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Continuing airworthiness
Moving an aircraft from the US registry to an EU registry is not just paperwork. Here is what changes when FAA continuous airworthiness meets EASA continuing airworthiness, and where transitions usually stall.
For a US operator, a lessor or an investor, an aircraft is also a financial asset. Its value depends on its records, and on its ability to fly and be traded on both sides of the Atlantic. Yet the gap between the FAA and EASA systems remains a frequent source of delays and unexpected costs.
In the United States, an operator under Part 121 or 135 manages airworthiness through its Continuous Airworthiness Maintenance Program (CAMP). For other aircraft, the owner or operator is primarily responsible for keeping the aircraft airworthy.
In Europe, the management of continuing airworthiness is entrusted to an approved Continuing Airworthiness Management Organisation (CAMO) for commercial and complex aircraft. Under Part-CAMO, introduced by Regulation (EU) 2019/1383, the CAMO manages the aircraft maintenance programme, the airworthiness directives and the airworthiness reviews that lead to the Airworthiness Review Certificate (ARC).
| Topic | FAA system | EASA system |
|---|---|---|
| Who manages airworthiness | Owner or operator; CAMP for Part 121 and 135 operators | An approved CAMO (commercial and complex aircraft) |
| Maintenance programme | Manufacturer program or CAMP | Aircraft Maintenance Programme (AMP) approved by the competent authority or the CAMO |
| Periodic review | Annual or progressive inspections, depending on operation | Airworthiness review leading to an ARC, normally every year |
| Airworthiness directives | FAA ADs | EASA ADs, plus those of the State of Design |
High-value transitions often stop during the records review. The BASA between the US and the EU makes cooperation easier, but it does not remove the need for complete, consistent records.
Key takeaway: start the records gap analysis before the aircraft changes registry, not after. Every gap found early avoids a delay in the airworthiness review and protects the asset’s residual value.
Part-CAMO requires a management system that includes safety risk management. In practice, a CAMO must:
For US organizations used to a different safety culture, this alignment takes time and needs to be planned.
Aero Consulting is an independent consultancy. We do not replace your CAMO: we help you prepare and secure the transition.
Learn more about our EASA Part-CAMO services.
Tell us about the aircraft and its current registry: we help you identify the gaps before the airworthiness review.