FAQ n.136735

The AMC1 21.A.7(c), point (a)(3)(ix), states:
‘(ix)        It is assumed that for those ICA  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 points 21.A.21(c)(4), 21.A.44 and 21.A.7. This is to satisfy EASA that such a delayed publication will not have an adverse effect on the continuing airworthiness of any individual aircraft. To allow the timely review and incorporation of a delayed part of the ICA 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, the Agency considers that the delayed ICA should typically be made available two years before the actual ICA has 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 ICA or the ICA itself, but they should not be less than 1 year before the ICA has to be used.’

This quoted point is belonging to Option 3 regarding the ICA availability - i.e. ICA available after the entry into service (EIS). Here the meaning is not that all ICA have to be seen by EASA (even if some are delayed) at EIS but that those which are not delayed - i.e. those available at EIS - should not be available only to EASA but should be available to owners/operators as well (see also the answer to the question 6, above).

EASA does not need to see systematically ICA furnished at EIS, ICA is an obligation of the approval holder. EASA may request involvement in the post-approval activities for ICA via a certification plan or dedicated actions raised. 

See also AMC1 21.A.7(c) point a(3) (vi) and (vii).