AD compliance evidence
Fixing AD closures that lack accomplishment evidence
An unsupported AD closure is a status line that says complied with, backed by nothing the operator can produce. This remediation recovers the substantiation: the work order, task card, or log entry showing what was done, when, at what times and cycles, and under which method of compliance. It is run for operators after an audit, diligence pass, or authority inquiry has flagged specific ADs, and it treats each one individually because a recurring inspection, a terminating action, and a one-time modification each close on different evidence. Maintenance leadership receives a substantiation file per AD and a corrected status entry where the record was wrong.
When this review is needed
- An auditor sampled the AD status list and asked for accomplishment evidence the operator could not produce.
- A prospective buyer's review flagged AD lines carried forward from a previous operator without source documents.
- The status list shows a recurring AD as terminated but no terminating-action record can be found.
- An authority inquiry names specific ADs and the response deadline will not wait for an open-ended archive search.
The problem
AD status lists migrate between systems and operators, and each migration copies conclusions without their evidence. A director of maintenance can inherit a list that has been marked complied with for a decade, only to find that the entries rest on a predecessor's spreadsheet rather than on work orders anyone retained. Under 14 CFR 39 the compliance obligation is absolute, so an entry that cannot be substantiated is indistinguishable, to an auditor, from work that was never done.
What gets reviewed
- Line-by-line examination of each flagged AD entry against the aircraft's actual applicability
- Retrieval of work orders, task cards, and log entries from the operator's archive and from performing organizations
- Verification that the recorded method of compliance matches one the AD permits, or an approved AMOC
- Confirmation of times, cycles, and dates of accomplishment against independent utilization records
- Reconstruction of recurring-inspection histories, including due-time recalculation where records were wrong
- Correction of the status list with an auditable change note for every amended entry
Scope this review
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What gets validated
- Applicability is confirmed by serial number and configuration before any effort goes into substantiating compliance
- Accomplishment evidence names the AD, the method, and the aircraft, rather than merely resembling the work
- Recorded compliance times and cycles reconcile with logbook utilization at the accomplishment date
- Terminating actions cited on the list are supported by the modification or inspection record that terminates recurrence
- AMOC references resolve to an approval actually issued to this operator or applicable to this aircraft
Evidence normally required
- The AD status list with the flagged entries identified
- Work-order and task-card archives for the periods in question
- Airframe and engine logbooks and utilization records
- Any AMOC approvals held by the operator or inherited with the aircraft
- Records correspondence from previous operators or the aircraft's delivery documentation
Common discrepancies
- The work order exists in an MRO's archive and was never returned to the operator's records set
- A method of compliance recorded on the list that the AD text does not actually offer
- Recurring inspections performed on time but logged against the wrong AD revision
- An entry inherited at delivery whose substantiation was never part of the delivery package at all
What is at stake
Unresolved, the exposure runs in two directions at once. If the work was done, the operator loses transactions and audit findings over paperwork it could have recovered. If the work was never done, the aircraft may be operating outside an AD, and every day the entry stands unexamined extends that possibility. Either way the status list stays untrustworthy, and every future review re-litigates the same lines.
Move from findings to resolution
Sequence the fixes and the documentation that closes each finding.
How the work runs
Confirm applicability
Screen each flagged AD against serial number and configuration; inapplicable entries close immediately with a documented basis.
Hunt the evidence
Search operator archives and request records from the organizations that performed the work.
Test the closure
Check recovered evidence for method, timing, and aircraft identity against the AD's actual requirements.
Correct and register
Amend the status list under change control and hand over the open-item register with recommendations.
What the buyer receives
- A substantiation file per AD containing the recovered accomplishment evidence
- A corrected AD status list with change notes documenting every amendment
- An open-item register for entries that remain unsupported, with the recommended action for each
- A summary suitable for an audit response or authority inquiry
Who uses the output
- The director of maintenance answering the auditor or authority who raised the finding
- CAMO staff maintaining the corrected status list going forward
- Transaction teams demonstrating AD compliance to a buyer or lessor
How the work fits into the transaction or program
This work sits between the finding and the response. An audit or diligence review identifies the unsupported lines; remediation converts them into substantiated entries or honestly open items; and whatever remains open feeds the operator's decision about re-accomplishment, which is a maintenance planning question rather than a records one.
Jurisdiction-specific considerations
FAA ADs bind under 14 CFR 39 and EASA ADs under the basic regulation, and an aircraft that has changed registries may owe its history to both systems, including foreign AD equivalents adopted at import. Evidence is judged against the directive that was in force when the work was done, so superseded ADs are substantiated under their contemporaneous text rather than today's revision.
Regulatory limits
This engagement gathers and evaluates compliance evidence. It does not perform AD work, approve an alternative method of compliance, or determine airworthiness; those decisions stay with the operator, approved maintenance organizations, and the authority.
What this review does not cover
Specific to this review
- A recurring AD marked terminated without a terminating-action record is a live compliance exposure, a different animal from a missing document on completed work.
- Recovering the work order sometimes creates a second finding, when the method actually used does not match anything the AD permits.
- Superseded ADs trip reviewers because compliance must be shown against the revision in force at accomplishment, not the current one.
- The cheapest closure is often re-inspection at the next scheduled visit, and knowing that early changes how hard anyone chases a twenty-year-old work order.
Sources
U.S. Government (eCFR). The legal basis for issuing and enforcing Airworthiness Directives on U.S.-registered products.
U.S. Government (eCFR). Records an owner or operator must keep, including total time in service, current status of life-limited parts, and AD compliance.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
Frequently asked questions
What happens when no evidence can be found at all?
The entry is reclassified from complied with to open, and the operator decides how to close it operationally, typically by re-accomplishing the inspection or verifying the modification physically at the next opportunity. That is a harder conversation than finding the paperwork, but it is a bounded one, and it ends with a status list that can survive the next audit.
Relevant glossary terms
Related pages
Where this fits
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