Airworthiness Considerations Related to EASA Part ML

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Presented by Sofema Online (SOL) (

SOL considers key features of EASA Part ML - What does it mean for the industry?

Beginning of the end of Part M Subpart F

From 24th March 2020 Part M Subpart F is no longer available as an approval option and will be discontinued completely from September 2021.

Continuing Airworthiness of Aircraft following Part-ML

Part-ML is the only option for ‘light aircraft’ not used by a licensed air carrier. All other aircraft must follow Part-M. It is not allowed to ‘voluntary’ apply Part-M on ‘light aircraft’ not used by a licensed air carrier.

One major difference from Part M Subpart F is that Part-ML provides a standard - it is not an approval, therefore, regulation (EU) 1321/2014 does not introduce a ‘Part-ML organisation’ because Part-ML is only a standard for ‘light aircraft’. However, all types of organisations provided for in this Regulation (Part-CAMO, Part-CAO, Part-145) may be involved in continuing airworthiness activities for aircraft following Part-ML.

Additionally, because Part ML is not an organisation there is no quality system included in the regulation - instead, the applicable quality requirements will be found in Part CAO or Part CAMO.

1. Aircraft Maintenance Programs (AMP) of Part-ML aircraft shall be developed I.A.W  ML.A.302.

Note 1: These AMP’s are no longer approved by the competent authority!

They are approved by the CAMO or CAO (or declared by the owner if no CAMO/CAO is contracted).

During the transition existing Subpart F Organisations will be known as Part MF and Subpart G Organisations will be known as Part MG

Concerning Existing CAMO’s Part M Subpart G (Part MG)

A new privilege of AMP approval is added in this respect to Part-MG organisations (M.A.711(a)(5)).

Note 2: Existing AMPs approved in compliance with M.A.302 before 24 March 2020 continue to be valid after 24 March 2020.

Defect management shall be performed according to ML.A.403 (with some alleviations).


To the following aircraft when not listed in the AOC of an air carrier licensed in accordance with Regulation (EC) No 1008/20088 and not classified as complex motor-powered aircraft:

a) Aeroplanes of 2 730 kg MTOM or less
b) Rotorcraft of 1 200 kg MTOM or less certified for a maximum of up to 4 occupants
c) Other ELA2 aircraft

Part ML is typically used in conjunction with Organisational Approval (Part-CAO) with alleviated requirements and with combined privileges for maintenance, continuing-airworthiness management, airworthiness reviews and issuance of permits to fly.

Note Regarding CAO Approval

This new Part-CAO organisation is applicable to:

a) Other-than-complex motor-powered aircraft not listed in the AOC of an air carrier licensed in accordance with Regulation (EC) No 1008/2008
b) Does not contain SMS requirements

Next Steps

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