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CAMO Frequently Asked Questions (FAQs)

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CAMO FREQUENTLY ASKED QUESTIONS

Answers to common questions about CAMO approval, certification, personnel, aircraft, and continuing airworthiness management.

CAMO-1What is CAMO?

Last updated: 14-Oct-2026

CAMO stands for Continuing Airworthiness Management Organisation. It is an organisation approved by CAAT to manage the continuing airworthiness of aircraft in accordance with TCAR AIR Part-CAMO, where required by § M.A.201 or § ML.A.201, as applicable.

A CAMO is responsible for ensuring that aircraft under its management remain airworthy by controlling activities such as the aircraft maintenance programme, maintenance planning, AD/MCAI control, defect control, modification and repair status, component and life-limited part status, technical records, maintenance arrangements, and other continuing airworthiness management activities.

A CAMO does not necessarily perform maintenance itself. Maintenance must be performed by an appropriately approved maintenance organisation, unless otherwise permitted by the applicable requirements. The CAMO’s role is to manage, control, coordinate, and verify that the required continuing airworthiness activities are properly planned and accomplished.

A CAMO is also expected to establish and demonstrate the airworthiness review process required under the applicable continuing airworthiness requirements. Therefore, the organisation should have suitable procedures, qualified airworthiness review staff, records, and control arrangements to support both continuing airworthiness management and airworthiness review activities for the aircraft under its management.

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CAMO-2Who should apply for a CAMO certificate?

Last updated: 14-Oct-2026

A CAMO certificate should be applied for by a Thai juristic person who is required or intends to manage the continuing airworthiness of aircraft under TCAR AIR Part-CAMO.

In particular, an AOC holder is required to hold a CAMO certificate for aircraft operated under its AOC. The expression “CAMO as part of the AOC” means that the same legal entity holding the AOC must also hold the CAMO certificate for the continuing airworthiness management of its AOC aircraft. This applies to aircraft operated under the AOC, regardless of aircraft type or category, where the aircraft is included in the AOC operation.

An independent CAMO may apply for a CAMO certificate where it intends to manage continuing airworthiness for non-AOC aircraft required to be managed by a CAMO, such as non-AOC complex motor-powered aircraft. An independent CAMO cannot directly manage aircraft operated under another organisation’s AOC. Where an AOC holder uses support from an independent CAMO, such support should be provided only as a subcontracted continuing airworthiness management task under the responsibility and control system of the AOC holder’s own CAMO.

The applicant must be a Thai juristic person. This generally means a juristic person established under Thai law, having registered location in Thailand, and having Thai nationality in accordance with the applicable Thai legal requirements. The applicant should be able to provide supporting evidence, such as a juristic person certificate, company registration document, shareholder information, authorised signatory information, and other documents required by CAAT.

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CAMO-3How much does the CAMO certification cost?

Last updated: 14-Oct-2026

The applicable CAMO certification fees have not yet been finalised. The fee regulation is currently being developed through the drafting and public consultation process.

The final fee structure and amounts will be established in the regulation once it is issued. Applicants should monitor CAAT’s official announcements for updates on the applicable fees and their effective date.

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CAMO-4Which aircraft is required to be managed by a CAMO?

Last updated: 14-Oct-2026

In simple terms, an aircraft is required to be managed by a CAMO where the applicable continuing airworthiness responsibility rules require CAMO management under § M.A.201 or § ML.A.201, as applicable.

The main cases are:

  1. Aircraft operated under an AOC
    All aircraft operated under an AOC must be managed by a CAMO that is part of the AOC holder. This applies regardless of aircraft type or category.
  2. Non-AOC complex motor-powered aircraft (CMPA)
    All CMPA not operated under an AOC must also be managed by a CAMO. This applies regardless of whether the operation is commercial or non-commercial.
  3. Other-than-complex motor-powered aircraft (non-CMPA) used in certain commercial operations other than AOC
    For non-CMPA and are used in certain commercial operations other than AOC, the continuing airworthiness of the aircraft may be managed by either a CAMO or, a CAO with continuing airworthiness management privileges.
  4. Part-ML aircraft used in certain commercial operations
    For aircraft subject to Part-ML, such as certain light aircraft, balloons, and sailplanes, and used in certain commercial operations, the aircraft may be managed by either a CAMO or a CAO with continuing airworthiness management privileges, where such management is required by the applicable operating category.

For non-commercial Part-ML aircraft, CAMO or CAO-CAM management is generally not mandatory, although the owner may voluntarily contract one.

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CAMO-5What activity can a CAMO do?

Last updated: 14-Oct-2026

A CAMO may perform continuing airworthiness management activities only within the scope, privileges, limitations, approved aircraft ratings, aircraft list, and procedures approved by CAAT.

The activities that a CAMO may perform are specified in its CAMO certificate, approved CAME, list of organisation privileges, list of aircraft managed, and associated approved procedures. Therefore, not every CAMO can perform all CAMO activities automatically.

In general, a CAMO may be approved to perform the following activities, as applicable:

  1. manage the continuing airworthiness of aircraft not operated under an AOC, as listed on the CAMO certificate;
  2. manage the continuing airworthiness of aircraft operated under its own AOC, in accordance with the applicable operational requirements and as listed on the CAMO certificate;
  3. arrange limited continuing airworthiness management tasks to be performed by subcontracted organisations, while retaining responsibility for those tasks;
  4. approve maintenance programmes for Part-ML aircraft managed in accordance with TCAR AIR Part-ML, where applicable;
  5. conduct airworthiness reviews and issue airworthiness review reports in accordance with the applicable Part-M or Part-ML requirements;
  6. indirectly approve changes not requiring prior approval, where the relevant procedure has been approved by CAAT;
  7. apply an extended internal compliance monitoring cycle, where approved by CAAT;
  8. supervise airworthiness review staff candidates through an authorised ARS Examiner, where approved by CAAT;
  9. use permitted variation to maintenance periods for Part-M aircraft, where approved;
  10. indirectly approve aircraft maintenance programmes or amendments for Part-M aircraft, where approved;
  11. use alternative or additional AMP instructions in accordance with approved procedures, where approved;
  12. use Alternative Means of Compliance, where approved by CAAT.

The intended CAMO scope should clearly identify the aircraft type or series, engine type where relevant, applicable AMP reference, type of operation, aircraft category under Part-M or Part-ML, operator or owner, and any subcontracted organisation used for continuing airworthiness management tasks.

A CAMO shall not perform activities outside its approved scope, privileges, limitations, aircraft ratings, or approved procedures. Where the CAMO intends to expand its activities, add aircraft types, add privileges, change its management model, or introduce new procedures, it should follow the applicable CAAT variation or notification process.

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CAMO-6Do we need to acquire an aircraft before being approved as CAMO?

Last updated: 14-Oct-2026

No. An applicant does not always need to acquire or have a specific aircraft registration before being approved as a CAMO.

However, the applicant must be able to demonstrate that it has the capability, resources, procedures, personnel, maintenance arrangements, AMP control process, records system, and management system necessary to manage the aircraft type or rating requested.

Where no specific aircraft has been acquired or identified yet, the applicant may support the application by using a generic or baseline AMP, assumed aircraft configuration, proposed maintenance arrangements, and demonstration of the relevant continuing airworthiness management processes. In this case, CAAT may assess the applicant’s capability for the requested aircraft rating based on the submitted evidence and demonstration.

However, approval of an aircraft rating based on a generic or baseline AMP does not automatically allow the CAMO to add the first aircraft registration under that rating by itself. The first aircraft registration entry under such aircraft rating requires prior approval by CAAT. This is to allow CAAT to verify that the generic or baseline AMP has been properly converted into an aircraft-specific AMP, and that the aircraft records, AD/MCAI status, maintenance planning, defect status, modification and repair status, component and LLP status, maintenance arrangements, and airworthiness review arrangements are ready for that particular aircraft.

Before the CAMO actually manages a particular aircraft, that aircraft must be properly entered into the CAMO system in accordance with the approved CAME and applicable CAAT requirements.

For an AOC applicant or AOC holder, aircraft entry planning is particularly important. Where the aircraft is intended to be used for the AOC Phase 4.2 actual flight demonstration, the relevant CAMO approval process, aircraft rating, aircraft-specific AMP, aircraft entry package, and CAMO Phase 4 demonstration and inspection should be properly planned and coordinated with the AOC certification timeline. The aircraft should not proceed to the AOC Phase 4.2 actual flight demonstration until CAAT is satisfied that the CAMO has been approved or has satisfactorily completed the relevant CAMO Phase 4 demonstration and inspection for the aircraft type or rating concerned, as applicable. This is to ensure that the aircraft is properly managed by the CAMO in accordance with the applicable Part-M, Part-ML, and Part-CAMO requirements before it is used for actual flight demonstration.

KEY POINT

A CAMO certificate may be granted based on demonstrated capability for the requested aircraft rating, but the CAMO must not exercise continuing airworthiness management responsibility for a specific aircraft until that aircraft has been properly accepted into the CAMO system.

Where the aircraft is the first aircraft registration under a rating approved on a generic or baseline AMP basis, CAAT prior approval is required before the aircraft can be entered into the CAMO system.

For an AOC applicant or AOC holder, aircraft entry and CAMO readiness should be carefully coordinated with the AOC certification process, especially where the aircraft will be used for the AOC Phase 4.2 actual flight demonstration.

See FAQ n. CAMO-16 on how to manage aircraft delivery with the CAMO approval process.

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CAMO-7What is generic or baseline AMP?

Last updated: 14-Oct-2026

A generic or baseline Aircraft Maintenance Programme (AMP) is an AMP developed to support the applicant’s demonstration of capability to develop, control, and manage an AMP for the aircraft type, aircraft rating, or group of similar aircraft intended to be included in the CAMO approval scope.

It may be used to support:

  • CAMO initial certification;
  • approval variation for addition of an aircraft rating;
  • aircraft import or phase-in preparation; or
  • other cases where CAAT accepts that an aircraft-specific AMP cannot yet be fully established

This may apply where the applicant has not yet identified a specific aircraft registration, MSN, customer, contract, or aircraft configuration.

  1. BASELINE AMP

A baseline AMP is normally developed for a particular aircraft type, model, series, or rating. It should be based on applicable source documents, such as:

  • MRB report;
  • MPD;
  • ICA;
  • ALS;
  • CMR;
  • CDCCL;
  • maintenance manual scheduling information;
  • AD/MCAI requirements;
  • applicable operational requirements;
  • CAAT requirements.
  1. GENERIC AMP

A generic AMP is normally developed for a group of similar aircraft types or variants where the maintenance planning basis and continuing airworthiness management method are sufficiently similar.

The applicant should ensure that the aircraft types or variants covered by the generic AMP are sufficiently comparable in terms of maintenance planning basis, configuration assumptions, source data, operation, and continuing airworthiness control method.

  1. LIMITATION OF GENERIC OR BASELINE AMP

A generic or baseline AMP is not an aircraft-specific AMP.

It is not normally applicable to a particular aircraft registration or MSN. It is used to demonstrate to CAAT the scope and complexity of AMP development and continuing airworthiness management activities that the applicant intends to perform.

Acceptance of a generic or baseline AMP does not remove the need to establish an aircraft-specific AMP before the CAMO exercises continuing airworthiness management responsibility for an actual aircraft.

A generic or baseline AMP should not be treated as:

  • a separate AMP standard;
  • a simplified AMP;
  • a substitute for an aircraft-specific AMP; or
  • an authorisation to manage an actual aircraft.
  1. DEVELOPMENT BASIS

The applicant should develop any generic or baseline AMP by using the applicable CAAT guidance material for the development of, as applicable:

  • Part-M AMP; or
  • Part-ML AMP,

When preparing a generic or baseline AMP, the applicant should clearly identify:

  1. whether the AMP is a baseline AMP for a specific aircraft type, model, series, or rating, or a generic AMP for a group of similar aircraft types or variants;
  2. the aircraft type, model, series, engine, APU, propeller, equipment, or configuration assumptions used;
  3. the source documents used, such as MRB report, MPD, ICA, ALS, CMR, CDCCL, TCDS, AMM Chapter 04/05, AD/MCAI, CAAT requirements, and operational requirements;
  4. the assumed utilisation, operating environment, type of operation, maintenance concept, and intended privileges;
  5. any assumed standard equipment, optional equipment, modification, STC, repair, or operational approval;
  6. any limitation, assumption, or item requiring confirmation before the AMP can be applied to an actual aircraft.
  1. INFORMATION TO BE DISTINGUISHED

The generic or baseline AMP should clearly distinguish between:

  1. information already determined for the aircraft type, model, series, rating, or group of aircraft;
  2. information based on assumptions, such as assumed utilisation, operating environment, aircraft configuration, or maintenance concept; and
  3. aircraft-specific information to be confirmed, such as:
  • registration;
  • MSN;
  • actual configuration;
  • modification status;
  • repair status;
  • component status;
  • life-limited parts status;
  • AD/MCAI status;
  • maintenance history;
  • utilisation;
  • operating environment.
  1. CONVERSION INTO AIRCRAFT-SPECIFIC AMP

Before an aircraft is accepted into the CAMO system, the generic or baseline AMP should be converted into an aircraft-specific AMP and approved or accepted in accordance with the applicable requirements.

The conversion should take into account, as applicable:

  • actual aircraft registration and MSN;
  • actual aircraft configuration;
  • utilisation and operating environment;
  • modification and repair status;
  • AD/MCAI status;
  • component and life-limited parts status;
  • maintenance history;
  • applicable operational requirements;
  • bridging actions;
  • additional maintenance requirements;
  • aircraft-specific limitations and applicability.
  1. THE FIRST AIRCRAFT ENTRY

Where an applicant is approved or assessed based on a generic or baseline AMP, the first aircraft registration entry under the relevant aircraft rating shall be subject to prior approval by CAAT, unless otherwise accepted by CAAT.

This is to ensure that the generic or baseline AMP has been properly converted into an aircraft-specific AMP and that the CAMO has demonstrated the ability to control the actual aircraft before exercising continuing airworthiness management responsibility.

A generic or baseline AMP is normally used for certification demonstration only. It does not, by itself, authorise the CAMO to manage an actual aircraft.

Any assumptions used in the generic or baseline AMP should be clearly identified and verified before aircraft entry into the CAMO system.

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CAMO-8How to specify aircraft ratings to be managed?

Last updated: 14-Oct-2026

The applicant should specify the aircraft type, series, model, and engine type that it intends to manage under the CAMO approval. The level of detail may depend on the applicant’s intended scope.

An applicant may choose to request approval for:

  • a specific model;
  • several models within the same series; or
  • several series within the same family.

The aircraft rating should be clear enough for CAAT to understand exactly which aircraft the applicant intends to manage, including engine type where relevant.

EXAMPLES

Possible way to specify aircraft rating

Rating

Specific model and engine

Airbus A320-251N (CFM LEAP-1A26)

Diamond DA62 (Austro Engine E4P)

Multiple models within the same series

Boeing 777-232LR/-200LR (GE90-115B)

Multiple series

Airbus A318/A319/A320/A321 (CFM56)

Series with engine coverage

Airbus A330 (GE CF6, PW 4000 & RR Trent 700)

Multiple series with engine coverage

Boeing 737-8/9 (RR Trent 1000 & GEnx-1B)

The applicant should not request a broad aircraft rating unless it can demonstrate capability for the full scope requested. This means the applicant should be able to demonstrate, as applicable, that it has:

  • access to the applicable ICA, maintenance data, and other continuing airworthiness data for all aircraft models, series, and engine types requested;
  • suitable AMP or generic/baseline AMP coverage for each aircraft model, series, or MPD basis requested;
  • procedures, systems, and records arrangements capable of supporting all requested aircraft;
  • maintenance arrangements appropriate to the requested aircraft rating;
  • personnel training, qualification, experience, and competency covering the requested aircraft models, series, and engine types;
  • airworthiness review staff capability appropriate to the aircraft rating requested.

For airworthiness review demonstration or aircraft physical survey, CAAT may determine the required demonstration sample based on the applicable maintenance programme basis, MPD logic, aircraft configuration, and complexity of the requested rating. For example, if the applicant requests both B737-400 and B737-800, CAAT may require demonstration on both because they are based on different MPD/maintenance programme bases. However, for A318/A319/A320/A321, where the aircraft are supported by a common MPD logic, CAAT may accept a demonstration on one representative aircraft within the series, provided that the applicant can demonstrate capability for the remaining models.

KEY POINT

The applicant may choose how broad or narrow the requested aircraft rating should be, but the broader the requested rating, the more evidence CAAT may require to confirm that the CAMO can effectively manage all aircraft models, series, engine types, and configurations included in that rating.

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CAMO-9There is no AMO for the aircraft type to be managed; what should we do?

Last updated: 14-Oct-2026

The applicant must have an acceptable maintenance arrangement for the aircraft type to be managed. A CAMO cannot be approved to manage an aircraft type, or accept a particular aircraft into its CAMO system, unless CAAT is satisfied that the required maintenance can be properly performed and released to service by an appropriately approved maintenance organisation (AMO).

The applicant should identify, from the Phase 2 – Formal Application preparation stage, which AMO is able to support the aircraft rating requested. The maintenance arrangement should be discussed, coordinated, and agreed with the relevant AMO before submitting the formal application package. The applicant should not wait until Phase 4 demonstration, aircraft entry, or aircraft delivery to find out whether an AMO is available for the aircraft type.

This is because the CAMO is responsible for ensuring that the aircraft remains in an airworthy condition. If there is no AMO capable of performing and certifying the required maintenance for the aircraft type, the CAMO would not be able to effectively discharge its continuing airworthiness responsibilities. For example, the CAMO will not be able to ensure timely accomplishment of AMP tasks, AD/MCAI requirements, defect rectification, troubleshooting, repairs, component replacement, or other scheduled and unscheduled maintenance necessary to keep the aircraft airworthy.

The absence of an acceptable maintenance arrangement may result in maintenance tasks becoming overdue, defects remaining unresolved, AD/MCAI or mandatory tasks not being accomplished within the required time, aircraft records not being supported by proper release to service, and the aircraft becoming unavailable for operation or not meeting the applicable continuing airworthiness requirements.

If there is no AMO approved for the aircraft type, the applicant must resolve the maintenance arrangement before the aircraft type or aircraft entry can be accepted. This may include, as applicable:

  • arranging for an approved AMO through contract to obtain or extend the required aircraft rating or capability;
  • establishing its own approved maintenance capability, where applicable;
  • revising the requested CAMO scope, aircraft rating, aircraft entry plan, or certification timeline until an acceptable maintenance arrangement is available.

The maintenance arrangement must be sufficient for the intended CAMO scope and aircraft operation. It should cover, as applicable, line maintenance, base maintenance, defect rectification, troubleshooting, scheduled and unscheduled maintenance, AD/MCAI accomplishment, AMP tasks, repairs, major components, rotable parts, and other required maintenance support.

Where no acceptable maintenance arrangement can be demonstrated, CAAT will not be able to approve the requested aircraft rating, aircraft entry, or CAMO scope for that aircraft type. For an AOC applicant or AOC holder, this may affect the planned aircraft delivery, C of R, C of A, aircraft entry, and AOC certification timeline, particularly the actual flight demonstration.

KEY POINT

A CAMO manages continuing airworthiness, but aircraft maintenance must still be performed and released to service by an appropriately AMO. Without an acceptable maintenance arrangement, the CAMO cannot effectively ensure that required maintenance is accomplished and that the aircraft remains airworthy. Therefore, the maintenance arrangement must be resolved before the CAMO can manage that aircraft.

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CAMO-10Who can be the Accountable Manager in our CAMO?

Last updated: 14-Oct-2026

To demonstrate compliance with § CAMO.A.305(a) for the appointment of the Accountable Manager, an official document signed by the CEO, Board, or authorised signatory of the company should be provided. This document should state that the nominated Accountable Manager has the authority to act on behalf of the company in continuing airworthiness matters and to ensure that the necessary resources and funds are available for the activities sought.

The Accountable Manager is normally intended to mean the CEO, or equivalent person, who by virtue of his or her position has overall responsibility, including financial responsibility, for running the organisation. The Accountable Manager may be the accountable manager for more than one approved organisation and is not necessarily required to be knowledgeable on technical matters, provided that the exposition defines the continuing airworthiness standards, responsibilities, and control arrangements.

Where the CAMO manages aircraft operated under an AOC, the Accountable Manager of the CAMO shall be the same person as the Accountable Manager of the AOC in accordance with CAMO.A.305(b)(1). This is to ensure that the same person has overall accountability for the airworthiness-related responsibilities supporting the AOC operation, including the availability of resources, funding, and management control necessary for continuing airworthiness management.

Where the Accountable Manager is not the CEO, the organisation should demonstrate to CAAT that the Accountable Manager has direct access to the CEO and has the necessary authority and funding allocation for the activities sought.

If CAAT finds clear evidence that the proposed Accountable Manager previously held a senior role in any CAAT-approved organisation, such as an AOC holder, AMO, ANSP, or aerodrome operator, and used that position to violate regulatory requirements or failed to ensure compliance, CAAT may reject the appointment. This safeguard is intended to ensure that Accountable Managers are persons with a history of upholding aviation safety and regulatory standards.

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CAMO-11What is EMPIC, and how do we get the EMPIC Account?
CAMO-12Do we need to prepare a continuing airworthiness management contract?

Last updated: 14-Oct-2026

It depends on the aircraft management arrangement.

A continuing airworthiness management contract or arrangement is required where the CAMO manages, or intends to manage, aircraft on behalf of another aircraft owner or operator. In this case, the applicant must demonstrate that the responsibilities, authority, interfaces, records access, maintenance planning control, AMP control, AD/MCAI control, defect control, and other continuing airworthiness management responsibilities are clearly defined between the CAMO and the aircraft owner/operator.

The contract or arrangement should be established in accordance with the applicable continuing airworthiness requirements, including the intent of § Appendix I to Part-M or Part-ML, where applicable.

For an AOC holder managing aircraft operated under its own AOC, a separate continuing airworthiness management contract between the AOC holder and its CAMO is normally not required, because the CAMO must be part of the same legal entity as the AOC holder. In this case, the continuing airworthiness responsibilities should be controlled through the approved CAME, the operator’s manuals, internal procedures, and defined interfaces between the CAMO and operational functions.

However, where an AOC holder or any CAMO intends to manage aircraft for another aircraft owner or operator, this is a different responsibility-interface model. The organisation must have an appropriate procedure and contract or arrangement to control that activity before such aircraft can be accepted into the CAMO system.

The contract or arrangement should clearly address in accordance with § Appendix I to Part-M or Part-ML, as applicable:

  • identification of the aircraft to be managed;
  • responsibilities of the owner/operator and the CAMO;
  • CAMO authority to manage continuing airworthiness matters;
  • access to aircraft records, maintenance data, and operational information;
  • AMP control and amendment process;
  • maintenance planning and coordination with approved maintenance organisations;
  • AD/MCAI assessment and accomplishment control;
  • defect reporting and rectification control;
  • modification and repair status control;
  • component and life-limited part control;
  • technical records transfer and retention;
  • occurrence reporting and mandatory reporting interfaces;
  • airworthiness review arrangements, where applicable;
  • arrangements for aircraft transfer, termination, or return to the owner/operator;
  • access by CAAT to relevant records, aircraft, and arrangements.

The continuing airworthiness management contract is not the same as a maintenance contract. The CAMO contract defines who is responsible for managing continuing airworthiness. Maintenance must still be performed and released to service by an appropriately approved or accepted maintenance organisation under a separate maintenance arrangement.

Where the applicant does not intend to manage aircraft for another owner or operator, this procedure may be marked as not applicable. However, the limitation should be clear in the CAME and the organisation should not accept aircraft under an external owner/operator management model unless the relevant procedure, contract template, responsibility interface, and demonstration have been accepted by CAAT.

KEY POINT

A continuing airworthiness management contract is required when the CAMO manages aircraft on behalf of another owner or operator. It is not normally required for an AOC holder managing its own AOC aircraft through its own CAMO, but the internal responsibilities and interfaces must still be clearly controlled in the approved CAME and related procedures.

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CAMO-13Do we need to contract approved maintenance organisations?

Last updated: 14-Oct-2026

Yes, where the CAMO applicant, or the organisation to which it belongs, does not hold the full approved maintenance capability required for the aircraft to be managed, the applicant must establish acceptable maintenance arrangements with appropriately approved maintenance organisation(s).

A CAMO is responsible for managing continuing airworthiness, but maintenance must be performed and released to service by an organisation approved for the applicable maintenance scope. Therefore, the applicant must demonstrate that all required maintenance support for the aircraft type, model, engine, components, and intended operation is available through either:

  1. its own approved maintenance capability, such as an applicable Part-145 or Part-CAO approval; or
  2. maintenance arrangements with appropriately contracted approved maintenance organisation(s).

The maintenance arrangements should be identified and coordinated from the Phase 2 – Formal Application preparation stage. Before submitting the formal application package, the applicant should already know which approved maintenance organisation will support each required maintenance area for the aircraft rating requested.

Where an external approved maintenance organisation is intended to be used, the CAMO applicant must conduct an appropriate pre-audit, assessment, or evaluation of that maintenance organisation before entering into the maintenance agreement. The purpose of the pre-audit is to confirm that the maintenance organisation holds the appropriate approval and has the necessary capability, personnel, facilities, tools, equipment, maintenance data, procedures, and capacity to support the aircraft type and maintenance scope required by the CAMO.

The maintenance agreement, draft agreement, contract, letter of intent, or other acceptable evidence of arrangement should be established after the CAMO has satisfactorily completed the pre-audit or assessment of the relevant maintenance organisation. The agreement should be supported by evidence of the CAMO’s evaluation, including the scope assessed, any limitations identified, and how the CAMO is satisfied that the maintenance organisation can support the intended aircraft operation.

The applicant should consider whether acceptable maintenance arrangements are available for, as applicable:

  1. Line maintenance, including routine line maintenance, defect rectification, troubleshooting, transit checks, daily/weekly checks, and on-call maintenance support;
  2. Base maintenance, including scheduled base checks, heavy maintenance, structural inspections, and maintenance tasks requiring base maintenance capability;
  3. Major components, including engine, APU, landing gear, propeller, and other major component maintenance, overhaul, repair, or exchange support;
  4. Standard rotable parts, including wheels and brakes, avionics, instruments, emergency equipment, and other rotable components necessary to support aircraft availability and continuing airworthiness.

The maintenance contract should be established in accordance with § CAMO.A.135(c) and clearly address, as applicable:

  • aircraft type, model, engine, and registration covered;
  • scope of maintenance support provided by each maintenance organisation;
  • line maintenance and on-call maintenance arrangements;
  • base maintenance arrangements;
  • component and rotable support arrangements;
  • work order and maintenance planning interface;
  • defect reporting and rectification coordination;
  • AD/MCAI and mandatory task accomplishment;
  • AMP task accomplishment;
  • access to maintenance data, tools, equipment, and facilities;
  • release to service responsibility;
  • technical records return to the CAMO;
  • occurrence reporting and safety reporting interface;
  • CAAT access to relevant records, facilities, and aircraft;
  • termination or change of maintenance provider.

A commercial contract may not always be necessary where the maintenance capability is held within the same legal entity or group. However, the CAMO must still demonstrate that the maintenance arrangement is controlled, documented, supported by an appropriate approval, and subject to CAMO assessment or pre-audit as applicable. The responsibilities, interfaces, work order process, records flow, release-to-service process, and escalation channels should be defined in the CAME, and the maintenance organisation exposition, or agreement.

The maintenance contract or arrangement is not the same as a continuing airworthiness management contract. The maintenance arrangement controls the performance and release of maintenance. The continuing airworthiness management contract controls who is responsible for managing the aircraft’s continuing airworthiness.

Where no acceptable maintenance arrangement with an appropriately approved maintenance organisation can be demonstrated for the required scope, CAAT will not be able to approve the requested aircraft rating, aircraft entry, or CAMO scope for that aircraft type. For an AOC applicant or AOC holder, this may affect the planned aircraft delivery, C of R, C of A, aircraft entry, and AOC certification timeline, particularly the actual flight demonstration.

KEY POINT

The CAMO applicant does not necessarily need to contract an external approved maintenance organisation for every maintenance activity if the organisation already holds the required approved maintenance capability.

However, for any maintenance activity not covered by its own approved Part-145 or Part-CAO capability, the applicant must establish an acceptable arrangement with an appropriately approved maintenance organisation. The CAMO should first pre-audit or assess that maintenance organisation, then establish the maintenance agreement based on the satisfactory result of that assessment. This should be completed before the Phase 2 formal application package is submitted, and not left until aircraft delivery, aircraft entry, or Phase 4 demonstration.

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CAMO-14Which continuing airworthiness management tasks can be subcontracted?

Last updated: 14-Oct-2026

A CAMO may subcontract limited continuing airworthiness management tasks to another qualified organisation, provided that the subcontracted organisation works under the CAMO’s management system and the arrangement is accepted by CAAT.

The subcontracted organisation may support the CAMO, but it does not replace the CAMO’s responsibility. The CAMO remains fully accountable for the satisfactory completion of the continuing airworthiness management tasks, regardless of any contract or arrangement.

Examples of continuing airworthiness management tasks that may be subcontracted include:

  • Airworthiness Directive (AD/MCAI) analysis and planning;
  • Service Bulletin (SB) analysis and technical recommendation;
  • maintenance planning;
  • reliability monitoring and engine health monitoring;
  • maintenance programme development and amendments;
  • other limited continuing airworthiness management activities, where accepted by CAAT and where the arrangement does not limit or transfer the CAMO’s responsibilities.

The CAMO must retain active control of the subcontracted tasks. This may be done through direct involvement, review, agreement, endorsement of recommendations, monitoring, audits, and defined communication arrangements. The CAMO must also retain the authority to override the recommendation of the subcontracted organisation where necessary for continuing airworthiness.

Before subcontracting any continuing airworthiness management task, the CAMO should ensure that:

  • the task is within the scope accepted by CAAT;
  • the subcontracted organisation has been assessed or pre-audited;
  • the subcontracted organisation has sufficient qualified and competent personnel;
  • the CAMO has procedures in the CAME to control the subcontracting arrangement;
  • the contract clearly defines the scope, responsibilities, data access, reporting, communication, records, and CAAT access;
  • the subcontracted organisation does not further subcontract the CAM tasks to another organisation;
  • changes affecting the subcontracting arrangement are notified to the CAMO and, where required, to CAAT.

The following should not be understood as being transferred to the subcontracted organisation:

  • the CAMO’s accountability for continuing airworthiness;
  • the final responsibility for determining what maintenance is required, when it must be performed, by whom, and to what standard;
  • CAAT-approved CAMO privileges;
  • airworthiness review responsibility;
  • responsibility for ensuring compliance with Part-M, Part-ML, and Part-CAMO.

KEY POINT

Subcontracting is allowed only for limited continuing airworthiness management tasks. It is a support arrangement, not a transfer of CAMO responsibility. The CAMO remains accountable and must control, monitor, and endorse the subcontracted work through its approved CAME procedures and contract arrangements.

For detailed requirements and examples, applicants should refer to AMC1 CAMO.A.125(d)(3) and Appendix II to AMC1 CAMO.A.125(d)(3) – Subcontracting of continuing airworthiness management tasks.

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CAMO-15How to develop the Aircraft Maintenance Programme (AMP)?

Last updated: 14-Oct-2026

The Aircraft Maintenance Programme (AMP) should be developed based on the applicable continuing airworthiness requirements, the aircraft configuration, the intended operation, and the applicable maintenance data.

The applicant should ensure that the AMP is not only copied from the MPD, MRBR, AMM, or other source documents, but is properly adapted to the specific aircraft, aircraft configuration, utilisation, operating environment, modifications, repairs, life-limited parts, AD/MCAI requirements, and other applicable continuing airworthiness instructions.

For detailed guidance, the applicant should refer to the relevant CAAT guidance material:

GM Part-M AMP, for aircraft subject to Part-M; and

GM Part-ML AMP, for aircraft subject to Part-ML.

For Part-M aircraft

For aircraft subject to Part-M, the applicant should develop the AMP in accordance with the GM Part-M AMP.

The applicant should also use the CAAT AMP Compliance Checklist together with the GM Part-M AMP to ensure that all required information has been properly addressed. The checklist should be used as a structured tool to verify that the AMP contains all applicable elements, such as:

  • aircraft identification, applicability, and configuration;
  • source documents used for AMP development;
  • maintenance tasks and intervals;
  • airworthiness limitation items and certification maintenance requirements, where applicable;
  • AD/MCAI and mandatory continuing airworthiness instructions;
  • component and life-limited part control;
  • structural inspection programme, where applicable;
  • reliability programme, where required;
  • permitted variations, escalation, or alternative/additional instructions, where applicable;
  • AMP approval and amendment control.

The completed checklist should support the applicant’s statement of compliance and help CAAT verify that the AMP has been developed in a complete and traceable manner.

For Part-ML aircraft

For aircraft subject to Part-ML, the applicant should develop the AMP using the CAAT Part-ML AMP form.

The GM Part-ML AMP should be used as guidance when completing the form, especially to ensure that the AMP reflects the aircraft configuration, applicable ICA, required inspections, pilot-owner maintenance limitations, airworthiness limitations, AD/MCAI requirements, and other applicable maintenance instructions.

The Part-ML AMP form should be completed carefully and should clearly identify the maintenance basis used, the applicable tasks and intervals, and any deviations or alternative instructions proposed by the applicant.

Generic or baseline AMP

Where the applicant has not yet identified a specific aircraft registration, the applicant may develop a generic or baseline AMP for the aircraft type or rating requested. However, before a particular aircraft is entered into the CAMO system, the generic or baseline AMP must be converted into an aircraft-specific AMP reflecting the actual aircraft configuration, records, modifications, repairs, AD/MCAI status, component status, and operating profile.

See details in FAQ# CAMO-7.

KEY POINT

For Part-M aircraft, use the GM Part-M AMP together with the CAAT AMP Compliance Checklist to ensure that the AMP is complete and traceable.

For Part-ML aircraft, use the CAAT Part-ML AMP form as the main AMP format and use the GM Part-ML AMP as guidance when completing it.

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CAMO-16Aircraft Delivery vs. CAMO Approval?

Last updated: 14-Oct-2026

Aircraft delivery, aircraft registration, Certificate of Airworthiness issuance, CAMO approval, and aircraft entry into the CAMO system are related processes, but they are not the same process.

The issuance of a Certificate of Registration (C of R) or Certificate of Airworthiness (C of A) should not, by itself, be understood as acceptance of the aircraft into the CAMO continuing airworthiness management system. Aircraft entry into the CAMO system remains a separate continuing airworthiness process and must be completed in accordance with the approved CAME procedure.

The expected timeline depends on the CAMO status and the aircraft rating involved.

Scenario 1: Aircraft Entry through Indirect Approval

The aircraft entry may be managed through the approved procedure for changes not requiring prior approval where:

  • the applicable aircraft rating is already included in the CAMO approval certificate;
  • the aircraft is not the first aircraft registration introduced under that rating;
  • the aircraft is of the same configuration as aircraft already managed under that rating; and
  • the aircraft entry does not introduce any other change requiring prior approval under CAME 0.5.

Where these conditions are satisfied, the aircraft may be added to the list of aircraft managed through the approved indirect approval procedure and subsequently notified to CAAT in accordance with CAME 0.6.

The typical sequence is as follows:

    1. Pre-entry preparation

Before aircraft delivery or import inspection, the CAMO should prepare the aircraft entry package, including, as applicable:

  • risk assessment for aircraft entry;
  • lease, ownership document, or other arrangement identifying continuing airworthiness responsibility;
  • aircraft continuing airworthiness records and status information;
  • draft list of aircraft managed;
  • draft or proposed aircraft-specific AMP or AMP amendment;
  • bridging plan or phase-in plan, where applicable;
  • airworthiness review plan or draft ARR preparation.

    2. Aircraft becomes available / import assessment

When the aircraft becomes available, the CAMO applies for C of R and C of A inspection with the prepared documents.

At this stage, the CAMO should perform the aircraft entry and import assessment, including review of aircraft records, confirmation of maintenance status, AD/MCAI status, defect status, modification and repair status, component and LLP status, and aircraft configuration.

    3. Certificate of Registration

CAAT may issue the C of R when the applicable registration requirements are satisfied.

    4. Aircraft entry under the approved CAMO procedure

Once the aircraft is registered, the CAMO may proceed with aircraft entry under its approved CAME procedure, such as:

  • adding the aircraft registration to the list of aircraft managed;
  • approving or controlling the AMP amendment under the approved procedure;
  • notifying CAAT of the aircraft entry, together with the required aircraft entry package or draft ARR, as applicable.

    5. Certificate of Airworthiness

CAAT will issue the C of A when satisfied that the aircraft complies with the applicable airworthiness requirements, supported by the aircraft entry assessment and airworthiness review evidence.

    6. Validation of aircraft managed under CAMO

After C of R and C of A issuance, the CAMO finalises the aircraft entry process. For used aircraft, the ARS signs the ARR, and the CAMO submits the completed aircraft entry package to CAAT, as required by the approved indirect approval procedure.

Scenario 2: Aircraft Entry Requiring CAAT Direct Approval

This scenario applies where aircraft entry requires direct approval by CAAT. Direct approval by CAAT is required where any of the following applies:

  • the aircraft type/model is not included in the CAMO approval certificate;
  • the aircraft is the first aircraft registration to be introduced under an approved aircraft rating;
  • the aircraft is within an aircraft rating already included in the CAMO approval certificate, but is of a different configuration from aircraft already managed under that rating; or
  • the aircraft entry introduces any other change requiring prior approval in accordance with CAME 0.5.

In such cases, the CAMO shall submit an application for variation using CAAT Form 2C, together with the applicable supporting documentation, before the aircraft is accepted into the CAMO’s approved list of aircraft managed.

The typical sequence is as follows:

    1. Submit the CAMO Application

The applicant should submit the CAMO initial approval or variation application, including, as applicable:

  • requested aircraft rating;
  • intended aircraft registration or MSN, where known;
  • proposed aircraft entry arrangement;
  • proposed continuing airworthiness responsibility arrangement;
  • proposed AMP approval arrangement;
  • proposed airworthiness review arrangement.

    2. Proceed to CAMO Phase 3 – Document evaluation and pre-entry preparation

During Phase 3, the applicant should prepare the aircraft entry package, including, as applicable:

  • risk assessment for aircraft entry;
  • lease, ownership document, or other arrangement identifying continuing airworthiness responsibility;
  • generic, baseline, or draft aircraft-specific AMP;
  • bridging plan or phase-in plan;
  • aircraft records and continuing airworthiness status information;
  • draft list of aircraft managed;
  • maintenance arrangements;
  • personnel and ARS readiness;
  • airworthiness review plan.

At this stage, the applicant should not treat aircraft delivery as a separate commercial activity only. The delivery plan should be aligned with CAMO readiness, AMP readiness, maintenance arrangements, ARS readiness, and CAAT assessment schedule.

    3. Proceed to CAMO Phase 4 – CAMO demonstration before aircraft entry

Before aircraft entry, import inspection, or use of the aircraft for operational demonstration, the applicant should demonstrate to CAAT that the CAMO system is ready to accept and control the aircraft.

The Phase 4 CAMO demonstration or equivalent CAAT assessment should verify, as applicable:

  • CAME procedures and privileges;
  • management and nominated personnel readiness;
  • competent personnel and ARS readiness;
  • AMP development and control;
  • maintenance planning;
  • maintenance arrangements;
  • aircraft records control;
  • AD/MCAI, modification, repair, LLP, component, defect, and MEL status control;
  • airworthiness review process;
  • management system, including safety management and compliance monitoring;
  • aircraft entry, import, or phase-in control arrangement.

If significant deficiencies are found during Phase 4, the aircraft delivery, aircraft entry, import inspection, C of A issuance, or operational timeline may be delayed. Some findings may require re-demonstration, not only document correction.

    4. Aircraft entry / import assessment

Once the CAMO Phase 4 demonstration has been satisfactorily completed, the aircraft may be made available for aircraft entry or import assessment.

The CAMO then performs the aircraft entry and import assessment, including:

  • validation of continuing airworthiness responsibility arrangement;
  • aircraft records review;
  • finalisation of the aircraft-specific AMP or bridging assessment;
  • confirmation of aircraft continuing airworthiness status;
  • demonstration of maintenance status, AD/MCAI status, defect status, modification and repair status, LLP and component status;
  • airworthiness review and physical survey by the candidate ARS or ARS.

Where the CAMO approval, aircraft rating, AR privilege, or ARS acceptance has not yet been granted, the result of the airworthiness review should be treated as an airworthiness review demonstration, and the draft ARR should be submitted to CAAT.

    5. Proceed to C of R and C of A Issuance

CAAT will issue the Certificate of Registration (C of R) when the applicable registration requirements are satisfied, and the Certificate of Airworthiness (C of A) when CAAT is satisfied that the aircraft complies with TCAR AIR Part-21 or equivalent requirements. The applicable airworthiness review report, or draft report where permitted, must be submitted to support the C of A issuance process.

However, the issuance of a C of R or C of A does not, by itself, confirm that the aircraft has been fully accepted into the CAMO continuing airworthiness management system.

Under point § M.A.904(e), an aircraft may remain under import or phase-in status after the issuance of its C of R and C of A while the applicable CAMO certification or variation process is being completed. This applies where the aircraft is intended to be managed by a prospective CAMO, a CAMO applying for a new aircraft rating, or a CAMO whose approval for the relevant rating is supported by a generic or baseline maintenance programme.

During this period, continuing airworthiness responsibility must be assigned and discharged in accordance with § M.A.201 or § ML.A.201, as applicable, and identified in an arrangement acceptable to CAAT. The arrangement should clearly identify:

  • the CAMO or CAO responsible for continuing airworthiness, as applicable;
  • the aircraft identification and intended operator;
  • the scope of responsibility during the import or phase-in period;
  • the applicable AMP, proposed AMP, or import maintenance compliance basis;
  • the arrangements for controlling maintenance status, AD status, defects, modifications and repairs, life-limited parts, aircraft configuration, and continuing airworthiness records;
  • the approved maintenance organisation responsible for any required maintenance and its release to service; and
  • any limitations applicable before the aircraft is accepted into the CAMO system.

Import or phase-in status does not remove the requirement to establish and maintain the applicable continuing airworthiness management arrangements. Where approved CAMO management is required and has not been established, the aircraft does not comply with that requirement, even if a C of R or C of A has been issued.

This is particularly important for complex motor-powered aircraft (CMPA) which is required by § M.A.201(f). The applicant must coordinate the aircraft registration and CAMO approval process so that the required continuing airworthiness arrangements are effective when the aircraft is placed on the Thai register, including any period before final acceptance into the intended CAMO system.

The aircraft must not be operated under the responsibility of the prospective CAMO, or under the additional scope sought by an existing CAMO, until the applicable approval or variation has been granted. The issuance of a C of R or C of A, or the identification of the aircraft as being under phase-in, does not confer the outstanding CAMO privileges.

Where a flight is proposed during this period, the applicant must establish that the continuing airworthiness arrangements and the applicable flight authorisation permit the intended flight. A Special Flight Permit may need to be considered where the aircraft and intended flight meet the applicable eligibility criteria, subject to CAAT’s assessment and the conditions imposed. An incomplete CAMO approval process does not automatically establish eligibility for such a permit.

For example, where an aircraft is delivered outside Thailand and is intended to be flown to Thailand before the CAMO five-phase approval process has been completed, the applicant must resolve the continuing airworthiness responsibility, maintenance arrangements, applicable limitations and required flight authorisation before departure.

The applicant should therefore plan aircraft delivery, registration, C of A issuance, CAMO approval, AMP approval, airworthiness review and aircraft entry as one coordinated programme. The delivery schedule must not rely on the assumption that registration or C of A issuance alone will allow the aircraft to be flown.

    6. Coordinate with AOC or SPO actual flight demonstration

For aircraft intended to be operated under an AOC, or for SPO operation with CMPA, the CAMO timeline is critical.

The CAMO must pass, at least, the relevant CAMO Phase 4 demonstration and inspection for the aircraft rating before the aircraft enters the AOC/SPO Phase 4.2 actual flight demonstration.

This is to ensure that the aircraft used for actual flight demonstration is already properly controlled by a CAMO system that has been demonstrated to CAAT, including AMP control, maintenance planning, aircraft status control, AD/MCAI control, defect control, records control, maintenance arrangements, and airworthiness review arrangements.

    7. Phase 5 – Final CAMO approval or variation

Before the aircraft is accepted into the CAMO continuing airworthiness management system, the following should be completed, as applicable:

  • CAME and associated documents approved;
  • CAMO certificate or approval variation issued;
  • aircraft rating included in the approval scope;
  • aircraft-specific AMP approved or accepted;
  • aircraft added to the list of aircraft managed;
  • aircraft continuing airworthiness status established and controlled;
  • applicable risk mitigation actions completed or controlled.

FINAL AIRCRAFT ENTRY VALIDATION

The aircraft should not be considered accepted into the CAMO continuing airworthiness management system until:

  • where prior approval is required, the applicable CAMO approval or variation has been granted by CAAT, or, where the aircraft entry is eligible for indirect approval, the entry has been internally approved in accordance with CAME 0.6;
  • the aircraft has been added to the approved list of aircraft managed;
  • the applicable aircraft-specific AMP has been approved through the applicable direct or indirect approval process; and
  • the aircraft continuing airworthiness status has been established and is effectively controlled.

Where a generic or baseline maintenance programme has been used to support the CAMO approval or aircraft rating, the first aircraft to be added under that rating shall be subject to CAAT direct approval.

In addition, where an aircraft is to be added under an aircraft rating already included in the CAMO approval certificate but is not of the same configuration as aircraft already managed under that rating, the aircraft entry shall be subject to CAAT direct approval.

The CAMO should complete the remaining aircraft entry records, airworthiness review documentation and notification to CAAT in accordance with the applicable approved procedure. Any continuing airworthiness responsibility established for the import or phase-in period should be transferred or continued, as applicable, without a gap in the required management and control of the aircraft.

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CAMO-17CAMO Approval vs. AOC/SPO Approval — which should come first?

Last updated: 14-Oct-2026

The CAMO approval process and the AOC/SPO approval process are separate approval processes; however, they need to be appropriately coordinated especially where the aircraft will be operated under an AOC or under SPO involving a complex motor-powered aircraft (CMPA).

As a general sequence:

  1. CAMO application / variation
    The CAMO applies for the applicable aircraft rating and prepares the associated CAME procedures, aircraft-specific AMP, continuing airworthiness control arrangements, personnel competence, maintenance arrangements, and other supporting documentation.
  2. CAMO demonstration and inspection
    The CAMO demonstrates to CAAT that the organisation is capable of effectively managing the continuing airworthiness of the applicable aircraft rating, including implementation of the relevant procedures and aircraft-entry controls.
  3. AOC/SPO document evaluation and other certification activities may proceed in parallel, where appropriate.
  4. Before the aircraft enters the actual flight demonstration phase of the AOC or SPO process, the applicable CAMO demonstration and inspection phase for that aircraft rating should have been successfully completed.

*** For aircraft to be operated under an AOC, or for SPO operated with a CMPA, the CAMO should successfully complete the applicable CAMO demonstration and inspection phase for the aircraft rating before the aircraft enters the actual flight demonstration phase of the AOC or SPO process.

This sequencing is intended to ensure that, before the aircraft is used for an actual operational flight demonstration, the continuing airworthiness management system applicable to that aircraft has already been demonstrated as effective and acceptable to CAAT.

As a recommended practice, the CAMO approval should be fully completed before proceeding to the AOC/SPO actual flight demonstration phase. This provides the clearest regulatory status and avoids dependencies between unresolved CAMO findings, aircraft-entry conditions, AMP approval, or continuing airworthiness controls and the operational demonstration process.

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CAMO-18What is an Airworthiness Review (AR)?

Last updated: 14-Oct-2026

An Airworthiness Review (AR) is a periodic assessment of an aircraft and its continuing airworthiness records performed to ensure the continued validity of the aircraft’s Certificate of Airworthiness (CofA) and to confirm that the aircraft remains in an airworthy condition.

Under the CAAT system, a standard CofA is normally valid for 3 years. However, this does not mean that the aircraft is automatically considered airworthy throughout the entire three-year period without further review. During the validity period of the CofA, an airworthiness review shall be performed at intervals not exceeding 1 year. Upon satisfactory completion of the review, an Airworthiness Review Report (ARR) is issued and is valid for 1 year. The 3-year validity period of the standard CofA is established under the Air Navigation Act.

The AR therefore provides an annual continuing airworthiness assurance mechanism between CAAT CofA renewal inspections. While CAAT performs the applicable inspection when the CofA is renewed, the responsible CAMO or CAO manages the continuing airworthiness of the aircraft during the intervening period and, where authorised, performs the annual airworthiness review and reports the result through the ARR.

Unlike the EASA system, CAAT does not issue an Airworthiness Review Certificate (ARC). Instead, the outcome of the review is documented through an Airworthiness Review Report, using CAAT Form 15A for aircraft subject to Part-M or CAAT Form 15B, as applicable under Part-ML.

The airworthiness review consists principally of:

  1. a documented review of the aircraft continuing airworthiness records, including the applicable maintenance, AD, modification and repair, component, life-limited part, mass and balance, and configuration status; and
  2. a physical survey of the aircraft to confirm that the actual aircraft condition and configuration are consistent with the approved documentation and continuing airworthiness records.

The same authorised Airworthiness Review Staff (ARS) who signs the ARR should perform both the documented review and the physical survey.

A valid ARR is essential to the continuing operation of the aircraft during the CofA validity period. If the ARR expires, becomes invalid, or indicates a finding that endangers flight safety, the aircraft shall not fly, even though the expiry date stated on the CofA itself may not yet have been reached.

The ARR does not replace the CofA. Rather, it provides the annual documented assurance that the aircraft continues to satisfy the applicable airworthiness requirements throughout the CofA validity period.

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CAMO-19How to complete CAAT Form 2C for CAMO/CAO application?

Last updated: 14-Oct-2026

Applicants should complete CAAT Form 2C in accordance with the accompanying CAAT Form 2C Completion Instructions, which are provided with the form.

Before submission, applicants should ensure that all applicable sections have been completed and the required supporting documents are included.

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CAMO-20Who can be a CAMO Post Holder?

Last updated: 14-Oct-2026

For a CAMO that also holds an AOC, the Accountable Manager must nominate a CAMO Post Holder responsible for the management and supervision of the organisation’s overall continuing airworthiness activities.

The nominated person must have the knowledge, experience and competence required for the assigned responsibilities and should be able to exercise those responsibilities independently of the maintenance execution function.

Responsibilities and organisational position

The CAMO Post Holder’s responsibilities, authority and reporting lines must be clearly defined in the CAME. These responsibilities include ensuring the continuing airworthiness of the aircraft managed, ensuring that applicable ADs and other mandatory continuing airworthiness requirements are addressed, and ensuring that the AMP and any applicable reliability programme are developed and controlled.

The CAMO Post Holder must be identified in both the CAMO organisation chart and the AOC organisation chart. The charts should clearly show the reporting line to the Accountable Manager and the interfaces with the other relevant functions, particularly flight operations, safety management and compliance monitoring.

The allocation of responsibilities may reflect the size and complexity of the organisation:

  • For a small CAMO, the CAMO Post Holder may also fulfil applicable nominated-person functions, provided that the combined responsibilities are clearly defined and the applicable competence, independence and conflict-of-interest requirements are satisfied.
  • For a larger CAMO, the CAMO Post Holder may be supported by a nominated group of persons responsible for functions such as engineering, maintenance planning and airworthiness review. The CAMO Post Holder remains responsible for the overall management and supervision of continuing airworthiness activities.

Any additional responsibilities assigned to the CAMO Post Holder must be clearly described in the CAME and must not conflict with the responsibilities of other nominated personnel.

Independence from maintenance execution

In accordance with § CAMO.A.305(b)(2), the CAMO Post Holder:

  • must not be employed by any contracted TCAR AIR Part-145 approved maintenance organisation; and
  • must not simultaneously hold a position responsible for the direct management of maintenance execution, including where the organisation also holds a TCAR AIR Part-145 approval.

The applicant should assess the proposed person’s actual duties, reporting lines and decision-making authority, rather than the job title alone. Combining continuing airworthiness management duties within the CAMO must not result in the person also directly managing maintenance execution.

This functional separation enables the CAMO Post Holder to objectively assess maintenance performance, challenge deficiencies and escalate continuing airworthiness concerns without having to oversee their own maintenance execution decisions.

For further guidance, refer to AMC1 CAMO.A.305(b)(2), GM1 CAMO.A.305(b)(2) and the relevant CAME guidance on the CAMO Post Holder and organisation structure.

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CAMO-21Can the Part-CAMO compliance monitoring function be shared with other approvals, e.g. AOC or Part-145?

Last updated: 14-Oct-2026

Yes. The Part-CAMO compliance monitoring function may form part of an integrated management system covering other approvals, provided that the applicable requirements for each approval continue to be met.

Sharing compliance monitoring procedures, audit resources or reporting systems does not automatically mean that the same person may act as the Compliance Monitoring Manager (CMM) for all approvals. The proposed arrangement must demonstrate clear responsibilities, effective independent monitoring, appropriate competence, and sufficient time and resources for the full scope of activities.

The following arrangements should be distinguished:

Arrangement

Considerations for a common CMM

AOC and CAMO of the same operator

The Part-CAMO management system must be integrated into the operator’s management system. A common CMM may be proposed, provided that the person has the appropriate competence and sufficient support to oversee both operational and continuing airworthiness compliance monitoring. Integration of the management system does not, by itself, require a single CMM.

One organisation holding AOC, CAMO and Part-145 approvals under the same Accountable Manager

A common CMM may be proposed within the integrated management system. The arrangement must maintain independence from operational, continuing airworthiness management and maintenance execution functions, and provide adequate monitoring of the interfaces between those activities.

One organisation holding CAMO and Part-145 approvals under different Accountable Managers

The CMM for the CAMO approval and the CMM for the Part-145 approval should not be the same person, due to the potential for conflicting responsibilities and reporting obligations to different Accountable Managers.

A CAMO and its contracted AMO are separate organisations with different Accountable Managers

The CAMO CMM should not also act as the CMM of its contracted AMO, due to the potential conflict between the CAMO’s responsibility to independently monitor contracted maintenance and the person’s responsibilities within the AMO.

A CAMO and its contracted AMO are separate organisations with the same Accountable Manager

A common Accountable Manager does not, by itself, establish that a common CMM is acceptable. Each organisation’s responsibilities must remain clearly identified, and the arrangement must address any conflict arising from the CMM’s responsibilities in both organisations.

A common CMM responsible to 2 different Accountable Managers may compromise the person’s ability to report AMO deficiencies independently and objectively to the CAMO Accountable Manager, particularly where reporting those deficiencies could conflict with the interests or expectations of the AMO’s management.

The concern extends beyond independence in conducting an audit. It includes the risk that findings relevant to the CAMO’s continuing airworthiness responsibilities or the maintenance performed on its behalf may be withheld, delayed, understated or inadequately followed up because of competing responsibilities or management influence.

Direct access to both Accountable Managers does not, by itself, resolve this concern. Separate CMM appointments should therefore be maintained to support independent reporting, clear accountability and effective follow-up of corrective actions.

Independence and conflicts of interest

The assessment must consider the person’s actual duties, authority and involvement in the activities being monitored. Holding the CMM position in an AMO does not, by itself, make that person responsible for maintenance execution. However, a conflict may arise where the person is required, on behalf of the CAMO, to evaluate the effectiveness of an AMO compliance monitoring process that the same person manages.

The organisation must therefore establish arrangements that preserve independent audit and assessment. These should address:

  • the allocation of audits to personnel who are not responsible for the functions, procedures or products being audited;
  • independent assessment of the compliance monitoring function itself;
  • independent verification of corrective actions for matters within the CMM’s own responsibility; and
  • the ability to report findings and escalate unresolved deficiencies to the relevant Accountable Manager without interference.

Assigning another auditor is insufficient if the person with the conflict can still improperly influence the audit scope, findings, conclusions or verification of corrective actions. Where the proposed combination of duties cannot maintain effective independence, those duties must be separated.

Workload, personnel and resources

Where a common CMM is proposed, the organisation must demonstrate that the person has sufficient capacity to discharge the responsibilities under all approvals concerned. The assessment should consider:

  • the combined scope, size and complexity of the activities, including aircraft, locations and contracted or subcontracted organisations;
  • the time required for audit planning, oversight of audit performance, reporting, corrective-action follow-up and liaison with CAAT;
  • any additional duties or appointments held by the proposed CMM;
  • the number, competence and availability of supporting auditors and specialist personnel; and
  • arrangements for absence, peak workload and changes to the organisation’s activities.

A common CMM may be supported by personnel assigned to particular approvals or technical areas. Their responsibilities and reporting lines should be clearly defined, while the CMM retains responsibility for managing the compliance monitoring function within the approved arrangement.

The arrangement should be documented consistently in the CAME and the relevant manuals for the other approvals, including responsibilities, reporting lines, audit coverage, independence safeguards and resource allocation. Any changes requiring prior approval must be approved by CAAT before implementation.

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CAMO-22How to plan your aircraft entry?

Last updated: 14-Oct-2026

What does “aircraft entry” mean?

Aircraft entry means the process by which an aircraft is formally accepted into the CAMO continuing airworthiness management system.

This includes establishing the aircraft’s continuing airworthiness status, applicable AMP, records, maintenance planning, AD/MCAI status, defect status, modification and repair status, life-limited parts and component status, airworthiness review status, and aircraft-specific control within the CAMO system.

The issuance of a Certificate of Registration or Certificate of Airworthiness does not, by itself, mean that the aircraft has been accepted into the CAMO system.

Why should aircraft entry be planned?

Aircraft entry should be planned because certain aircraft must be managed under a CAMO in accordance with Part-M. This includes, as applicable, complex motor-powered aircraft and aircraft intended to be operated under an AOC, where continuing airworthiness management is required to be performed by an approved CAMO in accordance with points § M.A.201(e), § M.A.201(f), or § M.A.201(g), as applicable.

Therefore, once the aircraft is registered in Thailand and a Certificate of Airworthiness is issued, the aircraft must be controlled in accordance with the applicable Part-M continuing airworthiness requirements. For such aircraft, the aircraft should be ready to enter the CAMO continuing airworthiness management system in parallel with the Certificate of Registration, Certificate of Airworthiness, CAMO certification or variation, AMP approval, and any applicable AOC or Ops Spec process.

Before an aircraft registration can be added to the CAMO list of aircraft managed, the CAMO should ensure that, at minimum:

  1. Continuing airworthiness responsibility is properly assigned
    The continuing airworthiness responsibilities of the owner have been transferred to the lessee, where applicable, either by identifying the lessee/operator on the registration document or by detailing the transfer of responsibilities in the lease agreement in accordance with § M.A.201(b).
  2. The aircraft has an approved AMP managed by the CAMO
    The applicable aircraft maintenance programme should be approved or accepted, as applicable, and controlled under the CAMO system.
  3. Aircraft continuing airworthiness records have been transferred to the CAMO
    The CAMO should have access to the records necessary to establish and control the aircraft continuing airworthiness status.
  4. Aircraft continuing airworthiness information has been entered into the CAMO control system
    This should include, as applicable, the last accomplished and next due status for AD/MCAI and AMP tasks, deferred defect status, modification and repair status, component and life-limited parts status, current mass and balance statement, and other aircraft-specific continuing airworthiness information.
  5. The CAMO has sufficient resources for the additional aircraft
    The CAMO should have sufficient manpower, competence, facilities, systems, and arrangements to support the expected workload increase from the incorporation of the new aircraft.

Where the aircraft registration is associated with an AOC and Ops Spec, the aircraft is normally considered successfully added to the CAMO fleet when the registration has been added to the applicable AMP and notified to CAAT through the approved indirect approval process. However, this does not apply to the addition of the first aircraft registration under the relevant aircraft rating, which is subject to prior approval by CAAT unless otherwise accepted.

For this reason, aircraft entry should not be treated as a final administrative step after registration or C of A issuance. It should be planned together with the CAMO certification or variation process, C of R process, C of A process, AMP approval, aircraft records transfer, airworthiness review, and operational approval timeline, where applicable.

NOTE: Under the previous regulatory framework, aircraft registration or C of A activities may have been managed separately from CAMO aircraft entry. Under Part-M / Part-CAMO implementation, aircraft subject to CAMO management requirements should be planned so that continuing airworthiness control is established when the aircraft becomes subject to the applicable Part-M requirements.

When should the aircraft entry be planned?

The applicant or CAMO should plan the aircraft entry as early as possible, especially where the aircraft is being:

  • imported into Thailand;
  • delivered to a new operator;
  • added to an existing CAMO approval;
  • added under a new aircraft rating;
  • added as the first aircraft under a rating previously supported by a generic or baseline AMP;
  • used to support an AOC, SPO, or other operational approval.

The aircraft entry plan should be reflected in the Schedule of Events and coordinated with the CAMO certification or variation process, aircraft registration, Certificate of Airworthiness, AMP approval, airworthiness review, and any applicable AOC variation.

Which aircraft entry scenario applies?

The CAMO should first identify which scenario applies.

Scenario 1: Existing CAMO rating — adding another aircraft registration

This scenario may apply where the CAMO:

  • already holds the applicable aircraft rating;
  • Is adding the same configuration aircraft;
  • has approved aircraft entry procedures;
  • has demonstrated AMP control and airworthiness review process;
  • is not adding the first aircraft under that rating;
  • is not introducing a materially new continuing airworthiness control method.

In this case, the aircraft entry may normally be managed through the CAMO’s approved procedure for change not requiring prior approval (indirect approval) where applicable.

Scenario 2: Aircraft entry requiring CAAT direct approval

This scenario applies where aircraft-specific implementation has not yet been demonstrated. This includes:

  • initial CAMO approval where the aircraft will be managed after approval is granted;
  • addition of a new aircraft rating;
  • addition of a new aircraft configuration to the existing aircraft rating;
  • first aircraft registration under an existing rating that was previously supported by a generic or baseline AMP.

In this case, CAAT direct approval is required before the aircraft can be accepted into the CAMO system.

What should be prepared before aircraft entry?

The applicant or CAMO should prepare an aircraft entry package, as applicable. This may include:

    1. Aircraft responsibility arrangement

  • Lease agreement, ownership document, or other arrangement identifying continuing airworthiness responsibility.

    2. Aircraft records and status information

  • aircraft records;
  • maintenance status;
  • AD/MCAI status;
  • modification and repair status;
  • defect status;
  • LLP and component status;
  • aircraft configuration;
  • applicable operational approval information.

    3. AMP and bridging

  • aircraft-specific AMP;
  • AMP amendment;
  • generic or baseline AMP conversion, where applicable;
  • bridging plan or phase-in plan.

    4. CAMO system readiness

  • aircraft data loaded into the CAMO records and planning system;
  • maintenance planning control;
  • AD, defect, modification, repair, LLP, and component control;
  • maintenance arrangements;
  • records control;
  • competent personnel and ARS readiness.

    5. Airworthiness review

  • AR plan;
  • physical survey plan;
  • draft ARR or airworthiness review report, where applicable;
  • AR demonstration where the CAMO approval, aircraft rating, AR privilege, or ARS acceptance has not yet been granted.

    6. Risk assessment

  • aircraft entry risks;
  • required mitigation actions;
  • open actions before aircraft acceptance;
  • limitations applicable during import or phase-in status

Can aircraft registration and Certificate of Airworthiness be processed at the same time as aircraft entry?

Yes, they may be coordinated in parallel, but they are not the same process.

The Certificate of Registration and Certificate of Airworthiness are issued when CAAT is satisfied that the applicable registration and airworthiness requirements are met.

However, acceptance of the aircraft into the CAMO system remains a separate continuing airworthiness process. The CAMO must complete the applicable aircraft entry process under its approved CAME procedure or through CAAT direct approval, as applicable.

What should the CAMO consider before scheduling aircraft inspection or import inspection?

The CAMO should not normally schedule aircraft entry, import inspection, or Certificate of Airworthiness activities until its continuing airworthiness management system is ready to accept and control the aircraft.

Before aircraft entry, CAAT may verify the readiness of:

  • CAME procedures and approval scope;
  • facilities and personnel;
  • AMP development and control process;
  • generic or baseline AMP conversion, where applicable;
  • maintenance planning system;
  • maintenance arrangements;
  • aircraft continuing airworthiness records system;
  • AD, modification, repair, defect, LLP, component, and MEL status control;
  • airworthiness review process;
  • compliance monitoring and safety management system;
  • aircraft entry and import or phase-in control process.

If significant deficiencies are found, aircraft delivery, import inspection, Certificate of Airworthiness issuance, or aircraft operation may be delayed.

Can the aircraft remain under import or phase-in status after C of R and C of A issuance?

Yes, in some cases.

Where the applicable CAMO certification or variation has not yet been completed after the Certificate of Registration and Certificate of Airworthiness have been issued, the aircraft may remain under import or phase-in status, subject to the applicable requirements and CAAT acceptance.

During this period:

  • continuing airworthiness responsibility must be clearly assigned;
  • the aircraft must remain controlled for AMP, maintenance status, AD status, defect status, modification and repair status, LLP and component status, configuration, and records;
  • any limitation before CAMO acceptance must be observed;
  • the aircraft must not be operated under the responsibility of the CAMO until the applicable CAMO approval or variation has been granted.

When is the aircraft considered accepted into the CAMO system?

The aircraft should only be considered accepted into the CAMO continuing airworthiness management system when the applicable aircraft entry process has been completed.

This normally includes, as applicable:

  • CAMO approval or variation has been granted;
  • aircraft rating has been included in the CAMO approval scope;
  • CAME and associated documents have been approved or updated;
  • aircraft-specific AMP has been approved or accepted;
  • aircraft has been added to the CAMO list of aircraft managed;
  • continuing airworthiness status has been established and controlled;
  • ARS has signed the ARR, where applicable;
  • completed aircraft entry package has been submitted or retained in accordance with the approved CAME procedure;
  • CAAT has been notified where required.

Special note for AOC or SPO operations

Where the aircraft is intended to support an AOC or SPO operation, the CAMO should plan the aircraft entry together with the operational approval or AOC variation timeline.

*** For aircraft to be operated under an AOC, or for SPO operated with CMPA, the CAMO should successfully complete the applicable CAMO demonstration and inspection phase for the aircraft rating before the aircraft enters the actual flight demonstration phase of the AOC or SPO process.

Key reminder

Aircraft entry should be treated as a structured continuing airworthiness project, not only as an aircraft delivery or registration activity.

The CAMO should plan early, allow sufficient time for CAAT assessment, prepare aircraft records and AMP arrangements, ensure maintenance and ARS readiness, complete any required risk assessment, and avoid scheduling aircraft operation before the aircraft has been properly accepted into the CAMO system.

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CAMO-23If a group of persons is nominated, will all persons be interviewed by CAAT?

Last updated: 14-Oct-2026

Yes. Where a person or group of persons is nominated under CAMO.A.305, each nominated person should be available for CAAT assessment or interview for the function for which he or she is nominated.

Where a group of persons is nominated for a CAMO function, the assessment may be conducted according to the responsibilities assigned to each person within the group. For example, where the nominated group includes a Planning Manager and an Engineering Manager, each person should be able to demonstrate the knowledge, experience, authority, and understanding relevant to his or her assigned responsibilities.

The CAME should clearly describe the division of responsibilities, reporting lines, authority, interfaces, and decision-making process within the nominated group. This is necessary to allow CAAT to understand who is responsible for each continuing airworthiness management function and how the function will be effectively performed.

All nominated persons should comply with the applicable qualification and experience requirements under CAMO.A.305(c), as applicable to their nominated position and assigned responsibilities.

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CAMO-24Can nominated personnel be placed under a corporate director?

Last updated: 14-Oct-2026

No, generally, the nominated personnel under CAMO.A.305 should have a direct reporting line to the Accountable Manager for their CAMO responsibilities. The organisation structure should ensure that nominated personnel have direct access to the Accountable Manager to keep him or her properly informed on compliance and safety matters.

A corporate director, EVP, VP, or similar corporate position should not be placed as a line authority between the Accountable Manager and the nominated personnel where this would interrupt, control, or dilute the nominated personnel’s direct accountability to the Accountable Manager.

This is particularly important where the corporate director also oversees other approvals or functions, such as Part-145 / AMO, AOC operations, commercial functions, or corporate compliance. The structure should not create a conflict of interest or reduce the ability of the CAMO nominated personnel to independently control, challenge, and escalate continuing airworthiness, compliance, or safety matters.

Acceptable arrangements

Where the organisation needs to retain a corporate director position, the structure should normally be arranged in one of the following ways:

  1. Corporate director outside the CAMO reporting line
    The corporate director may be placed in another corporate function, such as commercial, marketing, finance, or other functions not directly controlling CAMO or continuing airworthiness management activities.
  2. Corporate director as staff/advisory function to the Accountable Manager
    The corporate director may act as an adviser or support function to the Accountable Manager, provided that the corporate director has no line authority, no approval authority, and no work-assignment authority over the CAMO nominated personnel.

In this case, the nominated personnel’s main reporting line for CAMO responsibilities should remain directly to the Accountable Manager.

CAME expectation

The CAME should clearly describe:

  • the direct reporting line from nominated personnel to the Accountable Manager;
  • the responsibilities and authority of each nominated person or group of persons;
  • how direct access to the Accountable Manager is ensured for compliance and safety matters;
  • how conflicts of interest are avoided, especially where the organisation holds both CAMO and AMO / Part-145 approvals;
  • how the CAMO remains able to independently control, verify, and challenge maintenance accomplishment, records, release, defect rectification, and maintenance feedback from the AMO.

KEY PRINCIPLE

The corporate structure should not prevent nominated personnel from reporting directly to the Accountable Manager on operational, resource, compliance, or safety matters. The nominated personnel remain responsible for the effective performance of their assigned CAMO functions.

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CAMO-25Who can be an ARSX?

Last updated: 14-Oct-2026

An ARSX (ARS Examiner) is an authorised Airworthiness Review Staff (ARS) member who is authorised to supervise and assess nominated ARS candidates under the organisation’s CAAT-approved supervision procedure and privilege in accordance with § CAMO.A.310(c).

The use of an ARSX is an optional arrangement. The organisation must obtain CAAT approval of the relevant privilege and the supervision procedure described in CAME 4.1 before exercising this arrangement.

Experience of the proposed ARSX

The proposed ARSX should meet the following criteria, or demonstrate equivalent experience acceptable to CAAT:

  • have been an authorised ARS of the organisation for at least 2 years;
  • have conducted at least 2 airworthiness reviews within the preceding 24 months; and
  • have conducted the most recent airworthiness review within 6 months of the ARSX application.

The ARSX privilege is considered for the specific aircraft ratings concerned. The proposed ARSX’s experience and competence should therefore support the scope of supervision requested.

Organisational capability

The CAMO’s airworthiness review process should have been internally audited on at least 2 occasions.

Approval also depends on the organisation’s demonstrated capability to perform airworthiness reviews and the effectiveness of its compliance monitoring system in overseeing the AR process. The CAMO should therefore have sufficient experience in both conducting airworthiness reviews and auditing the process before applying for the ARSX privilege.

Supervision and assessment responsibilities

The ARSX should be able to supervise and assess an ARS candidate’s qualifications, training, experience and practical performance, including:

  • knowledge of the applicable regulations and procedures;
  • preparation for the airworthiness review;
  • aircraft records review;
  • aircraft physical survey;
  • preparation of the airworthiness review report; and
  • communication, decision-making and complete documentation of the AR process.

The ARSX’s authority should be identified in CAME 5.2, and the supervision procedure should be subject to compliance monitoring as described in CAME 2.8.1.

Where the ARSX privilege has been approved for the relevant aircraft rating, practical supervision of nominated ARS candidates may be performed by the authorised ARSX. Formal acceptance of the nominated ARS remains with CAAT and will normally be based on document evaluation and an interview, without direct CAAT supervision of the airworthiness review.

The CAMO should submit the candidate’s qualification, training and experience evidence, the supervision and assessment results, the completed assessment checklist, and the proposed amendment to the ARS list for CAAT acceptance.

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CAMO-26When is an aircraft considered to be of the same configuration and eligible for indirect approval of aircraft entry?

Last updated: 14-Oct-2026

For aircraft entry purposes, an aircraft may be considered to be of the same configuration where its aircraft type, engine model, passenger or freighter configuration, and other relevant technical characteristics correspond to a configuration already managed by the CAMO within its approved scope, and any aircraft-specific differences can be addressed under the existing approved procedures.

Being within the same aircraft rating does not, by itself, establish eligibility for indirect approval. The CAMO must also demonstrate that the aircraft entry falls within its CAAT-approved indirect approval procedure and can be supported by its existing capability, personnel and resources.

Assessment of aircraft configuration

The CAMO should identify the aircraft or fleet configuration used as the reference and carry out a documented comparison covering, as applicable:

Aspect

Considerations

Aircraft type, model and series

Same configuration: Same aircraft type and model with a common maintenance programme basis (identical MPD revision/basis), subject to assessment of any model or series differences and the other configuration aspects below.

Different configuration: A different aircraft type, or a different model or series using a different maintenance programme basis, such as a separate model-specific or series-specific MPD. For example, B737-400 and B737-800 are considered different configurations for aircraft entry because they use different MPDs.

For aircraft subject to TCAR AIR Part-M, this also includes cases where aircraft entry requires the CAMO to develop a new, separate AMP, rather than incorporating the aircraft into an existing AMP previously approved by CAAT. Each new AMP requires initial approval by CAAT and cannot be initially approved through the CAMO’s indirect approval procedure.

Engine model

Same configuration: Same engine model as the approved rating.

Different configuration: A different engine model from the approved rating, even if from the same manufacturer or engine family.

Passenger, freighter or other configuration

Same configuration: Same configuration category. Cabin layout or seating differences may be accepted where their maintenance implications are covered by existing controls.

Different configuration: A different configuration category, such as passenger to freighter, combi, special-purpose configuration, or significant LOPA changes requiring new emergency equipment layouts/drawing or weight & balance procedures not previously managed.

Installed systems and equipment

Same configuration: Same systems, or equipment differences that can be managed using existing technical capabilities, maintenance controls, and operational manuals (e.g., MEL, CDL, WBM).

Different configuration: Systems or equipment requiring technical capability, specialized tooling, staff authorizations, or maintenance controls beyond those already established.

Modifications, STCs and repairs

Same configuration: Differences whose maintenance instructions (including Instructions for Continued Airworthiness – ICA), limitations, and inspection tasks can be fully incorporated into the AMP using existing approved procedures without requiring new technical capabilities, specialized tooling, or staff authorizations.

Different configuration: Changes introducing new Instructions for Continued Airworthiness (ICA), complex structural repairs, or operational changes that require new control processes, new technical capabilities, or new regulatory operational approvals (e.g., LVO, PBN, EDTO/ETOPS) not covered by the existing approved procedures or arrangements.

Any modification or STC that introduces new operational limitations or affects existing Specific Operational Approvals (such as PBN, LVO, ETOPS/EDTO, RVSM) shall automatically be classified as a Different Configuration.

Differences in aircraft age, flight hours, cycles or remaining component life do not, by themselves, constitute a different configuration. Their effect on aircraft entry and ongoing workload must nevertheless be assessed.

The documented configuration comparison must be formally recorded as a part of Risk Assessment in accordance with approved procedures and approved by the Compliance Monitoring function prior to exercising any indirect approval rights for aircraft entry.

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CAMO-27Is Guidance Material mandatory?

Last updated: 14-Oct-2026

Guidance Material (GM) is non-binding and does not, by itself, create additional regulatory requirements. It provides explanations and guidance to help applicants and approval holders understand and apply the applicable requirements and AMC.

However, the organisation remains responsible for demonstrating compliance. Where relevant GM identifies expected procedure content, responsibilities, controls, records or decision criteria, the organisation should address those elements in its CAME or associated procedures, or provide an equivalent approach that demonstrates an equivalent level of clarity, control, compliance and safety assurance.

The CAME must demonstrate how the organisation will achieve the required outcomes in practice. Procedures should explain how activities will be implemented, controlled, recorded and monitored. Merely reproducing regulatory or AMC headings, without describing the organisation’s actual arrangements, will not be sufficient for approval.

If the organisation adopts a different approach, it must be able to explain and substantiate how that approach meets the applicable requirements and can be effectively implemented. Where the submission does not adequately demonstrate compliance, CAAT may request additional information or amendments, delay evaluation, or refuse approval. These consequences arise from insufficient demonstration of compliance, rather than departure from GM alone.

Previously approved expositions or procedures may also require amendment if they are found to be incomplete, ineffective, not implemented as approved, or no longer capable of demonstrating compliance. CAAT may restrict the affected privilege or take other appropriate administrative action where warranted.

A departure from GM does not automatically constitute an Alternative Means of Compliance (AltMoC). However, where the proposed approach is an AltMoC to an AMC, the organisation must submit the proposal and a substantiated assessment demonstrating compliance and an equivalent level of safety, and obtain CAAT approval before implementation.

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