eVTOL records after type certification

If you are preparing to accept an eVTOL, an electric vertical take-off and landing aircraft, first establish which model will arrive, with which equipment and for what use. Those answers identify the maintenance rules, documents and authorised personnel to check.

Continuing airworthiness means keeping the aircraft safe to fly in accordance with applicable requirements. Type certification approves a design; it does not replace the records for each individual aircraft. Configuration means the equipment and versions actually installed. The word eVTOL alone does not determine all these rules.

The framework applicable since February 2026

Implementing Regulation 2025/111 adapts continuing airworthiness Regulation 1321/2014 to electric and hybrid propulsion and non-conventional aircraft. Article 2 states: “It shall apply from 13 February 2026.” It has been applicable since that date.

EASA Decision 2026/002/R, published on 3 February 2026, supports the change through acceptable means of compliance and guidance material. It does not announce a particular manufacturer's entry into service.

The practical task is to prepare usable records once the type, configuration and operating conditions are established. This article proposes a preparation method, not a universal maintenance programme.

Start with a scope sheet

The dossier's first page should answer three questions: which classification, which configuration and which operation? Keep the reference and verification date for each answer.

The regulation distinguishes non-conventional aircraft, complexity criteria and the scope of Part-ML, the part of the regulation intended for certain light aircraft. It also provides different treatment for certain aircraft listed on the certificate of an air carrier holding a European operating licence. A CAMO is a continuing airworthiness management organisation. The word eVTOL alone does not establish an obligation to use one.

For a specific project, confirm the applicable regime with the competent authority and the organisations involved. The preparation sheet should reference that analysis instead of ticking an unscoped “EASA compliant” box.

Our article on electric and hybrid fleet records discusses changing fleet data. The aim here is more specific: define what the recipient needs to be able to accept at document handover.

Connect documents to the configuration

A pile of files does not always answer a simple question: do these records describe the aircraft as it is today?

We recommend linking the aircraft's identity to installed equipment references, document revisions and recorded interventions. Information without a date or an associated configuration should remain an open question.

For batteries, do not invent a generic health threshold or replacement interval. Use the limits, methods and data required for the relevant type and equipment. A battery-management-system indicator only has meaning alongside its definition, unit and measurement conditions.

The dossier can identify where those data reside, who supplies them and how a change will be reflected. This proposed organisation does not replace the manufacturer's instructions for continued airworthiness.

Check the scope of competence too

B1.E is an aircraft maintenance licence subcategory introduced by the regulation for aeroplanes with electric power plants and a maximum take-off mass strictly below 5,700 kg. It provides for EASA to determine applicable categories for aircraft outside the defined categories. A qualification with “electric” in its name is therefore not a general authorisation for every eVTOL.

Decision 2026/001/R and its CS-MCSD Issue 2 annex address maintenance certifying staff training data. MCSD.100 links these specifications to Group 1 aircraft, a classification used for maintenance qualifications, and the certification basis established by EASA. These data address type-specific training; they are not an individual authorisation to work on an aircraft.

At dossier acceptance, request the training, qualification and authorisation references relevant to the type and planned tasks. Check their scope rather than inferring competence from a generic training document.

A hypothetical case: battery replacement before delivery

Imagine an aircraft acceptance project whose classification and regime have already been confirmed. A battery was replaced before delivery. The received dossier contains a battery identity, a test report and an outdated configuration list.

The records manager does not conclude that the aircraft is unsafe. The finding is that the link between the delivered equipment and documented configuration has not been established.

The manager requests the updated configuration, references applicable to the replacement, and the execution and certification evidence required for that intervention. They reconcile identifiers and check that the documents concern the same operation.

If something is missing, the tracking entry states precisely “configuration match to be established”. Digital integrity evidence can show that a file has not changed; it cannot fill an absent documentary requirement.

The issue closes when the competent person has the evidence required under the applicable procedures. This example prescribes neither a battery criterion nor a release-to-service decision.

The handover sheet to prepare

• Scope: classification, intended operation and reference to the regulatory assessment.
• Configuration: aircraft identity, relevant equipment and version of the reference list.
• Maintenance: applicable programme and instructions, revisions, recorded interventions and due items.
• Competence: organisations and individuals, scope of relevant qualifications and authorisations.
• Gaps: missing evidence, response owner and closure condition.
• Transfer: recipient, access to source files and acknowledgement of receipt.

This sheet is a working tool proposed by Kepler, not an exhaustive regulatory checklist. It helps formulate verifiable requests and prevents a change of contact from erasing outstanding questions.

Our analysis of AI search in maintenance records explains why finding a document does not establish its evidential value. For an eVTOL as for a conventional fleet, the dossier should connect a question to its evidence and to the person who can validate it.