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Part-M: Release to Service and Records

EASA Part-M maintenance and its evidence: current maintenance data, the certificate of release to service (M.A.801), airworthiness directives and records.

Dionysis Kefalas11 min readFor CAMO and Part-145 staff

Part 6 of 8 in EASA Continuing Airworthiness Show parts
  1. 1Continuing Airworthiness: Part-M and Part-CAMO
  2. 2Aircraft Maintenance Programme under Part-M
  3. 3EASA Reliability Programmes and Monitoring
  4. 4Airworthiness Reviews and the ARC
  5. 5CAMO and CAO Continuing Airworthiness Bodies
  6. 6Part-M: Release to Service and Records
  7. 7EASA Airworthiness Directives: AD Compliance Explained
  8. 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

Doing the work and proving it

Continuing airworthiness shows up on the aircraft and in the file. This guide covers the maintenance data the work is performed against, the certificate of release to service, and the records that keep the evidence. The airworthiness review is where that file is read. This page is the work and the paper it leaves.

Working from the current book

The data on the bench is either current, or the job is the wrong job. M.A.401 is that line.

M.A.401 (full rule text)Maintenance data

(a)The person or organisation maintaining an aircraft shall have access to and use only applicable current maintenance data in the performance of maintenance including modifications and repairs.

(b)For the purposes of this Annex, applicable maintenance data is any of the following:

(1)any applicable requirement, procedure, standard or information issued by the competent authority or the Agency;

(2)any applicable airworthiness directive;

(3)the applicable instructions for continuing airworthiness and other maintenance instructions, issued by the type-certificate holder, supplemental type-certificate holder, a declarant of a declaration of design compliance and any other organisation that publishes such data in accordance with Annex I (Part 21) or, as applicable, Annex Ib (Part 21 Light) to Regulation (EU) No 748/2012;

(4)for components approved for installation by the design approval holder or declarant of a declaration of design compliance, the applicable maintenance instructions published by the component manufacturers and acceptable to the design approval holder or declarant of a declaration of design compliance;

(5)any applicable data issued in accordance with point 145.A.45(d).

[…]

Quoted word for word from Regulation (EU) No 1321/2014, Easy Access Rules for Continuing Airworthiness, 2 Sep 2025 revision.

Point (a) is access, and use, of current data only. That includes modifications and repairs. Point (b) is what counts. An airworthiness directive is item (2). A revision that is no longer current is not data you can work to.

How the work is performed, outside a Part-145 organisation, is M.A.402.

M.A.402 (full rule text)Performance of maintenance

Except for maintenance performed by a maintenance organisation approved in accordance with Annex II (Part-145), any person or organisation performing maintenance shall:

(a)be qualified for the tasks performed, as required by this part;

(b)ensure that the area in which maintenance is carried out is well organised and clean in respect of dirt and contamination;

(c)use the methods, techniques, standards and instructions specified in the M.A.401 maintenance data;

(d)use the tools, equipment and material specified in the M.A.401 maintenance data. If necessary, tools and equipment shall be controlled and calibrated to an officially recognised standard;

(e)ensure that maintenance is performed within any environmental limitations specified in the M.A.401 maintenance data;

(f)ensure that proper facilities are used in case of inclement weather or lengthy maintenance;

(g)ensure that the risk of multiple errors during maintenance and the risk of errors being repeated in identical maintenance tasks are minimised;

(h)ensure that an error capturing method is implemented after the performance of any critical maintenance task; and

(i)carry out a general verification after completion of maintenance to ensure the aircraft or component is clear of all tools, equipment and any extraneous parts or material, and that all access panels removed have been refitted.

Quoted word for word from Regulation (EU) No 1321/2014, Easy Access Rules for Continuing Airworthiness, 2 Sep 2025 revision.

Part-145 maintenance sits outside this point. Everyone else works the list. Method, tools and environment come from the M.A.401 data: (c), (d) and (e). After a critical task, (h) is the error capture. Before the aircraft is left, (i) is tools, extraneous material, and the panels that were opened.

The certificate of release to service

The release is a certificate in the folder, not a verbal handover. Who signs it, and what it has to say, is M.A.801.

M.A.801 (full rule text)Aircraft certificate of release to service

(a)Except for aircraft released to service by a maintenance organisation approved in accordance with Annex II (Part-145), the CRS shall be issued in accordance with this Subpart.

(b)No aircraft shall be released to service unless a CRS is issued when all maintenance tasks ordered have been properly carried out. The CRS shall be issued by an authorised certifying staff of the maintenance organisation approved in accordance with Subpart F of this Annex or with Annex Vd (Part-CAO), except for maintenance tasks other than complex maintenance tasks listed in Appendix VII to this Annex where the CRS is issued, alternatively by:

1.independent certifying staff acting in accordance with the requirements laid down in Article 5 of this Regulation;

2.the pilot-owner acting in accordance with point M.A.803 of this Annex.

[…]

(e)A CRS shall contain at least:

1.basic details of the maintenance carried out;

2.the date on which the maintenance was completed;

3.the identity of the organisation or person issuing the CRS, including, alternatively:

(i)the approval reference of the maintenance organisation and the certifying staff issuing the CRS;

(ii)in the case referred to in point (b)(2), the identity and, where applicable, the licence number of the certifying staff issuing the CRS;

4.the limitations to airworthiness or operations, if any.

[…]

(g)A CRS shall not be issued in the case of any known non-compliance which endangers flight safety.

Quoted word for word from Regulation (EU) No 1321/2014, Easy Access Rules for Continuing Airworthiness, 2 Sep 2025 revision.

Point (a) leaves a Part-145 release outside this Subpart. Point (b) is who signs for the rest. Independent certifying staff and the pilot-owner are the alternatives at the end of (b), and only for the tasks that point allows. Read those limits before either of them signs. Point (e) is the minimum the certificate shows. Point (g) is the refusal: a known problem that endangers flight safety, and there is no certificate.

Airworthiness directives

An airworthiness directive is already on the data list, at item (2) of M.A.401. Carrying it out is M.A.303.

M.A.303 (full rule text)Airworthiness directives

Any applicable airworthiness directive must be carried out within the requirements of that airworthiness directive, unless otherwise specified by the Agency.

Quoted word for word from Regulation (EU) No 1321/2014, Easy Access Rules for Continuing Airworthiness, 2 Sep 2025 revision.

Follow the directive's own requirements. The only opening is where the Agency has specified otherwise. This point adds no second timetable.

AD status in the record system is item 1 of point (c) below. What the airworthiness review does with directives is in Airworthiness Reviews and the ARC. How to read a directive's compliance times, and what the AD status record should show, is in EASA Airworthiness Directives: AD Compliance Explained.

The record system

The certificate and the status have to be findable later. M.A.305 is the system that holds them.

M.A.305 (full rule text)Aircraft continuing airworthiness record system

(a)At the completion of any maintenance, aircraft certificate of release to service (‘CRS’) required by point M.A.801 or point 145.A.50, as applicable, shall be entered in the aircraft continuing airworthiness record system, as soon as practicable and no later than 30 days after the completion of any maintenance.

(b)The aircraft continuing airworthiness record system shall contain the following:

1.the date of the entry, the total in-service life accumulated in the applicable parameter for aircraft, engine(s) and/or propeller(s);

2.the aircraft continuing airworthiness records described in points (c) and (d) below together with the supporting detailed maintenance records described in point (e) below;

3.if required by point M.A.306, the aircraft technical log.

(c)The aircraft continuing airworthiness records shall include the current mass and balance report and the current status of:

1.ADs and measures mandated by the competent authority in immediate reaction to a safety problem;

2.modifications and repairs;

3.compliance with the AMP;

4.deferred maintenance tasks and deferred defects rectification.

(d)The aircraft continuing airworthiness records shall include the current status specific to components of:

1.life-limited parts, including the life accumulated by each affected part in relation to the applicable airworthiness limitation parameter; and

2.time-controlled components, including the life accumulated by the affected components in the applicable parameter, since the last accomplishment of scheduled maintenance, as specified in the AMP.

(e)The owner or operator shall establish a system to keep the following documents and data in a form acceptable to the competent authority and for the periods specified below:

1.aircraft technical log system: the technical log or other data equivalent in scope and detail, covering the 36 months period prior to the last entry,

2.the CRS and detailed maintenance records:

(i)demonstrating compliance with ADs and measures mandated by the competent authority in immediate reaction to a safety problem applicable to the aircraft, engine(s), propeller(s) and components fitted thereto, as appropriate, until such time as the information contained therein is superseded by new information equivalent in scope and detail but covering a period not shorter than 36 months;

(ii)demonstrating compliance with the applicable data in accordance with point M.A.304 for current modifications and repairs to the aircraft, engine(s), propeller(s) and any component subject to airworthiness limitations; and

(iii)of all scheduled maintenance or other maintenance required for continuing airworthiness of aircraft, engine(s), propeller(s), as appropriate, until such time as the information contained therein is superseded by new information equivalent in scope and detail but covering a period not shorter than 36 months.

3.data specific to certain components:

(i)an in-service history record for each life-limited part based on which the current status of compliance with airworthiness limitations is determined;

(ii)the CRS and detailed maintenance records for the last accomplishment of any scheduled maintenance and any subsequent unscheduled maintenance of all life-limited parts and time-controlled components until the scheduled maintenance has been superseded by another scheduled maintenance of equivalent scope and detail but covering a period not shorter than 36 months;

(iii)the CRS and owner’s acceptance statement for any component that is fitted to an ELA2 aircraft without an EASA Form 1 in accordance with point 21.A.307(b)(2) of Annex I (Part 21) to Regulation (EU) No 748/2012 but covering a period not shorter than 36 months;

(iv)the CRS and owner’s acceptance statement for any component that is fitted to an aircraft without an EASA Form 1 in accordance with point 21L.A.193(b)(2) of Annex Ib (Part 21 Light) to Regulation (EU) No 748/2012 but covering a period not shorter than 36 months.

4.Record-keeping periods when the aircraft is permanently withdrawn from service:

(i)the data required by point (b)(1) of point M.A.305 in respect of aircraft, engine(s), and propeller(s) which shall be retained for at least 12 months;

(ii)the last effective status and reports as identified under points (c) and (d) of point M.A.305 which shall be retained for at least 12 months; and

(iii)the most recent CRS(s) and detailed maintenance records as identified under points (e)(2)(ii) and (e)(3)(i) of point M.A.305 which shall be retained for at least 12 months.

[…]

Quoted word for word from Regulation (EU) No 1321/2014, Easy Access Rules for Continuing Airworthiness, 2 Sep 2025 revision.

Point (a) is the entry clock. Put the CRS in as soon as practicable, and no later than 30 days.

Point (c) is the status. Item 1 is the AD status. The other status lines sit beside it. Do not borrow a period from a neighbouring line when you file them.

Point (e) is not one retention rule. The technical log covers the 36 months before the last entry. Under item 2, the AD line and the scheduled-maintenance line stay until equivalent information covers a period not shorter than 36 months. The modifications and repairs line in that same item, the one that cites M.A.304, does not state 36 months. Item 3 states 36 months only on the lines that contain those words. The in-service history record for each life-limited part does not. After the aircraft is withdrawn, item 4 keeps the records it names for at least 12 months.

Where point (b) calls for it, the technical log is part of this system. M.A.306 says when.

M.A.306 (full rule text)Aircraft technical log system

(a)In addition to the requirements of point M.A.305, for CAT, commercial specialised operations and commercial ATO or commercial DTO operations, the operator shall use a technical log system containing the following information for each aircraft:

1.information about each flight, necessary to ensure continued flight safety, and;

2.the current aircraft certificate of release to service, and;

3.the current maintenance statement giving the aircraft maintenance status of what scheduled and out of phase maintenance is next due except that the competent authority may agree to the maintenance statement being kept elsewhere, and;

4.all outstanding deferred defects rectifications that affect the operation of the aircraft, and;

5.any necessary guidance instructions on maintenance support arrangements.

[…]

Quoted word for word from Regulation (EU) No 1321/2014, Easy Access Rules for Continuing Airworthiness, 2 Sep 2025 revision.

Point (a) names the operations. For those, the log is in use. It holds, for each aircraft, the flight information, the current CRS, the maintenance statement, the deferred defects and the support arrangements. Item 3 is the only line the authority may agree to keep somewhere else.

The rest of the series

This guide closes the loop the overview opened. The airworthiness review is covered in Airworthiness Reviews and the ARC. The organisation that manages the aircraft is the CAMO or CAO. On this page the data is current, the release is a CRS, and the CRS is in the record system. Two guides follow and go further into that record: the airworthiness directives guide and LLP Back-to-Birth Records and Component Tracking (M.A.305).

Where to read it yourself

The points quoted on this page are M.A.401, M.A.402, M.A.303, M.A.305, M.A.306 and M.A.801 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.