ORO.GEN.110 (a): “The operator is responsible for the operation of the aircraft in accordance with Annex IV to Regulation (EC) No 216/2008”. Is this requirement met when an Operator follows the Implementing Rules (965/2012)?
Reference: Regulation (EU) No 965/2012 on Air Operations, Annex III (Part-ORO)
The Essential Requirements (ER) are as applicable as the implementing rules.
The operators are responsible for checking that they comply with all the Essential Requirements contained in Annex IV of the Regulation (EC) 216/2008.
Some implementing rules make a direct reference to the Essential Requirements. This is the case when an ER is not further developed in the implementing rules.