Commission Implementing Regulation (EU) 2026/100 applies from 7 August 2026 and rewrites the airworthiness review process in Regulation (EU) No 1321/2014. The three biggest changes for continuing airworthiness organisations are that the “controlled environment” concept is abolished, Part-M and Part-ML Subpart I are renumbered so that existing cross-references now point at the wrong rules, and a written airworthiness review report becomes a mandatory, retained record. This article sets out what changed, why, and what CAMO and CAO postholders need to have in place.
What is Regulation (EU) 2026/100?
Regulation (EU) 2026/100 is a Commission Implementing Regulation of 15 January 2026, published in the Official Journal on 19 January 2026. It amends both Regulation (EU) No 748/2012 and Regulation (EU) No 1321/2014 as regards the airworthiness review process, the airworthiness certificate and occurrence reporting, and it corrects two errors in Regulation (EU) No 1321/2014.
It does not stand alone. It repeatedly cross-refers to points 21.A.174(b)(3), 21.A.174(d) and 21L.A.143(e), (f) and (h) of Regulation (EU) No 748/2012 — points created by Commission Delegated Regulation (EU) 2026/56 of 23 October 2025, which shares the same 7 August 2026 application date. Reading one without the other produces dead cross-references. Both instruments implement EASA Opinion No 08/2024.
The supporting acceptable means of compliance and guidance material were adopted on 6 July 2026 by ED Decision 2026/005/R, which issued AMC & GM to Part 21 (Issue 2, Amendment 18), Part-M (Issue 2, Amendment 10), Part-145 (Issue 2, Amendment 9), Part-ML (Issue 1, Amendment 4), Part-CAMO (Issue 1, Amendment 6) and Part-CAO (Issue 1, Amendment 6).
When does Regulation (EU) 2026/100 apply?
| Date | What Happens |
|---|---|
| 19 January 2026 | Published in the Official Journal |
| 8 February 2026 | Entry into force |
| 13 February 2026 | Article 3(1) correction applies retroactively (Part-66 B1.E derogation) |
| 22 February 2026 | Article 3(2) correction applies retroactively (CAMO.B.300 lettering) |
| 6 July 2026 | ED Decision 2026/005/R issues the AMC & GM |
| 7 August 2026 | Full application of Regulation (EU) 2026/100 and Delegated Regulation (EU) 2026/56 |
Article 4 sets the application date and contains no transitional provisions for existing airworthiness review certificates, existing airworthiness review staff authorisations, in-progress exposition amendments or form stock. Organisations should treat 7 August 2026 as a hard switchover and check the AMC & GM for any accommodation.
Change 1: the “controlled environment” is abolished
Until 6 August 2026, whether a CAMO or CAO could issue an ARC itself or had to send a recommendation to the competent authority depended on a three-part test: whether the aircraft was in a controlled environment (managed for the preceding 12 months by a unique CAMO or CAO and maintained by an approved maintenance organisation), whether it was above or below 2 730 kg MTOM, and whether it was used by an air carrier licensed under Regulation (EC) No 1008/2008.
The new M.A.901(b) replaces all of that with three plain conditions. Satisfactory completion of a review results in an ARC on EASA Form 15b if:
1. the continuing airworthiness has been continuously managed in accordance with M.A.201 or ML.A.201 since the previous ARC was issued;
2. the aircraft has been maintained in accordance with the Regulation since the previous ARC was issued; and
3. the airworthiness certificate was issued under Regulation (EU) No 748/2012 and is not revoked or surrendered at the time of the review.
If any condition is not met, the outcome is a recommendation to the competent authority instead.
The practical effect is significant. The MTOM threshold and the air-carrier distinction disappear from the issue-versus-recommend decision. Recital 5 states the policy intent directly: the need for a recommendation should be limited to cases where the involvement of the national competent authority is necessary to guarantee the expected safety level. Recommendation volumes across the EU should fall sharply.
Note also what the new condition (1) says and does not say. It requires continuity of management, not continuity of the same manager. The old “unique CAMO or CAO” wording is gone from the ARC-issue test. Extension is different: M.A.902(b) still permits extension only by the organisation managing the continuing airworthiness, which must have managed it continuously since the ARC was issued.
Change 2: Part-M and Part-ML Subpart I are renumbered
This is the change most likely to generate audit findings, because it is invisible unless you look for it.
| Until 6 August 2026 | From 7 August 2026 |
|---|---|
| M.A.901 Aircraft airworthiness review | M.A.901 Airworthiness review — General |
| M.A.902 Validity of the ARC | M.A.902 Validity of the ARC (rewritten) |
| M.A.903 Transfer of aircraft registration within the Union | M.A.903 Airworthiness review process |
| M.A.904 Airworthiness review of aircraft imported into the Union | M.A.904 Airworthiness review staff |
| M.A.905 Findings | M.A.905 Transfer of aircraft registration within the Union |
| — | M.A.906 AR of aircraft without a 748/2012 airworthiness certificate |
| — | M.A.907 Findings |
M.A.903 and M.A.904 are reused numbers carrying entirely different content. A continuing airworthiness management exposition that cites “M.A.901” for the review process does not merely become out of date on 7 August — it points at the wrong requirement. The same applies in Section B, where M.B.901 and M.B.902 swap meanings, M.B.903 and M.B.904 are deleted, and M.B.905, M.B.906 and M.B.907 are added. Part-ML follows the same pattern, with a new ML.B.901 inserted and ML.B.902 and ML.B.903 deleted.
Change 3: who may issue the ARC — the review is decoupled from management
This is the change with the largest commercial consequence, and it is widely misunderstood because the position it replaces was itself widely misunderstood.
What the old rule actually said
A common belief among continuing airworthiness professionals is that only a CAMO forming part of the air operator certificate on which the aircraft is listed could issue the ARC directly. That was never what point M.A.901 said. The old rule never mentioned the AOC at all. It operated in three tiers:
| Old M.A.901 | Who could issue the ARC directly |
|---|---|
| (e) — aircraft of 2 730 kg MTOM and below, not used by licensed air carriers | Any CAMO or CAO chosen by the owner or operator, with no requirement to manage the aircraft |
| (c) — air carrier aircraft and all aircraft above 2 730 kg, in a controlled environment | Only the organisation referred to in point (b)(1) managing the continuing airworthiness of the aircraft |
| (d) — the same aircraft outside a controlled environment, or managed by an organisation without the review privilege | Nobody. A recommendation went to the competent authority, which issued the ARC |
The gate in tier (c) was therefore “are you the CAMO or CAO that manages this aircraft?”, not “are you part of an AOC?”
Where the AOC requirement really came from
The belief is not baseless — it just describes a two-step chain, and it only ever applied to commercial air transport:
- Point M.A.201(e)(2) requires that, for aircraft used by air carriers licensed under Regulation (EC) No 1008/2008, the operator takes the necessary steps to ensure its approval as a CAMO as part of the air operator certificate for the aircraft it operates.
- Point M.A.201(ea), added by Commission Implementing Regulation (EU) 2022/410, relaxes this so that at least two operators forming part of a single air carrier business grouping may use the same CAMO, subject to five conditions.
- Point CAMO.A.125(b) mirrors the same architecture on the approval side.
Because only that CAMO could manage those aircraft, and because only the managing organisation could issue the ARC under the old M.A.901(c), the outcome looked like an AOC rule. The cause was the continuing airworthiness management rule, not the airworthiness review rule.
The distinction mattered in practice. For a non-AOC aircraft above 2 730 kg — a Part-NCC business jet, an aircraft in specialised operations, or a privately operated large aeroplane — an independent CAMO holding the airworthiness review privilege and managing the aircraft could always issue the ARC itself. That covers a substantial part of business aviation, and it never required an AOC.
What changes on 7 August 2026
New point M.A.901(c) provides that an organisation approved to carry out airworthiness reviews under CAMO.A.125(e) or CAO.A.095(c)(1) may carry out an airworthiness review of an aircraft included in its scope of work. That is the entire eligibility test for the reviewing organisation. There is no requirement that it also manages the aircraft.
The three conditions in M.A.901(b)(1) that decide between an ARC and a recommendation concern the aircraft’s history — continuity of management, continuity of compliant maintenance, and a valid unrevoked certificate of airworthiness — not the identity of the reviewer.
Two further provisions confirm this is deliberate rather than a drafting accident:
- New CAMO.A.220(a)(7), and the corresponding text in CAO.A.090(c), impose a five-year retention obligation specifically where the organisation issuing the ARC, recommendation, evaluation programme or report, or permit to fly is different from the organisation managing the continuing airworthiness of the aircraft.
- Point M.A.901(e) requires the M.A.201-responsible party to give records, accommodation, aircraft access and certifying-staff assistance to “the organisation or the competent authority carrying out the airworthiness review” — wording that only makes sense if the reviewer may be a third party.
So yes: from 7 August 2026 a Part-CAMO approved for airworthiness review and entirely independent of any air operator certificate may issue the ARC itself, and it does not have to be the organisation managing that aircraft. What existed only for aircraft of 2 730 kg MTOM and below is extended across the whole fleet, including aircraft on an AOC.
The limits that still apply
1. Points M.A.201(e)(2) and (ea) are not amended. For air carrier aircraft the AOC-integrated or business-grouping CAMO must still manage the continuing airworthiness. Only the review is decoupled.
2. The reviewing organisation must have its principal place of business in a Member State — CAMO.A.125(e).
3. The aircraft must be included in the scope of work in the CAME or CAE. This is the real practical gate and the point on which competent authorities will focus.
4. The airworthiness review still cannot be subcontracted — M.A.901(g). Your own authorised review staff must perform it.
5. Extension is not decoupled. Under M.A.902(b) only the organisation managing the continuing airworthiness may extend, and it must have managed the aircraft continuously since the ARC was issued. An independent organisation can issue the certificate but cannot extend it in year two.
6. Five-year retention of the ARC, the airworthiness review report and all supporting documents applies when the issuer is not the manager, and a copy of the ARC goes to the competent authority of the State of registry within 10 days under M.A.901(i).
Change 4: a written airworthiness review report is now mandatory
New points M.A.903(h) and ML.A.903(h) require that the details and the outcome of an airworthiness review be recorded in an airworthiness review report. Points CAMO.A.220(a)(3) and CAO.A.090(a)(4) then require the ARC or recommendation to be retained together with that report.
Most mature CAMOs already produce something equivalent as internal practice. From 7 August it becomes a regulated record: it needs a controlled template, defined minimum content, an accountable owner and a place in the record-keeping system with the correct retention period.
The same point brings other process obligations. M.A.903(e) requires the review to be planned so that the time elapsed between the records review and the corresponding physical verification is as short as possible — an auditable scheduling requirement. M.A.903(d) tightens the physical survey rule: review staff who are not qualified as certifying staff on that specific aircraft must be assisted by such personnel, replacing the looser reference to Part-66 qualification in general. And M.A.903(b)(12) introduces a check on maintenance released under a different regulatory system during any period the aircraft was outside the scope of the Regulation.
Change 5: the ARC survives a transfer of registration between Member States
Under the previous M.A.902(a), an ARC became invalid if the aircraft was no longer on the register of a Member State. That condition is deleted, as is the invalidity trigger linked to suspension or revocation of the type certificate.
The consequence, set out in M.A.905 and M.B.905, is that a valid ARC now remains valid to its expiry date through an intra-EU transfer and is simply amended with the new nationality and registration marks by the competent authority of the new Member State of registry. On the initial airworthiness side, point 21.B.320(a) now exempts these transfers from the requirement to perform investigation activities before issuing the certificate of airworthiness.
For anyone running a multi-register fleet, this removes the single largest cost and delay in re-registering an aircraft within the Union. Recital 7 frames it as enhancing the free movement of aircraft.
Change 6: a Level 1 finding no longer revokes the ARC automatically
The old M.B.903 required the competent authority, on a Level 1 finding, to require corrective action before further flight and to take immediate action to revoke or suspend the ARC.
New M.B.907(c) requires correction before further flight for Level 1 findings, and then provides that the ARC shall be revoked or suspended if the correction is not implemented immediately. The certificate now survives a Level 1 finding that is fixed immediately. M.B.907(d) adds an escalation ladder for uncorrected Level 2 findings.
Two related changes matter for compliance monitoring. M.B.907(e) requires the authority to inform, where different, the competent authority of the organisation responsible for continuing airworthiness and the competent authority of the organisation that issued the current ARC. And M.A.907 requires a corrective action plan including corrections and corrective actions — a distinction now written into the implementing rule itself, which many corrective action plan templates do not currently make.
Change 7: occurrence reporting is rebuilt, and Part-CAO gets a new point
Points M.A.202 and ML.A.202 previously applied to any person or organisation responsible under M.A.201 or ML.A.201, duplicating obligations that already existed under Regulation (EU) No 376/2014. They now apply only to three categories of individual: an owner carrying out continuing airworthiness tasks themselves, independent certifying staff, and the pilot-owner. Reports go to the competent authority of the Member State of registry and to the organisation responsible for the design, within 72 hours.
Organisational duties move to a rewritten CAMO.A.160 and to an entirely new CAO.A.120. Part-CAO previously contained no occurrence reporting point at all. Every CAO must now operate a reporting system covering mandatory and voluntary reporting, with a defined onward-distribution matrix, and — for organisations without a principal place of business in a Member State — explicit confidentiality safeguards for the identity of the reporter and of persons named in reports.
For a small CAO this is the heaviest genuinely new build in the package, because voluntary reporting implies a just-culture policy, a confidential channel, an analysis step and a records trail. A new point (f) in Part-ML Appendix I also requires every owner–CAMO and owner–CAO contract to specify each party’s occurrence reporting obligations, which means a contract amendment across the customer base.
Change 8: Part-ML reviews by independent certifying staff now require a Part-66 licence
New point ML.A.904(c) requires airworthiness review staff acting on their own behalf to hold a licence issued in accordance with Annex III (Part-66) rated for the corresponding aircraft, plus an authorisation from the competent authority that issued that licence. The alternative route based on a national certifying-staff qualification is removed, along with the associated mutual-recognition caveat.
In Member States that still authorise nationally qualified certifying staff to perform reviews, affected individuals lose the privilege on 7 August 2026 unless they hold a Part-66 licence. This is worth raising with the national competent authority now.
Change 9: new EASA forms
| Form | New Issue |
|---|---|
| EASA Form 15a — ARC issued by the competent authority (Part-M) | Issue 6 |
| EASA Form 15b — ARC issued by an approved organisation (Part-M) | Issue 7 |
| EASA Form 15c — ARC for aircraft complying with Part-ML | Issue 5 |
All three gain an “ARC reference” field. Form 15b now certifies a review carried out in accordance with M.A.903 and names Part-CAMO and Part-CAO organisations as issuers. Every system that prints an ARC needs its templates updated before 7 August 2026.
The new evaluation programme privilege
Where a statement of the airworthiness status of an imported aircraft is unavailable and cannot be obtained, Delegated Regulation (EU) 2026/56 introduces an alternative mechanism based on an evaluation programme and an evaluation report. Regulation (EU) 2026/100 creates the matching organisational privileges at CAMO.A.125(g) and CAO.A.095(c)(3), allowing an organisation that already holds the airworthiness review privilege to develop the programme, conduct the investigations and issue the report — using staff already approved to carry out airworthiness reviews for that aircraft.
Scope has widened too. What was “airworthiness review of aircraft imported into the Union” becomes M.A.906 “airworthiness review of aircraft without an airworthiness certificate issued in accordance with Regulation (EU) No 748/2012”. Recital 10 confirms this captures aircraft previously used for activities under Article 2(3)(a) of Regulation (EU) 2018/1139 — military, customs, police, search and rescue, firefighting and coastguard — as well as aircraft whose EU certificate of airworthiness was revoked or surrendered.
For organisations with import or ex-state conversion experience, this is a new and optional service line worth evaluating.
What CAMO and CAO postholders should do before 7 August 2026
1. Run a cross-reference sweep. Search every controlled document, checklist and IT template for M.A.901 to M.A.905, M.B.901 to M.B.904, ML.A.901 to ML.A.906, ML.B.902 and ML.B.903. Re-point every hit.
2. Write the airworthiness review report template and give it a place in the record-keeping system with the correct retention period.
3. Replace the ARC-versus-recommendation decision logic in the exposition and retrain airworthiness review staff on the three new conditions.
4. Decide whether you want to review aircraft you do not manage, and if so get the scope of work right in the CAME or CAE before you approach the authority.
5. Load EASA Form 15b Issue 7 and Form 15c Issue 5 into every system capable of printing an ARC, and quarantine the superseded templates.
6. If you are a CAO, start building CAO.A.120 now — it is the only requirement in the package that must be created from nothing.
7. Read ED Decision 2026/005/R alongside the regulation. The AMC and GM answer questions the implementing rule leaves open.
Sources
- Commission Implementing Regulation (EU) 2026/100 of 15 January 2026 — OJ L, 2026/100, 19.1.2026
- Commission Delegated Regulation (EU) 2026/56 of 23 October 2025 — OJ L, 2026/56, 19.1.2026
- Commission Regulation (EU) No 1321/2014, consolidated
- Commission Regulation (EU) No 748/2012, consolidated
- Commission Implementing Regulation (EU) 2022/410 (introducing point M.A.201(ea))
- EASA Opinion No 08/2024
- EASA ED Decision 2026/005/R, 6 July 2026
This article is a summary for professional readers and is not a substitute for the published regulation. Always work from the Official Journal text and the current EASA Easy Access Rules.
