Airworthiness Review Certificates: Roles, Responsibilities and Regulatory Boundaries

By Florin Necula, PhD | CAMO NP & Licensed Aircraft Engineer
Jan 6^th, 2026

1. INTRODUCTION AND BACKGROUND

The Airworthiness Review Certificate (ARC) is a foundational element within the European continuing airworthiness regulatory framework. Established under Regulation (EU) No. 1321/2014, the ARC represents an independent attestation that an aircraft continues to conform to its approved type design and remains in a condition for safe operation, as required by Part-M, M.A.901 and Part-CAMO, CAMO.A.305.

Although the procedural requirements for conducting airworthiness reviews are well documented, the interpretation of responsibility and accountability associated with ARC issuance or extension is often less clearly understood. Airworthiness Review Staff (ARS) occupy a critical position at the intersection of technical judgement, regulatory oversight and organisational governance.

This article examines the regulatory construct behind the ARC, clarifies stakeholder responsibilities, explores the limits of ARC accountability, distinguishes between ARC issuance and extension and provides a neutral, industry-relevant discussion of how the ARC is reviewed in the context of occurrences and investigations.

2. REGULATORY FRAMEWORK

2.1 Primary Regulations

The ARC process is governed by:

• Regulation (EU) No. 1321/2014
  • Part-M, Subpart I (M.A.901–M.A.904)
  • Part-CAMO, Subpart C (CAMO.A.300–CAMO.A.305)
• Associated AMC/GM material (AMC1 M.A.901; GM1 M.A.901; AMC1 CAMO.A.305)

2.2 Regulatory Intent

According to AMC1 M.A.901(a), an airworthiness review is a documented process intended to ensure that the aircraft:

1. Conforms to the approved type design, and
2. Is in a condition for safe operation.

The ARC is not designed to reconstruct the entire maintenance history of the aircraft back to manufacture, but rather to confirm the continuity and integrity of the airworthiness status within a defined scope.

3. ROLES AND RESPONSIBILITIES

3.1 Operator (Part-M, M.A.201)

The operator maintains the primary legal responsibility for the aircraft’s continuing airworthiness.
Key obligations include:

• Ensuring all maintenance is performed in accordance with the approved maintenance programme (M.A.302).
• Ensuring compliance with ADs and continuing airworthiness information.
• Maintaining accurate records (M.A.305).
• Supporting the ARC process with access to aircraft and documentation.

The ARC does not transfer this responsibility.

3.2 CAMO and Airworthiness Review Staff (CAMO.A.305)

Technical Responsibilities

• Review of maintenance records (typically 12 months).
• Verification of AD compliance.
• Assessment of repairs, modifications and STCs.
• Confirmation of correct maintenance organisation approvals.
• Completion of the physical survey for ARC issues.

Procedural Responsibilities

• Independent review, separate from maintenance activities.
• Compliance with CAME procedures.
• Documentation of findings and corrective actions.

Legal Responsibilities

The ARS signature attests that the review was performed in accordance with regulatory and organisational procedures, not that the aircraft is free from all possible defects or that all historical maintenance since manufacture has been validated.

3.3 TCH/DOA Responsibilities

Under Part-21 Subpart B, the TCH/DOA must:

• Maintain the type design.
• Supply ICA and other continuing airworthiness data.
• Provide design support to operators and maintenance organisations.

They are not responsible for the continuing airworthiness of individual aircraft.

3.4 The Competent Authority

The CAA is responsible for:

• Approval of CAMOs and ARS.
• Surveillance activities.
• System-level oversight of continuing airworthiness.
• Direct ARC issuance under specific conditions (e.g. import, unmanaged aircraft).

4. HOW FAR BACK MUST AN ARS LOOK?

AMC1 M.A.901 clarifies that the ARS must verify:

• Airworthiness status within the review period (normally 12 months).
• Proper incorporation of ADs, mandatory inspections and applicable modifications/repairs.
• Continuing airworthiness relevance of historical approvals, where applicable.

A full life-history reconstruction is not required unless anomalies suggest a break in the airworthiness chain.

5. ARC ISSUE VS ARC EXTENSION

5.1 ARC Issue (Full Review)

Occurs at least every 36 months, requiring:

• Full documentation review.
• Physical survey.
• Verification of compliance with all applicable airworthiness requirements.

5.2 ARC Extension (Administrative Review)

Allowed under M.A.901(f) for two consecutive 12-month periods if:

• The aircraft has been continuously managed by the CAMO.
• No mandatory findings remain open.
• The aircraft has not undergone unusual storage or major events requiring deeper review.

A physical survey is not required for an extension.

6. COMPARISON WITH THE FAA REGULATORY FRAMEWORK

Unlike EASA, the Federal Aviation Administration (FAA) does not utilise a formal Airworthiness Review Certificate (ARC) or an equivalent periodic independent review document.
The FAA system is built around continuous inspection, operator responsibility and oversight integrated into the maintenance programme itself, rather than a separate regulatory attestation.

This fundamental difference reflects distinct regulatory philosophies:

• EASA: Periodic independent verification (the ARC).
• FAA: Continuous conformity and inspection embedded in operations.

Below is a structured comparison.

6.1 FAA Airworthiness Maintenance Framework

 Commercial Operators – Part 121 and Part 135

Air carriers certified under 14 CFR Part 121 or Part 135 operate under the FAA’s Continuous Airworthiness Maintenance Program (CAMP) framework, which includes:

• Operator-specific maintenance programmes approved by the FAA.
• The Continuing Analysis and Surveillance System (CASS).
• Reliability programmes (for turbine aircraft).
• Mandatory FAA oversight and inspections.

In these systems, the FAA does not require a periodic independent review comparable to an ARC; instead, the operator’s maintenance programme, surveillance system and quality assurance processes serve as the primary controls.

6.2 Conceptual Differences: EASA ARC vs FAA Approach

Regulatory Element	EASA (ARC)	FAA (CFR Title 14)
Formal document attesting to continuing airworthiness	Yes – ARC issued/extended every 12 months	No – no equivalent certificate exists
Independent review separate from maintenance	Yes – performed by ARS	No – reviews occur within operator’s maintenance system
Legal structure	Reg. (EU) 1321/2014 Part-M & Part-CAMO	14 CFR 43, 91, 121, 135
Annual requirement	ARC issue or extension every 12 months	Annual Inspection (GA) or continuous maintenance (121/135)
Oversight model	Shared: operator + CAMO + ARS + CAA	Operator-centric with FAA surveillance
Documentation focus	Strong emphasis on records, configuration, AD compliance	Strong emphasis on physical inspection + operator programme compliance
Physical survey	Required every 36 months (ARC issuance)	Required annually or per programme

6.3 Practical Implications

EASA Model

• Provides periodic independent verification through ARS.
• Ensures a structured, system-level review beyond maintenance tasks.
• Strengthens traceability and configuration control.

FAA Model

• Relies on continuous processes within the operator’s system.
• Annual inspections focus more on the aircraft’s physical condition than on a holistic review of documentation.
• Oversight relies heavily on operator accountability and FAA surveillance.

Neither system is inherently “better”; each reflects:

• Historical regulatory evolution,
• Industry structure,
• Legal context, and
• Philosophical approaches to compliance assurance.

7. THE ARC IN THE CONTEXT OF OCCURRENCE INVESTIGATION

The ARC is one of many artefacts that may be reviewed during the investigation of a serious incident or accident. Its presence provides assurance that, at the time of issuance or extension, an independent verification of the aircraft’s airworthiness status was conducted according to applicable procedures.

Investigations generally assess:

• Whether the operator fulfilled its primary responsibilities under M.A.201.
• Whether the CAMO and ARS performed the review in accordance with Part-M, Part-CAMO, AMC/GM, and CAME procedures.
• Whether any identified non-compliance would have been reasonably detectable within the scope of an airworthiness review.
• Whether the CAA maintained appropriate oversight of the approvals involved.

The ARC serves as evidence of procedural compliance rather than as a guarantee of defect-free operation.

Responsibility boundaries remain defined by regulation:

• Operator: Overall continuing airworthiness responsibility.
• CAMO/ARS: Conformance with approved review procedures.
• TCH/DOA: Type design and continuing airworthiness data.
• CAA: Oversight and system-level assurance.

This structured distribution of responsibilities is fundamental to the European continuing airworthiness framework.

Conclusion

The Airworthiness Review Certificate is both a regulatory requirement and a key mechanism for maintaining continued confidence in the airworthiness system. Understanding its intent, scope, boundaries and interaction with broader safety processes is essential for operators, CAMOs, ARS and regulators alike.