Release to Service and Continuing-Airworthiness RecordsGuide · 11 min
Written by Dionysis Kefalas. Retired Hellenic Air Force Captain and founder of Avioverse. About the author
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