EASA AMP Requirements & M.A.302 Compliance: A CAMO Guide

Overview

EASA Part‑M M.A.302 mandates that every EU‑registered aircraft be maintained under an approved Aircraft Maintenance Programme (AMP). The AMP and its revisions must be approved by the competent authority (typically EASA or the Member State). CAMO-managed aircraft may use an indirect approval process (defined in the CAMO’s CAME) to apply routine revisions without full EASA re‑approval. In all cases the AMP must fully capture all maintenance requirements and processes – including all inspection tasks, intervals, and any reliability monitoring – and it must be reviewed and updated at least annually.

EASA publishes detailed guidance for CAMOs (UG.CAMO.00010‑002) and a compliance checklist (TE.CAMO.00011) to help meet these requirements. This guide summarizes the key M.A.302 components and best practices for structuring, approving and maintaining an AMP that satisfies EASA’s expectations (for example, see the official AMP Compliance Checklist in EASA’s User Guide.

NOTE: Guide UG.CAMO.00010-002 is not mandatory for camo organisation whose competent airworthiness authority is not EASA, nevertheless it is a very useful guide that helps maintain compliance if followed correctly. This article explains the approach EASA takes when it is acting as the competent authority however the principles should not be too different if the organisation is under the oversight of an EASA Member state authority as at the end the requirements are uniform and stipulated in M.A.302, the associated AMCs and GMs. It is important to also consult any reference material that is published by the competent airworthiness authority for any specific requirements that are to be met in addition to the standard M.A.302 requirements.

M.A.302 Summary: AMP Approval and Scope

• Mandatory AMP. M.A.302(a)–(b) require maintenance to be organised under an approved AMP for each aircraft.The AMP (and any amendments) must be approved by EASA or the national authority. CAMOs (or CAOs) managing the aircraft can establish an indirect approval procedure (documented in the CAME) so that routine AMP amendments are processed internally. Notably, indirect approval cannot be used for safety‑critical “escalated” interval changes.

   

• AMP Content (Scope). M.A.302(f)–(g) and Appendix I (AMC/GM) detail required AMP content. The AMP must list all maintenance tasks and their intervals (inspections, overhauls, replacements, etc.) for airframe, engines, APU, propellers, components and systems. It must also cover any specific tasks tied to the aircraft type or operation. For large or complex aircraft, any required Reliability Programme (to monitor trend data and AMP effectiveness) must be included.In effect, the AMP “shall contain details, including frequency, of all maintenance to be carried out”.

   

• Compliance with Airworthiness Data. By M.A.302(d), the AMP must demonstrate compliance with all applicable continuing‐airworthiness instructions: i.e. EASA‑approved Type Certificate Holder (TCH) maintenance instructions, STC instructions, manufacturer’s maintenance planning data, and any mandatory rules (ADs, CMRs, Part‑21/Part‑26 requirements). The AMP often does this by referencing approved documents (e.g. MRBR/MPD or CMR manuals) rather than repeating them.

   

• Reliability Programme (M.A.302(g)). For “complex motor‑powered aircraft” (typically multi-engine jets), the AMP must include a reliability monitoring plan. This involves systematic collection of usage and failure data (e.g. hours, cycles, dispatch reliability) to assess if the AMP remains effective. The AMP should describe which reliability/condition monitoring processes apply (aircraft, engine, component, APU, etc.) and reference where detailed procedures reside (usually in the CAME).

   

• Periodic Review (M.A.302(h)). The AMP is not static. M.A.302(h) requires the AMP be periodically reviewed and updated as needed. In practice this means at least an annual review of the AMP content against: updated TCH/STC maintenance data, new service experience, changes in usage or operations, and any new ADs or regulations. The approved AMP document should contain a section describing how and how often reviews are performed.

   

• Permitted Variations (M.A.302(e)). Operators are allowed one‑time short extensions of AMP intervals (“permitted variations”) under controlled circumstances. For example, if a required check is missed due to logistical reasons, a CAMO may extend that interval by a limited amount (e.g. a few percent or months) and log it as a Permitted Variation. However, all such extensions must be pre‑approved by EASA (or covered by the CAMO’s indirect approval privilege). 

Required AMP Content (Appendix I to AMC M.A.302)

EASA AMC Appendix I (to M.A.302) specifies the minimum data the AMP document must include. In practice, a compliant AMP will contain at least the following (examples from the Appendix):

• Aircraft and Program ID: Aircraft type/model and registration; engine/APU/propeller details; name and address of owner/operator/CAMO; AMP reference number, issue date and revision; and a signed statement by the responsible owner/CAMO agreeing to maintain the aircraft per the AMP.

   

• Document Control: A list of effective pages with revision status (page control), and provision to record incorporated amendments.

   

• Maintenance Task Schedule: A complete list of tasks and their intervals: for each aircraft system/part, list the inspection, check, lubrication or overhaul tasks and the frequency (hours/cycles/months) with inspection “depth” (e.g. “borescope inspection”, “detailed inspection”). Component maintenance tasks (cleaning, lubrication, replacement) and intervals must also be included.

   

• Special Programs: If applicable, include or reference any supplemental programs: (S)SIPs or SIDs for structural inspections, corrosion prevention/control programs (CPCP), any ageing aircraft structural requirements (e.g. Part‑26 tasks). Also include any Critical Design Configuration Control Limitations (CDCCLs) and the limit-of-validity (LOV) for structural inspections.

   

• Mandatory Data References: Cross-references to any documents approved by EASA that contain life‑limitations, Certification Maintenance Requirements (CMRs) or Airworthiness Directives.(The Appendix notes these should not be mixed into the main task list without clear identification.)

   

• Reliability Program Reference: A statement of the required reliability program (or reference to it) if applicable.

   

• Compliance Statement: A declaration that maintenance will comply with the TCH’s maintenance instructions or approved equivalent processes.

   

• Definitions/Glossary: All maintenance tasks and abbreviations used should be defined in a glossary

The above outline matches EASA’s Compliance Checklist items. In effect, your AMP must be a self-contained manual of what to do, when, plus proof of status. For example, Appendix I requires the AMP to contain “tasks and periods… to be inspected” with type of inspection,and to provide a “statement that… maintenance will be to the standards specified in the maintenance instructions”. A CAMO should use EASA’s official checklist (TE.CAMO.00011) to verify that all such items are covered.

AMP Approval Process: Direct vs Indirect

EASA distinguishes direct approval (EASA signs off every revision) from indirect approval (CAMO may implement approved changes per an internal process). According to the EASA User Guide:

• Direct Approval (4.4.1) – Default approach. All AMP issues or revisions normally require submission to EASA (or national authority) for approval. The AMP document should include in its approval sheet whether it was approved directly or indirectly. For direct approval, the CAMO submits revision proposals (with supporting data and justification) to EASA, and attaches the EASA approval letter to the AMP.

   

• Indirect Approval (4.4.2) – CAMO-controlled revisions. EASA may authorize a CAMO to apply specified changes without prior EASA review. To do this, the CAMO must establish an AMP Indirect Approval Procedure in its CAME (and have EASA accept it. The AMP itself should then refer to that CAME procedure. Examples of indirect changes might include routine editorial corrections, or adding pre‑agreed tasks. Even with indirect approval, all changes must still meet Part‑M rules, and an accountable person in the CAMO signs off the revision.

In practice, CAMOs should clearly document in the AMP how approval is obtained: a table or statement on the approval sheet listing “Approval Type: Direct (EASA) / Indirect (CAMO)” along with signatures. The User Guide explicitly notes that the AMP’s approval sheet must identify who approved the revision (by name, position, signature), and that an EASA approval letter or similar evidence be attached for direct approvals.

Periodic Review and Updates

Requirement: Under M.A.302(h), the AMP must be periodically reviewed and updated as needed.Both the AMC and the User Guide stress that CAMOs should review the AMP at least annually. The review ensures the AMP “continues to be up to date and valid in light of the operating experience and instructions” (TCH updates, STC data, new ADs, etc.)

Content of Review: The AMP (or accompanying CAME revision policy) should describe what the periodic review covers. At minimum, EASA expects the CAMO to check: updated maintenance instructions from the TCH/STC holders, new mandatory requirements, revised MRB/MPD tasks, any embodied modifications/repairs requiring new tasks, in-service reliability data or occurrence trends, and changes in operations/utilisation. Essentially, CAMOs compare “what is in the AMP” versus “what should be in the AMP” based on the latest data.

Frequency: The default frequency is annual (never exceeding 12 months). The AMP should state its chosen review interval (e.g. “annual review by March 31”) and any justification. More frequent reviews can be applied for special needs (e.g. high‑utilisation operations), but must still meet the 12-month maximum. All results of a review (even if no changes are needed) should be recorded internally.

Revisions: When review identifies changes, the CAMO issues an AMP revision or temporary revision (TR) to incorporate them. In general, these revisions are prepared by the CAMO/owner and then submitted for approval. The User Guide reminds us that “amendments (revisions) to the approved maintenance programme should be made by the Owner or the CAMO to reflect changes in the [TCH’s] recommendations, modifications, service experience… or as required by the competent authority”. The AMP’s revision history section should record each change (see below).

Permitted Variations (Interval Escalations)

Purpose: Permitted Variations are one-time extensions of a specific check or overhaul interval for an individual aircraft. For example, if a required 6‑month check is missed, a CAMO might be allowed to defer that check by a few weeks under variation rules. EASA explicitly states that permitted variations are not planning tools or permanent changes; they are emergency or exceptional allowances.

Approval: By default, any extension beyond the approved limit requires EASA approval on a case-by-case basis. EASA may however grant CAMOs an indirect-approval privilege so that minor pre‑agreed variations can be applied routinely without direct oversight. All permanent interval changes (escalations) beyond one-time cases must follow formal amendment procedures – these fall under indirect approval restrictions in M.A.302(e).

Reliability Programme Requirements

Even though the reliability programme is often administered in the CAMO’s CAME, the AMP should reference it. The User Guide recommends that the AMP include a section summarizing how AMP effectiveness is monitored. Typical elements (to be detailed in the CAME) include:

• Data Collection: Metrics collected (e.g. time between removals, defect/dispatch statistics) for aircraft, engines, components, and/or APUs.
• Analysis Method: Criteria for trend analysis or condition monitoring. This could be statistical methods (like Control Charts) or MSG-3 analysis rounds.
• Reliability Group: Organization and responsibilities (CAMO roles, engineering boards).
• Actions: Process for escalating AMP revisions if trends indicate excessive wear or failures.

At a minimum, the AMP should state that a reliability/monitoring programme exists and point to the CAME section where details can be found. For example, the AMP could include a brief note: “The CAMO implements aircraft/engine reliability programs as described in CAME.

Best Practices: Structuring a Compliant AMP

EASA’s User Guide gives extensive advice on AMP formatting. For CAMO professionals, following a clear template helps both internal use and the approval process. Key recommendations include:

• Approval Sheet (Cover Page): At the very front, include an approval page listing the AMP reference number, issue/revision date, and revision status. List the names, positions, organizations and signatures of the persons who developed and checked the AMP, and of the person approving it (owner or CAMO manager. Also specify the type of approval (Direct or Indirect) on this sheet. If EASA directly approved the AMP, attach the EASA approval letter here.

   

• List of Effective Pages: Maintain a “Table of Revisions” or “List of Effective Pages” section, listing each chapter or appendix, its page count and its current issue/revision date. This ensures missing or outdated pages are easily spotted. It should be updated whenever any page is revised.

   

• Revision History: Include tables to record each AMP Issue/Revision (with date and approval type) and each Temporary Revision (TR) if used. Typically this is a two‑column table: one for the AMP issue/revision number and date, another for TR number/date, along with approval signatures.

   

• Summary of Changes: Before or after the revision history, provide a brief summary (bulleted list or table) of changes in the current revision (tasks added/removed, interval changes, etc.). This helps reviewers quickly identify what was done.

   

• Table of Contents: Always include a clear Table of Contents at the start, listing chapters (e.g. 0. Document Control, 1. Introduction, 2. Pre-flight, 3. Line/Heavy checks, 4. Reliability, 5. Variations, Appendices, etc.) with page references. Use consistent numbering (e.g. Section 4.1, 4.2, etc.). The User Guide even suggests a template content structure cross-referenced to its checklist.

   

• Definitions/Glossary: Provide a section for abbreviations and definitions (e.g. for inspection levels: A, B, C checks; terms like “TC holder”) to avoid ambiguity.

   

• Distribution List: Document who receives the AMP. Common entries include: CAMO Postholder, CAMO Engineering, contracted Part-145 maintenance organizations, any subcontractors, the Approving Authority (EASA), the Operator, and the State of Registry. This can be in the AMP itself or referenced from the CAME.

   

• Cross-References to CAME: It’s good practice to minimize technical detail in the AMP by referencing the CAME or other manuals. For example, the AMP might note “Reliability program per CAME C08‑2” or “Indirect approval procedure per CAME C07‑3”. The User Guide explicitly permits AMP sections to be satisfied by referencing the CAME where appropriate.

By closely following these structuring guidelines, the AMP will look familiar to EASA reviewers and cover all checklist items systematically. It demonstrates that the CAMO has “robust procedures… when planning, developing and controlling the [AMP] prior to submission”

EASA Guidance & AMP Checklist

EASA provides several tools and references to assist CAMOs

• The AMP Compliance Checklist (TE.CAMO.00011) lists all M.A.302 and AMC items and helps verify compliance. The EASA User Guide frequently directs CAMOs to fill in the checklist. CAMOs should complete this checklist for each initial AMP approval (and mark “Not amended” for unchanged sections on later revisions.

   

• Relevant Acceptable Means of Compliance (AMC) include AMC M.A.302(d) (“Program Basis and Associated Programs”) and AMC M.A.302(e)–(h) (“Amendments, Periodic Review, Reliability”), among others. These AMCs explain how to base the AMP on the MRB report or MPD, how to handle optional/deviation tasks, and how to conduct reviews.

   

• FAQ and GM documents on EASA’s website answer common questions (e.g. FAQ 19061 on indirect approval, FAQ 19102 on permitted variations, FAQ 47406 on periodic review content). CAMOs should consult these when drafting procedures.

   

• Keep AMP content aligned with Airworthiness Directives (ADs): List AD checks and explain how they are captured (for instance by reference or explicit tasks) in the AMP. The user guide notes that ADs and SBs can be described in AMP text or managed via the CAME’s AD process.

Conclusion

For CAMO professionals, ensuring M.A.302 compliance means building an AMP that is both technically complete and well-organized. Structurally, it must clearly document who, what, when and how for every maintenance task and review cycle. Substantively, it must faithfully implement the aircraft manufacturer’s approved maintenance data, plus any approved deviations or national requirements. By following EASA’s User Guide sections (and the CAMO’s own procedures), a CAMO can present an AMP that meets the regulator’s standards.

Reference:

EASA's Part-CAMO & Part-CAO Organisations – Aircraft Maintenance Programmes (AMP)