AD compliance gap
Unsupported airworthiness directive (AD) closure
An unsupported AD closure is an airworthiness directive shown as complied with on the status list but without the accomplishment evidence, the method of compliance, or the recurring-action basis to back it. It is a problem for lessors, airlines, and MROs before a return, an induction, or an audit. The check reconciles each AD status against the source records that should prove it, including work cards, release entries, and the applicable method. You receive the ADs whose closure is unsupported, the evidence each one needs, and the path to recover or re-accomplish it.
When this review is needed
- A return condition requires the AD status to be supported by accomplishment evidence and the status report stands alone.
- An aircraft is inducted and the incoming operator must confirm every AD shown as closed is actually backed by a record.
- An audit or airworthiness review is approaching and an AD reads as complied with but the work card cannot be found.
- A recurring AD shows a one-time accomplishment with no recurring inspection or terminating action recorded.
The problem
AD status is produced by a tracking system that marks a directive closed once a code is entered, but the code is only as good as the record behind it. A directive can read as fully complied with while the accomplishment record, the method used, and the part-effectivity evidence are missing or do not match the method the AD actually calls for. A recurring AD can show a single sign-off with no recurring action, which leaves the aircraft exposed without the status list showing it.
What gets reviewed
- Each applicable AD against its accomplishment record and method of compliance
- The effectivity of each AD against the actual aircraft and engine configuration
- One-time versus recurring action, with the recurring basis and next-due where required
- Terminating actions and the modification or part change that satisfies them
- Alternative methods of compliance and the approval that authorized them
- Cross-reference between the AD status report and the source work cards and releases
Scope this review
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What gets validated
- Each AD shown as complied with has an accomplishment record that matches the method called for
- The AD applies to the actual configuration by part number, serial number, or modification state
- A recurring AD shows the recurring action and a correctly calculated next-due
- A terminating action is supported by the modification or part change that closes the AD
- An alternative method of compliance carries the approval that authorized its use
- The status-report code reconciles with the source work card and release entry
Evidence normally required
- Current AD status report for the airframe, engines, and components
- AD accomplishment records, work cards, and release entries
- Method-of-compliance and alternative-method documentation
- Configuration and modification status establishing AD effectivity
- Service-bulletin or part-change records cited as terminating actions
Common discrepancies
- An AD coded as closed with no accomplishment record behind the code
- Accomplishment recorded by a method other than the one the AD calls for
- A recurring AD with a one-time sign-off and no recurring action or next-due
- A terminating action claimed without the modification that actually closes the AD
- An AD marked not applicable on a configuration its effectivity does in fact cover
- An alternative method of compliance used without the approval that authorizes it
What is at stake
An AD whose closure cannot be supported may have to be re-accomplished, which is costly and can ground the aircraft until the work and its evidence are in place. At a return, an unsupported closure transfers that exposure to the party that accepted the aircraft, and a recurring AD missed because the status showed it closed is a continuing airworthiness failure rather than a paperwork gap.
Move from findings to resolution
Sequence the fixes and the documentation that closes each finding.
How the work runs
List applicable ADs
Establish the AD set that applies to the actual configuration by effectivity rather than the status report's list alone.
Test each closure
Match every AD shown as complied with to its accomplishment record and confirm the method matches the directive.
Check recurring and terminating actions
Confirm recurring ADs show the recurring action and next-due, and terminating actions show the modification that closes them.
Register and map closure
Record each unsupported AD, state the evidence it needs, and assign a recovery or re-accomplishment path.
What the buyer receives
- A register of ADs whose closure the records do not support, with the gap stated per directive
- The accomplishment evidence each unsupported AD requires to be closed properly
- A recommended path to recover the record or re-accomplish the action, with responsibility assigned
Who uses the output
- Continuing-airworthiness teams correcting the AD status against source evidence
- Quality staff preparing for an audit or airworthiness review
- Asset teams pricing AD exposure before a return or acquisition
How the work fits into the transaction or program
The review tests the AD status against the records that should prove it, so a tracking-system closure is never taken at face value. It feeds the discrepancy register and the redelivery binder, and it connects to the service-bulletin and modification status, since many ADs are closed by an embodiment recorded elsewhere.
Jurisdiction-specific considerations
An AD issued by the state of design is mirrored by the receiving authority, but the directive that governs and the method accepted can differ across the FAA and EASA systems. Where an aircraft crosses authorities, the closure is read against the AD the receiving registry enforces rather than the one the prior operator complied with.
Regulatory limits
The review confirms whether AD closures are supported by accomplishment evidence consistent with the method called for. It does not accomplish an AD, approve an alternative method, make an airworthiness determination, or certify compliance on the authority's behalf.
What this review does not cover
- Physical accomplishment or re-accomplishment of any AD
- Approval of an alternative method of compliance
- Any airworthiness determination or regulatory approval
Specific to this review
- A tracking-system closure code is only as good as the source record behind it, so a closed status is treated as a claim to be tested rather than a fact.
- A recurring AD recorded with a single sign-off is a continuing exposure, because the next-due inspection is the part most often dropped at a tracking change.
- A terminating action is checked against the actual modification or part change, since an AD closed by embodiment fails if the embodiment is not itself supported.
- An AD marked not applicable is verified against effectivity, because a wrong applicability call hides an open AD as effectively as a missing record.
Sources
U.S. Government (eCFR). The legal basis for issuing and enforcing Airworthiness Directives on U.S.-registered products.
U.S. Government (eCFR). Maintenance recordkeeping content and approval-for-return-to-service requirements, including 43.9, 43.11, and Appendix B.
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.
Federal Aviation Administration. FAA guidance on making and keeping maintenance records and acceptable recordkeeping practices.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
Frequently asked questions
Does an unsupported AD closure mean the AD was not accomplished?
Not necessarily. The work may have been done but the record lost or mismatched. The review distinguishes a documentation gap that can be recovered from a closure that has to be re-accomplished, since the cost and the exposure differ sharply.
How are recurring ADs handled?
A recurring AD is checked for both the initial accomplishment and the recurring action with a correctly calculated next-due. A one-time sign-off on a recurring directive is flagged, since the ongoing inspection is the part most often missing.
Relevant glossary terms
Related pages
Where this fits
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