A Cross-Jurisdictional Checklist for Operators, CAMOs, MROs, and Regulatory Affairs Teams
Disclaimer: This aviation compliance checklist reference guide is published by aviationregwatch.com for informational purposes only. It is not legal, regulatory, or airworthiness advice. It does not replace your obligation to consult the applicable regulations, advisory material, and guidance issued by your national civil aviation authority. Regulatory requirements differ by jurisdiction, aircraft type, operation type, and approval scope. The content reflects publicly available regulatory frameworks current as of July 2026 and may not reflect amendments, exemptions, or national variations applicable to your specific operation. Always verify requirements against the current edition of the applicable regulation and consult your CAMO, legal counsel, or regulatory authority before making compliance decisions. Aviation Reg Watch accepts no liability for actions taken or not taken based on this guide.
Quick Answers
What should an aviation compliance checklist cover?
A comprehensive aviation compliance checklist should cover airworthiness and AD compliance, continuing airworthiness management, flight operations, maintenance organization approval, Safety Management Systems, training and licensing, security, environmental obligations, insurance, passenger rights, and record-keeping — mapped across all applicable regulatory jurisdictions.
What are the main aviation compliance obligations for operators in 2026?
Key 2026 obligations include ICAO Annex 19 Amendment 2 applicability (November 26, 2026), EASA Part-IS cybersecurity compliance, FAA Part 5 SMS requirements for all certificate holders, CORSIA emissions monitoring and reporting, EU Air Passenger Rights reform preparation, and ongoing AD compliance tracking across all applicable regulatory jurisdictions.
How to Use This Guide
This guide is organized by compliance domain — not by regulator. Each section covers a functional area of aviation compliance and maps the key obligations across the major regulatory jurisdictions: FAA, EASA, UK CAA, Transport Canada, ICAO, and CASA (Australia).
Use it as a pre-audit self-check, a compliance program gap-analysis tool, or a reference when building or reviewing your compliance management framework.
It is not exhaustive. It covers the most common and most consequential obligations. Niche requirements specific to particular aircraft types, operational environments, or national variations are not included.
1. Airworthiness and Continuing Airworthiness
This is the foundation. Every aircraft on every register must maintain its airworthiness throughout its operational life. The responsibility sits with the operator or owner, typically discharged through a CAMO.
1.1 Airworthiness Directive (AD) Compliance
Obligation
Detail
Monitor applicable ADs
Track all ADs issued by your State of Registry, State of Design, and any bilateral adoption sources
Compliance tracking
Maintain a current AD status list for every aircraft. Record compliance date, method, and next action for repetitive ADs
Bilateral AD adoption
FAA ADs may adopt EASA, Transport Canada, or other MCAI sources. Confirm which version applies to your registration
AMOC management
If an Alternative Method of Compliance is approved, document the approval, method, and any conditions
Superseded AD tracking
When an AD is superseded, confirm the replacement AD’s requirements are met — do not assume continuity
Key regulators: FAA (14 CFR Part 39), EASA (Part 21 / AD system), UK CAA (assimilated Part 39), Transport Canada (CARs Part V), CASA (Part 39)
1.2 Continuing Airworthiness Management
Obligation
Detail
CAMO approval
Maintain a valid CAMO approval under your applicable regulation (EASA Part-CAMO, UK Part-CAMO, or equivalent)
Keep current. Review against regulatory amendments at least annually
Aircraft Maintenance Program (AMP)
Approved by the authority. Aligned with current manufacturer’s MPD/MRB. Updated for all applicable ADs and SBs
Airworthiness Review Certificate (ARC)
Valid and current for each aircraft. Renewal process documented
Component life tracking
Hard-time components, life-limited parts, and on-condition components tracked to current status
Reliability programme
If required by your approval scope — data collection, analysis, and escalation/de-escalation process documented
Deferred defect management
MEL/CDL items tracked, time limits monitored, rectification confirmed before expiry
Record retention
Comply with your jurisdiction’s retention requirements. Typical: aircraft records for the life of the aircraft; maintenance records 1–3 years depending on jurisdiction
Key regulators: EASA (Part-CAMO, Part-ML), UK CAA (assimilated Part-CAMO, CAP 2153), FAA (14 CFR 91.417, 121.380), Transport Canada (CARs 571/573), CASA (Part 42)
1.3 Airworthiness Limitations
Obligation
Detail
ALS/ALI incorporation
Incorporate all applicable Airworthiness Limitations into your approved maintenance program. These are mandatory — not advisory
Manufacturer revisions
Monitor for ALS revisions from the TC holder. Incorporate within the compliance time specified by your authority
Aging aircraft programs
If applicable: Widespread Fatigue Damage (WFD), Supplemental Structural Inspection Program (SSIP), Fuel Tank System Flammability Reduction, Corrosion Prevention and Control Program
EWIS compliance
Enhanced Wiring Interconnect System requirements — applicable to aircraft in accordance with Part 26 / 14 CFR 26
2. Flight Operations
2.1 Air Operator Certificate (AOC) and Operations Specifications
Obligation
Detail
AOC currency
Maintain a valid AOC. Monitor renewal dates and authority conditions
Operations Specifications (OpSpecs)
Current and aligned with actual operations. Review after any fleet, route, or operational change
Operations Manual
Approved by the authority. Updated for regulatory changes, fleet changes, and operational procedures
Minimum Equipment List (MEL)
Derived from the Master MEL. Approved by the authority. Dispatch procedures documented. Rectification intervals tracked
Flight Manual (AFM)
Current revision for each aircraft type. All AD-mandated AFM revisions incorporated
Operational limitations
Weight, altitude, runway, performance — confirmed for each route and aircraft combination
Flight and duty time limitations
Compliant with applicable FTL scheme. Records maintained. Fatigue Risk Management System (FRMS) in place if required
Key regulators: EASA (Part-ORO, Part-CAT, Part-SPA), UK CAA (assimilated Air Ops), FAA (14 CFR Parts 91, 121, 135), Transport Canada (CARs Part VII), CASA (Part 119, Part 121)
Monitor for known jamming and spoofing zones. Alternate navigation procedures documented
Radio altimeter limitations
If applicable (e.g., Canadian 5G environment): confirm AFM limitations and operating procedures are incorporated and crew briefed
Volcanic ash and weather avoidance
Procedures documented. SIGMET/AIRMET monitoring in place
3. Maintenance Organization (MRO / Part 145)
3.1 Organisation Approval
Obligation
Detail
Part 145 / equivalent approval
Current and valid. Scope of approval matches actual work performed
Maintenance Organization Exposition (MOE)
Approved by the authority. Reviewed and updated at least annually
Competence assessment
All certifying staff, support staff, and inspectors assessed for competence. Records current
Authorisation management
Individual authorizations issued, controlled, and reviewed. Scope limitations documented
Tooling and equipment
Calibrated to current standards. Calibration records maintained. Unserviceable tools quarantined
Facility standards
Adequate for the scope of work. Environmental controls (lighting, cleanliness, temperature) documented where required
3.2 Maintenance Execution
Obligation
Detail
Work order management
Every task traceable from work order to sign-off. RII (Required Inspection Items) identified and independently inspected
AD/SB compliance in shop
Confirm incoming component AD status. Do not return a component to service with an outstanding AD
Parts and materials
Only approved parts installed. Traceability documented. Suspected unapproved parts (SUP) reporting procedure in place
Shelf-stock management
Parts with life limits, AD-affected lot numbers, or storage-sensitive conditions tracked and controlled
Human factors and error management
Procedures for error capture, reporting, and investigation. Maintenance human factors training current
Occurrence reporting
Mandatory reporting to the authority within required timeframes. Internal reporting culture documented
Key regulators: EASA (Part-145), UK CAA (assimilated Part-145), FAA (14 CFR Part 145), Transport Canada (CARs 573), CASA (Part 145)
4. Safety Management Systems (SMS)
4.1 SMS Framework
Obligation
Detail
SMS required?
Mandatory for AOC holders, Part 145 organizations (in most jurisdictions), certified aerodromes, ANSPs. Expanding to RPAS operators and certified heliports under ICAO Annex 19 Amendment 2 (applicable November 26, 2026)
Safety policy
Signed by the Accountable Manager. Communicated to all personnel. Reviewed annually
Safety objectives and performance indicators
Defined. Measurable. Reviewed at management review meetings
Hazard identification
Formal process in place. Sources include occurrence reports, audits, flight data monitoring, and voluntary reports
Safety risk assessment
Documented methodology. Risk register maintained. Controls assigned and tracked
Safety assurance
Internal audits and reviews confirm the effectiveness of SMS. Management review at defined intervals
Safety promotion
Training, communication, and safety culture activities documented
4.2 Safety Intelligence (NEW — ICAO Annex 19 Amendment 2)
Obligation
Detail
Applicable from
November 26, 2026 (ICAO SARPs — implemented through national regulation)
Requirement
Develop safety intelligence — structured analysis of safety data to identify patterns and emerging risks before they become events
Gap analysis
Assess your current SMS against Amendment 2 provisions. Focus on whether your SMS turns data into decisions, not just reports
Documentation
Safety Management Manual, SPI framework, safety committee terms of reference — all require review against the new provisions
Key regulators: ICAO (Annex 19), EASA (Part-ORO Subpart GEN, implementing rules), UK CAA (assimilated SMS requirements), FAA (14 CFR Part 5), Transport Canada (CARs 107), CASA (Part 142)
5. Training and Licensing
5.1 Flight Crew
Obligation
Detail
Licence validity
All flight crew licenses current. Medical certificates valid. Ratings and endorsements current
Recurrent training
Type-specific recurrent training and checking completed within required intervals
CRM and human factors
Initial and recurrent training documented
Dangerous goods training
Where required by operational scope — initial and recurrent
Route and aerodrome competency
Where required by regulation — documented for each crew member
5.2 Maintenance Personnel
Obligation
Detail
License and authorization
All certifying staff hold valid licenses with appropriate type ratings. Authorizations issued by the organization are current
Continuation training
Completed within required intervals. Topics include regulatory updates, human factors, and type-specific technical training
Competence assessment
Documented assessment of knowledge and practical skills. Reassessment at defined intervals
Records
Training records maintained for the period specified by your authority
5.3 Approved Training Organizations (ATOs)
Obligation
Detail
ATO approval
Current and valid. Scope matches actual training delivered
Training manual
Approved. Current revision. Aligned with applicable syllabus requirements
Simulator qualification
Applicable simulator devices approved and qualified by the authority. Qualification maintained through recurring evaluations
6. Security
6.1 Aviation Security Programme
Obligation
Detail
Operator security programme
Approved by the authority. Reviewed and updated as required
Security training
All relevant personnel trained. Training records maintained
Background checks
Staff vetting completed in accordance with applicable requirements
Cargo and mail screening
Where applicable — procedures documented and audited
6.2 Information Security and Cybersecurity
Obligation
Detail
EASA Part-IS
Applicable from February 22, 2026. Organizations must reach full “Operational” and “Effective” compliance within 18 months
FAA Cybersecurity ARC
Civil Aviation Cybersecurity Aviation Rulemaking Committee established 2025 — watch for rulemaking output
Data protection
Flight data, passenger data, and operational data managed in accordance with applicable privacy regulations
Supply chain cyber risk
Third-party system providers and connected systems assessed for cyber risk
7. Environmental Compliance
7.1 Emissions and Carbon
Obligation
Detail
CORSIA
Carbon Offsetting and Reduction Scheme for International Aviation. Mandatory offsetting obligations for international flights (baseline: 85% of 2019 emissions). Monitor and report per ICAO Annex 16, Volume IV
EU ETS
Currently covers intra-EEA flights. Proposed expansion to international departures within 5,000 km from 2029 (under legislative review). Free allocation fully phased out for aviation in 2026
UK ETS
Covers UK domestic and UK-EEA flights. Separate from EU ETS. Monitor for UK-specific amendments
MRV (Monitoring, Reporting, Verification)
CO₂ emissions monitoring plans approved and implemented. Annual emissions reports verified and submitted
Night curfews, noise abatement procedures, and quota count systems at applicable airports — confirm compliance for each route
8. Passenger Rights and Consumer Protection
Obligation
Detail
EU Regulation (EC) No 261/2004
Compensation, assistance, and rerouting obligations for delays, cancellations, and denied boarding on EU flights. Major reform adopted July 13, 2026 — entry into force approximately August 2027. New obligations include 96-hour notification, 30-day claims response, 400% self-rerouting right, and no-show prohibition
UK261
UK domestic equivalent. Separate legislation. Does not automatically update with EU reform. Compensation in GBP (approximately £220–£520)
US DOT
DOT passenger protection rules. Wheelchair Rule I enforcement dates (certain provisions delayed until December 31, 2026). Refund rules for cancellations and significant delays
Montreal Convention
International carrier liability framework. Liability limits indexed periodically. Covers personal injury, death, baggage, and cargo
9. Insurance
Obligation
Detail
Minimum liability insurance
Meet the minimum requirements of your State of Registry and all states of operation. Canada: CTA indexation effective July 1, 2026 — new minimums by MCTOW bracket
Certificate of Insurance
Filed with applicable authority. Current and valid
Wet-lease and code-share
Confirm which party bears the insurance obligation under each arrangement
10. Record-Keeping and Documentation
Obligation
Detail
Aircraft technical records
Life-of-aircraft retention for airworthiness records (type certificate, modification status, AD compliance, weight and balance)
Maintenance records
Retention per jurisdiction. Typical: 1 year (routine), 2–3 years (overhaul/component), life-of-aircraft (structural)
Flight records
Flight time, crew assignments, fuel — retained per applicable FTL and operational regulation
Electronic records
If using electronic systems: data integrity, backup, access control, and e-signature compliance documented
Transfer of records
On aircraft sale, lease return, or change of CAMO — complete records package transferred with the aircraft
This reference guide is maintained by aviationregwatch.com as a resource for aviation compliance professionals. It is updated periodically to reflect significant regulatory changes.
It is not a substitute for the applicable regulations, advisory material, or guidance published by your national civil aviation authority. Requirements differ by jurisdiction, operation type, aircraft type, and approval scope. Always verify against the current edition of the applicable regulation.
For compliance decisions specific to your operation, consult your CAMO, legal counsel, or regulatory authority directly.
Last reviewed: July 2026
aviationregwatch.com publishes regulatory intelligence for aviation compliance professionals.