Repairs and alterations
Tracing repair and alteration approvals through the data-room package
Every repair on an airframe carries a question: what approved data supports it, and where is the disposition record. This review answers both from the seller's data room, matching each entry on the repair map to the engineering approval, approved data reference, and closing documentation behind it. Diligence teams run it in the pre-purchase or pre-lease window, with structural and major repairs taken first. Unsupported repairs come back as exception entries stating what evidence is absent, ready to drop into the diligence exception schedule.
When this review is needed
- The dent and buckle chart or repair map lists entries whose substantiation has never been pulled.
- Major structural repairs appear in the history and the deal model assumes they are fully approved.
- An STC or alteration is installed and its approved data trail in the room is unclear.
- The counterparty's own reviewers will read the repair file next, and unpriced findings would be theirs.
The problem
Repair records decay differently from status lists: the repair stays visible on the airframe and its chart forever, while the pages of approval and disposition behind it scatter across the shop that did it, the engineering organization that approved it, and whichever operator held the aircraft at the time. Data rooms reliably contain the chart. What varies is how much of the substantiation made it in, and the difference is invisible until each entry is traced.
What gets reviewed
- The repair map or dent and buckle chart reconciled to the repairs the records describe
- Each mapped repair matched to its approved data basis: SRM reference, engineering order, or approval document
- Major repairs checked for the classification and disposition record the regime requires
- Alterations and STC installations traced to their approval and instructions for continued airworthiness
- Repair dispositions read for completeness: findings, method, inspection, and sign-off
- Chart entries without records, and recorded repairs missing from the chart, both directions
Scope this review
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What gets validated
- Every mapped entry cites an approved data basis appropriate to the repair's classification
- Major repair dispositions include the approval instrument the jurisdiction expected at the time
- Alteration entries connect to ICA where the modification generates continuing requirements
- Repair locations, dimensions, and descriptions agree between chart, records, and approval data
- No open repair assessment or interim disposition is silently carried as a closed item
Evidence normally required
- The repair map, dent and buckle chart, or equivalent structural summary
- Data-room access including heavy-check packages and engineering approvals
- STC and modification lists with associated documentation
- Utilization and check history to place repairs in time
Common discrepancies
- Chart entries whose only record is the chart itself, with no disposition anywhere in the room
- Repairs performed to superseded SRM revisions without evidence of later reassessment
- Major repairs carrying operator-level sign-offs where the regime required an approval instrument
- An STC installed with the certificate present but the ICA and flight-manual supplement absent
What is at stake
A repair without approved data is a permanent question mark on the airframe that resurfaces at every heavy check and every transaction, and regulators or receiving CAMOs can require re-substantiation or rework on the buyer's account. Alterations without their approval trail can also constrain the aircraft's transfer to another registry until resolved.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Consolidate the map
Merge chart, records mentions, and check findings into one repair inventory to trace.
Trace substantiation
Match each inventory entry to approved data and disposition evidence in the room.
Judge by era and regime
Apply the approval standard that governed when and where each repair was done.
Price and route
Deliver the substantiation table, exception entries, and the seller-curable cure list.
What the buyer receives
- A repair-by-repair substantiation table across chart, records, and approvals
- Exception entries naming the missing instrument or data for each unsupported repair
- A prioritized cure list separating seller-curable items from permanent open questions
Who uses the output
- The transaction lead pricing repair exceptions into the deal
- Technical due diligence staff sequencing seller demands before the window closes
- The buyer's future CAMO or records team inheriting the open items knowingly
How the work fits into the transaction or program
Repair substantiation closes the structural chapter of data-room diligence, alongside the release-document and LLP workstreams that share its shop-visit sources. Its exception table shapes the schedule, and its cure list becomes the post-closing action plan for whichever items the seller cannot resolve in time.
Jurisdiction-specific considerations
Repair and alteration recording duties sit in 14 CFR Part 43 with retention under 91.417 on the FAA side, while EU 1321/2014 requires the continuing-airworthiness records to preserve repair status and approvals for EASA-managed aircraft. The approval instrument a major repair needed depends on the regime and era in which it was performed, so entries are judged against the rules of their time and place rather than today's.
Regulatory limits
The review reports documentary support for each repair, judged against stated criteria. It does not approve repairs, classify them on the authorities' behalf, or determine the aircraft's airworthiness, and it does not perform engineering assessment of repair adequacy.
What this review does not cover
- Physical survey of the airframe against the chart
- Engineering re-substantiation of unsupported repairs
- Regulatory applications or approvals for open alterations
Specific to this review
- The two-direction check matters: repairs visible in records but absent from the chart are as common as chart entries without records, and both become findings.
- Era judgment prevents false exceptions; a repair approved correctly under the rules of its day does not fail because today's process differs.
- Heavy-check packages are the richest recovery source for missing dispositions, since shops filed repair paperwork inside the check that found the damage.
- Alteration gaps travel worse than repair gaps at registry changes, because the receiving authority must find an approval basis it recognizes before accepting the aircraft.
Sources
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.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
Frequently asked questions
The seller says all repairs were done by approved organizations. Does that settle it?
It settles who performed the work, nothing further. An approved organization can still repair against data that was never approved for that application, and the record of the disposition can still be missing from the room. The buyer inherits the repair, so the buyer's file needs the substantiation, whoever performed it.
Relevant glossary terms
Related pages
Where this fits
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