EASA Airworthiness Review Certificate: The Complete Guide for Private Owners

EASA Airworthiness Review Certificate: The Complete Guide for Private Owners

Meta description: Learn what the EASA airworthiness review certificate covers, how the ARC renewal process works, and what documents you need to prepare.

Your ARC expires in eight weeks. You know the aircraft needs a review before you can legally fly it again, but the specifics are hazy. What exactly will the reviewing engineer inspect? Which documents do you need to have ready? And what happens if something in your maintenance records doesn’t add up? This guide covers exactly what private owners need to know about the EASA airworthiness review certificate—no padding, just the information you need to prepare properly.

What the Airworthiness Review Certificate Actually Is

The Airworthiness Review Certificate is the document that confirms your aircraft remains in compliance with its type design and is safe to operate. Without a valid ARC, your aircraft cannot fly under EASA regulations—full stop. It’s the regulatory mechanism that forces a periodic verification of your aircraft’s continuing airworthiness status.

The ARC is governed primarily by Part-ML for aircraft used in non-commercial operations (which covers most private owners), specifically ML.A.901 through ML.A.905. For aircraft under Part-M (typically commercial or more complex operations), the equivalent requirements sit in M.A.901 and related sections.

The certificate itself is EASA Form 15c for Part-ML aircraft. It states the aircraft registration, the date of issue, the expiry date, and confirms that at the time of review, the aircraft was found airworthy in accordance with the applicable requirements.

One critical point: the ARC is not a maintenance release. It doesn’t replace the Certificate of Release to Service after maintenance work. It’s a separate, higher-level confirmation that looks at the complete airworthiness picture—maintenance records, modifications, ADs, life-limited components, and the physical condition of the aircraft.

Who Can Issue an ARC and How Long It Lasts

For private owners operating under Part-ML, two routes exist for ARC issuance and renewal:

Route 1: CAMO or CAO
A Continuing Airworthiness Management Organisation (CAMO) or Combined Airworthiness Organisation (CAO) with the appropriate privilege can issue and renew your ARC. They take responsibility for verifying the complete airworthiness status.

Route 2: Appropriately Qualified Personnel
Under Part-ML, certain licensed engineers can conduct airworthiness reviews and issue or extend ARCs. Specifically, ML.A.903 permits licensed certifying staff holding a Part-66 licence with appropriate type rating, or personnel specifically authorised by the competent authority, to perform this function for ELA1 and ELA2 aircraft. [VERIFY: ML.A.903(1) — confirm current scope of personnel privileges for ARC issuance]

The validity period is straightforward: 12 months from the date of issue. The expiry date is printed on the certificate. Flying with an expired ARC means flying an aircraft that is not legally airworthy under EASA rules.

The Two-Extension Rule

Here’s where many owners get confused. An ARC can be extended twice—each extension adding 12 months—without requiring a full airworthiness review, provided certain conditions are met. After two extensions, a full review is mandatory.

The conditions for extension under ML.A.901(c) include:

• The aircraft has been maintained by an appropriately approved organisation or certifying staff
• No airworthiness issues have been identified that would affect the aircraft’s continued airworthiness
• The person extending the ARC has verified the maintenance records and confirmed compliance

This means your ARC can theoretically cover three years (initial issue plus two extensions) before requiring another full physical inspection and documentation review. However, each extension still requires someone qualified to verify the records and confirm no issues exist. It’s not automatic.

Practical tip: Many owners use the extension option to align ARC renewals with annual inspections or seasonal maintenance schedules. But don’t rely on extensions to avoid proper reviews—they exist for flexibility, not as a shortcut.

What the ARC Engineer Actually Checks

The airworthiness review is a two-part process: documentation review and physical survey. Understanding what’s checked helps you prepare properly.

Documentation Review

The reviewing engineer or organisation must verify:

Maintenance records: Complete and continuous records showing all maintenance performed, including scheduled maintenance per your Aircraft Maintenance Programme (AMP), unscheduled maintenance, defect rectification, and component replacements.

Airworthiness Directives: Evidence that all applicable ADs have been complied with. This means cross-referencing the current AD status for your aircraft type, engine, propeller, and any appliances against your maintenance records.

Type Certificate and modifications: Confirmation that the aircraft conforms to its type design. Any modifications or repairs must be properly documented and approved (STC, EASA minor modification, etc.).

Life-limited components: Verification that all components with life limits (calendar, hours, or cycles) are within limits and properly tracked.

Weight and balance: Current weight and balance report reflecting the actual aircraft configuration.

Flight manual: Correct and current version for your aircraft.

Aircraft Maintenance Programme: Valid, current AMP appropriate for your aircraft and approved or declared in accordance with Part-ML.

Certificate of Registration and CoA: Valid and matching the aircraft.

Noise and emissions certificates: Where applicable.

Physical Survey

The physical inspection is not a full annual inspection—it’s a survey to verify the aircraft’s general condition matches what the paperwork suggests. The engineer will typically check:

• General external condition: corrosion, damage, missing panels, security of fairings
• Landing gear condition and tyre wear
• Engine compartment: leaks, security, general condition
• Propeller: damage, erosion, security
• Control surfaces: freedom of movement, security, condition
• Cockpit: instruments readable, placards present, required equipment installed
• Safety equipment: fire extinguisher, first aid kit (where required), ELT status

The physical survey must identify any obvious defects and verify the aircraft hasn’t been operated beyond limitations or with unresolved defects.

Grounds for ARC Refusal or Suspension

An ARC will be refused or suspended if the aircraft fails to meet airworthiness requirements. Common reasons include:

Incomplete or inconsistent records: Gaps in the maintenance documentation, missing logbook entries, or records that don’t add up. If the engineer cannot verify continuous airworthiness, they cannot issue the ARC.

Outstanding Airworthiness Directives: Non-compliance with mandatory ADs—especially repetitive ADs with expired intervals—is an automatic failure.

Exceeded life limits: Any life-limited component found beyond its approved limit stops the process immediately.

Unresolved defects: Known defects that haven’t been properly deferred or rectified.

Invalid or expired AMP: Operating without a valid maintenance programme, or with one that doesn’t match your actual operations.

Physical condition issues: Significant corrosion, obvious damage, or safety-critical defects found during the physical survey.

Modifications without approval: Unapproved modifications or alterations to the aircraft.

If the ARC is refused, you cannot fly the aircraft until the deficiencies are corrected and a new review confirms compliance. If your ARC is suspended (say, due to a newly discovered issue), the same applies—no flight operations until resolved.

CAMO vs. Self-Managing Under Part-ML: What’s the Difference?

Private owners under Part-ML have a choice: contract with a CAMO to manage continuing airworthiness, or self-manage.

With a CAMO:
The CAMO takes responsibility for managing your aircraft’s continuing airworthiness. They track maintenance due dates, AD compliance, life-limited components, and coordinate the ARC process. They can issue and renew your ARC directly. The owner still has legal obligations, but the CAMO handles the administrative complexity. This suits owners who want hands-off management or who operate more complex aircraft.

Self-managing:
You, as the owner, are responsible for ensuring continuing airworthiness. You must have a valid AMP (either the TCDS minimum inspection programme or a custom programme declared to your NAA), track all maintenance requirements, ensure AD compliance, and arrange for a qualified person to conduct airworthiness reviews. The owner declares their AMP under Part-ML rather than having it approved by a CAMO.

Self-management works well for owners who are engaged with their aircraft’s maintenance and keep meticulous records. It requires more personal involvement but gives direct control over scheduling and costs.

The ARC process itself is similar in both cases—the same documentation and physical survey requirements apply. The difference is who manages the ongoing tracking and who takes administrative responsibility for the airworthiness status between reviews.

How Squawkd Helps

Squawkd’s aircraft management tools track your ARC expiry alongside all your other airworthiness items—ADs, life-limited components, and scheduled maintenance tasks. When your ARC review approaches, you can pull the complete documentation package the reviewing engineer needs directly from the platform, eliminating last-minute scrambles through logbooks.

Frequently Asked Questions

Q: Can I fly while waiting for my ARC renewal appointment?
No. Once your ARC expires, the aircraft is not legally airworthy under EASA regulations. You cannot fly it—even to reposition for the review—until a new ARC is issued or the existing one is extended. Plan your renewal timing so you’re not grounded waiting for an available slot.

Q: What if my ARC engineer finds a minor discrepancy during the review?
Minor discrepancies don’t necessarily mean automatic refusal. If an issue can be quickly resolved (a missing signature, a minor paperwork correction), many engineers will allow you to fix it during the review process. However, airworthiness-affecting issues must be resolved before the ARC can be issued. The engineer cannot sign off on an aircraft that doesn’t meet requirements, regardless of how inconvenient the timing.

Q: Do I need a new ARC if I change my aircraft’s registration to another EASA state?
Generally, yes. When you transfer registration between EASA member states, the receiving state’s competent authority will require verification of airworthiness status. This typically involves a new airworthiness review and ARC issuance under the new state’s oversight. The specific process varies by NAA, so contact the receiving state’s authority early in your transfer planning.

Tags: EASA airworthiness review certificate, ARC renewal, Part-ML, continuing airworthiness, aircraft maintenance programme, private owner maintenance, CAMO

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