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GM No 1 to 21.A.101(g) Establishment of the operational suitability data (OSD) certification basis for changes to type certificates (TCs)

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

GMGuidance material

GM No 1 to 21.A.101(g) Establishment of the operational suitability data (OSD) certification basis for changes to type certificates (TCs)

This GM provides guidance on the application of point 21.A.101(g) in order to determine the applicable OSD certification basis in accordance with points 21.A.101(a), (b), (c), (d), (e) and (f) for major changes to the OSD of type-certified aircraft.

1.Minor changes Minor changes to the OSD are automatically outside the scope of point 21.A.101. See GM 21.A.95 for their certification basis.

2.Major changes a. If the design change that triggered the change to the OSD constituent is classified as non-significant, the change to the OSD constituent is also non-significant. b. If the design change that triggered the change to the OSD constituent is classified as significant, the change to the OSD constituent should comply with the latest amendment of the applicable CSs, unless the exceptions of 21.A.101(b)(3) apply or unless the OSD change can be classified as minor as per 21.A.91. The guidance of GM 21.A.101 Section 3.10 regarding the exceptions ‘impractical’ and ‘not contributing materially to the level of safety’, can be applied by analogy and as far as it is applicable to OSD changes. c. Stand-alone changes to an OSD constituent are considered to be non-significant. d. When a new OSD constituent is added or required to be added, it should comply with the latest amendment of the applicable CSs. e. Reserved. f. Reserved. g. Point 21.A.101(c) provides an exception from the requirements of 21.A.101(a) for a change to the OSD of certain aircraft below a specified maximum weight. If an applicant applies for a change to the OSD for an aircraft (other than rotorcraft) of 2 722 kg (6 000 lbs) or less maximum weight, or for a non-turbine-powered rotorcraft of 1 361 kg (3 000 lbs) or less maximum weight, the applicant can demonstrate that the changed OSD complies with the OSD certification basis incorporated by reference in the TC. The applicant can also elect to comply, or may be required to comply, with a later amendment. See also Chapter 4 Section 4.1 (GM 21.A.101) for specific guidance on this requirement. Note: Refer to GM No 1 to 21.A.15(d) for the applicability of the OSD to other-than-complex motor-powered aircraft.

GM — 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.