Regulation 2026/100: preparing an airworthiness review

Regulation (EU) 2026/100 changes how airworthiness reviews are organised and recorded. A review periodically checks an aircraft’s records and physical condition. The review provisions have applied since 7 August 2026. For your next deadline, start by separating three questions: which organisation is authorised, whether the certificate can be issued or extended, and which report must stay in the records.

ARC stands for Airworthiness Review Certificate. The issuance and recommendation route described below concerns Part-M, part of the continuing airworthiness regulation. Part-ML, which covers certain categories of light aircraft, has its own provisions. Establish which regime applies to the aircraft before choosing a route.

A separate organisation can perform the review, with conditions

A CAMO is a continuing airworthiness management organisation. A CAO is a combined airworthiness organisation whose activities depend on its approval. The organisation reviewing the aircraft can be different from the one managing it, but must hold the necessary privileges and act within its approved scope. The regulation does not allow any service provider to issue an ARC.

After satisfactory completion of the review, M.A.901(b)(1) allows the organisation to issue the ARC when three conditions are met:

• Since issuance of the previous ARC, continuing airworthiness has been managed without interruption in accordance with M.A.201 or ML.A.201.
• Throughout that period, maintenance has complied with the continuing airworthiness regulation.
• At the time of the review, the aircraft holds an airworthiness certificate issued under Regulation (EU) 748/2012 that has neither been revoked nor surrendered.

In the other cases covered by M.A.901(b)(2), a recommendation goes to the authority of the State of registry for ARC issuance. That route does not bypass non-compliance: M.A.903(g) prevents issuance of the ARC or recommendation until all actions needed to eliminate detected non-compliance have been implemented. M.A.901(h) also prohibits ARC issuance where evidence or indications show that the aircraft is not airworthy. Source: Annex III to Regulation 2026/100, amending Annex I (Part-M) to Regulation 1321/2014.

A management change does not necessarily break continuity

This distinction matters when preparing the records. GM1 M.A.901(b), pages 7 and 8, explains that successive persons or organisations can provide management, provided there is no interruption. GM means explanatory guidance material from EASA.

In a fictional example, a CAMO takes over on the day its predecessor’s contract ends, with a handover that maintains continuity. That change alone does not require a recommendation to the authority. The actual continuity and the other issuance conditions still need examination.

Extension follows a different rule

M.A.902 allows a maximum of two consecutive one-year extensions of an ARC with one-year validity. For this route, the same organisation must have managed continuing airworthiness continuously since ARC issuance. Maintenance must have been performed by Part-145 or Part-CAO approved organisations, and there must be no evidence or indications that the aircraft is not airworthy. The text nevertheless allows pilot-owner maintenance tasks carried out and released to service by the pilot-owner or independent certifying staff to be included.

Access to an independent review therefore does not create an automatic right to extend a certificate. Nor does the new text, by itself, invalidate every previously issued ARC. Check its expiry and the validity conditions in M.A.902. Source: M.A.902.

The report must explain the outcome

M.A.903(h) and ML.A.903(h) require the details and outcome of the review to be recorded. AMC1 M.A.903(h), pages 23 to 25, describes an acceptable means of compliance covering records and areas examined, findings, corrections, personnel and the conclusion. These details support the rules; they do not prescribe software.

The report must be retained with the ARC or recommendation. Retention is not uniformly five years for a CAMO or CAO: the rules distinguish, among other things, copies retained for three years after management is transferred and documents retained for five years from issuance by a separate issuing organisation. Our article on retention and evidence explains this distinction.

Prepare the next review

Our recommendation is to confirm the aircraft’s applicable regime and the organisation’s privileges, reconstruct management continuity since the previous ARC, then establish the issuance or extension route. Prepare the report and its archive with those conducting the review.

The regulation was published on 19 January 2026. Article 4 sets general application at 7 August, with specific February dates for the corrections in Article 3. The associated AMC and GM were adopted on 6 July 2026 through EASA Decision 2026/005/R. This explanation is current to 12 September 2026. Decisions for an individual aircraft remain with authorised parties examining its records.