FAQ n.19491

The provisions for a Pilot-Owner or Flight Crew to accomplish AD actions are to be found in Commission Regulation (EU) No 1321/2014 on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these tasks, Annex I (Part-M), Annex II (Part-145), Annex Vb (Part-ML) & Annex Vd (Part-CAO).

For AD tasks carried out by Flight Crew:

• IF INDICATED IN THE AD (*- see Note), THE FOLLOWING APPLIES:
  145.A.30(j)3 or M.A.606(h)1 Personnel requirements, or CAO.A.040(c)(1) Certifying staff.

For a repetitive pre-flight task, where the AD specifically states that the flight crew may carry out such task, the organisation (Part-145, Part-M Subpart F or Part-CAO maintenance organisation) may issue a limited certifying staff authorisation to the pilot-in command/aircraft commander on the basis of the flight crew licence held, provided that the organisation ensures that sufficient practical training has been carried out to ensure that such person can accomplish the AD task to the required standard. A repetitive pre-flight task in an AD does not mean that the task needs to be certified prior to each flight. At AD issuance EASA will determine that the task is simple enough and does not require complex tools nor complex instructions, which allows the Maintenance Organisation to authorise the person.

• IF NOT INDICATED IN THE AD, THE FOLLOWING APPLIES:
  145.A.30(j)4 or M.A.606(h)2 Personnel requirements, or CAO.A040(c)(2) Certifying staff.

In the case of aircraft operating away from a supported location the organisation may issue a limited certification authorisation to the pilot-in command/aircraft commander on the basis of the flight crew licence held, provided that the organisation ensures that sufficient practical training has been carried out to ensure that such person can accomplish the specified AD task to the required standard. The organisation’s manual shall include specific procedures for such authorisations, and in addition the task must be simple maintenance.

For AD actions performed by Pilot-Owner for aircraft subject to Part-M:

M.A.803 Pilot-owner authorisation

• This is only applicable for other than complex motor-powered aircraft of 2 730 kg MTOM and below, which are not used commercially;
• The accomplishment of an AD task by the Pilot-Owner is permitted only in the case where it is specifically allowed in the AD (* - see Note); and
• Furthermore, it is only permitted to the Pilot-Owner under the conditions of M.A.803 (a) and (b) (limited Pilot-owner maintenance (Appendix VIII to Part-M)).

For AD actions performed by Pilot-Owner for aircraft subject to Part-ML:

ML.A.803 Pilot-owner authorisation

• This is only applicable to aircraft not operated commercially, to balloons not operated under Subpart-ADD of Regulation (EU) 2018/395 or to sailplanes not operated under Subpart DEC of Regulation (EU) 2018/1976;
• The accomplishment of an AD task by the Pilot-Owner is permitted only in the case where it is specifically allowed in the AD (* - see Note); and
• Furthermore, it is only permitted to the Pilot-Owner under the conditions of ML.A.803 (a) and (b) (limited Pilot-owner maintenance (Appendix II to Part-ML)).

* Note: For ADs issued by EASA, when the flight crew / pilot-owner is entitled to carry out the AD task(s) subject to the applicable requirements, the AD will contain a text similar to the following:

The action(s) required by paragraph (x) of this AD may be accomplished, as appropriate: either by suitably authorised flight crew under the provisions of Commission Regulation (EU) No 1321/2014 145.A.30(j)3, M.A.606(h)1, or CAO.A.040(c)(1), as applicable; or by the pilot-owner under the provisions of M.A.803 or ML.A.803, as applicable, of the same regulation.

In respect of aircraft not subject to (EU) No 1321/2014, the State of Registry should consider if the national regulations allow the action(s) to be accomplished by the flight crew or pilot owner.