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21.A.21 Requirements for the issuance of a type certificate or restricted type certificate

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

IRImplementing rule

21.A.21Requirements for the issuance of a type certificate or restricted type certificate

(a)In order to be issued with a product or a CMU type certificate, or with an aircraft restricted type certificate for the aircraft that does not meet the essential requirements laid down in Annex II to Regulation (EU) 2018/1139,, the applicant shall:

1.demonstrate its capability in accordance with point 21.A.14;

2.demonstrate compliance in accordance with point 21.A.20;

3.for an aircraft type certificate or restricted type certificate, demonstrate that the engine or propeller, or both, if installed on the aircraft:

(i)has/have a type certificate issued or determined in accordance with this Regulation; or

(ii)is/are compliant with the aircraft type-certification basis established for aircraft other than unmanned aircraft, or with the UAS type-certification basis for unmanned aircraft, and the environmental protection requirements designated and notified by the Agency as necessary to ensure the safe flight of the aircraft;

4.for an unmanned aircraft type certificate or restricted type certificate:

(i)demonstrate compliance with the UAS type-certification basis in accordance with point 21.B.80;

(ii)demonstrate that the CMU has a type certificate issued in accordance with this Regulation, if the CMU has been certified separately from the unmanned aircraft.

(b)By way of derogation from point (a)(2), at the applicant’s request included in the declaration referred to in point 21.A.20(d), the applicant is entitled to have the aircraft type certificate or restricted type certificate issued before the applicant has demonstrated compliance with the applicable operational suitability data certification basis, provided that the applicant demonstrates such compliance before the date on which this data is to be actually used.

IR · 21.A.21 — Regulation (EU) No 748/2012 · Regulation (EU) 2024/1108 · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

GMGuidance material

GM 21.A.21(a)(3)(i)Clarification of the term ‘determined’

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A type certificate ‘determined’ in accordance with Part 21 means a type certificate, or a document that allows the issuance of a certificate of airworthiness, issued before 28 September 2003 by a Member State complying with Article 3(1)(a) of Regulation (EU) No 748/2012.

GM · GM 21.A.21(a)(3)(i) — Regulation (EU) No 748/2012 · ED Decision 2021/011/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

GMGuidance material

GM 21.A.21(b)21.A.95(c), 21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b) and 21.B.111(b) Approval of operational suitability data (OSD)

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It is acknowledged that it may not always be possible to have the OSD available on the date of the issue of the (restricted) type certificate ((R)TC), change approval or supplemental type certificate (STC). The derogation provided by 21.A.21(b), 21.A.95(c), 21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b) and 21.B.111(b) is intended for that case. The (R)TC, change approval or STC can be issued before compliance with the OSD certification basis has been demonstrated. However, the OSD needs to be approved before the data is used by a training organisation for the purpose of obtaining a European Union (EU) licence, rating or attestation, or by an EU operator. This is normally done before the entry into service of the first aircraft by an EU operator but it could also be done later for some of the OSD constituents, such as the definition of the scope of validation source data to support the objective qualification of a simulator, which should only be available when a simulator has to be qualified. The derogation provided in points 21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b), and 21.B.111(b) is applicable to all major changes to a TC, so it is also applicable to minor design changes when triggering a major master minimum equipment list (MMEL) change, as well as to changes in which at least one of the OSD constituent changes is major.

GM · GM 21.A.21(b) — 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.21(b)21.A.95(c), 21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b) and 21.B.111(b) Approval of operational suitability data (OSD)

Show the text

It is acknowledged that it may not always be possible to have the OSD available on the date of the issue of the (restricted) type certificate ((R)TC), change approval or supplemental type certificate (STC). The derogation provided by 21.A.21(b), 21.A.95(c), 21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b) and 21.B.111(b) is intended for that case. The (R)TC, change approval or STC can be issued before compliance with the OSD certification basis has been demonstrated. However, the OSD needs to be approved before the data is used by a training organisation for the purpose of obtaining a European Union (EU) licence, rating or attestation, or by an EU operator. This is normally done before the entry into service of the first aircraft by an EU operator but it could also be done later for some of the OSD constituents, such as the definition of the scope of validation source data to support the objective qualification of a simulator, which should only be available when a simulator has to be qualified. The derogation provided in points 21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b), and 21.B.111(b) is applicable to all major changes to a TC, so it is also applicable to minor design changes when triggering a major master minimum equipment list (MMEL) change, as well as to changes in which at least one of the OSD constituent changes is major.

GM · GM 21.A.21(b) — 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.21(b)21.A.95(c), 21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b) and 21.B.111(b) Approval of operational suitability data (OSD)

Show the text

It is acknowledged that it may not always be possible to have the OSD available on the date of the issue of the (restricted) type certificate ((R)TC), change approval or supplemental type certificate (STC). The derogation provided by 21.A.21(b), 21.A.95(c), 21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b) and 21.B.111(b) is intended for that case. The (R)TC, change approval or STC can be issued before compliance with the OSD certification basis has been demonstrated. However, the OSD needs to be approved before the data is used by a training organisation for the purpose of obtaining a European Union (EU) licence, rating or attestation, or by an EU operator. This is normally done before the entry into service of the first aircraft by an EU operator but it could also be done later for some of the OSD constituents, such as the definition of the scope of validation source data to support the objective qualification of a simulator, which should only be available when a simulator has to be qualified. The derogation provided in points 21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b), and 21.B.111(b) is applicable to all major changes to a TC, so it is also applicable to minor design changes when triggering a major master minimum equipment list (MMEL) change, as well as to changes in which at least one of the OSD constituent changes is major.

GM · GM 21.A.21(b) — 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.21(b)21.A.95(c), 21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b) and 21.B.111(b) Approval of operational suitability data (OSD)

Show the text

It is acknowledged that it may not always be possible to have the OSD available on the date of the issue of the (restricted) type certificate ((R)TC), change approval or supplemental type certificate (STC). The derogation provided by 21.A.21(b), 21.A.95(c), 21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b) and 21.B.111(b) is intended for that case. The (R)TC, change approval or STC can be issued before compliance with the OSD certification basis has been demonstrated. However, the OSD needs to be approved before the data is used by a training organisation for the purpose of obtaining a European Union (EU) licence, rating or attestation, or by an EU operator. This is normally done before the entry into service of the first aircraft by an EU operator but it could also be done later for some of the OSD constituents, such as the definition of the scope of validation source data to support the objective qualification of a simulator, which should only be available when a simulator has to be qualified. The derogation provided in points 21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b), and 21.B.111(b) is applicable to all major changes to a TC, so it is also applicable to minor design changes when triggering a major master minimum equipment list (MMEL) change, as well as to changes in which at least one of the OSD constituent changes is major.

GM · GM 21.A.21(b) — 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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