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21.A.15 Application

Annex I · Regulation (EU) No 748/2012 · EAR revision 27 Nov 2025

IRImplementing rule

21.A.15Application

(a)An application for a type-certificate or restricted type-certificate shall be made in a form and manner established by the Agency.

(b)An application for a type-certificate or restricted type-certificate shall include, as a minimum, preliminary descriptive data of the product, the UAS or the CMU, and the kind of operations for which certification is requested. In addition, it shall include, or be supplemented after the initial application by, a certification programme for the demonstration of compliance in accordance with point 21.A.20, consisting of all of the following:

1.a detailed description of the type design, including all the configurations to be certified;

2.the proposed operating characteristics and limitations;

3.the intended use of the product, the UAS or the CMU, and the kind of operations for which certification is requested;

4.a proposal for the initial type-certification basis, operational suitability data certification basis and environmental protection requirements, prepared in accordance with the requirements and options specified in points 21.B.80, 21.B.82 and 21.B.85;

5.a proposal for a breakdown of the certification programme into meaningful groups of compliance demonstration activities and data, including a proposal for the means of compliance and related compliance documents;

6.a proposal for the assessment of the meaningful groups of compliance demonstration activities and data, addressing the likelihood of an unidentified non-compliance with the type-certification basis, operational suitability data certification basis or environmental protection requirements and the potential impact of that non-compliance on the product or UAS safety or environmental compatibility or on the safety of the CMU. The proposed assessment shall take into account at least the elements set out in points 1 to 4 of point 21.B.100(a). Based on that assessment, the application shall include a proposal for the Agency’s involvement in the verification of the compliance demonstration activities and data;

7.a project schedule including major milestones.

(c)After its initial submission to the Agency, the certification programme shall be updated by the applicant when there are changes to the certification project affecting any of the points 1 to 7 of point (b).

(d)An application for a type-certificate or restricted type-certificate for an aircraft shall include, or be supplemented after the initial application by, an application supplement for approval of the operational suitability data.

(e)An application for a type-certificate or restricted type-certificate for a large aeroplane or a large rotorcraft shall be valid for 5 years and an application for any other type-certificate or restricted type-certificate shall be valid for 3 years, unless the applicant demonstrates at the time of application that its product, UAS or CMU requires a longer period of time to demonstrate and declare compliance and the Agency agrees to that longer period of time.

(f)In the case where a type-certificate or restricted type-certificate has not been issued, or it is evident that it will not be issued, within the time limit provided for in point (e), the applicant may:

1.submit a new application and comply with the type-certification basis, operational suitability data certification basis and environmental protection requirements, as established and notified by the Agency in accordance with points 21.B.80, 21.B.82 and 21.B.85 for the date of the new application; or

2.apply for an extension of the time period provided for in point (e) and propose a new date for the issuance of the type-certificate or restricted type-certificate. In that case, the applicant shall comply with the type-certification basis, operational suitability data certification basis and environmental protection requirements, as established and notified by the Agency in accordance with point 21.B.80, 21.B.82 and 21.B.85 for a date to be selected by the applicant. However, that date shall not precede the new date proposed by the applicant for the issuance of the type-certificate or restricted type-certificate by more than five years for an application for a type-certificate or restricted type-certificate for a large aeroplane or a large rotorcraft, and by more than three years for an application for any other type-certificate or restricted type certificate.

IR · 21.A.15 — Regulation (EU) No 748/2012 · Regulation (EU) 2025/1065 · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

AMCAcceptable means of compliance

AMC 21.A.15(a)Form and manner

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The applicant should file an application using the web-based ‘EASA Applicant Portal’ or the application form for a type certificate or restricted type certificate (FO.CERT.00030), which may be downloaded from the EASA website. The form should be completed in accordance with the instructions embedded at the bottom of the application form, and sent to EASA by fax, email or regular mail following the information provided on the EASA website.

AMC · AMC 21.A.15(a) — Regulation (EU) No 748/2012 · ED Decision 2019/018/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

AMCAcceptable means of compliance

AMC 21.A.15(b)Content of the certification programme

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The certification programme is a document that allows the applicant and EASA to manage and control the evolving product type design or OSD, as well as the process of compliance demonstration by the applicant and its verification by EASA when required. The certification programme may be based on modules that may be updated independently. The level of detail in the certification programme depends on the complexity of the product and its intended use. In particular, the following information should typically be expected: General Identification of the relevant personnel who make decisions affecting airworthiness, operational suitability and environmental protection, and who will interface with EASA, unless otherwise identified to EASA (e.g. within the DOA procedures). A project schedule including major milestones. Subcontracting arrangements for design, operational suitability, environmental protection and/or production as well as design organisation approval (DOA) responsibility sharing. 21.A.15(b)(1) ‘a detailed description of the type design, including all the configurations to be certified’ An overview of the: architecture, functions, systems; dimensions, design weights, payloads, design speeds; engines and power/thrust rating; materials and technologies; maximum passenger seating capacity, minimum flight and cabin crew; cabin configuration aspects; options (e.g. weight variants, power/thrust rating variants, optional avionics equipment items, auxiliary power unit (APU) choices, brake options, tire options, floats, skids); noise/emissions level; and other items, if considered to be more appropriate, that address the specific aeronautical product. 21.A.15(b)(2) ‘proposed operating characteristics and limitations’ Operating speed limitations. Service ceiling, maximum airfield elevation. Cabin pressure. Limit load factors. Number of passengers, minimum crew, payload, range. Weight and centre-of-gravity (CG) envelope and fuel loading. Performance. Environmental envelope. Runway surface conditions. Other items, if considered to be more appropriate, that address the specific aeronautical product. 21.A.15(b)(3) ‘the intended use of the product and the kind of operations for which certification is requested’ Category A or B (relevant for CS-27 and CS-29), ditching, take-off and landing on water, emergency floatation equipment. Extended overwater operation, high-altitude operation (above 41 000 ft). High-airfield operation, steep approach, short take-off and landing, extended-range twin-engine operations (ETOPS), all-weather operations (AWO), visual flight rules (VFR)/instrument flight rules (IFR), reduced vertical separation minimum (RVSM), required navigation performance (RNP) type, increased bank angles, single-pilot operation, flight into known icing conditions. Flight in ice crystal icing. Engine operations in ice-forming conditions, helicopter hoist operations, operation on unpaved runway, operation on narrow runway. Take-off and landing in tailwind. Volcanic-ash operation (limitation or operation as per CS 25.1593 and CS-E 1050). Design service goal (DSG)/limit of validity targets. Fatigue missions (general description of assumptions for flight durations, main phases, and parameters, as appropriate). Other items, if considered to be more appropriate, that address the specific aeronautical product. 21.A.15(b)(4) ‘a proposal for the initial type-certification basis, operational suitability data certification basis, where applicable, and environmental protection requirements, considering the requirements and options specified in 21.B.80, 21.B.82 and 21.B.85’ The proposed certification basis should include applicable certification specifications, proposed special conditions, proposed equivalent safety findings, as well as a proposed ‘elect to comply’ and proposed deviations, as applicable. 21.A.15(b)(5) ‘a proposal for a breakdown of the certification programme into meaningful groups of compliance demonstration activities and data, hereinafter referred as “compliance demonstration items” (CDIs), including references to their proposed means of compliance and related compliance documents’ See AMC 21.A.15(b)(5) for the determination of the compliance demonstration items (CDIs). 21.A.15(b)(6) on information relevant for the determination of the level of involvement (LoI) The applicant should provide sufficient detailed information about the novelty, complexity, and criticality aspects of each proposed CDI. It is recommended to provide this information at the level of each EASA panel or discipline affected by a proposed CDI. Further interpretative material on the necessary level of details is provided in AMC 21.B.100(a) and 21.A.15(b)(6). The applicant should provide detailed information about the proposed means of compliance with the applicable requirements identified under 21.A.15(b)(4). The information provided should be sufficient for EASA to determine its (initial) LoI. This should include the following, as far as this information is available at the time of submission to EASA: a compliance checklist addressing each requirement, the proposed means of compliance (see Appendix A to AMC 21.A.15(b) below for the relevant codes), and the related compliance document(s); identification of industry standards (Society of Automotive Engineers (SAE), American Society for Testing and Materials (ASTM), European Organisation for Civil Aviation Equipment (EUROCAE), AeroSpace and Defence Industries Association of Europe (ASD), etc.), methodology documents, handbooks, technical procedures, technical documents and specifications specified in the type certificate data sheet, certification memoranda, policy statements, guidance material, etc., that should be followed in the demonstration of compliance; when the compliance demonstration involves testing, a description of the ground and flight test article(s), test method(s), test location(s), test schedule, test house(s), test conditions (e.g. limit load, ultimate load), as well as of the intent/objective(s) of the testing; and when the compliance demonstration involves analyses/calculations, a description/identification of the tools (e.g. name and version/release of the software programs) and methods used, the associated assumptions, limitations and/or conditions, as well as of the intended use and purpose; furthermore, the validation and verification of such tools and methods should be addressed. For every aspect mentioned above, the applicant should clearly identify whether the demonstration of compliance involves any method (analysis or test) which is novel or unusual for the applicant. This should include any deviations from the published AMC to the relevant CS.

AMC · AMC 21.A.15(b) — Regulation (EU) No 748/2012 · ED Decision 2019/018/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

AMCAcceptable means of compliance

AMC 21.A.15(b)(5)Breakdown of the certification programme into compliance demonstration items (CDIs)

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1.What is a CDI? A CDI is a meaningful group of compliance demonstration activities and data identified in the certification programme which can be considered in isolation for the purpose of performing the risk assessment that allows EASA to determine its level of involvement (LoI) using a risk-based approach. The possibility to create this grouping of compliance demonstration activities and data is intended to facilitate the risk assessment. However, there may be cases in which the risk assessment may also be performed at the level of the compliance demonstration activity or data, or at the level of the whole certification project. The chosen breakdown into CDIs may affect the resulting risk classes (please refer to AMC 21.B.100(a) and 21.A.15(b)(6)), but should not have any effect on the compliance demonstration itself or on EASA’s LoI.

2.The grouping of compliance demonstration activities and data The compliance demonstration activities and data grouped in a CDI may demonstrate compliance with a requirement, a group of requirements, or even a part of a requirement. In this context, ‘requirement’ means any element of the type-certification basis or operational suitability data (OSD) certification basis as specified in 21.B.80 and 21.B.82, or the environmental protection requirements as specified in 21.B.85. A CDI may comprise any of the means of compliance listed in Appendix A to AMC 21.A.15(b). CDIs may be tailored to the scope and size of the project. On simple projects, a CDI may address all the compliance demonstration activities within a given technical area (e.g. avionics, flight, structures, hydromechanical systems, OSD-cabin crew data (CCD), etc.) or of the whole project. A CDI should not be too large, by combining completely unrelated compliance demonstration activities or data, so that it becomes meaningless, but neither should it be so small that it might not be considered in isolation from some other related compliance demonstration activities or data. A way of meaningfully grouping compliance demonstration activities and data, for example, is to select some activities and data and group them into a single CDI, as the certification programme must already contain the applicable requirements, the proposed means of compliance for each requirement, as well as the associated compliance documents for each means of compliance. Another way to meaningfully group the data is to do it at the level of the technically related compliance demonstration activities and data. This may facilitate the assessment of those activities and data against the novelty, complexity, and criticality criteria (see AMC 21.B.100(a) and 21.A.15(b)(6)). The resultant CDI may encompass various means of compliance.

3.Description of CDIs Each CDI should be sufficiently described in the certification programme, and should detail the following: the scope of the CDI; and the information on the novelty, complexity, and criticality of the item being certified. However, in cases where the rationale of the assessment is obvious, it is considered to be sufficient to indicate whether or not a CDI is novel or complex, and whether or not the impact is critical. Note: Obvious cases are cases for which the classification is straightforward and does not require additional clarifications. In general, applicant explanations/notes regarding the proposed classification should be provided, since this will also facilitate the acceptance of the LOI proposal. Nevertheless, to avoid unnecessary additional effort, these explanations can be omitted if they are obvious. Additionally, it is recommended to identify the EASA panel(s)/discipline(s) affected by each CDI, as this will support the determination of the novelty, complexity, and criticality, and finally identify the performance of the design organisation approval (DOA) holder.

AMC · AMC 21.A.15(b)(5) — Regulation (EU) No 748/2012 · ED Decision 2019/018/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

GMGuidance material

GM 21.A.15(c)Updates to the certification programme

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Point 21.A.15(b) recognises that the initial submission of the certification programme may not be fully complete, e.g. due to schedule constraints of the design, analysis and testing activities. Furthermore, even if the initial submission of the certification programme is complete, it may be necessary to amend it throughout the duration of the project. The certification programme should be updated and resubmitted to EASA. In particular, updates to the following elements should be provided: any complementary information that was not included in the initial submission of the certification programme; any change in the intended use or kind of operations of the product itself, or of the aircraft on which the product is installed; a change in the key characteristics of the product such as but not limited to any declared limits that are intended to be recorded in the type certificate data sheet (TCDS); any change in the product design or its characteristics that may affect the criteria used to assess the likelihood of an unidentified non-compliance with the type-certification basis, operational suitability data (OSD) certification basis or the environmental protection requirements, including the potential impact of that non-compliance on product safety or environmental compatibility, as defined in 21.A.15(b)(6) and 21.B.100(a)(1) to (4); Note: An update of the DOA dashboard after the first issuance of the certification programme only needs to be considered if there is a significant change in the performance. any change to the initial type-certification basis, OSD certification basis or environmental protection requirements, as applicable to the product, regardless whether the change is initiated by EASA or by the applicant; any change in the breakdown of the certification programme into compliance demonstration items (CDIs) or in the content of those CDIs; any change in the proposed means of compliance, including its/their methodology; any change in the structure of compliance documents that may affect the determination of EASA’s level of involvement (LoI), as defined in 21.B.100; any relevant change to the design organisation approval (DOA) holder’s personnel (and design organisation (DO) suppliers) who are involved in the project; and any changes to the schedule that impact on the EASA LoI. Following each update to the certification programme as submitted by the applicant, EASA may update the determination of its LoI in accordance with 21.B.100(c).

GM · GM 21.A.15(c) — Regulation (EU) No 748/2012 · ED Decision 2025/016/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

GMGuidance material

GM4 21.A.15(d)Application

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SCOPE OF OPERATIONAL SUITABILITY DATA In the application for the approval of operational suitability data, the TC applicant may apply for the approval of different types of operations. If the aircraft is certified for certain types of operations (e.g. ETOPS, RNP, LVO), the impact on the OSD constituents of 21.A.15(d) should be addressed. The five defined OSD constituents are listed in paragraph (2)(k) of Article 1 of Regulation (EU) No 748/2012. As explained in GM No 1 to 21.A.15(d), they may not all be applicable to all aircraft types. The content of each OSD constituent is defined in the relevant certification specification (CS) and will be approved under a type certificate (TC), supplemental type certificate (STC) or change to those certificates. As explained in GM No 3 to 21.A.15(d), each OSD constituent can have a part that is mandatory for the end user (operator, training organisation, etc.) and a part that is not mandatory (recommendation) for the end user. However, both the mandatory and the non-mandatory part together are the OSD constituent. Furthermore, the OSD constituent always includes the element required from the TC/STC applicant, as specified in the CS, and may include additional elements at the request of the TC/STC applicant, but still as defined in the CS.

GM · GM4 21.A.15(d) — Regulation (EU) No 748/2012 · ED Decision 2021/001/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

GMGuidance material

GM 21.A.15(e)and (f) Period of validity for the application for a type certificate (TC) or restricted type certificate (RTC)

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Point 21.A.15(e) establishes a maximum period of validity for an application for a TC or an RTC. During this period, the type-certification basis, operational suitability data (OSD) certification basis, and the environmental protection requirements (hereinafter referred to as the ‘certification basis’), established and notified by EASA in accordance with points 21.B.80, 21.B.82 and 21.B.85, remain effective. However, the period of validity of the certification basis is limited so that the standards notified as part of the certification basis at the time of application do not become outdated. For various reasons (e.g. development, business, commercial, etc.), the applicant may not be able to complete the certification within the established time limit. In this case, the applicant has the following two options (see 21.A.15(f)(1) and (2)):

1.Submit a new application In this case, EASA establishes and notifies a new certification basis in accordance with points 21.B.80, 21.B.82 and 21.B.85, considering the standards that are available at the date of the new application. In accordance with point 21.A.15(e), the new application has a maximum period of validity that is equal to the first one, corresponding to the product category. Beyond this period of validity, the applicant may need to choose again between the two options of either submitting a new application or applying for an extension of the initial application.

2.Apply for an extension of the initial application In this case, the applicant proposes a ‘new target date’ to EASA for the issuance of the certificate, and selects a date that becomes the reference date for the establishment of the certification basis by EASA. For the purposes of this GM, the selected reference date is referred to as the ‘new effectivity date’ of the initial application. The ‘new effectivity date’ of the initial application may be any date in the past between the following time limits: the ‘new target date’ for a TC proposed by the applicant minus the time limit used under 21.A.15(e) (e.g. 5 years for large aeroplanes and large rotorcraft, 3 years for the other products); and the date on which the applicant applies for the extension of the initial application. This calculation is visualised in Figure 1 below: [Figure or form omitted from this preview — available in the Avioverse workspace library.] Figure 1

This ensures that the standards used to establish the certification basis are never older than the ones available at the start of the period of validity required by point 21.A.15(e). If the applicant is not able to complete the product certification by the new target date, the applicant may choose again between the two options of either submitting a new application or applying for a new extension of the initial application.

GM · GM 21.A.15(e) — Regulation (EU) No 748/2012 · ED Decision 2019/018/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

All rules in SECTION A — TECHNICAL REQUIREMENTS

Consolidated from the EASA Easy Access Rules (revision 27 Nov 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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