ML.A.201 Responsibilities

Annex Vb (Part-ML) · Regulation (EU) No 1321/2014 · EAR revision 2 Sep 2025

IRImplementing rule

ML.A.201Responsibilities

(a)The owner of the aircraft shall be responsible for the continuing airworthiness of the aircraft and shall ensure that no flight takes place unless all of the following requirements are met:

(1)the aircraft is maintained in an airworthy condition;

(2)any operational and emergency equipment fitted is correctly installed and serviceable or clearly identified as unserviceable;

(3)the airworthiness certificate is valid;

(4)the maintenance of the aircraft is performed in accordance with the Aircraft Maintenance Program (‘AMP’) specified in point ML.A.302.

(b)By derogation from point (a), where the aircraft is leased, the responsibilities set out in point (a) shall apply to the lessee, if the lessee is identified either in the registration document of the aircraft or in the leasing contract.

(c)Any person or organisation performing maintenance of aircraft and components shall be responsible for the maintenance tasks being performed.

(d)The pilot-in-command of the aircraft shall be responsible for the satisfactory accomplishment of the preflight inspection. That inspection shall be carried out by the pilot or another qualified person but need not be carried out by an approved maintenance organisation or by certifying staff.

(e)For aircraft operated by commercial Approved Training Organisations (‘ATO’) and commercial Declared Training Organisations (‘DTO’) referred to in Article 10a of Regulation (EU) No 1178/2011 or not operated in accordance with Annex VII to Regulation (EU) No 965/2012 (Part-NCO) or operated in accordance with Subpart-ADD of Annex II (Part-BOP) to Regulation (EU) 2018/395 or Subpart-DEC of Annex II (Part-SAO) to Regulation (EU) 2018/1976, the operator shall:

(1)be approved as a CAMO or as a CAO for the management of the continuing airworthiness of its aircraft in accordance with Annex Vc (Part-CAMO), Subpart G of Annex I (Part-M) or Annex Vd (Part-CAO), or contract such an organisation using the contract set out in Appendix I to this Annex;

(2)ensure that all maintenance is performed by maintenance organisations approved in accordance with point (c)(2) of point ML.1.;

(3)ensure that the requirements of point (a) are satisfied.

(f)For aircraft not included in point (e), in order to satisfy the requirements of point (a), the owner of the aircraft may contract the tasks associated with continuing airworthiness management to an organisation approved as a CAMO or CAO in accordance with Annex Vc (Part-CAMO), Subpart G of Annex I (Part-M) or Annex Vd (Part-CAO). In that case, the contracted organisation shall assume responsibility for the proper performance of those tasks and a written contract shall be concluded in accordance with Appendix I to this Annex. If the owner does not contract such an organisation, the owner is responsible for the proper performance of the tasks associated with the continuing airworthiness management

(g)The owner shall grant the competent authority access to the aircraft and the aircraft records, in order for the competent authority to determine whether the aircraft complies with the requirements of this Annex.

(h)In the case of an aircraft included in an air operator certificate is used for non-commercial or specialised operations under point ORO.GEN.310 of Annex III or point NCO.GEN.104 of Annex VII to Regulation (EU) No 965/2012, the operator shall ensure that the tasks associated with continuing airworthiness are performed by the CAMO approved in accordance with Annex Vc (Part-CAMO) or Subpart G of Annex I (Part-M) or the combined airworthiness organisation (“CAO”) approved in accordance with Annex Vd (Part-CAO), whichever applicable, of the air operator certificate holder.

IR · ML.A.201 — Regulation (EU) No 1321/2014 · Regulation (EU) 2020/270 · Continuing Airworthiness Easy Access Rules · EAR revision 2 Sep 2025

GMGuidance material

GM1 ML.A.201Responsibilities

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The following tables provide a summary of Part-ML main provisions and alleviations established in ML.A.201, ML.A.302, ML.A.801 and ML.A.901. In the tables, the term ‘CAO(-CAM)’ designate a CAO with continuing airworthiness management privileges.

	Balloon
	Part-BOP Subpart ADD	Part-BOP non-Subpart ADD
	Part-BOP Subpart ADD	commercial ATO/DTO	Non-ATO/DTO or non-commercial ATO/DTO
Contract with CAMO/CAO (CAM) required?	yes	yes	no*
Aircraft maintenance programme (AMP)	The AMP document must be approved by the contracted CAMO/CAO(-CAM)		If there is no CAMO/CAO(-CAM), the AMP must be declared by the owner.
			If there is a contracted CAMO/CAO(-CAM), the AMP must be approved by the CAMO/CAO(-CAM).
	If ML.A.302(e) conditions are met, producing an AMP document is not required.
Maintenance	By a maintenance organisation		By a maintenance organisation or by independent certifying staff or the pilot-owner**
Airworthiness review (AR) and airworthiness review certificate (ARC)	By a maintenance organisation*** or by the contracted CAMO/CAO(-CAM) or by the competent authority		By a maintenance organisation* or independent certifying staff* or by the CAMO/CAO(-CAM) (if contracted) or by the competent authority

	Sailplane
	Part-SAO Subpart-DEC	Part-SAO non-Subpart-DEC
	Part-SAO Subpart-DEC	commercial ATO/DTO	Non-ATO/DTO or non-commercial ATO/DTO
Contract with CAMO/CAO (-CAM) required?	yes	yes	no*
AMP	The AMP document must be approved by the contracted CAMO/CAO(-CAM).		If there is no CAMO/CAO(-CAM), the AMP must be declared by the owner.
			If there is a contracted CAMO/CAO(-CAM), the AMP must be approved by the CAMO/CAO(-CAM).
	If ML.A.302(e) conditions are met, producing an AMP document is not required.
Maintenance	By a maintenance organisation		By a maintenance organisation or by independent certifying staff or pilot-owner**
AR and ARC	By a maintenance organisation*** or by the contracted CAMO/CAO(-CAM) or by the competent authority		By a maintenance organisation* or independent certifying staff* or by the CAMO/CAO(-CAM) (if contracted) or by the competent authority

	Aircraft (other than balloons and sailplanes)
	non Part-NCO	Part-NCO
	non Part-NCO	commercial ATO/DTO	Non-ATO/DTO or non-commercial ATO/DTO
Contract with CAMO/CAO (-CAM) required?	yes	yes	no*
AMP	The AMP document must be approved by the contracted CAMO/CAO(-CAM).		If there is no CAMO/CAO(-CAM), the AMP must be declared by the owner.
			If there is a contracted CAMO/CAO(-CAM), the AMP must be approved by the CAMO/CAO(-CAM).
	If ML.A.302(e) conditions are met, producing an AMP document is not required.
Maintenance	By a maintenance organisation		By a maintenance organisation or by independent certifying staff or the pilot-owner**
AR and ARC	By a maintenance organisation*** or by the contracted CAMO/CAO(-CAM) or by the competent authority		By a maintenance organisation* or independent certifying staff* or by the CAMO/CAO(-CAM) (if contracted) or by the competent authority

*: A CAMO/CAO(-CAM) is not required but the owner may decide to contract a CAMO/CAO(-CAM). **: in the limit of their privileges ***: together with the 100-h/annual inspection

GM · GM1 ML.A.201 — Regulation (EU) No 1321/2014 · ED Decision 2020/002/R · Continuing Airworthiness Easy Access Rules · EAR revision 2 Sep 2025

GMGuidance material

GM1 ML.A.201(e)Responsibilities

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COMMERCIAL ATO/DTO According to industry practice, the following are examples of aircraft not considered to be operated by a commercial ATO or a commercial DTO:

(a)Aircraft operated by an organisation holding an ATO certificate or a DTO declaration, created with the aim of promoting aerial sport or leisure aviation, on the conditions that:

(1)the aircraft is operated by the organisation on the basis of ownership or dry lease;

(2)the ATO/DTO is a non-profit organisation; and

(3)whenever non-members of the organisation are involved, such flights represent only a marginal activity of the organisation.

(b)Aircraft operated under Part-NCO by its owner together with an ATO or a DTO flight instructor for the purpose of training, when the contract between the owner and the training organisation and the procedures of the training organisation allow it. The continuing airworthiness of such aircraft remains under the responsibility of the owner, or of the CAMO or CAO contracted by the owner, if the owner has elected to contract a CAMO or CAO in accordance with ML.A.201(f).

(c)Aircraft used for very limited training flights due to the specific configuration of the aircraft and limited need for such flights.

GM · GM1 ML.A.201(e) — Regulation (EU) No 1321/2014 · ED Decision 2020/002/R · Continuing Airworthiness Easy Access Rules · EAR revision 2 Sep 2025

GMGuidance material

GM1 ML.A.201(f)Responsibilities

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If an owner (see definition in point ML.1(c)(3)) decides not to make a contract with a CAMO or CAO, the owner is fully responsible for the proper accomplishment of the corresponding continuing airworthiness management tasks. As a consequence, it is expected that the owner properly and realistically self-assesses his or her own competence to accomplish those tasks or otherwise seek the necessary expertise.

GM · GM1 ML.A.201(f) — Regulation (EU) No 1321/2014 · ED Decision 2020/002/R · Continuing Airworthiness Easy Access Rules · EAR revision 2 Sep 2025

GMGuidance material

GM1 ML.A.201(h)Responsibilities

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USE OF AIRCRAFT INCLUDED IN AN AOC FOR NON-COMMERCIAL OPERATIONS OR SPECIALISED OPERATIONS As point (h) is not a derogation, points ML.A.201(e) and (f) are still applicable. Therefore, the management of continuing airworthiness of the aircraft by the CAMO or CAO of the AOC holder means that the other operator has established a written contract as per Appendix I to Part-ML with this CAMO or CAO.

GM · GM1 ML.A.201(h) — Regulation (EU) No 1321/2014 · ED Decision 2020/002/R · Continuing Airworthiness Easy Access Rules · EAR revision 2 Sep 2025

All rules in SECTION A — TECHNICAL REQUIREMENTS

Consolidated from the EASA Easy Access Rules (revision 2 Sep 2025, extracted 17 Aug 2026) for convenience. Not the official publication — verify against the Official Journal of the European Union and the EASA publications before operational use.

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