Pilot-Owner Maintenance on EASA Light Aircraft: What You Can and Can't Certify Yourself

If your light aircraft sits on an EU Member State register and is flown non-commercially, Part-ML allows you, as pilot-owner, to certify limited pilot-owner maintenance: simple visual inspections or operations to check general condition, obvious damage and normal operation. Critical maintenance tasks, complex tasks, anything needing special tools or test equipment, and the 100-hour/annual check are excluded. The certificate of release to service (CRS) goes in the logbooks, and the regulation sets a 30-day limit for entering it in the records.

First, which rulebook are you under?

A word for UK readers before anything else. Since Brexit the United Kingdom has run its own continuing airworthiness regime under the CAA. That regime is not in the material this article is based on, so nothing below describes what applies to a UK-registered aircraft. This article covers only the EU rule: Annex Vb (Part-ML) to Regulation (EU) No 1321/2014, consolidated to 22 February 2026, and EASA's official continuing airworthiness FAQ.

Under Article 1 of the regulation, the EU rules follow the register: they apply to aircraft registered in a Member State (unless their oversight has been delegated to a third country and they are not used by an EU operator), and to third-country-registered aircraft used by an EU operator where oversight has been delegated to a Member State. So a UK resident who owns a share in an aircraft registered in an EU Member State is under Part-ML for that aircraft, provided it falls within the Part-ML weight and type limits.

The two conditions in ML.A.803(a)

To be a pilot-owner in the EASA sense, you must satisfy both of the following:

1. You hold a valid pilot licence, or equivalent licence, issued or validated by a Member State for the aircraft type or class rating.
2. You own the aircraft, solely or jointly, either as a natural person named on the registration form, or as a member of a non-profit recreational legal entity shown on the registration document as owner or operator, who is directly involved in its decision-making and designated by it to carry out pilot-owner maintenance.

The licence must be one “issued or validated by a Member State”. The base does not deal with how a licence from outside the EU is validated or recognised, so a UK licence holder should put that question to the competent authority of the Member State of registry (ML.1(b)) before relying on the pilot-owner route.

ML.A.803(b) adds a condition on operations: the pilot-owner may issue a CRS for aircraft operated under Annex VII (Part-NCO) to Regulation (EU) No 965/2012, balloons not operated under Subpart-ADD of Part-BOP, and sailplanes not following Subpart DEC of Part-SAO. In plain terms, EASA's FAQ describes this as aircraft not operated commercially.

What is allowed, and the principles behind it

Appendix II to Part-ML authorises “simple visual inspections or operations to check the airframe, engines, systems and components for general condition, obvious damage and normal operation.” It frames that permission with three principles:

• the pilot-owner is always responsible for any maintenance he or she performs;
• the pilot-owner must have a satisfactory level of competence for the task, and must become familiar with the standard maintenance practices for the aircraft and with the aircraft maintenance programme (AMP);
• the maintenance data under ML.A.401 must be available during the work and must be followed.

Anything the flight manual describes as preparing the aircraft for flight is not maintenance at all: rigging a glider's wings, the pre-flight inspection, or putting together a balloon's basket, burner, fuel cylinders and envelope. No CRS is needed, though whoever assembles the parts must ensure they are eligible and serviceable.

Where the line is drawn: the nine exclusions

A pilot-owner shall not release a maintenance task if any of the following applies (Appendix II, point (b)). The list cannot be relaxed by less restrictive instructions in the AMP.

1. It is a critical maintenance task, meaning one that disturbs or assembles a system or part where an error could directly endanger flight safety (Article 2(n)).
2. It requires removal of major components or a major assembly.
3. It is done to comply with an AD or an airworthiness limitation item, unless the AD or ALI specifically allows it.
4. It needs special or calibrated tools, except a torque wrench and a crimping tool.
5. It needs test equipment or special testing, such as NDT, system tests or operational checks on avionics.
6. It is an unscheduled special inspection, such as a heavy-landing check.
7. It affects systems essential for IFR operations.
8. It is a complex task under Appendix III, or component maintenance under ML.A.502(a) or (b).
9. It forms part of the 100-h/annual check.

Appendix III in brief

Appendix III spells out complex tasks reserved for an approved maintenance organisation or independent certifying staff. They include riveted, bonded, laminated or welded repairs to primary members such as spars, spar flanges, wing main ribs, engine mounts, fuselage longerons and frames, landing-gear struts, axles and wheels; repairs to skin needing a jig or fixture; repairs to load-bearing control parts such as bell cranks and torque tubes; most piston engine dismantling; disassembly of engines, main batteries or fuel cells beyond removal and refitting; work on high-pressure power-plant lines; and propeller balancing beyond the stated exceptions.

Can I carry out an AD myself?

Only in a narrow case. EASA's FAQ sets out three conditions for Part-ML aircraft: the aircraft is not operated commercially; the AD specifically permits the pilot-owner to accomplish the action; and the task stays within ML.A.803(a) and (b) and Appendix II. An EASA AD that grants the permission says so in terms, referring to accomplishment by the pilot-owner under M.A.803 or ML.A.803. Where the AD says nothing, exclusion (3) above applies.

Recording the work: logbook entry and deadlines

ML.A.803(c) requires the pilot-owner CRS to be entered in the logbooks with basic details of the work, the maintenance data used, the completion date, and the pilot-owner's identity, signature and pilot licence (or equivalent) number.

Keep the AMP in mind as well. ML.A.302(e)(4) says the option of running without a separate AMP document is lost if the pilot-owner, or any of the pilot-owners on a jointly owned aircraft, is not authorised to do pilot-owner maintenance, because that authorisation has to be written into the declared or approved AMP.

A practical sequence for syndicate members

Group ownership is common for light aircraft, and that is where pilot-owner rules most often go wrong. A sensible sequence:

1. Confirm each member who will do maintenance is named on the registration form, or designated by the non-profit entity that is.
2. Check that each such member's licence is issued or validated by a Member State for the class or type.
3. Make sure the declared or approved AMP names pilot-owner maintenance as authorised.
4. Agree who records defects: under ML.A.403, any defect not rectified before flight is entered in the record system and made available to the pilot.
5. Keep the maintenance data used, and quote it in each CRS.

When in doubt, the cleanest test is to put the exact task to the EASA continuing airworthiness knowledge base, for example “As a pilot who owns my plane, can I carry out an airworthiness directive inspection myself instead of paying a mechanic?” The answer quotes the relevant point of Part-ML or the FAQ.

This article summarises EU law and is not advice on any particular aircraft. Read the consolidated regulation on EUR-Lex and EASA's FAQ. The UK CAA regime and EASA's AMC/GM to Part-ML are outside the knowledge base.