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Continuing airworthiness

FAA vs EASA continuing airworthiness: the CAMO guide

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.

By Alain François, Aero ConsultingUpdated October 2026
FAA vs EASA continuing airworthiness and Part-CAMO

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.

Two philosophies: CAMP and CAMO

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

Where transitions stall: the records

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.

  • Life-limited parts: full back-to-birth traceability is expected for every life-limited part.
  • Airworthiness directives: the status of FAA and EASA ADs must be demonstrated, with the method of compliance.
  • Repairs and modifications: each one must be backed by data acceptable to EASA.
  • Maintenance programme: the history must allow the transfer to an EASA-approved AMP.

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.

Safety management in Part-CAMO

Part-CAMO requires a management system that includes safety risk management. In practice, a CAMO must:

  • collect and analyze occurrence reports, in a just culture;
  • identify hazards and assess maintenance-related risks before they turn into AOG events;
  • use reliability data to adjust the maintenance programme.

For US organizations used to a different safety culture, this alignment takes time and needs to be planned.

How Aero Consulting helps

Aero Consulting is an independent consultancy. We do not replace your CAMO: we help you prepare and secure the transition.

  • Transition advisory: planning the move of an aircraft between the FAA and EASA systems.
  • Records audits: back-to-birth review, AD status, repairs and modifications, for operators, lessors and buyers.
  • CAMO support: maintenance programme review, safety management and training of your teams.

Learn more about our EASA Part-CAMO services.

AF
Alain François

Founder of Aero Consulting. Former OSAC-approved Quality Manager for an EASA Part-145 and Part-CAMO organization, airline pilot (French ATPL, FAA Commercial Pilot) and instructor in EASA Part 21, Part 145 and Part-CAMO at ESTACA aerospace engineering school.

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