AAC No.

4 of 2024
Dated 14th November 2024

Government of India
DIRECTORATE GENERAL OF CIVIL AVIATION
AIRWORTHINESS
ADVISORY CIRCULAR
F. No. DGCA-25011(02)/95/2024-AW

Subject: Transition to New regulations (CAR-CAMO, CAR-CAO)

DGCA has issued new regulations (CAR-CAO and CAR-CAMO) and amended
existing regulations CAR-145 & CAR-M in the continuing airworthiness domain on
31.7.2024. These regulations introduce new types of organisations (CAR-CAO and
CAR-CAMO). This AAC provides guidelines on the transition of existing continuing
airworthiness organisations to the new CAR-CAO and CAR-CAMO organization.

I. Introduction

a. General

CAR-CAO (Issue I dated 31.7.2024), CAR-CAMO (Issue I dated 31.7.2024) and CAR-
ML (Issue I dated 31.7.2024), CAR-145 (Issue III) & CAR-M (Issue III) will become
effective from 01-01-2025. Thereby, the structure of the existing regulation is modified
as shown below:

Designation Topic
CAR-M Continuing airworthiness requirements – other-than-‘light aircraft’ and aircraft used
by Air operator certified in accordance with Rule 134 and Schedule XI of the Aircraft
Rules, 1937
Includes Subpart F and Subpart G organisation requirements, applicable only until
30-June-2026
CAR-145 Maintenance organisation
(all types of aircraft types and operation)
CAR-ML Continuing airworthiness requirements – ‘light aircraft’ not used by Air operator
certified in accordance with Rule 134 and Schedule XI of the Aircraft Rules, 1937
CAR-CAMO Continuing airworthiness management organisation
(all types of aircraft types and operation)
CAR-CAO Combined (continuing airworthiness management and/or maintenance) organisation
– non-complex aircraft and operators other than Air operator certified in accordance
with Rule 134 and Schedule XI of the Aircraft Rules, 1937
Note: the denomination ‘Light aircraft’ means the following non-complex motor-powered aircraft:
 aeroplanes up to 2730 Kg MTOM
 rotorcraft up to 1200 Kg MTOM / max 4 occupants
 other LA2 aircraft.

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 Important:

CAR-ML is the only option for ‘light aircraft’ not used by Air operator certified in
accordance with Rule 134 and Schedule XI of the Aircraft Rules, 1937. All
other aircraft must follow CAR-M standard1.

It is not allowed to ‘voluntary’ apply CAR-M on ‘light aircraft’ not used by Air
operator certified in accordance with Rule 134 and Schedule XI of the Aircraft
Rules, 1937.

As a consequence, from 30 June 2026, each aircraft must follow either CAR-M
or CAR-ML standard, and any person or organisation involved in continuing
airworthiness must comply with CAR-M, or CAR-ML or both, depending on the
scope of activities (related type(s) of aircraft and operation(s)).

Regulation does not introduce a ‘CAR-ML organisation’ because CAR-ML is

only a standard for ‘light aircraft’. However, all types of organisations (CAR-
CAMO, CAR-CAO, CAR-145) may be involved in continuing airworthiness
activities for aircraft following CAR-ML.

The new organisations introduced are CAR-CAO organisations and CAR-CAMO

organisations.

 CAR-CAMO provides requirements for Continuing Airworthiness

Management Organisation (CAMO): compared with CAR-M Subpart G
organisation, the main difference is the introduction of SMS principles.

 CAR-CAO provides a new set of requirements for Combined

Airworthiness Organisation: such organisation may perform CAMO
activities or Maintenance Organisation activities, or both, but limited to
non-complex aircraft not used by an air operator certified in accordance
with Rule 134 and Schedule XI of the Aircraft Rules, 1937.

These CAR-CAMO and CAR-CAO organisations are supposed to gradually

replace CAR-M Subpart F and CAR-M Subpart G organisations. After 30 June
2026, there should be no more CAR-M Subpart F and CAR-M Subpart G
organisations. This is the reason why, to be able to continue their activities, the
existing CAR-M Subpart F and CAR-M Subpart G organisations must eventually
receive a new approval.

1
Subparts F and G are excluded from this statement because they are organisation requirements as
opposed to technical standard.

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b. Transition

To facilitate the issue of new approval for existing organisation, this AAC provides the guidelines for organisations with a valid
CAR-M Subpart F, CAR-M Subpart G and CAR-145 approval to make a transition to CAR-CAO or CAR-CAMO, instead of
following the complete process of an initial approval to CAR-CAO or CAR-CAMO.

Depending on the current approval and scope held, the existing organisation may choose one of the below transition paths:
Existing approval New approval using transition (same scope)
Approval type Scope Approval type Initial Privileges
complex motor-powered aircraft (CMPA) Same
and/or aircraft used by air operator
CAR-M Subpart G CAR-CAMO
certified in accordance with Rule 134 and
Schedule XI of the Aircraft Rules, 1937
non-CMPA not used by air operator Same
CAR-CAO
CAR-M Subpart G certified in accordance with Rule 134 and Or
Schedule XI of the Aircraft Rules, 1937 CAR-CAMO Same

CAR-M Subpart G All types of aircraft and operation CAR-CAMO Same

non-CMPA not used by air operator CAR-CAO maintenance only

CAR-M Subpart F certified in accordance with Rule 134 and No transition facilitation to CAR-
Schedule XI of the Aircraft Rules, 1937 145 (initial approval required) Not applicable

non-CMPA not used by air operator CAR-CAO maintenance only

CAR-145 certified in accordance with Rule 134 and Or keep CAR-145 (no
Schedule XI of the Aircraft Rules, 1937 Not applicable
transition)
Transition to CAR-CAO not
CAR-145 All types of aircraft and operation possible for that scope of work: Not applicable
keep CAR-145

If existing approved organization, do not transition to CAR-CAO or CAMO:

• CAR-145 organisation may continue their activities with the CAR-145 approval;
• CAR-M Subpart F organisation may continue their activities with the CAR-M Subpart F approval only till 30 June 2026;

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 • CAR-M Subpart G organisation may continue their activities with the CAR-M Subpart G approval only till 30 June 2026.

Note: If an organisation holds both continuing airworthiness and maintenance approvals, this organisation can make a
single request to DGCA to transition both approvals to a single CAO (to the extent that both existing approvals satisfy the
above transition paths).

The request from organisation to apply for such transition to CAR-CAO and CAR-CAMO should be made to DGCA on eGCA
platform in a form and manner established. The transition period ends on 30 June 2026, so the request should be made sufficiently
in advance of this date (no later than 31.12.2025) to allow for completion of the transition process in due time.

If an organisation wishes to transition only one part of its activities to CAR-CAO (e.g. non-CMPA scope of work of CAR-145),
this case will be treated as a new approval and not as a transition. This is because, in order to follow the transition process, an
existing approved exposition or manual is required as a basis for that particular activity.

Convention:
In the rest of the document:
 ‘CAR-MG’ and ‘CAR-MF’ will designate respectively ‘CAR-M Subpart F’ and ‘CAR-M Subpart G’
 ‘CAR-CA(M)O’ will designate ‘CAR-CAO or CAR-CAMO’

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II. Overview of the transition to CAR-CA(M)O

The following figure provides an overview of the expected transition process and chronology:
Publication date Becomes effective End of transition
(31-July-2024) (01-Jan-2025) 30-June-2026

CAR-145 CAR-145 org. not requesting

org. CAO
CAR-145 CAR-145 CAR-CAO org. (if requested) CAR-CAO
org. org. org.

CAR-MG CAR-MG CAR-CAMO org. (if requested) CAR-CAMO

org. org. org.
CAR-MG CAR-MG CAR-CAO org. (if requested) CAR-CAO
org. org. org.

CAR-MF CAR-MF CAR-CAO org. (if requested) CAR-CAO

org. org. org.

Phase 0: Phase 1: Phase 2:

Alignment with new Regulation Transition to CAR-CAMO and CAR- Subpart F and Subpart G no longer
CAO applicable

Note: Initial approvals to CAR-MF and CAR-MG may still be issued until 31-Dec-2024.

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The following figure provides an overview of the step approach developed in the next chapter.

31-July-2024 31-Dec-2024 30-June-2026

By DGCA
Prepare revision of
exposition/manual By Organisation
to comply with
amendments to
Reg. Request CA(M)O
(e.g. references
to CAR-ML)
Issue CA(M)O
certificate

Raise generic
‘transition finding’
CAR-145/-MF/-MG org.
Surveillance iaw CAR-145/-MF/-MG CA(M)O org.

CA(M)O org. (existing scope of work)

Surveillance iaw CAR-CA(M)O

‘transition findings’ raised and closed

Submit revision Approve Submit CA(M)E Approve CA(M)E Revoke CA(M)O if

of exposition/ exposition/manual and re-issue ‘transition findings’
manual with CA(M)O certificate not closed
CA(M)O approval
reference

Note: request for CAR-CA(M)O is required to be submitted online on EGCA platform from 01-01-2025.

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III. Steps for transition to CAR-CA(M)O
The following propose a 10-steps approach for the transition of CAR-145/-MF/-MG organisation to CAR-CAO or CAR-CAMO

Overview:
Phase Step Description
0 0 Compliance with new Regulation
1 1 Eligibility to CAR-CA(M)O
2 Request for CAR-CA(M)O approval
3 Exposition/manual amendment
4a Initial CA(M)O approval
4b Finding notifications
5 Implementation plan
6 Acceptance of the plan and oversight programme adjustment
7 Oversight during transition
8 Implementation plan execution
9 Final CA(M)O approval
2 10 End of transition and changes to organisation

Convention: in the following table, the term “exposition/manual” designates the type of document used by the organisation demonstrating compliance
with CAR-MF/-MG/- 145 at the time when the organisation requests a transition to CAR-CA(M)O, while the term “CA(M)E” designates the organisation
exposition demonstrating compliance to CAR-CA(M)O at the end of the transition process. After approval of the “CA(M)E”, the approval of the
“exposition/manual” is no longer valid.

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 Step Action Remark
0 Compliance with Regulation This means that CAR-145, CAR-MF and CAR-MG organisations, if
working on CAR-ML aircraft, have introduced reference to (or
CAR-145, CAR-MF and CAR-MG organisations will need to prepare the amendments in compliance with) CAR-ML.
necessary amendments to the exposition/manual to be in compliance with CAR-
145 Issue 3, CAR-MF Issue 3 and CAR-MG Issue 3. Appendix I provides a list of some of the main changes introduced.

1 Eligibility to CAR-CA(M)O Note:

The organisation reviews the eligibility for their organisation to transition CAR-CAO is applicable under the following conditions:
to CAR-CA(M)O, analysing existing (and future desired, where applicable) a. The aircraft is not used by an air operator certified in
scope of work. accordance with Rule 134 and Schedule XI of the Aircraft
Rules, 1937;
b. The aircraft is a not a complex motor-powered aircraft
2 Request for CAR-CA(M)O approval After 01-01-2025 and before 30 June 2026

The approved organisation requests a CAR-CA(M)O approval to DGCA by Note: All existing organisations desirous of obtaining CAR-CAMO or
applying through EGCA. CAR-CAO approvals shall submit application to DGCA no later than
31.12.2025.
Note: the organisation may already accompany this request with a draft of the
‘implementation plan’ which will be asked to the organisation at step 4b.

DGCA verifies the eligibility of the organisation, and if the organisation is

eligible, informs the organisation.

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 Step Action Remark
3 Exposition/manual amendment

The organisation submit the amendment to the existing exposition/manual to --

DGCA for approval. This amendment introduces:
 the changes necessary to comply with CAR-145 Issue 3/ CAR-MF Issue
3/ CAR-MG Issue 3 as required. (see step 0)

Once approved, the organisation uses this amended exposition/manual until the
re-issue of the CAR-CA(M)O certificate and the approval of the CA(M)E (step 9).
4a Initial CA(M)O approval After 01-01-2025 and before 30 June 2026

a. The DGCA issues ‘Form 3-CAO’ or ‘Form 14-CAMO’ certificate with the Initial DGCA Form 3-CAO (for CAR-CAO) or DGCA Form 14 (for
approval number/reference. This certificate must reflect the same CAR-CAMO) certificates should include, on page 2, the reference
privileges as the ones held by the organisation under CAR-145/-MF/- to the amended exposition/manual.
MG and not exceed the CAR-CA(M)O defined privileges (Refer to the
table in section I(b) of this AAC); In case an organisation holds both CAR-MF and MG approvals and
request a CAR-CAO covering both activities, references to both
b. After verification the DGCA approves the amended exposition/manual; expositions/manuals (if they are separated) should be mentioned
on page 2.
NOTE: DGCA may make certain verifications (e.g. privileges, scope of
work, update of organisations forms, consideration of CAR-ML if DGCA is not required to issue the Approval Recommendation
applicable), but it is not the intent to verify compliance to CAR-CA(M)O at Report at this step.
this stage. The intent is to “grandfather” the existing organisation as a CAR-
CA(M)O organisation.

c. The organisation surrender the existing CAR-MF/-MG or CAR-145

certificate to the DGCA.

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 Step Action Remark
4b Finding notifications Proposed wording for the ‘Generic transition finding’ (Level 2):

The DGCA also: “On the basis of CAR-145 Issue 3/ CAR-MF Issue 3/ CAR-MG
d. notifies to the applicant a ‘generic transition finding’ Issue 3, approval reference [IND].CAR-CAMO.[XXXX]/ [IND].CAR-
e. transfer the open findings raised against CAR-MF/-MG or CAR-145 into CAO.[XXXX] is issued to [Company name], but the organisation
‘oversight findings’ against the relevant equivalent CAR-CA(M)O has not demonstrated that it complies with all requirements of
requirements with no change in agreed closure dates. CAR-CAMO or CAR-CAO.

Remark: if no equivalent requirement exists in CAR-CA(M)O, the finding will The organisation shall take necessary measures to demonstrate to
be closed without further showing. the satisfaction of DGCA that, before 30.6.2026, it complies with
the applicable requirements newly introduced by CAR-CA(M)O
and not included in CAR-145 Issue 3/ CAR-MF Issue 3/ CAR-MG
Issue 3. To this end, the organisation should establish and submit
to DGCA an implementation plan.

In the meantime, the organisation shall continue working with the

existing procedures as per the approved exposition/manual
amended to account for the new approval reference and
amendments to CAR-145 Issue 3/ CAR-MF Issue 3/ CAR-MG
Issue 3.”

For the re-notification of existing findings, DGCA may use the

correspondence tables provided in appendices.
5 Implementation plan

As a response to the ‘generic transition finding’, the organisation develops and For the gap analysis, please refer to the correspondence tables
submits an implementation plan that includes the following: between CAR-145 Issue 3/ CAR-MF Issue 3/ CAR-MG Issue 3 and
CAR-CAMO/-CAO provided in appendices.
 Gap analysis between the existing organisation procedures and the new
CAR-CA(M)O requirements. Note: The CAE should not be considered to be a revision of the
 A roadmap for developing the CA(M)E (compliant with CAR-CA(M)O) existing exposition/manual but a new document.
 Training of staff on CAR-CA(M)O and training on the future CA(M)E

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 Step Action Remark
6 Acceptance of the implementation plan and oversight programme
adjustment

DGCA assesses the implementation plan proposed by the organisation, and if

the assessment concludes that it is sufficient to address the transition, accepts
this plan.

DGCA also reviews the existing oversight programme, considering the following:
 For requirements which are not new in CAR-CA(M)O (i.e. for which there is Please refer to the correspondence tables between CAR-145
an equivalent in CAR-145 Issue 3/ CAR-MF Issue 3/ CAR-MG Issue 3), Issue 3/ CAR-MF Issue 3/ CAR-MG Issue 3 and CAR-CAMO/-
DGCA may take credit from oversight activities (audits, inspections, etc.) CAO provided in appendices.
already performed as part of the ongoing oversight cycle to declare
compliance of the organisation with the concerned CAR-CA(M)O
requirements.
 The current Annual Surveillance Programme (ASP) cycle may be continued,
but the oversight programme should be reviewed to ensure that, before 30
June 2026, DGCA will have checked compliance of the organisation against
the CAR-CA(M)O novelties (i.e. requirement which are newly introduced in
CAR-CA(M)O and for which there is no equivalent in CAR-145 Issue 3/ CAR-
MF Issue 3/ CAR-MG Issue 3) (see chapter IV).
7 Oversight during transition For the oversight activities during the transition period, 2 types of
findings may be raised:
DGCA continues to perform the oversight of the organisation, in accordance  Transition finding: Finding raised against requirements which
with: are newly introduced in CAR-CA(M)O (novelties).
 CAR-CA(M)O; Closure date for these transition findings shall not exceed 30
 the implementation plan; June 2026. This include the ‘generic’ transition finding.
 the amended exposition/manual.
 Oversight finding: Finding raised against CAR-CA(M)O
requirements for which an equivalent requirement already
exists in CAR-145 Issue 3/ CAR-MF Issue 3/ CAR-MG Issue
3.
Oversight findings should be managed in accordance with
Airworthiness Procedures Manual (APM).

Please refer to the correspondence tables between CAR-145 Issue

3/ CAR-MF Issue 3/ CAR-MG Issue 3 and CAR-CAMO/-CAO
provided in appendices. Column 3 offers a recommended policy for
the finding classification (transition vs oversight findings). This
column also includes a summary of the novelties where relevant.

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 Step Action Remark
8 Implementation plan execution

Organisation execute the implementation plan, including the acquisition of the DGCA review the implementation by desktop activities and onsite
necessary resource and the development of the CA(M)E. It should be ensured audit as specified in the oversight programme reviewed at step 6.
that the staff receives difference training on the future approved CA(M)E and
associated procedures. Note: The CAE should not be considered to be a revision of the
existing manual/exposition but a new document.
The drafting of the CA(M)E should take into account the transition findings raised
by DGCA during the oversight. But it should be avoided to submit successive To help in the CAE development, appendixes VI, VII and VIII offer
exposition amendments for approval with the aim to close these transition cross-references between the CAE and respectively the MOE,
findings individually. MOM and CAR-MG Issue 3 CAME.

Once the CA(M)E is considered fully compliant with CAR-CA(M)O, it shall be To help in the CAME development, appendixes IX highlights the
submitted to DGCA for approval. difference with the CAR-MG exposition.

9 Final CA(M)O approval Before 30 June 2026

At this stage, the DGCA should have: Note: at this stage, an ‘oversight finding’ may remain open, within
 checked compliance of the organisation against every CAR-CA(M)O the limit of APM.
novelties
 checked that every ‘transition finding’ raised during oversight has been
closed;
 implementation plan has been completed.

DGCA issues an approval recommendation report (refer to Form 13-CAMO or

Form 613), and approves the CA(M)E, issue a revision of the ‘CA Form 3-CAO’
or ‘CA Form 14’ certificate and closes the ‘generic transition finding’.

On the certificate, the mention introduced on page 2 (step 4a) should be

removed and the reference to the approved CA(M)E should be introduced.

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 Step Action Remark
10 End of transition and changes to organisation

At this stage, the organisation becomes a full compliant CAR-CA(M)O

organisation and therefore this AAC, and in its appendices, are no longer
applicable.
Changes must follow CAR-CA(M)O requirements and the
The organisation may apply for a change to extend the privileges introduced approved CA(M)E.
at step 4a as foreseen by CAR-CA(M)O.

After 30 June 2026:

 CAR-MF/-MG organisations which have initiated, but not completed
the transition to CAR-CA(M)O shall be revoked, limited or suspended,
in whole or in part;
 CAR-MF/-MG organisations which have not applied to a CAR-CA(M)O
shall be revoked.

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IV. Overview of DGCA Oversight during transition

The following figure provides an overview of the content of the DGCA oversight programme during the transition (in accordance
with the steps 4b, 6 and 7 of preceding chapter).

Check compliance to CAR-CA(M)O Novelty

Check compliance to provision having an Equivalent in CAR-MG/-MF/-145 and CAR-CA(M)O

31 July 2024 01 Jan 2025 30 June 2026

30 June 2026
CAR-MG/-MF/-145 Org.

CAR-MG/-MF/-145 i.a.w CAR-CA(M)O

*: recommendation report at the end of this cycle will mark:

• the particular novelty ‘Ni‘ as applicable and reviewed;
• the novelties other than Ni as applicable but not reviewed (‘N/R’) .

This particular Ni novelty is part of the subsequent 2 YE oversight cycle, but it may be rechecked after 30 June 2026.

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 (CAR-CA(M)O novelties)

(on equivalent CAR-MG/-MF/-145 & CAR-CA(M)O provisions)

31 July 2024 01 Jan 2025

30 June 2026

30 June 2026
CAR-MG/-MF/-145 Org.

CAR-MG/-MF/-145 i.a.w CAR-CA(M)O

(oversight finding to be closed

within the provisions of relevant
APM Chapter)

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V. Changes to the CAR-MF, CAR-MG or CAR-145 organisation

Independently of the transition to CA(M)O, certain change may need to be introduced in the organisation during the transition. The following constitutes the guidance for the
management of the requests for change to the organisation during the transition period (e.g. change of nominated person).
— Request for change submitted by the organisation before Step 4 need to be managed as agreed with the DGCA.
— Request for change submitted by the organisation between Step 4 and Step 9 need to follow the organisation’s change procedure (as specified in the
exposition/manual) valid at time of request. In particular:
o new privilege provided for in CAR-CAO (e.g. maintenance for a subpart G organisation) cannot be granted by DGCA at this stage (see note
below).
o If the change is affected by a CAR-CA(M)O novelty without introducing a new CAR-CAO privilege, it may be approved by DGCA if it complies
with the current exposition/manual and associated procedures, but a ‘transition finding’ should be raised if it does not comply with the CAR-
CA(M)O novelty.
o The existing organisation exposition/manual should be amended to introduce this change upon its approvals.
— A change approved and introduced in the existing organisation exposition/manual between Step 4 and Step 9 should normally be reflected in the CA(M)E
under development.
— Request for changes submitted by the organisation after Step 9, need to follow CAR-CA(M)O requirements and the approved CA(M)E.

Note 1: the above guidance relates to changes to the original organisation, necessary to ensure the continuity of the business; this does not prevent that, as
part of the transition activities (and implementation plan) to CAR-CA(M)O, the organisation seeks a CAR-CA(M)O terms of approval at Step 9 going beyond the
original scope of approval (e.g. maintenance for a CAR-MG organisation transitioning to CAR-CAO). The implementation plan should in this case be clear about
such intention and DGCA should include the additional relevant elements in their oversight programme. The provisions which relate to the new intended scope
of approval should be treated as novelties by DGCA and subject to ‘transition findings.

Note 2: In case the organization seeks approval beyond the existing scope of approval, applicable fees as per Rule 133C/ Rule 155A of the Aircraft Rules, 1937
shall be charged.

Sd/-
(Tuhinanshu Sharma)
Joint Director General
for Director General of Civil Aviation

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VI. Appendices

Appendix I — Compliance with new Regulations (CAR-CAMO, CAR-CAO, CAR-ML, CAR-

M Issue 3, & CAR 145 Issue 3)

Before 31 December 2024, organisations holding a valid CAR-MG, CAR-MF or CAR-145

approval certificate should amend their exposition/manual and associated procedures,
where applicable to account for changes introduced by new Regulations (CAR-CAMO,
CAR-CAO, CAR-ML, CAR-M Issue 3, & CAR 145 Issue 3)

For that purpose, below is a non-exhaustive list of some of the main changes:

Airworthiness Review
 DGCA Forms 15a/b/c are updated. DGCA Forms 15 have to be used as follows:

— DGCA Form 15a: to be issued by DGCA for aircraft following CAR-M regime.

— DGCA Form 15b: to be issued by CAR-CAMO (or CAR-MG during transition period)
for aircraft following CAR-M regime. (In case of organisations holding the AR
privilege)

— DGCA Form 15c: to be issued by DGCA for aircraft following CAR-ML regime.

Note: existing Airworthiness Review Certificates (ARC) issued before 30 June 2026
continue to be valid after 30 June 2026.

 After 30 June 2026, Airworthiness reviews for light aircraft not used by Air operator
certified in accordance with Rule 134 and Schedule XI of the Aircraft Rules, 1937 shall
be performed in accordance with Subpart I of CAR-ML.

 DGCA Form 15c becomes extendable and corresponding extension have to be carried
out in accordance with ML.A.901.

Continuing Airworthiness of aircraft following CAR-ML

 AMP of CAR-ML aircraft shall be developed iaw ML.A.302.

Note: existing AMPs approved in compliance with M.A.302 before 31 December 2024
continue to be valid till 30 June 2026.

 Defect management shall be performed according to ML.A.403.

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 Appendix II — CAR-CAMO vs CAR-MG Correspondence table and transition oversight policy

Potential transition findings are identified in blue background

CAR-M subpart G CAR-CAMO requirement Oversight policy to be applied to grandfathered CAR-CAMO from 01 January 2025 to 30 June 2026
requirement, where
applicable
In case of non-compliance with CAMO.A.115(a)/(b)(2), an oversight finding should be raised.

M.A.702 - Application CAMO.A.115 – Application for an CAMO.A.115(b)(1) is a new requirement for the organisation to provide the results of a pre-audit against the applicable
organisation certificate requirements together with its application. When the organisation is grandfathered to CAR-CAMO, provision of the result
of that pre-audit is not mandatory at the time the CAR-CAMO certificate is issued.

If not already in place, the organisation should provide the DGCA with a procedure describing how changes not requiring
prior approval will be managed and notified to the DGCA before 30 June 2026 (refer to CAMO.A.130).
In case of non-compliance with CAMO.A.125(a)/(b)/(c), an oversight finding should be raised.

CAMO.A.125(a)/(b)/(c) – Terms of approval CAMO.A.125 covers both M.A.703 and M.A.711 requirements (refer to the line dedicated to M.A.711), M.A.711
M.A.703 – Extend of approval and privileges of the organisation ‘Privileges of the organisation’ is incorporated (new points (d) to (f)) and relevant references updated. Only minor
changes are made to the text stemming from M.A.711 to update the cross references and replace ‘quality system’ with
‘management system’. The text is further amended to include the CAR-M/CAR-ML references for the extension of the
ARC (cf. point (d)(4)) and for the issue of a recommendation for the airworthiness review by the DGCA (cf. point (e)(2)).

M.A.711 – Privileges of the CAMO.A.125(d)/(e)/(f) – Terms of approval In case of non-compliance with CAMO.A.125(d)/(e)/(f), an oversight finding should be raised.
organisation and privileges of the organisation

Potential transition finding: “Due to on-going transition from CAR-M subpart G to CAR-CAMO, current exposition does not
contain necessary provisions to address CAMO.A.130 requirements”.

M.A.713 – Changes to the CAMO.A.130 introduces the term ‘changes not requiring prior approval’ replacing the ‘indirect approval’. Changes not
approved continuing CAMO.A.130 – Changes to the organisation requiring prior approval will be managed as agreed between the organisation and the authority. The organisation should
airworthiness organisation amend current exposition to account for CAMO.A.130 before 30 June 2026.

Until the organisation is fully compliant with CAR-CAMO changes to the organisation should be managed i.a.w. the
organisation current approved procedure. As a result, in case of non-compliance with M.A.713 and/or with the current
procedure in place within the organisation, an oversight finding should be raised and managed i.a.w. relevant APM.

M.A.715 – Continued validity of CAMO.A.135 – Continued validity Changes are made to update references and for consistency throughout the new CAR-CAMO.
approval
In case of non-compliance with CAMO.A.135, an oversight finding should be raised and managed i.a.w. relevant APM.
A new CAMO.A.140 Access is added. It contains the requirements for granting access to DGCA for the purpose of
N/A – New requirement CAMO.A.140 - Access determining continued compliance.
introduced by CAR-CAMO In case of non-compliance with CAMO.A.140, an oversight finding should be raised and managed i.a.w. relevant
APM as this requirement was already existing in point (a)(2) of M.A.715 and is therefore not considered as a novelty.

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Potential transition findings are identified in blue
CAR-M subpart G CAR-CAMO requirement Oversight policy to be applied to grandfathered CAR-CAMO from 01 January 2025 to 30 June 2026
requirement where
applicable
Potential transition finding: “Due to on-going transition from CAR-M subpart G to CAR-CAMO, current exposition
procedure is not compliant with CAMO.A.150(a)(1)”.

M.A.716 - Findings CAMO.A.150 – Findings CAMO.A.150 add a requirement to identify the root causes of and contributing factors to the non-compliance. The
organisation should amend current exposition to account for CAMO.A.150(a)(1) before 30 June 2026.

In case of non-compliance with CAMO.A.150(a)(2)/(a)(3)/(b), an oversight finding should be raised and managed
i.a.w. relevant APM.
Potential transition finding: “Due to on-going transition from CAR-M subpart G to CAR-CAMO, current exposition
procedure is not compliant with CAMO.A.155”.

N/A –not explicit requirement CAMO.A.155 – Immediate reaction to a CAMO.A.155 add a new requirement to implement any safety measures mandated by DGCA and any relevant
in CAR-MG safety problem mandatory safety information issued by DGCA. Even if newly formally introduced through CAMO.A.155, this
requirement is not considered as a novelty and apart from the case of the exposition update to account for that new
article (refer to above transition finding), in case of non-compliance with CAMO.A.155, an oversight finding should be
raised and managed i.a.w. relevant APM.

N/A – Previous M.A.202 A new CAMO.A.160 Occurrence reporting is added to introduce the occurrence reporting requirements applicable to
requirement transferred into CAMO.A.160 – Occurrence reporting CAMOs. As similar M.A.202 requirement applied to CAR-MG organisation, CAMO.A.160 is not considered as a novelty
CAR-CAMO and in case of non- compliances with CAMO.A.160, an oversight finding should be raised and managed i.a.w. relevant
APM.
Potential transition finding: “Due to on-going transition from CAR-M subpart G to CAR-CAMO, current exposition
procedure is not compliant with CAMO.A.200(a)(2)/(a)(3)/(a)(5)”.

The organisation should amend current exposition quality system procedure to account for CAMO.A.200 and
CAMO.A.202. Main novelties compared to M.A.712 are:
CAMO.A.200 – Management system  CAMO.A.200(a)(2): Safety policy.
 CAMO.A.200(a)(3): identification of aviation safety hazards and management of associated risks.
 CAMO.A.200(a)(5): documentation of all management system key processes.

In case of non-compliance with CAMO.A.200(a)(1)/(a)(4)/(a)(6)/(a)(7)/(b)/(c)/(d) an oversight finding should be

M.A.712 – Quality system raised and managed i.a.w. relevant APM.

Potential transition finding: “Due to on-going transition from CAR-M subpart G to CAR-CAMO, current exposition does
not contain necessary provisions to address CAMO.A.160 requirements”.

A new CAMO.A.202 Internal safety reporting scheme is added to establish an internal reporting scheme supporting the
CAMO.A.202 – Internal safety reporting scheme organisation’s hazard identification and safety risk management processes and fostering its safety culture. The internal
reporting scheme shall also be accessible to organisations working under the CAMO’s management system. It also
forms the basis for establishing mandatory and voluntary occurrence reporting as required by AAC 02 of 2024.

The organisation should amend its procedures to account for CAMO.A.202 before 30 June 2026.

19
Potential transition findings are identified in blue
CAR-M subpart G CAR-CAMO requirement Oversight policy to be applied to grandfathered CAR-CAMO from 01 January 2025 to 30 June 2026
requirement where
applicable
Potential transition finding: “Due to on-going transition from CAR-M subpart G to CAR-CAMO, current exposition
procedure is not compliant with CAMO.A.205(a)(2)”.

A new CAMO.A.205 Contracting and subcontracting is added to clarify the responsibility of the CAMO to ensure that
any contracting (maintenance) or subcontracting (specific continuing-airworthiness-management-related activities)
N/A - New requirement CAMO.A.205 – Contracting and subcontracting complies with applicable requirements. In this context it is important to clarify that the term ‘subcontracting’ covers cases
introduced in CAR-CAMO where the contracted organisation is itself CAR-CAMO or CAR-CAO approved and cases where such organisation is
not CAR-CAMO/CAR-CAO approved. Any continuing-airworthiness-management related services provided by third
parties are to be considered ‘subcontracting under the management system’ for the purpose of CAR-CAMO.

The organisation should amend current exposition to account for CAMO.A.205(a)(2) before 30 June 2026.

In case of non-compliance with CAMO.A.205(a)(1)(b), an oversight finding should be raised and managed i.a.w. relevant
APM.
M.A.705 - Facilities CAMO.A.215 - Facilities In case of non-compliance with CAMO.A.215, an oversight finding should be raised and managed i.a.w. relevant APM.
In case of non-compliance with CAMO.A.220(a)(1)/(a)(3)/(a)(4)/(a)(6)/(d)/(f), an oversight finding should be raised and
managed i.a.w. relevant APM.

M.A.714(a)(1)/(a)(3)/(a)(4)/(a)(5)/ CAMO.A.220(a)(1)/(a)(3)/(a)(4)/(a)(6)/(d)/(f) – The record-keeping duration for aircraft related records is changed to 3 years after the responsibility for the aircraft has
(a)(6)/(f)/(e) – Records-keeping Records-keeping been permanently transferred, to align with the validity of the airworthiness review certificate (ARC) and 1 year for aircraft
permanently withdrawn from service.

In addition, record keeping duration for personnel records is 3 years after a person has left the organisation. This will
ensure that for any ARC issued, personnel records will remain accessible for the entire ARC validity, including in the
case a person has left the CAMO shortly after an ARC was issued.
Potential transition finding: “Due to on-going transition from CAR-M subpart G to CAR-CAMO, current exposition is not
compliant with CAMO.A.220(a)(2)/(a)(5)/(b)/(e)”.
N/A – New requirement
introduced by CAR-CAMO CAMO.A.220(a)(2)/(a)(5)/(b)/(e) – Records- CAMO.A.220 Record-keeping includes management-system-. A record-keeping duration of 5 years for management-
keeping system-related records is introduced. In addition, the organisation shall record all details of work carried out and the
format of the records shall be specified in the organisation’s manual.

Potential transition finding: “Due to on-going transition from CAR-M subpart G to CAR-CAMO, current exposition is not
M.A.706(h) – Personnel compliant with CAMO.A.220(c)”.
M.A.707(e) – Airworthiness CAMO.A.220(c) – Records-keeping
Review Staff CAMO.A.220 Record-keeping includes personnel related record-keeping. Personnel-related records (qualification and
experience) shall include personnel involved in safety management and be kept until 3 years after a person has left the
organisation.
M.A.707(e) – Airworthiness CAMO.A.220(c)(1)(ii)/(2)/(3) – Records-keeping In case of non-compliance with CAMO.A.220(c)(1)(ii)/(c)(2)/(c)(3), an oversight finding should be raised and
Review Staff managed i.a.w. relevant APM except if corresponding records have been kept for only 2 years.

20
Potential transition findings are identified in blue
CAR-M subpart G CAR-CAMO requirement Oversight policy to be applied to grandfathered CAR-CAMO from 01 January 2025 to 30 June 2026
requirement where
applicable
Potential transition finding: “Due to on-going transition from CAR-M subpart G to CAR-CAMO, current exposition is not
compliant with CAMO.A.300”.

CAMO.A.300 include additional management-system-related elements, such as:

 the safety policy,
 a description of the internal safety reporting scheme (CAMO.A.202),
 a general description of how the organisation ensures availability of staff (CAMO.A.305(d)),
 a procedure defining the scope of changes not requiring prior approval and describing how such changes will
be managed and notified (CAMO.A.115(b) and CAMO.A.130(c)), the procedures specifying how the
organisation controls any contracted or subcontracted tasks, including contracted maintenance
(CAMO.A.315(c)),
 The compliance statement in point (a)(1) is amended to cover all CAR-M, CAR-ML, and CAR-CAMO
M.A.704 – Continuing CAMO.A.300 – Continuing airworthiness requirements, as applicable.
Airworthiness management management exposition  In point (a)(11), additional clarification is provided on the procedures required specifying how the organisation
exposition ensures compliance with CAR-CAMO, CAR-M and CAR-ML.
 In point (a)(9), now (a)(12), the requirement for a list of approved maintenance programmes is clarified, by
stating this is only relevant for aircraft for which a contract exists for continuing airworthiness management, not
being required for initial approval of the CAMO. Accordingly, baseline and generic maintenance programmes
are no longer required (see also CAMO.A.325).
 Point (b) is reviewed to specify that the initial CAME is subject to DGCA approval.
 A requirement to maintain the CAME to remain an up-to-date description of the organisation is also added.
 Point (c) on amendments to the CAME refers to the changes requiring prior approval (cf. CAMO.A.130(a))
and to the new provisions on managing changes without prior DGCA approval, based on an agreed
procedure.

The organisation should amend current exposition to account for CAMO.A.300. As long as the organisation is not fully
compliant with CAR-CAMO, any non-compliance with CAMO.A.300 should be classified as a transition finding except
when there is a non-compliance with M.A.704 which should be classified i.a.w. relevant APM.
M.A.706(a)/(b)/(c)/(d)/(e)/(f)/(g)/(i CAMO.A.305(a)(1)/(a)(3)/(a)(4)/(a)(6)/(a)(7)/(b)/( In case of non-compliance with CAMO.A.305(a)(1)/(a)(3)/(a)(4)/(a)(6)/(a)(7)/(b)/(c)/(d)/(e)/(f)/(g), an oversight finding
)/(j)/(k) – Personnel requirements c)/(d)/(e)/(f)/(g) – Personnel requirements should be raised and managed i.a.w. relevant APM except if the non-compliance concerns understanding of safety
(also M.A.712(a)) management and human factors principles appropriate to the person’s function and responsibilities where a
transition finding should be raised.

21
Potential transition findings are identified in blue
CAR-M subpart G CAR-CAMO requirement Oversight policy to be applied to grandfathered CAR-CAMO from 01 January 2025 to 30 June 2026
requirement where
applicable
Potential transition finding: “Due to on-going transition from CAR-M subpart G to CAR-CAMO, current exposition is not
compliant with CAMO.A.305(a)(2)/(a)(5)”.

 CAMO.A.305 includes the nomination of a person or group of persons for the compliance monitoring function
and for safety-management related responsibilities, to clarify the responsibilities of the accountable manager,
and to state that competence must include an understanding of the application of safety management and
human factors principles and human performance issues.
 Additional changes are made to improve the overall structure of this CAR and to clarify the link with Rule 134
N/A - New requirement CAMO.A.305(a)(2)/(a)(5) – Personnel of the Aircraft Rules, 1937 and related CARs. In particular, point (b)(1) states that for organisations also
introduced in CAR-CAMO requirements approved as an air operator certified in accordance with Rule 134 and Schedule XI of the Aircraft Rules, 1937,
the accountable manager shall be the person appointed as accountable manager for the air carrier.
 A requirement is added for a system to plan the availability of staff to ensure that the organisation has sufficient
appropriately qualified staff to plan, perform, supervise, inspect and monitor its activities in accordance with the
terms of approval (new point (d)).
 A new point (e) is added to include in CAMO.A.305 the reference to airworthiness review staff currently
embedded in M.A.707 point (a). This way, CAMO.A.305 includes the requirements for all categories of staff
and CAMO.A.310 may concentrate on airworthiness review staff qualification requirements.

In case of non-compliance with CAMO.A.310, an oversight finding should be raised and managed i.a.w. relevant APM
except if the non-compliance concerns understanding of safety management and human factors principles by
Airworthiness Review Staff where a transition finding should be raised.

 specific qualification requirements not applicable within the scope of CAR-CAMO are removed.
 Point (d) on listing airworthiness review staff in the CAME is deleted as this is already addressed in point
CAMO.A.300(a)(8).
M.A.707 – Airworthiness review CAMO.A.310 – Airworthiness review staff  These airworthiness review staff qualifications apply regardless of the aircraft managed, meaning for example
staff qualification that a CAR-CAMO-approved organisation performing airworthiness reviews of aircraft other than CMPA may not
use airworthiness review staff complying with the ‘lower’ requirements of the new CAR-CAO.

22
 Potential transition findings are identified in blue
CAR-M subpart G requirement CAR-CAMO requirement Oversight policy to be applied to grandfathered CAR-CAMO from 01 January 2025 to 30 June 2026
where applicable

In case of non-compliance with CAMO.A.315, an oversight finding should be raised and managed i.a.w. relevant APM
except in case of non-compliance with CAMO.A.315(b)(4) (default in using the organisation’s safety risk
management process) where a transition finding should be raised.

 CAMO.A.315 Continuing airworthiness management is reviewed to eliminate overlaps with M.A.301. The
underlying principle is that purely technical requirements are included in CAR-M and that CAR-CAMO focuses
on the related organisational responsibilities. This will improve consistency and facilitate future amendments.
M.A.708 – Continuing CAMO.A.315 – Continuing airworthiness  Additional changes are made to update relevant cross references. As a CAR-CAMO-approved organisation
airworthiness management management may also manage the continuing airworthiness of other than CMPA or of aircraft not used by air operator
certified in accordance with Rule 134 and Schedule XI of the Aircraft Rules, 1937, references to CAR-CAO
organisations are added and references to Subpart F maintenance organisations are maintained (to allow for
a smooth transition to CAR-CAO, Subpart F will be maintained during the transition period).
 Point (e) is added to include a requirement for human factors principles and human performance limitations to
be taken into account for any continuing airworthiness management tasks.

In case of non-compliance with CAMO.A.320, an oversight finding should be raised and managed i.a.w. relevant APM.

M.A.710 – Airworthiness review CAMO.A.320 – Airworthiness review The text of existing M.A.710 is replaced with a requirement to follow CAR-M Section A point M.A.901. The specific
elements constituting the airworthiness review process are transferred to those CAR-M.

In case of non-compliance with CAMO.A.325, an oversight finding should be raised and managed i.a.w. relevant APM.
CAMO.A.325 – Continuing airworthiness
M.A.709 – Documentation management data CAMO.A.325 Continuing airworthiness management data is changed for consistency to reflect the scope of the new
CAR-CAMO and to update the relevant cross references. Point (b) is deleted as the requirement to produce baseline or
generic maintenance programmes is not maintained.

23
 Appendix III — CAR-CAO vs CAR-MG Correspondence table and transition oversight policy

Potential transition findings are identified in blue

CAR-M subpart G CAR-CAO requirement Oversight policy to be applied to grandfathered CAR-CAO from 01 January 2025 to 30 June
requirement where 2026
applicable
M.A.702 - Application CAO.A.015 – Application for an organisation certificate In case of non-compliance with CAO.A.015, an oversight finding should be raised and managed i.a.w. relevant
APM.

Potential transition finding: “Due to on-going transition from CAR-M subpart G to CAR-CAO, current exposition
is not compliant with CAO.A.020 requirements”.

M.A.703 – Extend of approval CAO.A.020 – Terms of approval The above transition finding is meant to address format changes in the way the scope of work is described in
the organisation manual. In case the grandfathered CAR-CAO organisation uses privileges on aircraft/
component that are out of its scope, an oversight finding should be raised against CAO.A.020. The organisation
should amend its scope of work as specified by CAO.A.020 before 30 June 2026 or completion of transition
process.
Potential transition finding: “Due to on-going transition from CAR-M subpart G to CAR-CAO, current exposition
is not compliant with CAO.A.025”.

Structure of the CAE is as follows:

 The CAE is made of the 4 following parts:
o Part A – General description
o Part B - General procedures
o Part C – Maintenance procedures
M.A.704 – Continuing o Part D – Continuing airworthiness management procedures
Airworthiness management CAO.A.025 – Combined airworthiness exposition o Part E – Supporting documents
exposition
 Organisation grandfathered as CAR-CAO based on a CAR-MG should prepare a CAE which covers
Part A, Part B, Part D and Part E. To help the organisation in preparing the CAE based on existing
exposition:
o A table comparing CAE with CAR-MG exposition is available in annex 2-2, and
o A detailed table of content of the CAE along with CAO requirements to be covered by each
section of the CAE is provided in AMC1 CAO.A.025.

The organisation should develop a CAE to account for CAO.A.025. As long as the organisation is not fully
compliant with CAR-CAO, any non-compliance with CAO.A.025 should be classified as a transition finding
except when there is a non-compliance with M.A.704 which should be classified i.a.w. relevant APM.

M.A.705 - Facilities CAO.A.030 - Facilities In case of non-compliance with CAO.A.030, an oversight finding should be raised and managed i.a.w. relevant
APM.
M.A.706 - Personnel CAO.A.035 – Personnel requirements In case of non-compliance with CAO.A.035, an oversight finding should be raised and managed i.a.w. relevant
requirements APM.

24
Potential transition findings are identified in blue
CAR-M subpart G CAR-CAO requirement Oversight policy to be applied to grandfathered CAR-CAO from 01 January 2025 to 30 June
requirement where 2026
applicable
In case of non-compliance with CAO.A.075(a)/(b), an oversight finding should be raised and managed i.a.w.
M.A.708(a)/(b) /(c)/(d) – relevant APM.
Continuing airworthiness CAO.A.075(a)/(b)– Continuing airworthiness management
management CAO.A.075 Continuing airworthiness management is reviewed to eliminate overlaps with M.A.301 and
ML.A.301. The underlying principle is that purely technical requirements are included in CAR-M and CAR-ML
and that CAR-CAO focuses on the related organisational responsibilities. This will improve consistency and
facilitate future amendments.
M.A.709 – Documentation CAO.A.080 – Continuing airworthiness management data In case of non-compliance with CAO.A.080, an oversight finding should be raised and managed i.a.w. relevant
APM.
M.A.714 – Records-keeping CAO.A.090(a)(2)/(a)(3)/(a)(4)/(c)/(d)/(e)/(f)/(g)(2) – In case of non-compliance with CAO.A.090(a)(2)/(a)(3)/(a)(4)/(c)/(d)/(e)/(f)/(g)(2), an oversight finding should be
Records- keeping raised and managed i.a.w. relevant APM.

M.A.711 – Privileges of the CAO.A.095(b)/(c)/(d)/(e) – Privileges of the organisation In case of non-compliance with CAO.A.095(b)(1)/(b)(3)/(b)(4)/(c)/(d)/(e), an oversight finding should be
organisation raised and managed i.a.w. relevant APM.

In case of non-compliance with CAO.A.100, an oversight finding should be raised and managed i.a.w. relevant
APM.

M.A.712 – Quality system CAO.A.100 – Quality system and organisational review A CAR-CAO can elect to replace its quality system by an organizational review when one of the following
condition is met:
 The scope of the CAO does only contain aircraft covered by CAR-ML
 The CAO does not exceed 10 full-time equivalent staff involved in maintenance.
 The CAO does not exceed 5 full-time equivalent staff involved in continuing airworthiness
management.
Potential transition finding: “Due to on-going transition from CAR-M subpart G to CAR-CAO, current exposition
does not contain necessary provisions to address CAO.A.105 requirements”.

CAR-CAO mandate the organisation to have a procedure to address changes not requiring prior approval.
M.A.713 – Changes to the
approved continuing CAO.A.105 – Changes to the organisation Changes not requiring prior approval will be managed as agreed between the organisation and DGCA. The
airworthiness organisation organisation should develop a procedure to account for CAO.A.105 before 30 June 2026.

Until the organisation is fully compliant with CAR-CAO, changes to the organisation should be managed i.a.w.
the organisation current approved procedure. As a result, in case of non compliance with M.A.713 and/or with
the current procedure in place within the organisation, an oversight finding should be raised and managed i.a.w.
relevant APM.

25
Potential transition findings are identified in blue
CAR-M subpart G CAR-CAO requirement Oversight policy to be applied to grandfathered CAR-CAO from 01 January 2025 to 30 June
requirement where 2026
applicable
M.A.715 – Continued validity CAO.A.110 – Continued validity Minor changes are made to update references and for consistency throughout the new CAR-CAO.
of approval
In case of non-compliance with CAO.A.110, an oversight finding should be raised and managed i.a.w. relevant
APM.

M.A.716 - Findings CAO.A.115 – Findings In case of non-compliance with CAO.A.115, an oversight finding should be raised and managed i.a.w. relevant
APM.

26
 Appendix IV – CAR-CAO vs CAR-MF Correspondence table and transition oversight policy

Potential transition findings are identified in blue

CAR-M subpart F CAR-CAO requirement Oversight policy to be applied to grandfathered CAR-CAO from 01 January 2025 to 30 June 2026
requirement where
applicable
M.A.602 - Application CAO.A.015 – Application for an In case of non-compliance with CAO.A.015, an oversight finding should be raised and managed i.a.w. relevant APM.
organisation certificate

Potential transition finding: “Due to on-going transition from CAR-M subpart F to CAR-CAO, current manual is not
compliant with CAO.A.020 requirements”.

The above transition finding is meant to address format changes in the way the scope of work is described in the organisation
manual. In case the grandfathered CAR-CAO organisation uses privileges on aircraft/ component that are out of its scope,
an oversight finding should be raised against CAO.A.020. The organisation should amend its scope of work as specified by
CAO.A.020 before 30 June 2026.
M.A.603 – Extend of approval CAO.A.020 – Terms of approval
CAO.A.020(a)(3) introduces the following limitation: a CAO which employs only one person for both planning and carrying
out of all maintenance tasks cannot hold privileges for the maintenance of:

 aeroplanes equipped with a turbine engine (in the case of aircraft-rated organisations);
 helicopters equipped with a turbine engine or with more than one piston engine (in the case of aircraft-rated
organisations);
 complete piston engines of 450 HP and above (in the case of engine-rated organisations); and
 complete turbine engines (in the case of engine-rated organisations).

Current CAR-MF organisation being in one of the above situation cannot be grandfathered as a CAR-CAO.

27
Potential transition findings are identified in blue
CAR-M subpart F requirement CAR-CAO requirement Oversight policy to be applied to grandfathered CAR-CAO from 01 January 2025 to 30 June 2026
where applicable

Potential transition finding: “Due to on-going transition from CAR-M subpart F to CAR-CAO, current manual is not
compliant with CAO.A.025”.

Structure of the CAE is as follows:

 The CAE is made of the 4 following parts:

o Part A – General description
o Part B - General procedures
o Part C – Maintenance procedures
M.A.604 – Maintenance CAO.A.025 – Combined airworthiness
o Part D – Continuing airworthiness management procedures
organisation manual exposition
o Part E – Supporting documents
 Organisation grandfathered as CAR-CAO based on a CAR-MF should prepare a CAE which covers Part A, Part
B, Part C and Part E. To help the organisation in preparing the CAE based on existing manual:
o A table comparing CAE with CAR-MF manual is available in annex 3-2, and
o A detailed table of content of the CAE along with CAO requirements to be covered by each section of
the CAE is provided in AMC1 CAO.A.025.

The organisation should develop a CAE to account for CAO.A.025. As long as the organisation is not fully compliant with
CAR-CAO, any non-compliance with CAO.A.025 should be classified as a transition finding except when there is a non
compliance with M.A.604 which should be classified i.a.w. relevant APM.

M.A.605 - Facilities CAO.A.030 - Facilities In case of non-compliance with CAO.A.030, an oversight finding should be raised and managed i.a.w. relevant APM.
M.A.606(a)/(b)/(c)/(d)/(e)/(f) - CAO.A.035 – Personnel requirements In case of non-compliance with CAO.A.035, an oversight finding should be raised and managed i.a.w. relevant APM.
Personnel requirements

M.A.606(g)/(h) – Personnel CAO.A.040(c) – Certifying staff In case of non-compliance with CAO.A.040(c), an oversight finding should be raised and managed i.a.w. relevant APM.
requirements

M.A.607 – Certifying staff and CAO.A.040(a)/(b)/(d) – Certifying staff In case of non-compliance with CAO.A.040(a)(b)(d), an oversight finding should be raised and managed i.a.w. relevant APM.
airworthiness review staff

M.A.608 – Components, CAO.A.050 – Components, equipment In case of non-compliance with CAO.A.050, an oversight finding should be raised and managed i.a.w. relevant APM.
equipment and tools and tools
CAO.A.050(b) requires the organisation to have a procedure to ensure that it has access to all equipment and tools
necessary to carry out its work, used only on an occasional basis.
M.A.609 – Maintenance data CAO.A.055(a) – Maintenance data and In case of non-compliance with CAO.A.055(a), an oversight finding should be raised and managed i.a.w. relevant APM.
work orders

M.A.610 – Maintenance work CAO.A.055(b) – Maintenance data and In case of non-compliance with CAO.A.055(b), an oversight finding should be raised and managed i.a.w. relevant APM.
orders work orders

M.A.611 – Maintenance standards CAO.A.060 – Maintenance standards In case of non-compliance with CAO.A.060, an oversight finding should be raised and managed i.a.w. relevant APM.

28
Potential transition findings are identified in blue
CAR-M subpart F CAR-CAO requirement Oversight policy to be applied to grandfathered CAR-CAO from 01 January 2025 to 30 June 2026
requirement where
applicable
M.A.612 – Certificate of release CAO.A.065 – Aircraft certificate of release In case of non-compliance with CAO.A.065, an oversight finding should be raised and managed i.a.w. relevant APM.
to service to service

M.A.613 – Component certificate CAO.A.070 – Component certificate of In case of non-compliance with CAO.A.070, an oversight finding should be raised and managed i.a.w relevant APM.
of release to service release to service

M.A.609 – Documentation CAO.A.080 – Continuing airworthiness In case of non-compliance with CAO.A.080, an oversight finding should be raised and managed i.a.w. relevant APM.
management data

M.A.614 – Maintenance and CAO.A.090– Records-keeping In case of non-compliance with CAO.A.090, an oversight finding should be raised and managed i.a.w. relevant APM.
airworthiness review records

M.A.615(a)/(b)/(c)/(d) – CAO.A.095(a)(1)/(a)(2)/(a)(3)/(a)(4)/(c)(2)/(d) In case of non-compliance with CAO.A.095(a)(1)/(a)(2)/(a)(3)/(a)(4)/(c)(2)/(d), an oversight finding should be raised and
Privileges of the organisation – Privileges of the organisation managed i.a.w. relevant APM.

In case of non-compliance with CAO.A.100(f), an oversight finding should be raised and managed i.a.w. relevant APM.

CAO.A.100(f) – Quality system and A Part-CAO can elect to replace its quality system by an organisational review when one of the following condition is met:
M.A.616 – Organisational review organisational review
 The scope of the CAO does only contain aircraft covered by Part-ML
 The CAO does not exceed 10 full-time equivalent staff involved in maintenance
 The CAO does not exceed 5 full-time equivalent staff involved in continuing airworthiness management

Potential transition finding: “Due to on-going transition from CAR-M subpart F to CAR-CAO, current manual does not contain
necessary provisions to address CAO.A.105 requirements”.

CAR-CAO mandates the organisation to have a procedure to address changes not requiring prior approval.
M.A.617 – Changes to the
approved continuing CAO.A.105 – Changes to the organisation Changes not requiring prior approval will be managed as agreed between the organisation and the authority. The organisation
airworthiness organisation should develop a procedure to account for CAO.A.105 before 30 June 2026.

Until the organisation is fully compliant with CAR-CAO, changes to the organisation should be managed i.a.w. the organisation
current approved procedure. As a result, in case of non-compliance with M.A.617 and/or with the current procedure in place
within the organisation, an oversight finding should be raised and managed i.a.w. relevant APM.

M.A.618 – Continued validity of CAO.A.110 – Continued validity Minor changes are made to update references and for consistency throughout the new CAR-CAO.
approval
In case of non-compliance with CAO.A.110, an oversight finding should be raised and managed i.a.w relevant APM.
M.A.619 - Findings CAO.A.115 – Findings In case of non-compliance with CAO.A.115, an oversight finding should be raised and managed i.a.w. relevant APM.

29
 Appendix V – CAR-CAO vs CAR-145 Correspondence table and transition oversight policy

Potential transition findings are identified in blue

CAR-145 requirement where CAR-CAO requirement Oversight policy to be applied to grandfathered CAR-CAO from 01 January 2025 to 30 June 2026
applicable
145.A.15 - Application CAO.A.015 – Application for an In case of non-compliance with 145.A.15, an oversight finding should be raised and managed i.a.w. relevant APM.
organisation certificate

Potential transition finding: “Due to on-going transition from CAR-145 to CAR-CAO, current exposition is not
compliant with CAO.A.020 requirements”.

The above transition finding is meant to address format changes in the way the scope of work is described in the
organisation manual. In case the grandfathered CAR-CAO organisation uses privileges on aircraft/component
that are out of its scope, an oversight finding should be raised against CAO.A.020. The organisation should amend
its scope of work as specified by CAO.A.020 before 30 June 2026.

145.A.20 – Terms of approval CAO.A.020 – Terms of approval CAO.A.020(a)(3) introduces the following limitation: a CAO which employs only one person for both planning and
carrying out of all maintenance tasks cannot hold privileges for the maintenance of:

 aeroplanes equipped with a turbine engine (in the case of aircraft-rated organisations);
 helicopters equipped with a turbine engine or with more than one piston engine (in the case of aircraft-
rated organisations);
 complete piston engines of 450 HP and above (in the case of engine-rated organisations); and
 complete turbine engines (in the case of engine-rated organisations).

Current CAR-145 organisation being in one of the above situation cannot be grandfathered as a CAR-CAO.

30
Potential transition findings are identified in blue
CAR-145 requirement where CAR-CAO requirement Oversight policy to be applied to grandfathered CAR-CAO from 01 January 2025 to 30 June 2026
applicable
Potential transition finding: “Due to on-going transition from CAR-145 to CAR-CAO, current exposition is not
compliant with CAO.A.025”.

Structure of the CAE is as follows:

 The CAE is made of the 4 following parts:
o Part A – General description
o Part B - General procedures
o Part C – Maintenance procedures
o Part D – Continuing airworthiness management procedures
145.A.70 – Maintenance CAO.A.025 – Combined airworthiness o Part E – Supporting documents
organisation exposition exposition
 Organisation grandfathered as CAR-CAO based on a CAR-145 should prepare a CAE which covers
Part A, Part B, Part C and Part E. To help the organisation in preparing the CAE based on existing
manual:
o A table comparing CAE with CAR-145 exposition is available in annex 4-2, and
o A detailed table of content of the CAE along with CAO requirements to be covered by each
section of the CAE is provided in AMC1 CAO.A.025.

The organisation should develop a CAE to account for CAMO.A.025. As long as the organisation is not fully
compliant with CAR-CAO, any non-compliance with CAO.A.025 should be classified as a transition finding except
when there is a non-compliance with 145.A.70 which should be classified i.a.w. relevant APM.

145.A.25 - Facilities CAO.A.030 – Facilities In case of non-compliance with CAO.A.030 or CAO.A.060(b)/(f), an oversight finding should be raised and
CAO.A.060(b)/(f) – Maintenance standards managed i.a.w. relevant APM.

145.A.30(a)/(b)/(d)/(e)/(f) - CAO.A.035 – Personnel requirements In case of non-compliance with CAO.A.035, an oversight finding should be raised and managed i.a.w. relevant
Personn APM.
el requirements
145.A.30(g)/(h)/(i)/(j)(3)/(j)(4)/(j)(5) – CAO.A.040(a)/(b)/(c) – Certifying staff In case of non-compliance with CAO.A.040 or CAO.A.060(a), an oversight finding should be raised and
Personnel requirements CAO.A.060(a) – Maintenance standards managed i.a.w. relevant APM.

Provisions given by 145.A.30(j)(1)/(j)(2) are not available in CAR-CAO.

145.A.35(j) – Certifying staff and CAO.A.040(d) – Certifying staff In case of non-compliance with CAO.A.040(d), an oversight finding should be raised and managed i.a.w. relevant
support staff APM.

31
Potential transition findings are identified in blue
CAR-145 requirement where CAR-CAO requirement Oversight policy to be applied to grandfathered CAR-CAO from 01 January 2025 to 30 June 2026
applicable
In CAR-CAO there is no “base” and “line” maintenance and therefore there is no “support staff” vs “certifying
staff”. As stated in CAO.A.040, Certifying staff shall exercise their privileges to release maintenance if the CAO has
ensured:

145.A.35(a)/(b)/(c)/(d)/(e)/(f)/(g)/(h)/(i)/(k  that these certifying staff meet the requirements of point (b) of point 66.A.20 or point 66.A.215 of CAR 66;
)/(l)/(m)/(n) – Certifying staff and N/A – No equivalent requirement in CAR-CAO  that these certifying staff have an adequate understanding of the relevant aircraft or aircraft component(s) to
support staff be maintained, or both, as well as of the organisation procedures required to perform such maintenance.

In case of open non-compliance against 145.A.35(a)(b)(c)(d)(e)(f)(g)(h)(i)(k)(l)(m)(n) when the organisation is

grandfathered as a CAR-CAO, compliance against CAO.A.040 should be evaluated and if the situation is
compliant with CAO.A.040, the finding should be cancelled.

CAO.A.050(a)/(b) – Components, equipment In case of non-compliance with CAO.A.050(a)/(b) or CAO.A.060(d), an oversight finding should be raised and
145.A.40 – Equipment and tools and tools managed i.a.w. relevant APM.

CAO.A.060(d) – Maintenance standard

145.A.42 – Components CAO.A.050(c) – Components, equipment and In case of non-compliance with CAO.A.050(c), an oversight finding should be raised and managed i.a.w. relevant
tools APM.
In case of non-compliance with CAO.A.055(a) or CAO.A.060(c)/(e)/(j), an oversight finding should be raised and
145.A.45(a)/(b)/(e)/(f)/(g) – CAO.A.055(a)/(b) – Maintenance data and managed i.a.w. relevant APM.
Maintenance data work orders  145.A.45(b) requirement are applicable to CAR-CAO organisation through a reference to M.A.401 and
145.A.48(d) – Performance of CAO.A.060(c)/(e)/(j) – Maintenance standard ML.A.401.
maintenance  There is no requirement equivalent to 145.A.45(c)/(d) in CAR-CAO

145.A.45(c)/(d) – Maintenance data N/A – No equivalent requirement in CAR-CAO Open findings against 145.A.45(c)(d) at the time of grandfathering should be cancelled.
145.A.65(b)(1) – Safety and quality
policy, maintenance procedures and CAO.A.055(b) – Maintenance data and work In case of non-compliance with CAO.A.055(b), an oversight finding should be raised and managed i.a.w. relevant
quality system orders APM.

There is no requirement to produce and maintain a production planning as required by 145.A.47 in CAR-CAO.
145.A.47 – Production planning N/A – No equivalent requirement in CAR-CAO However; as mention in CAO.A.035(d), the CAO shall demonstrate having sufficient appropriately qualified staff
for it to be able to carry out the planned work

145.A.48(a)/(b)/(c) – Performance of CAO.A.060(g)/(h)/(i) – Maintenance standards In case of non-compliance with CAO.A.060(g)/(h)/(i), an oversight finding should be raised and managed i.a.w.
maintenance relevant APM.

In case of non-compliance with CAO.A.065, an oversight finding should be raised and managed i.a.w. relevant
145.A.50(a)/(b)/(c)/(e)/(f) – Certification APM.
of maintenance CAO.A.065 – Aircraft certificate of release to
service Aircraft release to service requirement are different in CAR-CAO compared to CAR-145 (no need of “C” licensed
staff, no difference between “base” and “line” maintenance, etc. Even if the organisation complies with CAR-145
and CAO.A.065, the release to service procedure needs to be amended to account for these changes.
145.A.50(d) – Certification of CAO.A.070 – Component certificate of release In case of non-compliance with CAO.A.070, an oversight finding should be raised and managed i.a.w. relevant
maintenance to service APM.

32
Potential transition findings are identified in blue
CAR-145 requirement where CAR-CAO requirement Oversight policy to be applied to grandfathered CAR-CAO from 01 January 2025 to 30 June 2026
applicable
145.A.55 – Maintenance and CAO.A.090(a)(1)/(b)/(c)/(d)/(e)/(f)/(g)(1) – In case of non-compliance with CAO.A.090(a)(1)/(b)/(c)/(d)/(e)/(f)/(g)(1), an oversight finding should be raised
airworthiness review records Record-keeping and managed i.a.w. relevant APM.

145.A.75(a)/(b)/(c)/(d)/(e) – Privileges CAO.A.095(a)(1)/(a)(2)/(a)(3)/(a)(4) – Privileges In case of non-compliance with CAO.A.095(a)(1)/(a)(2)/(a)(3)/(a)(4), an oversight finding should be raised and
of the organisation of the organisation managed i.a.w. relevant APM.

In case of non-compliance with CAO.A.100, an oversight finding should be raised and managed i.a.w. relevant
APM.
145.A.65(a)/(b)(2) – Safety and quality CAO.A.100 – Quality system and
policy, maintenance procedures and organisational review A CAR-CAO can elect to replace its quality system by an organisational review when one of the following
quality system condition is met:
 The scope of the CAO does only contain aircraft covered by CAR-ML
 The CAO does not exceed 10 full-time equivalent staff involved in maintenance
 The CAO does not exceed 5 full-time equivalent staff involved in continuing airworthiness management
Potential transition finding: “Due to on-going transition from CAR-145 to CAR-CAO, current exposition does
not contain necessary provisions to address CAO.A.105 requirements”.

As opposed to CAR-145 where approval of the exposition can optionally be performed through indirect
145.A.85 – Changes to the approved approvals, CAR-CAO mandate the organisation to have a procedure to address changes not requiring prior
continuing airworthiness organisation CAO.A.105 – Changes to the organisation approval.

Changes not requiring prior approval will be managed as agreed between the organisation and DGCA. The
organisation should develop a procedure to account for CAO.A.105 before 30 June 2026.

Until the organisation is fully compliant with CAR-CAO, changes to the organisation should be managed i.a.w.
the organisation current approved procedure. As a result, in case of non compliance with 145.A.85 and/or with
the current procedure in place within the organisation, an oversight finding should be raised and managed i.a.w.
relevant APM.
145.A.90 – Continued validity of approval CAO.A.110 – Continued validity Minor changes are made to update references and for consistency throughout the new CAR-CAO.
In case of non-compliance with CAO.A.110, an oversight finding should be raised and managed i.a.w. relevant
APM.
145.A.95 - Findings CAO.A.115 – Findings In case of non-compliance with CAO.A.115, an oversight finding should be raised and managed i.a.w. relevant
APM.

33
 Appendix VI — Comparison CAE with CAR-145 MOE

Chapter Description CAR reference MOE MOE chapter description

chapter
PART A – GENERAL DESCRIPTION
A.1 Statement by accountable manager CAO.A.025(a)(1); 1.1 Corporate commitment by the accountable manager
CAO.A.035(a)
A.2 General presentation of the organisation CAO.A.035(a); 0 GENERAL ORGANISATION (Operators within the
CAO.A.100(e) European Union)
A.3 Description and location of the facilities CAO.A.025(a)(9); 1.8 General description of the facilities at each address
CAO.A.030 intended to be approved
5.3 List of Line maintenance locations as per 145.A.75(d)
A.4 Scope of work CAO.A.020(a); 1.9 Organisations intended scope of work
CAO.A.025(a)(2);
CAO.A.095(e); Appendix
I point (a)
A.5 Exposition amendments and changes to the CAO.A.025(a)(11)/(c); 1.10 Notification procedure to DGCA regarding changes to the
organisation CAO.A.105 organisation’s activities/approval/location/personnel

1.11 Exposition amendment procedures including, if

applicable, delegated procedures
A.6 Reserved
A.7 Management personnel CAO.A.025(a)(3); 1.3 Management personnel
CAO.A.035(b); 1.4 Duties and responsibilities of the management personnel
CAO.A.100(a)
A.8 Organisation chart CAO.A.025(a)(4) 1.5 Management organisation chart
A.9 Manpower resources CAO.A.035(d) 1.7 Manpower resources
2.22* Control of manhour planning versus scheduled
maintenance work
2.28* Production planning procedures
A.10 List of certifying staff CAO.A.025(a)(5) 1.6 List of certifying staff, support staff and airworthiness
review staff
A.11 Reserved

34
Chapter Description CAR reference MOE MOE chapter description
chapter
A.12 Reserved

A.13 Reserved

PART B – GENERAL PROCEDURES

B.1 Quality (or organisational review) system CAO.A.100(a)/(b)/(d)/(e) 1.2* Safety and quality policy
/(f) 3.3 Quality audit remedial action procedure
3.10 Concession control for deviation from organisations’
procedures
3.12 Control of manufacturers’ and other maintenance working
teams
B.2 Audit plan (or frequency and content of CAO.A.100(b)/(f) 3.1 Quality audit of organisation procedures
organisational review) 3.2 Quality audit of aircraft
B.3 Monitoring of maintenance contracts CAO.A.100(b)(2) 2.10 Aircraft maintenance programme compliance
2.11 Airworthiness directives procedure
3.9 Aircraft or aircraft component maintenance tasks
exemption process control
B.4 Qualification, assessment and training of staff CAO.A.035(c)/(d)/(e)/(f); 3.4 Certifying staff and support staff qualification and training
CAO.A.040(a); procedures
CAO.A.060(a) 3.6 Quality audit personnel
3.7 Qualifying inspectors
3.8 Qualifying mechanics
3.11 Qualification procedure for specialised activities such as
NDT welding, etc.
3.13* Human factors training procedure
3.14 Competence assessment of personnel
3.15 Training procedures for on-the-job training as per Section
6 of Appendix III to CAR-66
3.16 Procedure for the issue of a recommendation to DGCA
for the issue of a CAR-66 licence in accordance with

35
Chapter Description CAR reference MOE MOE chapter description
chapter
66.B.105 of APM Part II Chapter 17.

B.5 One-off certification authorisation CAO.A.040(b)

B.6 Limited certification authorisation CAO.A.040(c)
B.7 Subcontracting CAO.A.095(a)(2)/(b)(3); 2.1 Supplier evaluation and subcontract control procedure
CAO.A.100(f)
B.8 Maintenance data and continuing CAO.A.055(a); 2.8 Maintenance instructions and relationship to aircraft/
airworthiness management data CAO.A.080 aircraft component manufacturers’ instructions including
updating and availability to staff
2.13 Maintenance documentation in use and its completion
2.27 Procedures for notification of maintenance data
inaccuracies and ambiguities, to the type certificate
holder
B.9 Records management and retention CAO.A.035(e); 2.13 Maintenance documentation in use and its completion
CAO.A.040(d); 2.14 Technical record control
CAO.A.050(b);
2.17 Records for the operator
CAO.A.060(j);
CAO.A.075(a)/(b)(9); 2.21 Control of computer maintenance record systems
CAO.A.090; 2.29 Airworthiness review procedures and records for ELA1
CAO.A.100(c); aircraft not involved in commercial operations
L2.4 Line procedure for completion of technical log
3.5 Certifying staff and support staff records
4.2 Operator procedures and paperwork
4.3 Operator record completion
6 OPERATORS MAINTENANCE PROCEDURES
B.10 Reserved
B.11 Reserved
B.12 Reserved
PART C – MAINTENANCE PROCEDURES
C.1 Maintenance - general CAO.A.025(10) 2.26* Shift/task handover procedures
3.12 Control of manufacturers’ and other maintenance working
teams

36
Chapter Description CAR reference MOE MOE chapter description
chapter
C.2 Work order acceptance CAO.A.055(b) 4.1 Contracting operators
6 OPERATORS MAINTENANCE PROCEDURES
C.3 Components, equipment, tools and material CAO.A.050; 2.1 Supplier evaluation and subcontract control procedure
(supply, acceptance, segregation, storage, CAO.A.060(d); 2.2 Acceptance/inspection of aircraft components and
calibration…) CAO.A.030(b) material
from outside contractors
2.3 Storage, tagging and release of aircraft components and
material to aircraft maintenance
2.4 Acceptance of tools and equipment
2.5 Calibration of tools and equipment
2.19 Return of defective aircraft components to store
2.20 Defective components to outside contractors
L2.1 Line maintenance control of aircraft components, tools,
equipment, etc.
L2.5 Line procedure for pooled parts and loan parts
L2.6 Line procedure for return of defective parts removed from
aircraft
C.4 Maintenance facility (selection, organisation, CAO.A.060(b)/(e)/(f) 2.7 Cleanliness standards of maintenance facilities
cleanliness and environmental limitations)
C.5 Maintenance accomplishment and CAO.A.095(a)(1); 2.6 Use of tooling and equipment by staff (including alternate
maintenance standards CAO.A.060(c); Appendix tools)
I points (b)/(c)/(d) 2.9 Repair procedure
2.10 Aircraft maintenance programme compliance
2.11 Airworthiness directives procedure
2.12 Optional modification procedure
2.16 Release to service procedure
C.6 Prevention of maintenance error CAO.A.060(g)/(i) 2.25 Procedures to detect and rectify maintenance errors.
C.7 Critical maintenance tasks and error- CAO.A.060(h) 2.23 Critical maintenance tasks and error-capturing methods
capturing method L2.7 Line procedure for critical maintenance tasks and error-
capturing methods
C.8 Fabrication CAO.A.020(c)
C.9 Certifying staff responsibilities and 2.11 Airworthiness directives procedure
maintenance release 2.16 Release to service procedure

37
Chapter Description CAR reference MOE MOE chapter description
chapter
CAO.A.040(a); L2.4 Line procedure for completion of technical log
CAO.A.065; 4.2 Operator procedures and paperwork
CAO.A.070;
CAO.A.095(a)(4) 6 OPERATORS MAINTENANCE PROCEDURES
C.10 Defects arising during maintenance CAO.A.075(b)(6) 2.15 Rectification of defects arising during base maintenance
2.18 Reporting of defects to DGCA / operator / manufacturer

L2.3 Line maintenance control of defects and repetitive defects

C.11 Maintenance away from approved location CAO.A.095(a)(3)
C.12 Procedure for component maintenance under Appendix I point (b)/(c)
aircraft or engine rating
C.13 Procedure for maintenance on installed engine Appendix I point (c)/(d)
(or component) under engine (or component)
rating
C.14 Special procedures (specialised tasks, NDT, CAO.A.030(a); 2.9 Repair procedure
engine running…) Appendix I point (e) 2.24 Reference to specific maintenance procedures such as -
— Engine running procedures
— Aircraft pressure run procedures
— Aircraft towing procedures
— Aircraft taxiing procedures
L2.2 Line maintenance procedures related to
servicing/fuelling/de- icing, including inspection
for/removal of de-icing/anti-icing fluid residues, etc.
PART E – SUPPORTING DOCUMENTS

E.1 Sample documents 5.1 Sample of documents

2.13 Maintenance documentation in use and its completion
E.2 List of subcontracted organisations 5.2 List of Subcontractors as per 145.A.75(b)
E.3 List of organisation contracted by the CAO 5.4 List of contracted organisations as per 145.A.70(a)(16)
E.4 Aircraft technical log system (if applicable)
E.5 Reserved

38
 Chapter Description CAR reference MOE MOE chapter description
chapter
E.6 Copy of contracts for subcontracted
continuing airworthiness tasks

*: these elements are not explicitly required by CAR-CAO, but if associated procedures already exist in the organisation that transitions to CAR-
CAO, it is recommended to integrate them in the CAE under the chapter indicated.

39
 Appendix VII — Comparison CAE with CAR-MF MOM (small organisation)

Chapter Description CAR reference MOM MOM (small org.) chapter description
(small (Appendix IV to AMC M.A.604)
org.
Chapter)
PART A – GENERAL DESCRIPTION
A.1 Statement by accountable manager CAO.A.025(a)(1); Part A Accountable manager statement
CAO.A.035(a)
A.2 General presentation of the organisation CAO.A.035(a); Part B Description
CAO.A.100(e) — General presentation of the organisation
A.3 Description and location of the facilities CAO.A.025(a)(9); Part B Description
CAO.A.030 — Organisation’s scope of work
— Identification of the level of work which can be
performed at each facility.
— General description of the facility
Part E Appendices
— List of maintenance locations.
A.4 Scope of work CAO.A.020(a); Part B Description
CAO.A.025(a)(2); — Organisation’s scope of work
CAO.A.095(c);
Appendix I point (a)
A.5 Exposition amendments and changes to the CAO.A.025(a)(11)/(c); Part A Amendment procedure
organisation CAO.A.105 Part D Working Procedures
— Management of indirect approval of the manual

A.6 Reserved
A.7 Management personnel CAO.A.025(a)(3); Part B Description
CAO.A.035(b); — Name and title of management personnel
CAO.A.100(a)
A.8 Organisation chart CAO.A.025(a)(4) Part B Description
— Organisation chart
A.9 Manpower resources CAO.A.035(d) Part B Description

40
Chapter Description CAR reference MOM MOM (small org.) chapter description
(small (Appendix IV to AMC M.A.604)
org.
Chapter)
— Personnel
— Technical personnel (number, qualifications and
experience)
— Administrative personnel (number)
A.10 List of certifying staff CAO.A.025(a)(5) Part B Description
— Certifying staff and airworthiness review staff
A.11 Reserved
A.12 Reserved

A.13 Reserved

PART B – GENERAL PROCEDURES

B.1 Quality (or organisational review) system CAO.A.100(a)/(b)/(d)/(e Part C General Procedures
) — Organisational review
/(f)
B.2 Audit plan (or frequency and content of CAO.A.100(b)/(f) Part C General Procedures
organisational review) — Organisational review
— Organisation, frequency, scope and content
(including
processing of authority’s findings)
— Planning and performance of the review
B.3 Monitoring of maintenance contracts CAO.A.100(b)(2)
B.4 Qualification, assessment and training of staff CAO.A.035(c)/(d)/(e)/(f); Part B Description
CAO.A.040(a); — Personnel
CAO.A.060(a) — Technical personnel (number, qualifications and
experience)
Part C General Procedures
— Training
B.5 One-off certification authorisation CAO.A.040(b) Part C General Procedures
— One time authorisations
B.6 Limited certification authorisation CAO.A.040(c)

41
B.7 Subcontracting CAO.A.095(a)(2)/(b)(3); Part C General Procedures
CAO.A.100(f) — Training

42
Chapter Description CAR reference MOM MOM (small org.) chapter description
(small (Appendix IV to AMC M.A.604)
org.
Chapter)
B.8 Maintenance data and continuing CAO.A.055(a); Part C General Procedures
airworthiness management data CAO.A.080 — Subcontracting of specialised services
B.9 Records management and retention CAO.A.035(e); Part D Working Procedures
CAO.A.040(d); — Records
CAO.A.050(b);
CAO.A.060(j);
CAO.A.075(a)/(b)(9);
CAO.A.090;
CAO.A.100(c)
B.10 Reserved
B.11 Reserved
B.12 Reserved

PART C – MAINTENANCE PROCEDURES

C.1 Maintenance - general CAO.A.025(10) Part D Working Procedures
— Occurrence reporting

C.2 Work order acceptance CAO.A.055(b) Part D Working Procedures

— Work order acceptance
— Preparation and issue of the work package
— Control of the work order
C.3 Components, equipment, tools and material CAO.A.050; Part B Description
(supply, acceptance, segregation, storage, CAO.A.060(d); — Tools, equipment and material
calibration…) CAO.A.030(b) Part D Working Procedures
— Logistics
— Execution
— Procedures for accepting components from stores
including eligibility check

43
Chapter Description CAR reference MOM MOM (small org.) chapter description
(small (Appendix IV to AMC M.A.604)
org.
Chapter)
— Procedures for returning unserviceable components
to stores
C.4 Maintenance facility (selection, organisation, CAO.A.060(b)/(e)/(f)
cleanliness and environmental limitations)
C.5 Maintenance accomplishment and CAO.A.095(a)(1); Part D Working Procedures
maintenance standards CAO.A.060(c); — Preparation and issue of the work package
Appendix I points — Preparation of the planned work
(b)/(c)/(d) — Work package content (copy of forms, work
cards, procedure for their use, distribution)
— Responsibilities and signatures needed for the
authorisation of the work
— Execution
C.6 Prevention of maintenance error CAO.A.060(g)/(i)
C.7 Critical maintenance tasks and error-capturing CAO.A.060(h)
method
C.8 Fabrication CAO.A.020(c)
C.9 Certifying staff responsibilities and CAO.A.040(a); Part D Working Procedures
maintenance release CAO.A.065; — Release to Service – Certifying staff
CAO.A.070; — Release to Service – Supervision
CAO.A.095(a)(4) — Release to Service – Certificate of release to service
C.10 Defects arising during maintenance CAO.A.075(b)(6)
C.11 Maintenance away from approved location CAO.A.095(a)(3)
C.12 Procedure for component maintenance under Appendix I point (b)/(c)
aircraft or engine rating
C.13 Procedure for maintenance on installed Appendix I point (c)/(d)
engine (or component) under engine (or
component) rating
C.14 Special procedures (specialised tasks, NDT, CAO.A.030(a); Part D Working Procedures
engine running…) Appendix I point (e) — Special procedures
C.15 Reserved
PART E – SUPPORTING DOCUMENTS
E.1 Sample documents Part E Appendices

44
Chapter Description CAR reference MOM MOM (small org.) chapter description
(small (Appendix IV to AMC M.A.604)
org.
Chapter)
— Sample of all documents used
E.2 List of subcontracted organisations Part E Appendices
— List of subcontracted specialised services
E.3 List of organisation contracted by the CAO Part E Appendices
— List of Part-145 or M.A. Subpart F organisations
E.4 Aircraft technical log system (if applicable)
E.5 Reserved

E.6 Copy of contracts for subcontracted

continuing airworthiness tasks

45
 Appendix VIII — Comparison CAE with CAR-MG CAME

Chapter Description CAR reference CAME CAME description (Appendix V to AMC M.A.704)
chapter
PART A – GENERAL DESCRIPTION
A.1 Statement by accountable manager CAO.A.025(a)(1) 0.1 Corporate commitment by the accountable manager
; CAO.A.035(a)
A.2 General presentation of the organisation CAO.A.035(a); 0.2 General information
CAO.A.100(e)
A.3 Description and location of the facilities CAO.A.025(a)(9); 0.2 General information
CAO.A.030
A.4 Scope of work CAO.A.020(a); General information - Scope of work — Aircraft
CAO.A.025(a)(2); 0.2(c) managed
CAO.A.095(c);
Appendix I point
(a)
A.5 Exposition amendments and changes to the CAO.A.020(a)(1) 0.5 Procedure to notify DGCA of changes to the
organisation & (2); organisation’s activities/ approval/ location/ personnel
CAO.A.025(a)(11 0.6 Exposition amendment procedures
)/(c); CAO.A.105
A.6 Reserved
A.7 Management personnel CAO.A.025(a)(3); 0.3 Management personnel
CAO.A.035(b);
CAO.A.100(a)
A.8 Organisation chart CAO.A.025(a)(4) 0.4 Management organisation chart
A.9 Manpower resources CAO.A.035(d) 0.3(e)(1) Management personnel - Manpower resources
A.11 Reserved
A.12 Reserved
A.13 Reserved
PART B – GENERAL PROCEDURES

46
Chapter Description CAR reference CAME CAME description (Appendix V to AMC M.A.704)
chapter
B.1 Quality (or organisational review) system CAO.A.100(a)/(b) 2.1 Continuing airworthiness quality policy, plan and audit
/(d)/(e)/(f) procedure
2.2 Monitoring of continuing airworthiness management
activities
2.3 Monitoring of the effectiveness of the maintenance
programme(s)
2.4 Monitoring that all maintenance is carried out by an
appropriate maintenance organisation
B.2 Audit plan (or frequency and content of organisational CAO.A.100(b)/(f) 2.1 Continuing airworthiness quality policy, plan and audit
review) procedure
B.3 Monitoring of maintenance contracts CAO.A.100(b)(2) 2.5 Monitoring that all contracted maintenance is carried
out in accordance with the contract, including
subcontractors used by the maintenance contractor
B.4 Qualification, assessment and training of staff CAO.A.035(c)/(d) 2.6 Quality audit personnel
/(e)/(f); 4.1 Airworthiness review staff
CAO.A.040(a);
CAO.A.060(a)
B.7 Subcontracting CAO.A.095(a)(2)/ 2.2 Monitoring of continuing airworthiness management
(b)(3); activities
CAO.A.100(f)
B.8 Maintenance data and continuing airworthiness CAO.A.055(a);
management data CAO.A.080
B.9 Records management and retention CAO.A.035(e); 1.3 Time and continuing airworthiness records,
CAO.A.040(d); responsibilities, retention and access
CAO.A.050(b); 4.2 Review of aircraft records
CAO.A.060(j);
CAO.A.075(a)/(b) 4.7 Airworthiness review records, responsibilities, retention
(9); CAO.A.090; and access
CAO.A.100(c); 1.1 Aircraft continuing airworthiness record system
utilisation
B.10 Reserved

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Chapter Description CAR reference CAME CAME description (Appendix V to AMC M.A.704)
chapter

B.11 Reserved
B.12 Reserved

PART D – CONTINUING AIRWORTHINESS MANAGEMENT PROCEDURES

D.1 Continuing airworthiness management - general CAO.A.025(10); 1.9 Engineering activity
CAO.A.095(b)(1);
CAO.A.075(a)/(b)
(7)/(b)(9)
D.2 MEL (and CDL) application CAO.A.075(a) 1.1 Aircraft technical log utilisation and MEL application

D.3 AMP development, control and periodic review CAO.A.075(a)/(b) 1.2 Aircraft maintenance programmes — development
(1)/(b)(2) amendment and approval
1.5 Analysis of the effectiveness of the maintenance
programme(s)
1.10 Reliability programmes
D.4 Airworthiness directives and other mandatory CAO.A.075(a)/(b) 1.4 Accomplishment and control of airworthiness directives
airworthiness requirements (5)/(b)(8)
D.5 Modifications and repairs CAO.A.075(b)(3) 1.6 * Non-mandatory modification embodiment policy
1.7 Major repair and modification standards
D.6 Pre-flight inspection CAO.A.075(a) 1.11 Pre-flight inspections
D.7 Defects CAO.A.075(b)(6) 1.8 Defect reports
D.8 Establishment of contracts and work orders for the CAO.A.075(a)/(b) 3.1 Maintenance contractor selection procedure
maintenance (4)/(b)(7)
D.9 Coordination of maintenance activities CAO.A.075(b)(8) 2.4 Monitoring that all maintenance is carried out by an
appropriate maintenance organisation
2.5 Monitoring that all contracted maintenance is carried
out in accordance with the contract, including
subcontractors used by the maintenance contractor
D.10 Mass and balance statement CAO.A.075(a)/(b) 1.12 Aircraft weighing
( 10)
D.11 Reserved

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 Chapter Description CAR reference CAME CAME description (Appendix V to AMC M.A.704)
chapter

D.12 Reserved
D.13 Maintenance check flights CAO.A.075(a) 1.13 Check flight procedures
PART E – SUPPORTING DOCUMENTS
E.1 Sample documents 5.1 Sample documents
E.2 List of subcontracted organisations 5.3 List of subcontractors as per M.A.711(a)(3)

E.3 List of organisation contracted by the CAO 5.4 List of contracted approved maintenance organisations
E.4 Aircraft technical log system (if applicable) 1.1 Aircraft technical log utilisation and MEL application
E.5 Reserved
E.6 Copy of contracts for subcontracted continuing 5.5 Copy of contracts for subcontracted work (Appendix II
airworthiness tasks to AMC M.A.711(a)(3))

*: these elements are not explicitly required by CAR-CAO, but if associated procedures/document already exist in the organisation that transitions
to CAR-CAO, it is recommended to integrate them in the CAE under the chapter indicated.

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 Appendix IX — Amending CAME from CAR-MG to CAR-CAMO

The text of this appendix is arranged to show deleted text, new or amended text as shown below, to revise an existing CAR-MG exposition with
the objective to show compliance with CAR-CAMO.
 deleted text is struck through;
 new or amended text is highlighted in blue.

Part 0 General organisation, safety policy and objectives

0.1 Safety policy, objectives and Corporate commitment by the accountable manager statement
0.2 General information and scope of work
0.3 Management personnel
0.4 Management organisation chart
0.5 Procedure for changes requiring prior approval to notify DGCA of changes to the organisation’s activities/ approval/ location/ personnel
0.6 Procedure for changes not requiring prior approval Exposition amendment procedures
0.7 Reserved
Part 1 Continuing airworthiness management procedures
1.1a Use of aircraft continuing airworthiness record system and if applicable, aircraft technical log (ATL) system utilisation and MEL application
Aircraft continuing airworthiness record system utilisation
1.1b MEL application
1.2 Aircraft maintenance programmes (AMP) — development amendment and approval
1.3 Time and Continuing airworthiness records, responsibilities, retention and access
1.4 Accomplishment and control of airworthiness directives
1.5 Analysis of the effectiveness of the maintenance programme(s)
1.6 Non-mandatory modification and inspections embodiment policy
1.7 Major Repairs and modifications standards
1.8 Defect reports
1.9 Engineering activity
1.10 Reliability programmes
1.11 Pre-flight inspections
1.12 Aircraft weighing
1.13 Maintenance check flight procedures
Part 2 Quality system Management system procedures
2.1 Hazard identification and safety risk management schemes
2.2 Internal safety reporting and investigations
2.3 Safety action planning
2.4 Safety performance monitoring
2.5 Change management

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2.6 Safety training and promotion
2.7 Immediate safety action and coordination with operator’s emergency response plan (ERP)
2.8 Compliance monitoring
2.8.1 Continuing airworthiness quality policy, Audit plan and audit procedure
2.8.2 Monitoring of continuing airworthiness management activities
2.8.3 Monitoring of the effectiveness of the maintenance programme(s)
2.8.4 Monitoring that all maintenance is carried out by an appropriate maintenance organisation
2.8.5 Monitoring that all contracted maintenance is carried out in accordance with the contract, including subcontractors used by the maintenance
contractor
2.8.6 Compliance monitoring Quality audit personnel
2.9 Control of personnel competency
2.10 Management system record-keeping
2.11 Occurrence reporting
Part 3 Contracted maintenance — management of maintenance
3.1 Maintenance contractor selection procedure
3.2 Quality Product audit of aircraft
Part 4 Airworthiness review procedures
4.1 Airworthiness review staff
4.2 Documented review of aircraft records
4.3 Physical survey
4.4 Additional procedures for recommendations to DGCA for the import of aircraft
4.5 ARC Recommendations to DGCA for the issue of ARC
4.6 Issue of ARC
4.7 Airworthiness review records, responsibilities, retention and access
4.8 ARC extension
Part 4B Special flight permit procedures
4B.1 Conformity with approved flight conditions
4B.2 Issue of the special flight permit
4B.3 Reserved
4B.4 Interface with the DGCA for the flight
4B.5 Special Flight permit records, responsibilities, retention and access.
Part 5 Appendices Supporting documents
5.1 Sample documents, including the template of the ATL system
5.2 List of airworthiness review staff
5.3 List of subcontractors as per point M.A.711(a)(3) CAMO.A.125(d)(3)
5.4 List of contracted approved maintenance organisations and list of maintenance contracts as per point CAMO.A.300(a)(13)

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5.5 Copy of contracts for subcontracted work (Appendix II to AMC1 CAMO.A.125(d)(3) AMC M.A.711(a)(3))
5.6 List of approved maintenance programme as per CAMO.A.300(a)(12)
5.7 Reserved

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