Understanding Part 26

Before we dive into Part-26, let’s clear up a common point of confusion: the difference between the Part-145 maintenance organisation and the Continuing Airworthiness Management Organisation (CAMO). Both are essential to keeping aircraft airworthy—but they play very different roles.

The CAMO 

....is responsible for managing the ongoing airworthiness of the aircraft. That means planning maintenance, ensuring compliance with airworthiness directives and regulations, reviewing technical data and making decisions about when and how changes are applied.

The Part-145 Organisation

....on the other hand, is responsible for doing the work, i.e. carrying out the inspections, repairs, modifications and routine servicing. 

So, when a regulation like EASA’s Part-26 introduces a mandated change, the CAMO leads the planning and compliance and the Part-145 team carries out the physical implementation.

Now onto Part-26

We all know that modern aircraft are built to last.  Keeping those safe over decades of service, however, means more than just good maintenance, it means understanding how design continues to evolve after an aircraft enters service.  This is where EASA Part-26 comes in.”

Whilst it might not be the most well-known piece of aviation regulation, for anyone responsible for operational safety or airworthiness oversight, it’s something you need to be familiar with and understand why it matters. This article is here to help you understand your role, especially as EASA rolls out new changes under Part-26.

What is Part-26?

Part-26 is a set of EASA rules focused on continuing airworthiness and safety improvements. It specifically affects aircraft which have already a type certificate; i.e. they are already in operation or will be manufactured in short/medium term.

There are two scenarios, and this is where it’s important for operators. 

In many cases, the type-certificate holder (usually, the original equipment (aircraft) manufacturer – the OEM) will evaluate their older aircraft designs against new Part-26 requirements and then develop compliance documents or retrofit solutions to support their operators upon request. This is certainly true for operators of aircraft manufactured by EU design holders like Airbus and ATR who fall under the oversight of EASA, but this is not always the case for manufacturers in other parts of the world. 

As the operator of a particular aircraft, however, it is your responsibility to make sure all your aircraft meet any relevant Part-26 requirement. The aircraft cannot fly anymore without the right changes indicated in Part-26 being implemented at the time of the Certificate of Airworthiness (CofA).  

Reinforcing Why It Matters to Operators

So, while you might have been thinking, “this sounds like a job for the manufacturer,” hopefully this last point really hits home. 

The moment EASA mandates a design change under Part-26, operators often become responsible for implementation.

For an operator, that means the following things:

• The Continuing Airworthiness Management Exposition (CAME) will need to be updated to reflect new requirements.

• The fleet will need to be assessed to see which aircraft are affected and liaise with the OEM to identify what they might have already done to deal with the change. 

• Coordinate modification schedules and downtime planning.

• Ensure correct installation of updated equipment, systems, and/ or structural reinforcements as needed. 

• Record the compliance status of each aircraft for the CofA, audits and oversight.

In short: when a new requirement under Part-26 is issued, your CAMO and technical teams need to be ready. It is important to monitor EASA publications and OEM updates regularly to stay aware of changes. 

EASA continually communicates any changes and new rules so hopefully nothing will take you by surprise, which is the primary purpose of this article. 

Upcoming Changes and New Requirements

Large aeroplane operators should be aware of the following important change coming in Part-26 that you should be aware of: 

• From 1 July 2026: Large aeroplanes should be installed with a Runway Overrun Awareness and Alerting System (ROAAS) to reduce the risk of a longitudinal runway excursion during landing. 

Here it is an opportunity to also remind about Halon replacement. In Part-26 there was already the requirement large aircraft having their first CofA issued as of 18 May 2019 are equipped with halon-free portable fire extinguishers. Please, also  keep in mind that the Ozone Regulation is requiring that:

• From 31 December 2025: Halon-based portable fire extinguishers should be replaced (this applies to all aircraft and helicopters – not just large aeroplanes).

For more information about Part-26 requirements, visit the EASA Easy Access Rules page on the EASA website here. 

Final Thought: Part-26 is About Proactive Safety (and Environmental Protection as well)

We believe that people create safety—but that also means we must stay connected to the systems and regulations designed to keep us flying safely.

Part-26 may sit in the background of day-to-day operations, but it plays a critical role in aligning old designs with today’s safety expectations. For safety and technical teams, that means knowing what’s coming, understanding what it means, and acting early to make sure it’s done right.

If you’re involved with airworthiness, your job doesn’t stop at compliance, it takes clear communication and good planning to make sure the changes that matter get done safely.

Finally, some of the Part-26 change also help us to be more sustainable and environmentally friendly. One recent example was the change to replace all the Halon fire extinguishers on our aircraft. Being safe and sustainable helps to look after our passengers and our planet.