Introduction
In March 2026, EASA published a significantly updated edition of the Easy Access Rules (EAR) for Additional Airworthiness Specifications, consolidating Regulation (EU) 2015/640 — commonly known as Part-26. This new edition replaces the March 2023 version and grows from 73 to 88 pages, reflecting a wave of regulatory change driven primarily by the adoption of Commission Regulation (EU) 2024/2954 and EASA Executive Director Decision 2024/010/R (Issue 5 of CS-26 and GM-26).
For airlines and Continuing Airworthiness Management Organisations (CAMOs) operating in Europe, these changes are not cosmetic. They broaden Part-26's scope, introduce entirely new airworthiness requirements for both fixed-wing and rotary-wing aircraft, and refine the ageing aircraft structural integrity programme. This article breaks down the key differences and explains what they mean in practice.
The Regulatory Driver: Regulation (EU) 2024/2954
The single most significant factor behind the March 2026 update is Commission Regulation (EU) 2024/2954, which became applicable on 22 December 2024. This amending regulation touches the cover regulation and numerous points within Annex I (Part-26). Its impact cascades throughout the document, from redefined articles and new definitions to entirely new airworthiness points and amended structural integrity requirements.
The March 2023 edition incorporated amendments up to Regulation (EU) 2022/1254 and ED Decision 2022/019/R (Issue 4). The March 2026 edition adds Regulation (EU) 2024/2954 and ED Decision 2024/010/R (Issue 5), completing a three-year cycle of rulemaking that significantly reshapes Part-26.
Key Changes to the Cover Regulation
Expanded Scope Through Article 1
Article 1 has been rewritten by Regulation (EU) 2024/2954. The previous wording referred to operators of aircraft "used by an operator for which a Member State ensures oversight." The new text introduces more precise language, now addressing aircraft "operated by an aircraft operator established, residing or with a principal place of business in the territory to which the Treaties apply." This tightens the jurisdictional framework.
The scope for design approval holders has also been refined, distinguishing between "design change approvals" and "repair design approvals" as separate categories, aligning more precisely with Regulation (EU) No 748/2012.
New Definition: Small Aeroplane
One of the most consequential definitional changes is the addition of Article 2(ba), which defines a "small aeroplane" as an aeroplane that has the Certification Specifications for Normal-Category Aeroplanes CS-23 or equivalent in its certification basis. This is entirely new — it did not exist in the March 2023 edition. The practical effect is that Part-26 now extends its reach beyond large CS-25 aeroplanes to include smaller CS-23 aircraft for specific requirements such as cargo compartment fire protection.
Deletion of Article 3
Article 3 — "Additional airworthiness specifications for a given type of operation" — has been deleted entirely by Regulation (EU) 2024/2954. In the 2023 version, Article 3 required operators to comply with Annex I. Its removal simplifies the structure, as compliance obligations are now embedded directly within the individual points of Part-26 and through the applicability provisions of Article 1.
Refined Definitions for the Ageing Aircraft Programme
Several definitions in Article 2 have been refined. The CPCP definition has been streamlined, removing operator-level detail. Definitions for DTI, REG, and baseline structure now include references to restricted TC holders and STC holders alongside TC holders, reflecting the expanded scope.
Subpart B: From “Large Aeroplanes” to “Aeroplanes”
Perhaps the most visible structural change is the renaming of Subpart B from "LARGE AEROPLANES" in the 2023 edition to simply "AEROPLANES" in the 2026 edition. This is not merely a cosmetic change — it reflects the expanded applicability of Part-26 to include small aeroplanes (CS-23) for certain provisions. Airlines and CAMOs managing mixed fleets that include CS-23 types should take particular note.
New Point 26.175 — Cargo Compartment Fire Protection (Aeroplanes)
Point 26.175 is an entirely new addition introduced by Regulation (EU) 2024/2954. It requires TC, restricted TC, STC, and design change approval holders to provide operators with detailed cargo compartment fire protection design information for large aeroplanes and small aeroplanes with MTOW greater than 5,700 kg where the certificate of airworthiness is first issued on or after 1 January 2025. For small aeroplanes at or below 5,700 kg with a cargo compartment separated from the flight deck, the same obligation applies.
This information must be sufficiently detailed to support operators conducting a risk assessment for transporting goods in cargo compartments. For airlines, this means ensuring the design approval holders for their aircraft have supplied this data. For CAMOs, it means verifying that this information is reflected in operational documentation and easily identifiable by risk assessment personnel. CS 26.175 and GM1 26.175 detail the expected information, including cargo compartment classification, detection system features, fire suppression capabilities, and ventilation control characteristics.
Subpart C: Helicopter Safety — Two Major Additions
New Point 26.405 — Cargo Compartment Fire Protection (Helicopters)
Mirroring the aeroplane requirement, point 26.405 introduces cargo compartment fire protection information obligations for helicopters. Both small (CS-27) and large (CS-29) helicopters with at least one cargo compartment separated from the flight deck, and a first individual certificate of airworthiness issued on or after 1 January 2025, fall within scope. The obligations are structurally identical to 26.175.
New Point 26.440 — Fuel System Crash Resistance (Helicopters)
Point 26.440 is arguably the most technically significant new requirement for the helicopter sector. It mandates that operators of both small and large helicopters ensure the likelihood of a post-crash fire is minimised as far as practicable through fuel system design. The applicability is layered by TC issue date and helicopter size. For helicopters with a TC issued on or after 2 October 1994 and a first individual certificate of airworthiness issued on or after 22 December 2026, compliance is required at delivery. Existing helicopters face staggered deadlines: 22 December 2031 for those designed for six or more occupants and 22 December 2039 for five or fewer. Imported helicopters from non-Member States are also captured.
CS 26.440 details the technical standards, including fuel tank drop tests from at least 15.2 metres, self-sealing breakaway fuel line couplings, crash-resistant tank design, and puncture-resistant bladders tested under ETSO-C80 methodology. For CAMOs managing helicopter fleets, particularly in the offshore and EMS sectors, this introduces significant planning obligations.
Ageing Aircraft Structural Integrity: Refined and Expanded
The continuing structural integrity programme requirements in points 26.300 through 26.309, 26.330 through 26.334, and 26.370 have all been touched by Regulation (EU) 2024/2954. While the fundamental structure remains intact, the revisions introduce greater precision. Point 26.300 now explicitly includes restricted TC holders alongside TC holders. The exemptions in 26.300(b) have been restructured, with a specific reference to Appendix 1 (Table A.1) listing aeroplane models excluded from points 26.301 to 26.334.
The maintenance programme requirements in 26.370 have been substantially revised. The updated CS 26.370 (Issue 5) provides a detailed, step-by-step compliance framework for addressing the adverse effects of repairs and changes on fatigue-critical structures, including specific deadlines for record reviews, data requests, and DTI incorporation.
Appendix 1 has also been expanded. The exemption list now includes additional specific serial numbers for models such as the Airbus A320neo family, A330 series, ATR 72, and Boeing 737 MAX, specifically exempted from point 26.60 (emergency landing dynamic conditions).
What Does This Mean for Airlines and CAMOs?
The March 2026 Part-26 update demands action across several fronts. Airlines and CAMOs should consider the following priorities.
First, review the expanded scope. The inclusion of CS-23 small aeroplanes means operators of turboprops, light twins, and other CS-23 types must now assess whether the new cargo fire protection requirements apply. This is particularly relevant for regional airlines and specialist cargo operators.
Second, engage with design approval holders. Both 26.175 and 26.405 place the documentation obligation on the TC, restricted TC, STC, and design change approval holders. However, operators and CAMOs must ensure they have received this information and that it is integrated into their operational risk assessment processes. If this data has not been received, proactive engagement is necessary.
Third, assess helicopter fleet compliance timelines. Point 26.440 introduces staggered deadlines for fuel system crash resistance. CAMOs responsible for helicopter continuing airworthiness must map their fleet against the applicability criteria and build compliance plans well ahead of the 2026, 2031, and 2039 deadlines as applicable.
Fourth, update maintenance programmes. The revised 26.370 and supporting CS material introduce granular requirements for DTI incorporation, structural surveys, and DT data integration. CAMOs should verify alignment with the updated framework, particularly the 26 February 2026 deadline for DTI incorporation relating to certain major changes.
Fifth, update compliance monitoring. The Compliance Monitoring function should review checklists and audit criteria against the amended points. The deletion of Article 3, expanded definitions, and new requirements all warrant updates to CMPs, Management of Change procedures, and training materials.
Conclusion
The March 2026 edition of the EASA Easy Access Rules for Part-26 represents a substantial evolution of the Additional Airworthiness Specifications framework. Driven by Regulation (EU) 2024/2954 and ED Decision 2024/010/R, it broadens the scope to include small aeroplanes, introduces new cargo fire protection and helicopter fuel system crash resistance requirements, and refines the ageing aircraft structural integrity programme. For airlines, CAMOs, and design organisations operating within the European aviation system, staying ahead of these changes is not optional — it is a regulatory obligation. The time to act is now.
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