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Maintenance on aircraft not under the responsibility of the contracting state issuing the Approved Maintenance Organization (AMO) approval

Annex 6 – Operation of Aircraft requires an aircraft to be maintained in an airworthy condition in accordance with the procedures acceptable to the State of Registry. The aircraft registration defines various requirements that apply to that aircraft, including continuing airworthiness. However, there are cases when maintenance needs to be performed on an aircraft not currently on a registry and where the future State of Registry is unknown. Examples of such cases are aircraft in storage, repossession of an aircraft in the case of default by a debtor, or an aircraft that was de-registered due to an irrevocable deregistration and export request authorization (IDERA) request and is in the middle of maintenance. In such cases, a regulatory framework for continuing airworthiness does not exist. 


The current ICAO provisions on aircraft maintenance and continuing airworthiness do not consider maintenance on aircraft without registration - it is unclear whether this maintenance can be performed and, if so, how. Some States take a more restrictive approach and prohibit any maintenance on such aircraft. The Cross-border Transferability Task Force discussed the issue related to the continuing airworthiness of an aircraft without registration. It was acknowledged that aircraft without registration lack a specific regulatory airworthiness framework reference, and many States do not have a methodology to allow maintenance to be performed on them. This practice introduces complications when the aircraft is to be registered again, and therefore the issues related to aircraft maintenance without registration need to be addressed.


As a result, a note was published in amendment 109 to Annex 8 (see below) to clarify that the Approved Maintenance Organization (AMO) provisions in Annex 8 do not prevent the AMO from performing maintenance on aircraft which is not under the responsibility of the Contracting State issuing this approval; a practice that already occurs in many States. However, the State must have no obligation in relation to that particular maintenance or aircraft.


The guidance (CLICK HERE) was developed by the XBT-TF and the Airworthiness panel and will be included in the 4th edition of the Airworthiness Manual – Doc 9760.

Note.— The provisions in this Section do not prevent the maintenance organization from performing maintenance on an aircraft that is not under the responsibility of the Contracting State issuing this approval, including aircraft not registered in any Contracting State. Additional information is provided in the Airworthiness Manual (Doc 9760).

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