By Vincent Wigmans
By Vincent Wigmans
For many Cirrus SR owners, the convenience of a “one-stop shop” sounds perfect on paper. But behind closed doors, merging airworthiness management with physical maintenance creates a fundamental conflict of interest. Here is why that setup might be costing you thousands, and weeks of flying time.
The short version: under EASA Part ML a Combined Airworthiness Organisation may legally hold both management and maintenance privileges — that is what “combined” means. It is permitted and common. It also means the organisation deciding what work your aircraft needs is the one invoicing for it.
CAMO or CAO: which does your Cirrus actually need?
What Part-CAMO requires of you as an owner
A Continuing Airworthiness Management Organisation is approved under Part-CAMO to plan, track and control continuing airworthiness. It decides what maintenance is required and when; it does not perform that maintenance itself. A separate Part-145 or Part-CAO maintenance organisation carries out the work.
Part-CAMO carries the heavier compliance burden — including a formal safety management system — and applies to complex motor-powered aircraft and aircraft operated commercially. For a privately flown Cirrus SR, it is generally more organisation than the aircraft requires.
What Part-CAO allows, and why “combined” is the catch
Part-CAO was introduced under Part ML for lighter, non-complex, non-commercially operated aircraft — the category almost every private Cirrus SR falls into. A CAO may hold continuing airworthiness management privileges, maintenance privileges, or both.
The word “combined” refers to combining management and maintenance under one approval. The distinction that matters is not CAMO versus CAO, but whether the organisation signing off your maintenance is the one invoicing for it.
FA Aircraft Sales will hold airworthiness management privileges only. We never perform the maintenance on aircraft we manage.
The Illusory Convenience of the “One-Stop Shop”
When an aircraft maintenance company also holds the airworthiness management approval for your aircraft, the entity responsible for auditing, planning, and ordering work is the exact same entity profiting from performing that work.
An independent CAMO / CAO acts strictly as an owner’s advocate and technical auditor. Its sole objective is to keep the aircraft safe, compliant, and cost-effective.
When the CAMO / CAO and the repair station belong to the same parent company, that objective inevitably shifts toward keeping the shop floor busy and maximizing revenue per aircraft.
Key Takeaway: An independent CAMO / CAO works strictly for the aircraft owner. A combined CAMO / maintenance company ultimately serves the shop’s bottom line.
Why independence matters: what EASA actually says
EASA’s acceptable means of compliance for airworthiness review staff addresses this directly. Where an airworthiness review is conducted inside an organisation holding both continuing airworthiness management and maintenance approvals, the reviewing staff are expected to demonstrate independence from the airworthiness management process — explicitly to avoid a conflict of interest. The guidance further specifies that the reviewer should not have been involved in releasing the maintenance on the aircraft under review, with narrow exceptions for work arising during the physical survey itself.
AMC1 CAMO.A.310(a) Airworthiness review staff qualifications
(e) To hold a position with appropriate responsibilities means the airworthiness review staff should have a position in the organisation independent from the airworthiness management process or with overall authority on the airworthiness management process of complete aircraft. Independence from the airworthiness management process may be achieved, among other ways, as follows:
By being authorised to perform airworthiness reviews only on aircraft for which the person has not participated in their management. For example, performing airworthiness reviews on a specific aircraft type, while being involved in the continuing airworthiness management of a different aircraft type.A CAMO holding a maintenance organisation approval may nominate maintenance personnel from their maintenance organisation as airworthiness review staff, as long as they are not involved in the airworthiness management of the aircraft. These personnel should not have been involved in the release to service of that particular aircraft (other than maintenance tasks performed during the physical survey of the aircraft or performed as a result of findings discovered during such physical survey) to avoid possible conflict of interests.
By nominating as airworthiness review staff personnel from the compliance monitoring department of the CAMO.
The regulator built a firewall inside combined organisations because it recognised the risk. Independent management removes the need for the firewall entirely — there is no inherent maintenance service connected with it.
The Real-World Impact on Aircraft Owners
This lack of independence manifests in several critical ways that directly affect an owner’s wallet and flying schedule:
1. Zero Price Competition and Missing Quotes
When an in-house CAMO / CAO manages your maintenance program, work orders naturally flow directly to their own maintenance bay.
- No Alternative Bidding: Combined providers rarely, if ever, request quotes from competing maintenance facilities to secure better labor rates or faster turnaround times.
- Inflated Costs: Without competitive tension, owners are routinely charged top-tier prices for routine inspections and parts without knowing cheaper, high-quality alternatives exist nearby.
A worked example: three quotes, one inspection
In July 2026 we tendered a 50-hour inspection on a Cirrus SR22 to three EASA-approved facilities in France, Germany and the Netherlands. The scope went well beyond the 50h itself: engine on-condition tasks, a 1000-hour electrical bonding and shielding check, fuel pump overhaul, brake assembly O-rings, battery capacity test, fire extinguisher annual and a NAV light replacement. Identical aircraft, identical scope, quotes within five days of each other.
- Comparable totals, refundable core deposits stripped out: €3,552, €4,416 and €5,196 excluding VAT — a spread of €1,644, or 32% of the highest quote.
- The cheapest was also the fastest: two to three days turnaround against a full week elsewhere.
- Line items diverged further than totals. The same battery capacity test was quoted at €70 and at €450. The same O-ring part number at €2.93 and €39.60 each.
A combined provider requests none of these quotes, because the work was always going to its own bay. The saving wasn’t negotiated. It was simply asked for.
2. Artificially Inflated Downtime
What happens when your combined provider’s shop is fully booked for weeks?
In an independent setup, a CAMO / CAO searches the region for a qualified facility with an open slot to get your aircraft back in the air quickly. A combined company, however, will often keep the aircraft waiting on their own ramp for weeks, choosing to protect their own booking queue rather than transferring the job to a competitor who could assist sooner.
3. “Replacing” Over “Repairing”: A Case in Point
A telltale sign of an unoptimized, self-serving maintenance process is the default inclination to swap parts rather than explore certified repairs.
Consider this real-world scenario involving a cracked turbo bracket:
- The Combined Solution: Order a brand-new factory replacement part at €3,000 with a 5-week lead time at Cirrus, leaving the aircraft grounded for over a month.
- The Independent Solution: Locate an approved local repair facility to fix and re-certify the existing bracket under official regulations for a fraction of the price, reducing downtime to 2 weeks.
Because the combined shop benefits from higher parts markups and simpler part-swapping procedures, they have little financial incentive to research and execute approved local repair solutions that save the owner time and money.
Independent CAO vs combined provider: side by side
| Combined Management & Maintenance | Independent Management | |
| Who plans the work | The organisation that performs it | An organisation with no maintenance in-house |
| Competing quotes sourced | Rarely | Standard practice |
| Workshop slot allocation | Own queue first | Earliest qualified slot in the region |
| Repair vs replace | Replacement is the default | Approved repair assessed first |
| Who reviews the invoice | No independent party | Your management organisation |
| Fee structure | Absorbed into maintenance billing | Fixed and disclosed upfront |
How to switch CAMO or CAO providers
Switching is administrative, not technical, and it does not ground the aircraft.
- Select an approved organisation with no commercial ties to your maintenance provider. Ask directly whether they hold maintenance privileges — a combined organisation will say so.
- Sign a continuing airworthiness management agreement defining scope, responsibilities and fees.
- Transfer the maintenance records. Your existing provider is obliged to release them and transfer them to the new CAO or CAMO; incomplete handovers or inconsistenties are the most common source of delay.
- Review and revise the Approved Maintenance Programme against your serial number, generation and operating profile.
- Confirm ARC continuity so the certificate does not lapse during transition.
FA Aircraft Sales manages onboarding for a fixed intro fee of €1,250, with ongoing management from €75 per month. Maintenance is billed separately.
Reclaiming Control of Your Ownership Experience
An aircraft is a significant investment, and its management should prioritize safety, transparency, and efficiency above shop profit margins. By separating your airworthiness management from the maintenance provider executing the physical work, you introduce a crucial layer of oversight.
An independent management partner acts as your dedicated advocate, ensuring that every repair quote is fair, every procedure is optimized for your schedule, and every decision is made solely in your best interest.
See our independent CAO management for Cirrus SR aircraft — scope, pricing and proposal. Please contact us at sales@faaircraftsales.com or at +31 (0)15 820 0999.
Frequently asked questions
Structurally, yes. The organisation deciding what work is required is the same one invoicing for it. EASA addresses this in AMC1 CAMO.A.310(a), which expects airworthiness review staff in combined organisations to demonstrate independence from the maintenance release process.
art-CAMO covers complex and commercially operated aircraft and requires a safety management system. Part-CAO applies under Part ML to lighter, non-complex, non-commercial aircraft and allows one organisation to hold management privileges, maintenance privileges, or both. Our guide to the difference between Part CAMO and Part CAO covers the resale-value implications.
Yes. Nothing requires you to use the organisation that maintains your aircraft.
Independent management is charged as a disclosed fee rather than bundled into maintenance billing. Our rates start at €1,250 onboarding and €75 per month.
Your existing ARC stays valid until its expiry date — transferring management does not invalidate a certificate already issued. What changes is the extension route. Extending an ARC requires the aircraft to have been in a controlled environment: continuously managed for the previous 12 months by a single CAMO or CAO. A change of provider breaks that continuity, so your new organisation cannot extend the certificate — a full airworthiness review is required at expiry instead.
This makes timing worth planning. Switching shortly after an ARC issue or extension means the new organisation will have managed the aircraft for a full 12 months by the time the next one falls due, restoring the controlled environment and the extension option. Switching shortly before expiry means budgeting for a full review. We flag this at onboarding so it isn’t a surprise.
The management fee is visible where a combined provider’s is often absorbed into maintenance billing. Whether the total is higher depends on what competitive quoting and repair-versus-replace decisions recover over a year.