EASA 2026/100: Airworthiness Review Rules Change

Since 7 August 2026, Commission Implementing Regulation (EU) 2026/100 rewrites the airworthiness review process of Regulation (EU) No 1321/2014: the "controlled environment" concept disappears, a written review report becomes mandatory, and an independent organisation may issue the ARC for any aircraft included in its scope of work. If you run a CAMO or a CAO, the decision to make on Monday is not whether the text applies to you — it does — but whether you want to exploit the new privilege of reviewing aircraft you do not manage, and how to industrialise the review report that has become a regulatory record.

What concretely changes

Commission Implementing Regulation (EU) 2026/100 of 15 January 2026 amends Regulations (EU) No 748/2012 and (EU) No 1321/2014. It implements EASA Opinion No 08/2024 and works together with Commission Delegated Regulation (EU) 2026/56, which applies from the same date. The associated acceptable means of compliance (AMC) and guidance material (GM) were adopted on 6 July 2026 by EASA ED Decision 2026/005/R, which updates the AMC & GM to Part 21 (Amendment 18), Part-M (Amendment 10), Part-145 (Amendment 9), Part-ML (Amendment 4), Part-CAMO (Amendment 6) and Part-CAO (Amendment 6).

End of the controlled environment. Until 6 August 2026, the ability to issue an ARC directly depended on a test combining the "controlled environment", the 2 730 kg MTOM threshold and the air carrier status. The new point M.A.901(b) replaces all of this with three conditions about the aircraft's history: continuous management of continuing airworthiness since the previous ARC, maintenance in accordance with the Regulation since the previous ARC, and a valid certificate of airworthiness issued under Regulation (EU) No 748/2012. If any condition is not met, the review results in a recommendation to the competent authority instead of an ARC. The mass threshold and the air carrier distinction leave the decision. Recital 5 of the Regulation states the intent plainly: limit the recommendation to cases where the involvement of the competent authority is necessary to guarantee the expected level of safety.

The direct ARC issue test, before and after 7 August 2026.

The review is decoupled from management. New point M.A.901(c) provides that an organisation approved to carry out airworthiness reviews (points CAMO.A.125(e) or CAO.A.095(c)(1)) may review any aircraft included in its scope of work — without being the organisation managing that aircraft's continuing airworthiness. What previously existed only for aircraft of 2 730 kg and below is extended across the whole fleet, including aircraft operated under an AOC. Mind the limits: ARC extension remains reserved for the managing organisation (M.A.902(b)), which must have managed the aircraft continuously since the ARC was issued; the review cannot be subcontracted (M.A.901(g)); the aircraft must be listed in the scope of work of the CAME or CAE; and the review organisation must have its principal place of business in a Member State (CAMO.A.125(e)). Two provisions confirm the decoupling is deliberate: point M.A.901(e) obliges the M.A.201 responsible party to give the review organisation access to the records, the aircraft and the necessary assistance, and point M.A.901(i) requires a copy of the ARC to be sent to the competent authority of the State of registry within ten days.

A written review report becomes mandatory. New points M.A.903(h) and ML.A.903(h) require the details and the outcome of every airworthiness review to be recorded in a written report. Points CAMO.A.220 and CAO.A.090 require this report to be retained together with the ARC or the recommendation — with a five-year retention obligation where the organisation issuing the ARC is not the one managing continuing airworthiness (CAMO.A.220(a)(7), CAO.A.090(c)). What was good practice becomes a regulated record: controlled template, defined minimum content, an identified owner, and a place in the record-keeping system. The same point M.A.903 tightens the process itself: the time elapsed between the records review and the physical survey must be as short as possible (M.A.903(e)), and review staff not qualified as certifying staff on that specific aircraft must be assisted (M.A.903(d)).

Renumbering of points M.A.901 to M.A.907. This is the trickiest change, because it is invisible. The former M.A.903 (registration transfer) becomes M.A.905, the review process moves to M.A.903, and two new points appear: M.A.906 (review of aircraft without a certificate of airworthiness issued under Regulation (EU) No 748/2012) and M.A.907 (findings). Every exposition, checklist or procedure citing "M.A.901" or "M.A.903" must be reworked: an outdated cross-reference does not merely become stale — it points at the wrong requirement. Section B and Part-ML follow the same pattern.

New EASA forms. Form 15a (ARC issued by the authority) moves to Issue 6, Form 15b (ARC issued by an approved organisation) to Issue 7, and Form 15c (Part-ML ARC) to Issue 5. All three gain an "ARC reference" field.

All three ARC forms gain an 'ARC reference' field.

Who is affected

• CAMOs (Part-CAMO) and CAOs (Part-CAO) holding the airworthiness review privilege, or applying for it: procedures, exposition, review staff authorisations and forms must be updated.
• Operators and owners, who may now entrust the review to an organisation independent from the one managing continuing airworthiness — including business aircraft and multi-register fleets.
• CAOs, which must additionally build the new occurrence reporting system of point CAO.A.120, absent from Part-CAO until now.
• Competent authorities, whose volume of recommendations to process should mechanically decrease.

Practical CAMO / CAO checklist

1. Sweep regulatory cross-references. Search M.A.901 to M.A.905, M.B.901 to M.B.904, ML.A.901 to ML.A.906 in every controlled document, checklist and IT template, and re-point every occurrence to the new point.
2. Create the airworthiness review report template: minimum content aligned with the AMC & GM of ED Decision 2026/005/R, controlled version, designated owner, and filing in the record-keeping system with the applicable retention period (five years if the ARC issuer is not the manager).
3. Rewrite the ARC / recommendation logic in the exposition and retrain review staff on the three new conditions of point M.A.901(b).
4. Decide on the scope of work: do you want to review aircraft you do not manage? If so, get those aircraft into the scope of work of the CAME or CAE before approaching the authority.
5. Load Forms 15a Issue 6, 15b Issue 7 and 15c Issue 5 into every system capable of printing an ARC, and quarantine the superseded templates.
6. For CAOs: build CAO.A.120 (mandatory and voluntary occurrence reporting), the only requirement in the package that starts from nothing.
7. Read ED Decision 2026/005/R alongside the regulation: the AMC & GM answer the questions the rule leaves open, starting with the expected content of the review report.

Bounded case: reviewing a mixed fleet, step by step

Take a concrete, deliberately narrow case. A French CAMO — call it CAMO A — manages the continuing airworthiness of a mixed fleet: a turboprop operated under an AOC and a business jet in non-commercial operation. For 2026-2027, the jet's owner decides to entrust the airworthiness review to a second, independent organisation — CAMO B — holding the CAMO.A.125(e) privilege with its principal place of business in a Member State. CAMO A keeps managing the continuing airworthiness of both aircraft. Here is how the jet's review now unfolds, and who retains what.

Before the review. CAMO B first checks its own perimeter: is the jet included in the scope of work of its CAME? If not, that — not the privilege — is the blocker, and the scope of work must first be extended with the authority. On the customer side, point M.A.901(e) obliges the continuing airworthiness responsible party (the operator and CAMO A) to make the aircraft's records, access to the aircraft and the necessary assistance available to CAMO B: slow or refused access to records is the first operational risk of the new setup, and it is settled by contract, not by the Regulation.

During the review. CAMO B's authorised airworthiness review staff plans the records review and the physical survey so that the time elapsed between the two is as short as possible, as required by point M.A.903(e) — a scheduling requirement that has become auditable. If the review staff is not qualified as certifying staff on that specific aircraft type, point M.A.903(d) requires assistance by such personnel during the physical survey. The review follows the checks of point M.A.903(b), which now include verifying maintenance released under a different regulatory system during any period when the aircraft was outside the scope of the Regulation (M.A.903(b)(12)) — relevant for a business jet that may have spent time outside the Union.

The ARC-or-recommendation decision. CAMO B tests the three conditions of point M.A.901(b): continuous management of continuing airworthiness since the previous ARC, maintenance in accordance with the Regulation since the previous ARC, and a valid certificate of airworthiness issued under Regulation (EU) No 748/2012. All three are met: CAMO B issues the ARC on EASA Form 15b Issue 7. Had the jet changed managing CAMO mid-year — breaking management continuity — the same review would have ended in a recommendation to the authority.

The report and its retention. The details and the outcome of the review are recorded in the review report required by M.A.903(h), signed by the review staff who carried out the review, then filed together with the ARC. Because CAMO B issues the ARC without managing the jet's continuing airworthiness, point CAMO.A.220(a)(7) requires it to retain the ARC, the report and the supporting documents for five years. CAMO A keeps its copy with the aircraft's airworthiness records, and CAMO B sends a copy of the ARC to the competent authority of the State of registry within ten days (M.A.901(i)).

The last row of the table is the one contracts forget most often: an independent CAMO may issue the ARC, but it can never extend it the following year. An owner who decouples the review from management must therefore decide at contract signature who does what at the N+1 milestone — extension by CAMO A, or a new full review.

What the Regulation does not say

The text settles the architecture but deliberately leaves points open. Identifying them avoids searching the Regulation for answers it does not contain — and presenting internal choices as obligations.

• The content of the review report is not defined by the Regulation. Point M.A.903(h) requires the "details and outcome" of the review, with no template and no list of sections. The expected minimum content belongs to the AMC & GM adopted through ED Decision 2026/005/R: that document, not the Regulation, must drive the template design.
• The format remains free. Nothing on electronic records, signature, timestamping or the report's language: the text is technology-neutral. Those choices are documented in the exposition and agreed with the authority — they cannot be read off the Regulation.
• No transitional accommodation is written. Nothing for existing ARCs, in-progress authorisations or form stock. If any accommodation exists, it can only come from the AMC & GM or from your authority's practice — never from a basis in the text. Planning on an unwritten tolerance is a risk.
• The effect on recommendation volumes is not measured. Recital 5 states the intent to limit recommendations to cases where authority involvement is necessary, but the Regulation says nothing about national practices or processing times. Any quantified projection would be speculation.
• Extending the scope of work remains an approval. The Regulation conditions the review on the aircraft being listed in the scope of work of the CAME or CAE, but says neither the timeframe nor the evidence your authority will require to approve that extension. That is the point to settle with it first.

Timeline

The four dates of the 2026/100 package: no transitional provisions after 7 August 2026.

The regulation contains no transitional provisions for existing ARCs, in-progress authorisations or form stock: treat 7 August 2026 as a hard switchover.

Kepler's take: 2026/100 compliance is an industrialisation problem, not a legal-reading problem

Kepler's take: our practitioner conviction is that Regulation (EU) 2026/100 should not be handled as a legal memo to circulate, but as a documentary production project. The real difficulty is not understanding the three conditions of M.A.901(b) — any review staff learns them in an hour — but producing, review after review, homogeneous reports signed by the right person, filed in the right place, with the right retention period, while keeping hundreds of regulatory cross-references up to date in controlled documents. Organisations that treat this as a document-flow problem — versioned templates, validation workflows, tamper-evident archiving — will sail through the coming audits; those that treat it as an information circular will discover the gap at audit time.

Kepler Aviation designs traceability and document-automation tooling for maintenance and continuing airworthiness management, within the Kepler Digitals ecosystem. To discuss your Regulation (EU) 2026/100 compliance, contact us.