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FAQ n.65445

Do declared training organisations (DTO) need a CAMO/CAO and approved maintenance organisations?

Answer

Regulation (EU) No 1178/2011 was amended in July 2018 to introduce Part-DTO as regards to declared training organisations (ref. Reg. (EU) 2018/1119). Regulation (EU) No 1321/2014 was therefore amended and aligned the Continuing Airworthiness obligations of ATO with those of DTO. 

This means:

 

 

Complex motor-powered aircraft                                            

Other than complex motor-powered aircraft                                              

Commercial DTO

Applicable requirement

M.A.201(f) is applicable
 

M.A.201(h) or, for aircraft specified in Article 3(2), ML.A.201(e) are applicable
 

Continuing airworthiness management

CAMO is required

 

CAO (with continuing airworthiness management privilege) or CAMO is required

Maintenance

Part-145 organisation is required

CAO (with maintenance privilege) or Part-145 or Part-M Subpart F organisation is required

Non-Commercial DTO

Applicable requirement

M.A.201(g) is applicable

M.A.201(i) or, for aircraft specified in Article 3(2), ML.A.201(f) are applicable

Continuing airworthiness management

CAMO is required

 

CAMO is not required

CAO (with continuing airworthiness management privilege) is not required

 

Maintenance

Part-145 organisation is required

With the exception of complex maintenance tasks under Part-M:

CAO (with maintenance privilege) is not required

Part-145 organisation not required

Part-M Subpart F organisation is not required

 

Please also refer to GM1 ML.A.201(e) which provides examples of aircraft not considered to be operated by a commercial ATO or a commercial DTO.

Last updated
02/02/2021

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