Airworthiness review records traced through the seller's data room

When this review is needed

• The current ARC is near expiry and the buyer must know whether the file supports a fresh review or an extension.
• A review report in the room lists findings whose closure evidence is scattered or absent.
• The aircraft moves between CAMO organizations at closing and the incoming CAMO will re-read this file first.
• Diligence has flagged the airworthiness review folder as thin and someone must establish what is genuinely missing.

The problem

Airworthiness review records rarely arrive as one document. A certificate sits in one folder, the review report in another, extension statements in email exports, and the open items raised by review staff live wherever the previous CAMO filed them. Sellers answer questions about the ARC by pointing at the certificate, which says nothing about whether the findings under it were ever closed. Someone has to walk the whole chain before the room shuts.

What gets reviewed

• Current airworthiness review certificate and any extensions, located and dated against each other
• Review report and staff recommendation traced to the certificate they produced
• Findings and observations from each review matched to closure evidence in the room
• Continuity of reviews across the period the data room claims to cover
• Eligibility of any extension against the conditions that permit one
• Q&A statements about review status reconciled with the uploaded documents

What gets validated

• Certificate dates, aircraft identity, and issuing organization agree with the review report behind them
• Every finding recorded at review has a disposition document, or is honestly logged as open
• Extension statements fall inside the windows and conditions that allow extension
• No period in the claimed review history is covered by neither a review nor a valid extension
• The organization that signed each review held the privilege to do so at that date

Evidence normally required

• Data-room access with the airworthiness review folder and the room's index export
• The current ARC and prior certificates for the period under diligence
• Review reports, staff recommendations, and finding logs as uploaded
• Extension statements and the correspondence that supports them
• The seller Q&A log where review status has been discussed

Common discrepancies

• A finding raised at the last review with no closure evidence anywhere in the room
• An extension taken outside its permitted window, quietly breaking the review chain
• Review reports uploaded without their attachments, so the certificate stands unsupported
• A gap between certificates that the seller's narrative covers and the documents do not

What is at stake

A buyer who accepts an unverified review file can discover after closing that the ARC rested on findings never dispositioned, or on an extension whose eligibility conditions were not met. The incoming CAMO then repeats work the seller's organization already did, the next review becomes a full records and physical exercise instead of a routine one, and the aircraft's availability plan absorbs the delay.

How the work runs

What the buyer receives

• Exception entries for the diligence schedule, each anchored to a folder path or Q&A row
• A review-chain timeline showing certificates, extensions, and any unsupported periods
• A prioritized request list the seller can act on while the room remains open

Who uses the output

• The incoming CAMO, which inherits this file at transfer and plans the next review from it
• Transaction managers pricing or conditioning the deal on review-file completeness
• Technical due diligence leads folding review findings into the overall asset report

How the work fits into the transaction or program

The airworthiness review file sits between the status lists and the raw maintenance evidence in any diligence read. This check draws on the same room as the AD, LLP, and binder reviews and shares its exception format with them, so the transaction lead negotiates from one consolidated schedule rather than parallel lists.

Jurisdiction-specific considerations

Under EASA rules the airworthiness review and its certificate follow Regulation 1321/2014, with defined extension conditions and CAMO privileges. On an FAA-registered aircraft there is no ARC equivalent, and the analogous confidence comes from inspection status and records kept under 14 CFR 91.417. Cross-registry deals need the file read against the regime it was created under, then assessed for what the receiving regime will ask.

Regulatory limits

This work evaluates documentation. It is not an airworthiness review, does not issue or extend a certificate, and does not decide continued airworthiness. Any formal review remains the task of an appropriately privileged organization after the transaction.

What this review does not cover

• Performing the next airworthiness review or physical survey
• CAMO transition management between seller and buyer organizations
• Negotiating which exceptions the purchase agreement absorbs

Specific to this review

• A valid-looking ARC can sit on a broken chain: one out-of-window extension years earlier means later certificates were issued against a flawed basis.
• Review findings are often closed operationally but never documented as closed, which reads the same as unresolved in a data room.
• The staff recommendation route and the direct-issue route leave different paper trails, and diligence has to know which one it is reading.
• Sellers frequently upload only the current certificate because that is what counterparties historically asked for; the report behind it is the document diligence actually needs.

Sources

Frequently asked questions

Relevant glossary terms

Related pages

Where this fits