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EASA continuing airworthiness for light aircraft: Part-ML, Part-CAO/CAMO and Part-66 licences

Consolidated EU Regulation (EU) No 1321/2014 (text as of 22 February 2026): Part-ML continuing airworthiness for ELA1/ELA2 light aircraft, Part-CAMO and Part-CAO organisations, and Part-66 aircraft maintenance licences, together with EASA's official continuing airworthiness FAQ. Built for owners and operators of light aircraft, independent certifying staff, CAO/CAMO staff, and licensed engineers or students, it answers questions on maintenance programmes, airworthiness reviews, pilot-owner maintenance, certificates of release to service, licence categories and type ratings; it does not include the AMC/GM guidance to Part-ML, which is currently only available as an unreadable 'redline' document and was excluded. Curated by Kopik from public sources: EUR-Lex / Publications Office of the European Union (reuse authorised, Decision 2011/833/EU) and EASA (reproduction authorised with acknowledgement).

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This assistant answers questions on the continuing airworthiness of light aircraft in the EU: Part-ML maintenance rules, CAO and CAMO organisations, and Part-66 aircraft maintenance licences. It is meant for aircraft owners and pilot-owners, independent certifying staff, organisation staff and licensed engineers or students. Its answers come from the consolidated text of Regulation (EU) No 1321/2014 (as of 22 February 2026) and the official EASA continuing airworthiness FAQ.

Who is responsible for keeping a light aircraft airworthy

Under Part-ML, the owner of the aircraft is responsible for its continuing airworthiness. No flight may take place unless the aircraft is maintained in an airworthy condition, its operational and emergency equipment is serviceable or clearly identified as unserviceable, its airworthiness certificate is valid and its maintenance follows the aircraft maintenance programme (AMP).

When the aircraft is leased, these responsibilities pass to the lessee if the lessee is identified in the registration document or in the leasing contract. The pilot-in-command remains responsible for the preflight inspection, which does not need to be carried out by an approved organisation or certifying staff.

For most privately operated aircraft, the owner may contract the continuing airworthiness management tasks to a CAMO or CAO under a written contract. If no such contract exists, the owner is responsible for performing those tasks properly.

The aircraft maintenance programme (AMP)

Every aircraft covered by Part-ML must be maintained according to an AMP. Where no CAMO or CAO manages the aircraft, the owner declares the AMP; otherwise, the managing CAMO or CAO approves it. Whoever declares or approves it must keep it up to date.

The AMP identifies the owner and the aircraft, including any engine and propeller, and is based either on the minimum inspection programme (MIP) or on the instructions for continuing airworthiness issued by the design approval holder or the declarant of a design compliance declaration.

For aeroplanes, touring motor gliders and balloons, the MIP sets an inspection every year or every 100 hours, whichever comes first, with a tolerance of 1 month or 10 hours. Sailplanes and powered sailplanes other than touring motor gliders follow an annual interval with a 1-month tolerance.

CAO or CAMO: two kinds of approved organisation

A CAMO (Part-CAMO) is approved for the management of continuing airworthiness of aircraft and components. A CAO (Part-CAO, combined airworthiness organisation) can hold both maintenance and continuing airworthiness management privileges, for aircraft that are not complex motor-powered aircraft and not listed on the air operator certificate of a licensed air carrier.

A CAO with management privileges can approve the AMP of a Part-ML aircraft and extend an airworthiness review certificate, and with maintenance privileges it can maintain aircraft and issue certificates of release to service. Its approved scope of work is set out in its combined airworthiness exposition (CAE).

The EASA FAQ notes that these two organisation types were introduced by Regulation (EU) 2019/1383, as of 24 March 2020.

Releasing an aircraft after maintenance

A certificate of release to service (CRS) is issued after the required maintenance has been properly carried out. Under Part-ML, it can be issued by certifying staff of an approved maintenance organisation, by independent certifying staff, or by the pilot-owner within strict limits.

If an aircraft is grounded somewhere without an approved organisation or certifying staff, the owner may exceptionally authorise a person with at least 3 years of appropriate maintenance experience and the proper qualifications to release it. That work must then be rechecked and released normally within 7 days, or within 30 days for aircraft operated under Part-NCO (and the equivalent balloon and sailplane cases), and the contracted CAMO or CAO, or the competent authority, must be notified within 7 days.

Questions fréquentes

What counts as an ELA1 aircraft?

ELA1 covers, among others, aeroplanes with a maximum take-off mass of 1 200 kg or less that are not complex motor-powered aircraft, and sailplanes or powered sailplanes of 1 200 kg or less. Certain balloons and small airships are also included, within volume limits set in the regulation.

And an ELA2 aircraft?

ELA2 includes aeroplanes of 2 000 kg maximum take-off mass or less that are not complex motor-powered aircraft, sailplanes and powered sailplanes of 2 000 kg or less, balloons and hot air ships, among other categories listed in the regulation.

Do I have to report a safety problem found on my aircraft?

Yes. Any person or organisation responsible under ML.A.201 must report a condition that endangers flight safety to the competent authority of the State of registry and to the design holder. The report must be made as soon as possible and no later than 72 hours after the condition was identified, unless exceptional circumstances prevent it.

Can a flight school's aircraft be managed by the owner alone?

No. For aircraft operated by commercial ATOs or DTOs, among other cases listed in ML.A.201(e), the operator must be approved as a CAMO or CAO or contract one, and all maintenance must be carried out by approved maintenance organisations.

Must the owner give the authority access to the aircraft?

Yes. The owner must grant the competent authority access to the aircraft and its records so that it can check compliance with Part-ML.

What does the minimum inspection programme include besides the inspection interval?

Depending on the aircraft type, the MIP includes servicing tasks required by the design approval holder, inspection of markings, review of weighing records, an operational test of the transponder if installed and a functional test of the pitot-static system. For aeroplanes it also covers power plant checks such as power and rpm, magnetos, fuel and oil pressure and engine temperatures, plus inspection of structural items, systems and components.

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claude mcp add --transport http kopik-eu-easa-continuing-airworthiness-ml-66 "https://kopik.io/api/mcp?base=eu-easa-continuing-airworthiness-ml-66" --header "Authorization: Bearer kpk_…"
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{
  "mcpServers": {
    "kopik-eu-easa-continuing-airworthiness-ml-66": {
      "url": "https://kopik.io/api/mcp?base=eu-easa-continuing-airworthiness-ml-66",
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      }
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}

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