Amends Commission Regulation (EU) No 1321/2014 (continuing airworthiness) · entered into force February 8, 2026 · applies from August 7, 2026 (per EASA’s weekly regulatory review) · scope: EASA Member States
Quick Answers
What changed for the airworthiness review?
The rules on the airworthiness review and the Airworthiness Review Certificate (ARC) under Part-M (Annex I to Regulation (EU) 1321/2014) are rewritten: an ARC remains valid for 1 year with up to two consecutive 1-year extensions; the review may now be performed up to 90 days before ARC expiry without breaking the review-pattern continuity; the review itself may not be subcontracted; and a copy of any ARC issued or extended must reach the Member State of registry within 10 days.
Who is affected?
CAMOs and CAOs performing airworthiness reviews (Annex Vc Part-CAMO and Annex Vd Part-CAO scopes), owners/operators under Part-M and Part-ML, airworthiness review staff, and competent authorities — across all EASA Member State aircraft.
Is this a new burden?
Mostly, no — it is a modernization that clarifies and stabilizes long-practiced review patterns (e.g., the 90-day early-review window) and adds a formal intra-EU registration-transfer procedure (M.A.905).
Does it affect non-EU CAMOs?
Yes, where they hold EASA approvals (Part-145 organizations, CAMOs of EU-registered aircraft) and perform airworthiness reviews within an EASA approval scope.
Quick Compliance Summary
| Field | Detail |
|---|---|
| Regulatory body | European Union — amending Regulation (EU) 2026/100 of the Commission; implemented by EASA Members |
| Instrument | Commission Regulation (EU) 2026/100 — amends Regulation (EU) No 1321/2014 (continuing airworthiness) |
| Status | Applicable August 7, 2026 (entered into force February 8, 2026) |
| Key amendments | Replaces points M.A.901–M.A.905 (airworthiness review general rules, ARC validity, review process, review staff, registration transfer) and associated parts |
| ARC validity | 1 year; extendable twice, each for 1 year; continuity rules for extension timing |
| Early review window | Review may be carried out ≤90 days before ARC expiry with no loss of pattern continuity |
| Prohibitions | Airworthiness review may not be subcontracted; ARC must not be issued where there is evidence the aircraft is not airworthy |
| Reporting | ARC copy to the Member State of registry within 10 days of issue/extension |
| Light GA provision | For aircraft ≤2,730 kg MTOM, the competent authority may carry out the review and issue the ARC at the owner’s request |
| Enforcement | An aircraft may not fly with an invalid ARC or where continuing airworthiness does not meet the regulation |
Who Should Read This
- CAMO managers and airworthiness review staff (AR staff) — revised M.A.901–905 process and signatures
- Continuing Airworthiness Organizations (CAO) under Part-CAO — scope of review authority per CAO.A.095(c)(1)
- Owners and operators of EU-registered aircraft (Part-M / Part-ML) — ARC extension timing and the ≤2,730 kg authority-review option
- Owners buying/selling EU-registered aircraft — new intra-EU registration-transfer continuity procedure
- EASA-approved Part-145 and CAMO training providers — update of procedures, exposition and examiner material
- Non-EU organizations with EU-registered aircraft in their fleet — review-planning windows change
At a Glance
| Item | Detail |
|---|---|
| Base regulation | Commission Regulation (EU) No 1321/2014 (continuing airworthiness) |
| Annexes referenced | Annex I (Part-M), Annex Vc (Part-CAMO), Annex Vd (Part-CAO); airworthiness certificates per Regulation (EU) No 748/2012 (Part 21 / Part 21 Light) |
| ARC validity | 1 year + max two consecutive 1-year extensions |
| Extension start date | Previous expiry date if carried out ≤30 days before/after expiry; otherwise the extension date |
| Review performance | Documented review of continuing airworthiness records + physical survey; not subcontracted |
| ≤2,730 kg MTOM option | Competent authority may review and issue ARC at the owner’s request |
| ARC copy to authority | Within 10 days of issue or extension |
What This Does
Regulation (EU) 2026/100 rewrites the core Part-M provisions governing the airworthiness review so that the certificate’s life-cycle is explicit and predictable: validity — an ARC is valid for 1 year and may be extended twice, each extension adding 1 year, with clear rules on when the extension clock starts; timing flexibility — the next review can be performed up to 90 days before expiry without breaking the continuity of the review pattern; integrity — the review cannot be subcontracted, and an ARC cannot be issued where there is evidence the aircraft is not airworthy; traceability — a copy of every issued or extended ARC goes to the registry authority within 10 days; and mobility — a new procedure (M.A.905) covers transfer of aircraft registration within the Union, preserving ARC continuity through the transfer.
Organizations approved under Part-CAMO (CAMO.A.125(e)) or Part-CAO (CAO.A.095(c)(1)) may continue to perform reviews within their scope; AR staff who carried out the review must sign the ARC or recommendation.
What it does NOT do
- It does not create new inspection intervals for the aircraft itself — the maintenance program rules are unchanged.
- It does not change ARC validity for Part-ML aircraft differently from Part-M — validity logic applies consistently.
- It does not authorize CAMOs to outsource the review function — subcontracting is expressly prohibited.
Why This Exists Now
The change is part of the EU’s continuing-airworthiness simplification agenda. Experience with the airworthiness review since the original 1321/2014 framework showed operators and authorities needed: a stable, predictable ARC extension pattern (the two-extension rule), clarity that reviews close to expiry do not reset the pattern, a formal route for intra-EU registration transfers (which had previously been handled inconsistently between Member States), and sharper rules on who may perform and sign reviews.
The regulation entered into force on 8 February 2026 and — as reported in EASA’s weekly regulatory review (Week 34, 17–23 August 2026) — became applicable on 7 August 2026.
Operational Impact Matrix
| Affected function | Action required | Deadline / driver | Reference |
|---|---|---|---|
| CAMO (Annex Vc) | Update exposition/procedures for M.A.901–905; confirm review-scope approvals (CAMO.A.125(e)); update AR-staff signing arrangements | Applicable from Aug 7, 2026 | Part-CAMO; M.A.901(d) |
| CAO (Annex Vd) | Confirm review authority per CAO.A.095(c)(1) and align procedures | Applicable from Aug 7, 2026 | Part-CAO |
| AR staff | Update review checklists to the new M.A.903 process; document physical survey + records review | Next review after Aug 7, 2026 | M.A.903 |
| Owners (<2,730 kg) | Be aware of the option to request authority-performed review; ARC copy flows to registry within 10 days | Ongoing | M.A.901(j) |
| Fleet sales / registration transfers | Use the M.A.905 transfer procedure to preserve ARC continuity during intra-EU transfers | At each transfer | M.A.905 |
| Competent authorities | Accept ARC copies within 10 days; handle authority reviews for ≤2,730 kg aircraft | From Aug 7, 2026 | M.A.901(j), M.A.901(i) |
Compliance Checklist
- Procedures/exposition updated to M.A.901–M.A.905 revisions
- ARC tracking shows 1-year validity and the one-or-two-extension logic per aircraft
- Review planning uses the ≤90-day early window without resetting the pattern
- Subcontracting of the airworthiness review confirmed absent from all provider arrangements
- AR-staff signature rules aligned with M.A.901(d)
- 10-day transmission of issued/extended ARC copies to registry implemented
- Intra-EU registration-transfer checklist implemented per M.A.905
- For ≤2,730 kg aircraft: owner advisory on authority-review option published/communicated
ARW take: this is a low-risk modernization, but the 90-day early-window and the two-extension rule are exactly the clauses that generate audit findings when staff are unaware of them.
The most practical impact is on fleet transfers: buyers and sellers of EU-registered aircraft should build the M.A.905 continuity step into the technical handover checklist now, rather than discovering the requirement mid-transfer.
Watch for the corresponding Easy Access Rules revision, which EASA historically publishes shortly after application.
Key Dates
| Milestone | Date |
|---|---|
| Regulation (EU) 2026/100 entered into force | February 8, 2026 |
| Application date | August 7, 2026 |
| EASA Easy Access Rules update | Watch item — follow EASA publications |
Source Documents
- EUR-Lex — Commission Regulation (EU) 2026/100 (full text)
- EASA — Regulations portal (Easy Access Rules: Continuing Airworthiness — Reg (EU) 1321/2014)
- Secondary — EASA Weekly Regulatory Review, Week 34 (17–23 August 2026): application date of August 7, 2026 (LinkedIn post)
FAQ
I perform the review 75 days before the ARC expires and the aircraft is released with a big shortfall — is the pattern lost?
No. A review conducted within ≤90 days of expiry does not break the continuity of the review pattern (M.A.901(f)).
Can a CAMO hand the review to a subcontracted organization?
No. The airworthiness review may not be subcontracted (M.A.901(g)).
How long is my ARC valid, and can I extend it?
1 year, plus up to two consecutive 1-year extensions, subject to the conditions in M.A.902.
We operate light aircraft (≤2,730 kg MTOM). What’s new for us?
On request, the competent authority may carry out the review and issue the ARC itself (M.A.901(j)); the extension conditions in M.A.902(b) also apply to your maintenance release path.
Does this apply to UK-registered aircraft?
No. The UK left the EASA system; UK CAA rules under UK Regulation (EU) No 1321/2014 follow their own amendment path.
Related Reading
- FAA Radio Altimeter Final Rule — 5G Interference (ARW template reference article)
- EU Air Passenger Rights Regulation Formally Adopted — First Overhaul of EC 261/2004 Since 2004
- EASA Easy Access Rules for Continuing Airworthiness — June 2026 Revision Incorporates Electric and Hybrid Aircraft Requirements
- EU ETS Aviation Free Allowances Fully Phased Out in 2026 — 330 Million Allowances to Be Surrendered, July Scope Assessment Approaching
© 2026 Aviation Reg Watch. This article is an informational summary compiled from the sources listed above, not legal or airworthiness advice. Verify against the primary source (EUR-Lex full text) before making compliance decisions. Consult your CAMO, competent authority, or legal counsel for fleet-specific actions.