The CS-FSTD(A) - issue 2 was published on 3rd May 2018. When does the applicant/operator need to comply with issue 2?
ARA.FSTD.100, especially ‘AMC1 ARA.FSTD.100(a)(1) (b)(1)’:
Once an FSTD is contracted to be built, the organisation that is to operate the FSTD should ensure that the regulatory standard upon which the FSTD will eventually be qualified against is acceptable to the competent authority. This should be the current applicable version of CS-FSTD(A) or CS-FSTD(H) at the time of application.
And Article 2 of the ED Decision 2018/006/R) states:
‘…the day following that of its publication in the Official Publication of EASA’, which is the 4th of May 2018.
From that date on you may use Issue 2 for the initial evaluation of a device. This date is followed by a transition period until ‘...the applicability date of the related Commission Regulation’. The publication of this Commission Regulation is still pending but is expected for April 2019.
That means that the transition period is from 4th of May 2018 until April 2019. From April 2019 (unless the date is further extended due to delays with the regulation) Issue 2 has to be applied.