EASA issued on 20 March 2013 a paper to answer this question (please see link here):
‘Rulemaking interpretation on “Maintenance release of aircraft not covered by the Basic Regulation” ’.
Since that time:
- the Basic Regulation (Regulation (EU) 2018/1139 was issued, repealing the previous Basic Regulation (Regulation (EC) No 216/2008); and
- Commission Regulation (EU) No 1321/2014 was issued, repealing Commission Regulation (EC) No 2042/2003.
However, the intent of that paper is still valid in describing the various practices and EASA’s position on the release of maintenance on aircraft that are aircraft excluded from complying with the airworthiness requirements contained in the Basic Regulation, and in its delegated and implementing acts.