FAQ n.19363

What is a Specific Airworthiness Specification (SAS)?


Commission Regulation (EC) No 1702/2003 requires products, parts and appliances to be issued with certificates as specified in Part 21. Aircraft without a valid type certificate holder cannot comply with Subpart B of Part 21 and cannot therefore hold type certificates. The Specific Airworthiness Specification (SAS) is the replacement document. Specific Airworthiness 
Specifications are issued to aircraft without a valid Type Certificate Holder ('Orphan' aircraft) or for certain aircraft General Aviation types from CIS that have been certificated in CIS but not validated by EASA.

The eligibility of the proposed product should first be reviewed. Annex II aircraft, for example, cannot qualify for SAS as they are outside of the remit of the Agency. If a Type Certificate Holder (TCH) still exists, the preferred path to certification of the product is through a Type Certification or Type Validation. If the current Certification Specifications cannot be met, the option of a Restricted Type Certificate can be offered.

If the aircraft Type Certificate Holder is no longer in business ("orphan TC") or does not wish to apply for Type/ Restricted-Type Certification, the application for SAS can be initiated by an operator/owner. It should be emphasised that the SAS should not be seen as a mechanism for avoiding type certification in accordance with Part 21. For General Aviation types the SAS has been used to 'legalise' aircraft that had not been certificated in accordance with Part 21 but which were already on the registers of EU member states on accession to the EU. Whilst it legalises these aircraft, it is not intended to be used to allow the import of additional aircraft of the same type which should be certificated in the normal way.

The loss of an engine or propeller TC holder does not automatically invalidate the aircraft TC, so an orphan engine does not have to result in an orphan aircraft if the aircraft TC holder is prepared to accept the continued airworthiness responsibility of the engine. SASs do not apply to engines or propellers.

Before the creation of EASA, some orphan aircraft have been allowed to operate on non-ICAO level certificates of airworthiness (Permit to Fly, CDNR, etc) and cannot usually be returned to Restricted Certificate of Airworthiness standard. These examples are listed by serial number on the SAS and continue to qualify for EASA Permit to Fly under 21A.701(15). There is no intention to permit aircraft to otherwise voluntarily default to Permit to Fly if they otherwise conform to the SAS.

Aircraft conforming to the appropriate SAS are eligible for the issue of a Restricted Certificate of Airworthiness.

The SAS consists of:

  • The original State of design TCDS in EASA format
  • Airworthiness Directives
  • Instructions for reporting continued airworthiness occurrences
  • Any additional limitations including a prohibition from commercial activities#


Link to Specific Airworthiness Specifications page

See Article 5 (4) of the Basic Regulation and Regulation (EC) 1702/2003 Part 21, 21A.184

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