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21L.A.9 Instructions for continued airworthiness

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

IRImplementing rule

21L.A.9Instructions for continued airworthiness

(a)The holder of a type certificate, supplemental type certificate, design change or repair design approval or the declarant of a declaration of design compliance shall establish the information which is necessary for ensuring that the airworthiness of the aircraft type and any associated part, conforming to that design, is maintained throughout the operational life.

(b)The holder of a type certificate, supplemental type certificate, design change or repair design approval or the declarant of a declaration of design compliance shall provide the information established in (a) before that design is released to service.

(c)The instructions for continued airworthiness shall be provided by:

1.the holder of a type certificate or by the declarant of a declaration of design compliance to each known owner of one or more products upon its delivery or upon the issuance of the first certificate of airworthiness or restricted certificate of airworthiness, as applicable, for the affected aircraft, whichever occurs later;

2.the holder of a type certificate, supplemental type certificate or minor change approval or by the declarant of a declaration of design compliance for a design change to all known operators of the product affected by the change upon the release to service of the modified product;

3.the holder of a repair design approval or by the declarant of a declaration of design compliance for a repair design to all known operators of the product affected by the repair upon the release to service of the product in which the repair design is embodied. The repaired product or part may be released into service before the related instructions for continued airworthiness have been completed, but this shall be for a limited service period, and in agreement with the Agency. Thereafter, these certificate holders or declarants shall make this information available on request to any other person required to comply with those instructions for continued airworthiness.

(d)By way of derogation from point (b), the type-certificate holder or declarant of a declaration of design compliance may delay the availability of a part of the instructions for continued airworthiness, dealing with long lead accomplishment instructions of a scheduled nature, until after the product or modified product has entered into service, but shall make those instructions available before the use of this data is required for the product or modified product.

(e)The design approval holder or declarant of a declaration of design compliance who is required to provide instructions for continued airworthiness in accordance with point (b) shall also make available all the changes to those instructions to all the known operators of the product affected by the change, and, on request, to any other person required to comply with those changes.

IR · 21L.A.9 — Regulation (EU) No 748/2012 · Regulation (EU) 2022/1358 · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

AMCAcceptable means of compliance

AMC1 21L.A.9(a)Instructions for continued airworthiness

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INSTRUCTIONS FOR CONTINUED AIRWORTHINESS (ICAs) — CONTENTS

(a)The ICAs should identify the following, in accordance with the applicable certification specifications or applicable technical specifications:

(1)any limitations that are necessary for the continued airworthiness of the product or article;

(2)the means to determine when the product or article has deteriorated to the extent that it is no longer airworthy;

(3)the minimum actions required to restore the airworthiness of the product or article before the limitations (as per point (1)) have been exceeded or before their deterioration (as per point (2)), as an alternative to the withdrawal of the product or part from service.

(b)The ICAs should, therefore, include, in accordance with the applicable certification specifications or applicable technical specifications:

(1)any limitations determined through the certification or demonstration of compliance resulting in a declaration of compliance of the product or article, and instructions on how to determine that the limitations have been exceeded;

(2)any inspection, servicing or maintenance actions determined to be necessary by the certification process or demonstration of compliance resulting in a declaration of compliance;

(3)any inspection or troubleshooting actions determined to be necessary to establish the nature of faults and the necessary remedial actions;

(4)sufficient general information on the operation of the product or article to enable the understanding of the instructions in points (a)(1) to (a)(3) above.

AMC · AMC1 21L.A.9(a) — Regulation (EU) No 748/2012 · ED Decision 2023/013/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

AMCAcceptable means of compliance

AMC2 21L.A.9(a)Instructions for continued airworthiness

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IDENTIFICATION OF THE INSTRUCTIONS FOR CONTINUED AIRWORTHINESS (ICAs) The ICAs may be provided together with other, additional or optional, maintenance information, or in another acceptable format as per GM1 21L.A.9(a), with the following conditions:

(a)The information that is necessary for the continued airworthiness is clearly identified (refer to AMC1 21L.A.9(b)).

(b)The ICAs may reference additional instructions for continued airworthiness in separate publications, where necessary (for example, those produced by suppliers). If the product’s ICAs reference the use of supplier data (e.g. component maintenance manual (CMM) or section of it) as the appropriate location for the ICAs, those applicable instructions are incorporated by reference and become part of the complete set of the ICAs for the particular product.

(c)Additional or optional maintenance information that is not considered ICAs but referenced by the design approval holder (DAH) or declarant together with the ICAs should be evaluated appropriately by the DAH or declarant in order to ensure that its use will not compromise the continued airworthiness of the product or article.

(d)If the maintenance data made available by a DAH or declarant includes data from an operator (i.e. in order to customise the data for the operator, and created under the authority of the operator), the operator data should be identified as such, and the DAH or declarant is not required to additionally evaluate it.

AMC · AMC2 21L.A.9(a) — Regulation (EU) No 748/2012 · ED Decision 2023/013/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

AMCAcceptable means of compliance

AMC3 21L.A.9(a)Instructions for continued airworthiness

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DESIGN APPROVAL HOLDER (DAH) OR DECLARANT RESPONSIBILITY TO CHECK THE SUPPLIER DATA WHICH IS PART OF THE ICAs OR REFERENCED TOGETHER WITH THE ICAs The DAH or declarant may carry out a complete check of the supplier data, or may choose to rely, in whole or in part, on the supplier’s process for ensuring the accuracy and completeness of the data. In the latter case, the DAH or declarant will propose a means to validate the supplier’s process. Supplier data may also be issued by the supplier to the DAH or declarant under a contract or an arrangement, addressing the following:

(a)the accuracy and the adequacy of the technical documentation, which should be checked through a verification process (e.g. component workshop verification);

(b)evidence showing that workshop verification has been performed should be kept by the supplier and a clear statement should be given in the introduction to the supplier data as a confirmation that component verification is complete;

(c)evidence that the supplier has taken into account all justified feedback and changes to data requested by any person required to use the ICAs; typical examples would be the correction of reported errors, or mistakes. In addition, some validation activities may be decided by the DAH or declarant, depending on the articles and the capability level of the supplier. For articles subject to an ETSO authorisation, the validation of the supplier’s process for ensuring the accuracy and completeness of the data is not needed. This is also valid for other national TSO authorisations (e.g. FAA TSOs) accepted by EASA as stipulated in related bilateral agreements.

AMC · AMC3 21L.A.9(a) — Regulation (EU) No 748/2012 · ED Decision 2023/013/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

GMGuidance material

GM1 21L.A.9(a)Instructions for continued airworthiness

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SCOPE OF THE INSTRUCTIONS FOR CONTINUED AIRWORTHINESS (ICAs), THEIR PUBLICATION FORMAT AND TYPICAL ICA DATA

(a)The ICAs may be published in documents or in a manner other than the traditional understanding of a document — for example, as a series of web pages, or Information Technology (IT) tools, or in a publishing format linked to tasks or data modules rather than pages.

(b)The design approval holder (DAH) or declarant may decide, within the framework provided by point 21L.A.9 and its acceptable means of compliance and guidance material, to publish the ICAs in the most suitable location as part of all the information published to support the airworthiness of a given aircraft.

(c)The requirement for ICAs is not intended to ensure that all products or articles may be restored to an airworthy condition. A certain level of deterioration may require a product or an article to be permanently withdrawn from service, and restoration may not be reasonably achievable. Certain deteriorations or levels of deterioration may require specific instructions (e.g. inspection or restoration) that will only be developed and provided on a case-by-case basis, as needed, for a given product or article, and as such, will not be included in the ICAs. In some exceptional cases, ICAs for products may ultimately instruct the user to contact the DAH or declarant in order to define the specific instructions on a case-by-case basis. This typically happens when the definition of generic instructions covering all possible cases is not possible. For example, following an aircraft hard landing, a detailed analysis may have to be carried out by the DAH or declarant to determine the specific instructions to be followed, which depend on the touchdown loads.

GM · GM1 21L.A.9(a) — Regulation (EU) No 748/2012 · ED Decision 2023/013/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

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GM2 21L.A.9(a)Instructions for continued airworthiness

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DETERMINATION OF WHICH SUPPLIER DATA IS PART OF THE INSTRUCTIONS FOR CONTINUED AIRWORTHINESS (ICAs) Note 1: For the purposes of this GM, the term ‘supplier data’ also applies to similar types of data when issued directly by the DAH or declarant (e.g. component maintenance manuals (CMMs) issued by the DAH or declarant). Note 2: For the purposes of this GM, the term ‘supplier data’ should be understood as data coming from the supplier and related to either a full CMM or to part of a CMM. Note 3: The link between the aircraft ICAs and the engine/propeller CMM, as detailed below, is similar to the link between engine/propeller ICAs and the CMM of equipment fitted to the engine/propeller. Note 4: If the supplier is also the DAH (for instance, an engine or propeller manufacturer), then the ICAs for these items will be made available by virtue of the DAH obligations as type-certificate holder (TCH) and need not be included in the aircraft ICAs. Note 5: If the supplier is an engine or propeller manufacturer, then the ICAs for these items will be made available by virtue of the DAH obligations as type-certificate holder (TCH) and need not be included in the aircraft ICAs. If the supplier is an engine or propeller manufacturer that is not the TCH due to the aircraft TC or declaration of design compliance also including the compliance of the engine or propeller, then the supply of ICAs from the engine or propeller manufacturer will need to be subject to a suitable arrangement.

(a)When determining whether a supplier data is part of the ICAs, the following should be considered:

(1)Supplier data related to the Airworthiness Limitations Section (ALS) of the ICAs is part of the ICAs.

(2)Supplier data related to instructions on how to accomplish the scheduled maintenance part of the aircraft ICAs are part of the aircraft ICAs. A typical case is the periodical removal of a component to perform a workshop task.

(3)Supplier data related to scheduled maintenance on the component should be endorsed by the DAH or declarant before becoming part of the aircraft ICAs, to define and confirm that the supplier data is applicable and effective.

(4)If the ICAs are defined at aircraft level, the following principles apply to the other supplier data that is not related to the ALS nor to scheduled maintenance:

(i)If the supplier data includes a maintenance instruction for an action identified in the aircraft-level ICAs, including an engine or propeller, this supplier data should be referenced in the aircraft-level ICAs and should be made available like any other ICAs. As an alternative to linking such supplier data to the aircraft-level ICAs (e.g. with cross references), it is possible to include the relevant data directly into the aircraft ICAs. In such a case, the supplier data is not part of the aircraft ICAs since the aircraft ICAs already contain all the required information.

(ii)If an aircraft ICAs’ task only requires a replacement task for an engine, propeller or part (i.e. ‘remove and replace’ or ‘discard’) and does not refer to the supplier data for further maintenance of the removed engine, propeller or part, this means that the aircraft airworthiness may only be maintained by replacement action, and that the supplier data is not part of the ICAs for the particular aircraft. In such cases, the supplier data does not need to be referenced in the aircraft ICAs. Example: If supplier data provides off-aircraft maintenance instructions for an engine, propeller, or other article (i.e. workshop maintenance), then this data may not be considered as part of the complete set of the ICAs for the aircraft, but may be considered as part of the complete set of the ICAs for the engine or propeller. However, the procedure for removal from / installation on the aircraft is necessarily part of the aircraft ICAs.

(b)However, for the above cases, aircraft-level ICAs can provide, as additional or optional maintenance information, the references to the supplier data even if it is not considered part of the ICAs. In such cases, it should be made clear that the supplier data references are provided as additional or optional maintenance information and is not part of the product ICAs. Besides, it should be ensured that the use of additional or optional maintenance information not considered as ICAs but referenced together with the ICAs will not compromise the continued airworthiness of the product or article.

(c)For the supplier data identified as part of the ICAs, the DAH or declarant should:

(1)identify the supplier data that is part of the ICAs; this can be achieved either by creating a listing or by any other acceptable means that allow to identify which data is part of the ICAs and which data is not part of the ICAs (refer to AMC1 21L.A.9(b));

(2)just as for any other ICAs, ensure the publication of the supplier data;

(3)ensure the accuracy and the adequacy of the technical content of the supplier data.

GM · GM2 21L.A.9(a) — Regulation (EU) No 748/2012 · ED Decision 2023/013/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

GMGuidance material

GM3 21L.A.9(a)Instructions for continued airworthiness

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NON-ICAs SUPPLIER DATA (e.g. COMPONENT MAINTENANCE MANUALS (CMMs))

(a)Non-ICAs supplier data referenced together with the ICAs Supplier data, or parts of the supplier data, which is not considered part of the ICAs but is additional or optional maintenance information referenced together with the product-level ICAs may be issued by the supplier to the DAH or declarant under a contract or an arrangement, using the methodology proposed in AMC3 21L.A.9(a).

(b)Other non-ICAs supplier data Non-ICAs supplier data, which is not referenced together with the ICAs, but which can be used for the maintenance of components approved for installation by the DAH or declarant, should be acceptable to the DAH or declarant. This non-ICAs supplier data may be documented in a list.

GM · GM3 21L.A.9(a) — Regulation (EU) No 748/2012 · ED Decision 2023/013/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

AMCAcceptable means of compliance

AMC1 21L.A.9(b)Instructions for continued airworthiness

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IDENTIFICATION OF A COMPLETE SET OF INSTRUCTIONS FOR CONTINUED AIRWORTHINESS (ICAs) The design approval holder (DAH) or declarant should identify the complete set of ICAs according to point 21L.A.9(b) in such a way that the complete set can be:

(a)directly listed in the product’s type certificate data sheet (TCDS) or airworthiness data sheet; or

(b)indirectly referenced in the TCDS or airworthiness data sheet through other means, which allow the complete list of the ICAs to be obtained (e.g. a complete listing of ICAs contained in a ‘principal manual’ or a reference to the DAH’s or declarant’s website); or

(c)directly listed in the product’s supplemental type certificate (STC); or

(d)indirectly referenced in the STC through other means, which allow the obtainment of the complete list of the ICAs; or

(e)if direct reference is made to the ICAs in the product’s TCDS or the STC or airworthiness data sheet, no reference to the revision level of the ICAs should be made; in this case, the revision level should be available elsewhere (e.g. on the DAH’s or declarant’s website). For design changes and repairs to type certified or declared aircraft, the identification of ‘a complete set of the changes to the instructions for continued airworthiness’ should be performed by the DAH or declarant by a statement to provide this information, or by confirmation that there are no changes to the ICAs. This statement may also be made in the accomplishment document (e.g. embodiment instructions). For products and articles for which the DAH or declarant holds a design organisation approval (DOA), the ICAs are considered to have been issued under the authority of the DOA and, therefore, the approval of the ICAs should be made explicit to the reader in accordance with point 21.A.265(h) of Annex I (Part 21) to this Regulation, unless otherwise agreed with EASA.

AMC · AMC1 21L.A.9(b) — Regulation (EU) No 748/2012 · ED Decision 2023/013/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

GMGuidance material

GM1 21L.A.9(b)Instructions for continued airworthiness

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ANY OTHER PERSONS REQUIRED TO COMPLY For the purposes of this GM, ‘any other person required to comply’ means:

(a)any independent certifying staff that performs maintenance on a product or article, in accordance with Regulation (EU) No 1321/2014, in the framework of a contract (or work order) with the person or organisation responsible for the aircraft continuing airworthiness;

(b)any maintenance organisation approved to maintain a product or article, in accordance with Regulation (EU) No 1321/2014, in the framework of a contract (or work order) with the owner of the engine or article, or the person or organisation responsible for the aircraft continuing airworthiness;

(c)any organisation approved to manage the aircraft continuing airworthiness in accordance with Regulation (EU) No 1321/2014, in the framework of a contract with the aircraft owner or aircraft operator.

GM · GM1 21L.A.9(b) — Regulation (EU) No 748/2012 · ED Decision 2023/013/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

GMGuidance material

GM2 21L.A.9(b)Instructions for continued airworthiness

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INSTRUCTIONS FOR CONTINUED AIRWORTHINESS (ICAs) — FORMAT The ICAs may be furnished or made available by various means (including paper copies, electronic documents, or web-based access). Regardless of the format, the design approval holder (DAH) or declarant is expected to furnish or make the ICAs available in a means that is readily accessible for and useable by the owner and any other person required to comply with the ICAs. Service documents, such as service information letters, may be used for transmitting ICAs information and updates.

(a)Formatting standards DAHs or declarants may use the latest ATA, AECMA/ASD or GAMA formatting standards such as:

(1)AeroSpace and Defence Industries Association of Europe (ASD), ASD-S1000D, International Specification for Technical Publications Utilizing a Common Source Data Base, version 4 or higher;

(2)the Air Transport Association’s (ATA) iSpec 2200, Information Standards for Aviation Maintenance, latest edition (ATA is now known as Airlines for America (A4A) but the standard is still listed as ATA); or

(3)General Aviation Manufacturers Association (GAMA) Specification No. 2, Specification for Manufacturers Maintenance Data, latest edition. With regard to scheduled maintenance, DAHs or declarants may also refer to the glossary of the ATA MSG-3 standard, latest revision, for standardised task definitions and designations.

(b)General considerations The ICAs should be easy to read and to follow. All ICAs should include a means to identify their applicability (model, type, etc.), and the associated revision status. Refer to sample formats in the Air Transport Association’s iSpec 2200, Information Standards for Aviation Maintenance, latest edition, or AECMA/ASD standards. There is no requirement for any specific format or arrangement of the ICAs in a document or documents. However, the specific format selected by the DAH or declarant should be used and applied in a uniform manner. Empty pages in a document should contain the statement ‘Intentionally left blank’ or similar. At the beginning of each procedure, the ICAs should contain cautions and warnings regarding possible mistakes that can be made when following the instructions. Abbreviations, acronyms and symbolisation should be either avoided or explained as part of the ICAs documentation. The ICAs contain units of measurement. Measurements could be, for instance, instrument readings, temperatures, pressures, torque values with tolerances, limits, and ranges when applicable. If the ICAs contain units of measurement of a system other than the metric, the ICAs should include a conversion to the metric system for each measurement, tolerance, or torque value. A general conversion table alone should not be provided, as it may introduce an additional source of error. The DAH or declarant should use a means to indicate changes to the ICAs directly in relation to each item of the information/data of the ICAs, e.g. using a vertical change bar in the margin next to the line.

(c)Publication of the ICAs in multiple documents DAHs or declarants may prepare ICAs as a document, or several documents, depending on how much data is necessary to provide a complete set of ICAs. If there are multiple documents, there should be a principal document that describes the general scope of all other documents, in order to provide an overview of the multiple document structure. According to different standards, the Airworthiness Limitations Section (ALS) needs to be included in the principal document as a dedicated section. However, EASA may also accept a separate Airworthiness Limitations document when it is at least referenced as such in the principal document. DAHs or declarants that decide to segregate information dedicated to a specific subject from a principal document into a separate document, e.g. ‘Fuel Pipe Repair Manual’, ‘Cable Fabrication Manual’, ‘Duct Repair Manual’ or ‘Instrument Display Manual’, should declare these documents to be ICAs. DAHs or declarants may decide to integrate certain information in a principal document (as, for example, troubleshooting information as part of the aircraft maintenance manual (AMM) instead of a separate troubleshooting manual (TSM)).

(d)Language The ICAs should be provided in any of the official language(s) of the European Union which is (are) acceptable to the competent authority. Note: In certain countries, such as the USA, English is required for ICAs. EASA, therefore, recommends that DAHs or declarants include a version of the ICAs in simplified technical English (e.g. in accordance with ASD Specification STE100).

(e)Electronic media The ICAs may be provided in an electronic format (e.g. CDs, via the internet, etc.) instead of paper copies or microfilms (refer to AMC1 21L.A.9(b)). When electronic format is used, the DAH or declarant should consider aspects such as the traceability of updates, keeping previous versions (record-keeping), data security and the obligations of the person(s) or organisation(s) responsible for the aircraft continuing airworthiness, considering that the ICAs form the basis of the data used for continuing airworthiness activities.

GM · GM2 21L.A.9(b) — Regulation (EU) No 748/2012 · ED Decision 2023/013/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

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GM3 21L.A.9(b)Instructions for continued airworthiness

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APPROVAL STATUS OF THE MANUAL FOR A COMPONENT OR ARTICLE When the ICAs refer to a document for a specific component or article, it is possible that this document is used for products from more than one DAH. In such cases, instead of placing approval statements from each DAH in the same manual, it may be more practical to identify the approved status of the relevant document through its inclusion in lists managed by the DAH in accordance with AMC1 21L.A.9(b).

GM · GM3 21L.A.9(b) — Regulation (EU) No 748/2012 · ED Decision 2023/013/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

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GM4 21L.A.9(b)Instructions for continued airworthiness

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INTEGRATION OF THE INSTRUCTIONS FOR CONTINUED AIRWORTHINESS (ICAs) BETWEEN PRODUCTS (AIRCRAFT, ENGINES, PROPELLERS) The aircraft/engine/propeller type-certificate holder (TCH) and, if applicable, the declarant, should ensure the availability of ICAs to allow maintenance of the aircraft, including engines/propellers when installed on the aircraft. When referring to engine/propeller ICAs directly in the aircraft ICAs, the aircraft TCH or declarant should not perform additional verification and validation. However, the integration and interface aspects between the aircraft and the engine/propeller are still under the responsibility of the aircraft TCH or declarant. If the ICAs published by the aircraft TCH or declarant include some engine/propeller ICAs developed by the engine/propeller TCH, the engine/propeller TCH should make an arrangement with the aircraft TCH setting out engine/propeller TCH and aircraft TCH or declarant shared responsibilities with respect to the ICAs under point 21L.A.9. This arrangement should: define the part of the engine/propeller ICAs which is published in the aircraft ICAs; and address the development, publication and update processes of these ICAs, including completeness and timely availability aspects. The incorporated engine/propeller data content remains under the responsibility of the engine/propeller TCH, and the publication is under the responsibility of the aircraft TCH or declarant. Therefore, the aircraft TCH or declarant should coordinate with the engine/propeller TCH regarding any modification or alteration of the incorporated data.

GM · GM4 21L.A.9(b) — Regulation (EU) No 748/2012 · ED Decision 2023/013/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

AMCAcceptable means of compliance

AMC1 21L.A.9(d)Completeness and timely availability of the Instructions for Continued Airworthiness

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COMPLETENESS AND TIMELY AVAILABILITY OF THE INSTRUCTIONS FOR CONTINUED AIRWORTHINESS (ICAs) FOR TYPE-CERTIFICATE (TC) APPLICANTS OR DECLARATION OF DESIGN COMPLIANCE

(a)An applicant or declarant may wish to choose among the three options described below. Once the certification programme or demonstration of compliance for a declaration starts, it may be necessary to modify the initially selected option to accommodate programme changes. All such changes should be coordinated with EASA.

(1)Option 1: Complete ICAs are available at the time of the design approval (type certificate (TC)) or submission of a declaration of design compliance

(i)The ICAs will be made available at the time of the design approval or submission of the declaration of design compliance. This option minimises the risk of incomplete ICAs, especially for changes.

(ii)With all ICAs available at the time of the design approval or submission of the declaration of design compliance, they should also be furnished / made available to the aircraft operator / aircraft owner and made available to any other person required to comply with any of those instructions in accordance with point 21L.A.9, without using the provision to delay certain parts of the ICAs after the entry into service of the product.

(iii)Frequently, there is only a short period of time between the design approval or submission of the declaration of design compliance and the entry into service. Nevertheless, applicants/DAHs or declarants may still wish to apply Option 2 or 3 for a part of their ICAs as stated below.

(2)Option 2: Complete ICAs are available at entry into service (TC or submission of the declaration of design compliance) If an applicant or declarant plans to make part of the ICAs available to EASA upon entry into service, the following approach is acceptable:

(i)For the Airworthiness Limitations Section (ALS), as part of the type design, notwithstanding the selection of Option 2: the applicant or declarant submits the ALS prior to the design approval or submission of the declaration of design compliance. Any ALS content that is incomplete, not yet demonstrated for compliance, or delayed beyond the design approval or submission of the declaration of design compliance, requires to be compensated through an interim limitation to establish compliance within this limitation. The interim limitation is notified to the aircraft operator(s) concerned as a temporary operational limitation in a manner agreed with EASA. In this context, ALS content is understood as the task method (e.g. a detailed inspection), including its reference, title and applicability, and the associated threshold / interval / life-limit. The accomplishment procedure itself, i.e. how to carry out the task, is usually described in other parts of the ICAs (e.g. in the aircraft maintenance manual (AMM) or the non-destructive testing (NDT) manual). However, a feasibility study of the accomplishment procedure is required for compliance with specific requirements.

(A)This may typically apply when the aircraft’s structural full-scale fatigue testing required for compliance with the fatigue- and damage-tolerance requirements, considering the expected operational life, will not be completed prior to the type certificate being issued. In this case, a temporary operational limitation is assigned and stated in the ALS, dependent on the aircraft’s full-scale fatigue testing progress. The ALS is effectively incomplete beyond this temporary operational limitation, as the required justification and the resulting ICAs are not yet available to support the safe operation of the aircraft beyond this limitation.

(B)A type certificate data sheet (TCDS) or airworthiness data sheet notation is not necessary since the product is provided with complete ALS content up to the established temporary operational limitation.

(ii)A compliance plan identifying those parts of the ICAs that are only to be made available upon entry into service is produced, submitted to EASA and agreed between the applicant/declarant and EASA prior to the design approval or registration of the declaration of design compliance (refer also to point (iv) for the ICAs considered necessary at the time of the design approval/registration of a declaration of design compliance).

(iii)A commitment is made to produce, verify and, when requested, submit to EASA the relevant ICAs prior to entry into service. This commitment should be provided in a compliance document (e.g. the compliance plan). If the respective organisation responsible for design has not previously exercised the practice of delaying the ICAs beyond the design approval or submission of a declaration of design compliance, the required procedure should be agreed with EASA.

(iv)The ICAs considered necessary at the time of design approval or submission of the declaration of design compliance are provided or made available in a format that adequately defines the data. Furthermore, the way the data is presented at the time of the design approval or submission of the declaration of design compliance offers the same understanding of the data as the final published format does. The applicant or declarant should agree with EASA, in a compliance plan, on all ICAs necessary at the time of the design approval or registration of the declaration of design compliance. The Agency investigation may vary from no involvement or evaluating a limited sample of the ICAs to performing a thorough review of specific parts of the ICAs.

(v)In cases where EASA has doubts as to whether the applicant/holder or declarant can fulfil the applicable requirements of point 21L.A.9 to control and support delaying the ICAs beyond the design approval, or type certificate (TC), or submission of the declaration of design compliance and until entry into service, EASA may decide to assign a condition for entry into service for non-ALS ICAs or withhold the registration of the declaration of design compliance. As a condition for the entry into service, a note should be included in the type certificate data sheet (TCDS) or airworthiness data sheet as a result of these pending issues under the ICAs paragraph as follows: ‘Note: The ICAs are not complete. As per point 21L.A.9 of Annex Ib (Part 21 Light) to Commission Regulation (EU) No 748/2012, they must be completed before the entry into service of the aircraft. Contact EASA for information on the status.’ The decision to assign a condition may be based on the applicant’s or declarant’s performance, e.g. if the applicant or declarant has already demonstrated in previous projects that it has provided the complete set of ICAs before the entry into service, if the applicant or declarant has already experienced difficulties in providing the ICAs considered necessary at the time of the design approval or submission of the declaration of design compliance, or has previously failed on a different project to meet its commitment to complete the ICAs prior to entry into service, or if the applicant/holder or declarant has no previous experience with the practice of delaying the ICAs beyond the design approval or submission of the declaration of design compliance.

(vi)Post-TC action or the submission of the declaration of design compliance is established together with EASA (if EASA requests such a review) to review the ICAs’ status upon entry into service.

(vii)If all ICAs are made available to EASA at the time of entry into service, they should also be furnished at that time to the aircraft operator / aircraft owner and made available to any other person(s) required to comply with any of those instructions in accordance with point 21.A.7, without using the provision to delay certain parts of the ICAs beyond the entry into service.

(3)Option 3: Complete ICAs are available after the entry into service (TC or registration of declaration of design compliance) As per point 21L.A.9(d), certain ICAs dealing with the ‘overhaul or other forms of heavy maintenance’ may be delayed until after the aircraft entry into service. Although there is no definition of what is meant by ‘overhaul or other forms of heavy maintenance’, the intention of the requirement is to provide flexibility to applicants/holders or declarants for long-lead ICAs of a scheduled nature. If an applicant or declarant plans to make part of the ICAs available only after the entry into service, the following is acceptable for the complete set of ICAs:

(i)For the ALS, as it cannot be delayed until after the entry into service, point (i) of Option 2 applies.

(ii)For ICAs considered necessary at the time of the design approval or submission of the declaration of design compliance, point (iv) of Option 2 applies.

(iii)A detailed compliance plan identifying those parts of the ICAs that are to be provided prior to and after the entry into service. For ICAs made available after the entry into service, the plan should account for when the ICAs are needed so that they can be complied with. This approach may only be used for scheduled maintenance accomplishment procedures, where threshold / interval / life-limit requirements of the related scheduled tasks are established. In that respect, the following aspects should be considered:

(A)The majority of the ICAs are of an unscheduled nature; therefore, these items should be available at entry into service at the latest.

(B)Consideration should be given to the fact that a number of tasks are used for both scheduled and unscheduled maintenance (e.g. an operational check of a system is planned as a scheduled task at a certain point in time, but is also required as part of the installation procedure to determine the operational status of the system).

(C)For ICAs to be made available after entry into service, the detailed plan should contain threshold(s) controlled by the applicant/holder, stating the maximum value in flight hours (FHs) / flight cycles (FCs) or calendar time (CT), or a combination of them as applicable, by which point in time the delayed ICAs should be made available.

(D)This detailed plan should be available prior to the time of the design approval or submission of the declaration of design compliance and should be either directly integrated or cross-referenced in a compliance plan.

(E)Information on the format in which the ICAs delayed until after entry into service will be made available in time (e.g. regular revisions or temporary revisions (TRs) or service information (SBs, SIL, etc.).

(iv)A procedure/programme that ensures a detailed plan is produced and implemented in the applicant’s or declarant’s organisation in order to ensure the timely availability (to the aircraft operator / aircraft owner and to any other person(s) required to comply with any of those instructions and to EASA, if involved and when requested).

(v)A commitment is made to produce, verify and provide the relevant ICAs in accordance with the established detailed plan. This commitment should be provided in an appropriate document (e.g. a compliance plan). If the respective organisation responsible for design has not previously exercised the practice of delaying the ICAs beyond the design approval or submission of the declaration of design compliance, the required procedure should be agreed with EASA.

(vi)In order to ensure that the applicant/holder or declarant can meet their obligations as set out in point 21L.A.9 to control and support delaying the ICAs, EASA may decide:

(A)for ICAs delayed until entry into service, to assign a condition/notation for the entry into service to be included in the TCDS or airworthiness data sheet as a result of these pending issues under the ICAs paragraph, as per point (v) of Option 2;

(B)for ICAs delayed until after entry into service, to assign an interim limitation to be published and included in the ALS as a temporary operational limitation, also for non-ALS ICAs, to compensate for the delayed ICAs; this approach may only be used for scheduled maintenance accomplishment procedures, where task and interval requirements are available. The decision to assign a condition/limitation may be based on the applicant’s or declarant’s performance, e.g. if the applicant or declarant has already demonstrated in previous projects that it has provided the complete set of ICAs before the entry into service, if the applicant or declarant had already difficulties in providing the ICAs considered necessary at the time of the design approval or submission of the declaration of design compliance, or has failed before in a different project to control and support delaying the ICAs, or if the applicant/holder or declarant has not previously exercised the practice of delaying the ICAs beyond the design approval or submission of the declaration of design compliance.

(vii)Post-TC action or the submission of the declaration of design compliance should be established with EASA to regularly review the ICAs’ status, if EASA requests such a review, taking into account other oversight activities.

(viii)An applicant/holder or declarant should provide visibility, regarding the ICAs that are delayed beyond entry into service, to the aircraft operator / aircraft owner and to any other person(s) required to comply with any of those instructions. This can be achieved by providing this information, for example, on a website or in a document, such as a maintenance planning document (MPD) or an aircraft maintenance manual (AMM), preferably in the principal ICAs manual. This visibility information is then itself considered ICAs information.

(ix)It is assumed that for those ICAs that are made available to EASA at the time of entry into service, they are also at the same time furnished to the aircraft operator / aircraft owner and made available to any other person(s) required to comply with any of those instructions in accordance with point 21L.A.9. This is to satisfy EASA that such a delayed publication will not have an adverse effect on the continuing airworthiness of any given aircraft. To allow the timely review and incorporation of a delayed part of the ICAs into continuing airworthiness activities and processes (e.g. amendment of the aircraft maintenance programme) by the person or organisation responsible for the aircraft continuing airworthiness or for performing maintenance, EASA considers that the delayed ICAs should typically be made available 2 years before the actual ICAs have to be used, when using normal revisions as a format. However, shorter time margins may be acceptable, provided that the format used ensures the prompt notification of the availability of the delayed ICAs or the ICAs itself, but they should not be shorter than 1 year before the ICAs have to be used.

(b)Completeness and timely availability of changes to the ICAs (TC or declaration of design compliance) Point 21L.A.9(e) regulates the distribution of changes to the ICAs required from the TC holder or declarant. Those changes to the ICAs could result from the design change process (minor and major changes), in-service experience, corrections, and others. A programme showing how changes to the ICAs are distributed is part of the respective procedures (e.g. design organisation procedures, or other procedures used to demonstrate design capabilities). For changes to the ICAs triggered by design changes, typically these procedures follow the same principles as those available for TCs or the initial declaration of design compliance (Options 1 to 3), while taking into account the relevant privileges, e.g. that a DOA may approve minor changes in accordance with point 21.A.263(c)(2) of Annex I (Part 21).

AMC · AMC1 21L.A.9(d) — Regulation (EU) No 748/2012 · ED Decision 2023/013/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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