By Vincent Wigmans
Do you own a light aircraft in Europe? Then you enjoy the freedom of General Aviation (GA). But that freedom comes with an enormous responsibility: ensuring the continuing airworthiness of your aircraft. Surprisingly, many private aircraft owners don’t realize that they hold the ultimate responsibility for complying with all, often complex, maintenance regulations.
The European rules for aircraft maintenance, known as EASA Part-M and the more recent Part-ML (Maintenance for Light Aircraft), are in place to ensure safety. For many GA owners, Part-ML is the most relevant set of rules, yet it is also a significant source of confusion and misunderstandings. Ignorance can lead to fines, invalid Airworthiness Review Certificates (ARCs), or, worse, unsafe flying conditions.
What is EASA Part-ML and Who Does It Cover?
Part-ML is the simplified and proportionate regulation from EASA (European Union Aviation Safety Agency) specifically designed for the continuing airworthiness management of light, non-complex aircraft. It was introduced to reduce the administrative burden on General Aviation, compared to the more stringent Part-M rules.
Part-ML typically applies to:
- Aeroplanes with a maximum take-off mass (MTOM) of 2,730 kg or less.
- Rotorcraft with an MTOM of 1,200 kg or less and certified for a maximum of 4 occupants.
- Other ELA2 aircraft (such as gliders and balloons).
In short: if you own a Cirrus SR, Cessna 172, Piper Warrior, or a similar popular GA aircraft for private use, chances are your maintenance is governed by Part-ML.
The Owner’s Core Responsibilities (ML.A.201)
The biggest change under Part-ML is the clear emphasis on the owner’s ultimate accountability. Many owners assume that the contracted maintenance organisation (CAMO/CAO) handles everything, but this is a dangerous misconception.
As the owner, you are legally obligated to:
- Have a Valid Aircraft Maintenance Programme (AMP): You must ensure an Aircraft Maintenance Programme (AMP) exists for your specific aircraft and that this programme is actively followed.
- Declare the AMP: In many cases, if your Part-ML aircraft is not used commercially, you as the owner are allowed to ‘declare’ the AMP yourself. This means you take full responsibility for its content and compliance. This is a massive trust measure from EASA, but it requires a solid understanding of the rules.
- Comply with Airworthiness Directives (ADs): You are responsible for the timely execution of all mandatory Airworthiness Directives.
- Maintain Maintenance Records: Every maintenance task performed, every repair, or modification must be accurately documented and retained in the logbooks, ready for the annual Airworthiness Review.
New Flexibility: Pilot-Owner Maintenance
One of the most appreciated flexibilities within Part-ML is the provision for Pilot-Owner Maintenance (POM). This allows the pilot-owner (holding a valid pilot licence) to perform a limited set of simple maintenance tasks themselves.
What you must know about POM:
- Limited to Non-Complex Tasks: This includes simple tasks such as fluid level checks, or a light replacement, provided they follow the manufacturer’s instructions.
- Release is Mandatory: Even after performing POM, you must correctly document and release the work performed (using a Certificate of Release to Service), including your name and pilot licence number.
- Must be in the AMP: The tasks you are permitted to perform as POM must be specifically included in your aircraft’s approved/declared AMP.
The Most Dangerous Misconception
The biggest pitfall in the GA community is assuming that the “annual inspection” is sufficient. The Airworthiness Review Certificate (ARC) requires that the aircraft is in an airworthy condition at all times and that the complete AMP has been carried out, including tasks that are due on a calendar basis (e.g., every 500 hours or every 5 years), regardless of the yearly inspection.
Our Call to Action:
Take the continuing airworthiness management of your aircraft seriously. Study the regulations, consider taking a course, or contract a reliable CAO (Combined Airworthiness Organisation) or CAMO (Continuing Airworthiness Management Organisation) to manage the administrative burden for you.
Safety in the skies starts with compliance on the ground. Don’t let your passion for flying be grounded by neglected paperwork. Know your Part-ML.
Need help? Please contact us at sales@faaircraftsales.com