Introduction
EASA Part-26 (Regulation (EU) 2015/640) was introduced to ensure that large aeroplanes already in service continue to meet modern safety requirements. While newly designed aircraft must comply with the latest certification standards (such as CS-25 or CS-27), older type-certificated aircraft were originally not obliged to adopt subsequent safety enhancements. Part-26 bridges this gap by retroactively applying selected new airworthiness requirements to existing fleets. In practice, this means that even though a design previously certified under earlier rules is not automatically bound to updated Certification Specifications, additional airworthiness obligations have been mandated to maintain and improve the safety of these aircraft.
Note: (Historically, similar requirements existed under JAA’s JAR-26 since 1998.) In short, Part-26 was introduced so that older European-registered aeroplanes would be required to meet new safety requirements that were not part of their original certification.
Evolution of Regulation (EU) 2015/640
Since its original issue in 2015, the EU Part-26 rule has been amended several times to add new requirements or provide exemptions. Major amendments include:
- EU 2015/640 (May 2015) – Original introduction of Part-26 (OJ L106) with a delayed entry for some Subpart B provisions (e.g. exits, flammability, etc. applied from 2017)
- EU 2019/133 (Jan 2019) – 1st amendment (adopted 28 Jan 2019) – added requirements on fire-extinguishing agents (Halon replacement), seat crashworthiness, thermal/acoustic insulation flammability, and certain helicopter equipment.
- EU 2020/1159 (Aug 2020) – 2nd amendment (5 Aug 2020) – added detailed ageing-aircraft tasks (damage-tolerance inspections, etc.), runway overrun awareness systems, and new obligations on conversion of Class D cargo compartments.
- EU 2021/97 (Jan 2021) – 3rd amendment (28 Jan 2021) – delayed some requirements (e.g. exit-row markings) due to COVID-19, added an appendix of low-risk models exempt from certain rules, and modified rules on damage-tolerance evaluations
- EU 2022/1254 (Jul 2022) – 4th amendment (19 Jul 2022) – added requirements for large aeroplane tire-pressure monitoring (CS-25), helicopter ditching and water-impact occupant survivability (CS-27/29), and updated the list of aeroplanes exempt from Class D cargo conversion
- EU 2024/2954 (Nov 2024) – 5th amendment (29 Nov 2024) – further new provisions on cargo fire protection information, runway safety systems, and formalized the “Continuing Structural Integrity” program. (This amendment entered into force end 2024.)
Each amendment was accompanied by updated EASA CS-26 guidance (Certification Specifications) and GM. For example, EASA’s CS-26 Issue 4 (Sep 2022) reflects the 2022 updates (tyre pressure, helicopter ditching) and CS-26 Issue 5 (Dec 2024) reflects the latest fuel-system and cargo-fire measures.
In practice, Part-26 has evolved from transposing old JAR-26 rules into EU law, into a living regulation that incorporates new safety mandates as aviation standards advance.
Impact on European Air Operators
Part-26 has direct consequences for EU air carriers. By law, operators of applicable aircraft must comply with Part-26: EU Regulation 2015/640 explicitly states that “operators for which a Member State ensures oversight…shall…comply with the provisions of Annex I [Part-26]”. In other words, every EU operator of large aeroplanes (and related STCs or third-country aircraft operated by EU carriers) must implement the Part-26 requirements. For example, the national CAA might require AOC applicants to demonstrate compliance with Part-26 before issuing a certificate. Most European NAAs provide compliance checklists to prospective applicants of an AOC.
In practical terms, operators must update their manuals and processes: the aircraft flight manuals, Minimum Equipment Lists, training, and operations manuals may need revision to incorporate new seat-belt standards, exit procedures, halon replacement, tyre-pressure checks, etc. Dispatch and maintenance procedures must ensure that no flight departs with Part-26 equipment (e.g. properly marked exits, functional pressure monitors) missing or inoperative. Any affected aircraft must be modified or operated in a way that meets the new criteria. In short, Part-26 items become as binding on the operator as any other operational rule. European operators typically rely on their Continuing Airworthiness Management Organisation (CAMO) and engineering staff to implement these changes.
Implications for CAMOs
In most European air carriers, the CAMO is responsible for Part-26 compliance. Under Part-M (Annex I, M.A.302), the CAMO must amend the approved Aircraft Maintenance Programme (AMP) to account for new requirements. In most European air carriers, the CAMO holds responsibility for ensuring compliance with Part-26. Under Part-M (Annex I, M.A.302), the CAMO is required to update the approved Aircraft Maintenance Programme (AMP) to incorporate any new obligations introduced by Part-26. This places a direct duty on CAMO engineers to understand the regulation’s provisions, integrate the necessary inspections and modifications into maintenance planning, and coordinate with design approval holders or Part-21 organisations as appropriate.
CAMOs must also manage communication with manufacturers and STC holders. Under Part-26, TC/STC holders are obliged to provide updates to the Instructions for Continued Airworthiness (ICA) whenever design changes are needed for compliance. The CAMO needs to incorporate those ICA changes into the maintenance data and ensure technicians follow them. Overall, Part-26 adds to the CAMO’s workload: it requires new risk assessments (for example, on cargo fire scenarios), oversight of ageing-structure inspections, and coordination of any special workshops or training needed for new tasks.
Implications on the Aircraft Maintenance Programme
Part-26 also directly affects the maintenance program content for fixed-wing aircraft. EASA’s Part-26 includes specific requirements for continued airworthiness tasks. For large aeroplanes, CS-26.370(a) explicitly requires the maintenance program to include the following elements:
- Damage-tolerance inspections (DTI) for ageing structures – an approved inspection regime addressing fatigue-critical parts (for aeroplanes ≥30 passengers or payload >3,402 kg).
- Repairs/modifications checks – methods to address the adverse effects of repairs or modifications on fatigue-critical structure.
- Life-limited parts (LOV) tracking – an approved program tracking the life of structural components for very large aeroplanes (MTOW >75,000 lb).
- Corrosion Prevention and Control Program (CPCP) – a structured corrosion-control system for the airframe.
These requirements typically forced operators to revise their AMPs by set deadlines (for example, the initial implementation date was 26 February 2024). In practice, this means the AMP documents now should contain detailed tasks such as mandatory ultrasonic inspections, records of structural life limits, and corrosion inspections that must be performed at specified intervals. Maintenance planners must also ensure these tasks are scheduled and adequately resourced.
Examples of Part-26 items added to AMPs include: seats and berth inspections, emergency-exit checks, insulation fire-blocking inspections, halon extinguisher servicing, tyre pressure verification, and offshore emergency equipment checks. (These are in addition to the standard Part-CAT requirements.) In summary, CAMOs/AMOs must ensure that the AMP explicitly includes any Part-26 mandated inspections or procedures, with compliance dates met as specified by the regulation.
Demonstrating Compliance with Part-26
Airlines and CAMOs generally demonstrate Part-26 compliance through documentation. Operators often use a compliance checklist approach. For many requirements, compliance can be shown by referring to the aircraft’s certification basis or approved modifications: if the original Type Certificate or an STC already incorporated the requirement, that provides the needed evidence. TC/STC holders are required to make available to each operator any changes to the ICA needed for compliance, so operators must maintain and use those updated ICA documents.
EASA guidance (GM2 26.1) clarifies the process: for the initial Part-26 implementation “the operators will be responsible for showing compliance. In most cases this can be done by referring to the certification basis of the aircraft or approved changes… which indicate compliance”
If an operator cannot demonstrate compliance from existing documentation alone, the CAMO must involve the design organisation. In that case, the TC holder or STC holder should obtain an official EASA determination that the design meets the specific CS-26 requirement, and then provide that finding to the operator.
In summary, operators fulfill Part-26 by:
- Maintaining an updated compliance matrix or checklists keyed to Part-26 clauses.
- Incorporating any required design changes or compliance instructions provided by the manufacturer.
- Using ICA updates from the design holder and recording compliance in the AMP.
- If needed, working with the OEM to get an EASA confirmation of compliance for any uncovered item.
With these steps, European operators can show their National Aviation Authority (NAA) that they meet the “Additional Airworthiness Specifications” for their fleet.
Conclusion
EASA Part-26 extends modern airworthiness standards to older large aeroplanes by imposing new in-service requirements. Over the years it has been expanded (through multiple EU regulations) to cover seats, exits, fire protection, tire monitoring, structural inspections and more. All affected operators and CAMOs must revise their maintenance programmes and manuals to include the Part-26 tasks and show compliance during oversight. Understanding Part-26 is critical for continued safety of ageing fleets: it means proactively implementing damage-tolerance inspections, corrosion control, certification basis reviews and all newly mandated checks.
For companies looking to strengthen their CAMO and AMO expertise in these areas, our EASA Part-21 & Part-26 Training for CAMOs & AMOs course provides in-depth, practical guidance. This training covers the regulatory requirements, compliance strategies and best practices needed to manage Part-26 obligations effectively. By equipping maintenance managers and engineers with this knowledge, organizations can confidently meet the Additional Airworthiness Specifications and keep their aircraft safe and legal.
