Registry-change AD evidence
AD compliance status reviewed inside the import and export records package
Before an aircraft changes registry, its AD status list becomes an exhibit that the importing authority, the receiving CAMO, and the counterparty's diligence team will all read. This review tests the list against the records package assembled for the move, checking that each closure has accomplishment evidence, each recurring directive has a defensible next-due, and the importing registry's own directives have been assessed. Transition leads commission it while the export application and authority responses are in preparation. It returns an exception list keyed to the AD status list, ready for the authority-response evidence file.
When this review is needed
- The importing authority has asked for the AD status with substantiation and the package must answer without follow-up rounds.
- The status list came out of a maintenance system the receiving CAMO does not use and cannot independently query.
- Directives issued by the importing state have never been assessed because the aircraft always flew under the exporting registry.
- A pre-buy or lease negotiation runs in parallel, and both processes will cite the same list, so it has to be right once.
The problem
AD lists are system exports, and a system reflects what was entered rather than what was done. Closures inherited from prior operators arrive as single status lines, methods of compliance get recorded as an SB number without the terminating action being clear, and the importing registry's directives form a population nobody has been tracking because they never applied until now.
What gets reviewed
- Each closed AD on the status list traced to accomplishment evidence in the package
- Method of compliance checked for coherence: the cited SB, its revision, and its terminating or repetitive nature
- Recurring directives checked for interval basis, last-done evidence, and next-due arithmetic
- Applicability determinations sampled, including directives marked not applicable by configuration or serial range
- The importing registry's directive population screened against the aircraft, engines, and appliances
- AD lines reconciled with related package sections, such as modification status and component records
Scope this review
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What gets validated
- A closed AD cites the specific record, work order, or task card that accomplished it, and that record is in the package
- Not-applicable determinations state their basis and survive a check against the actual configuration records
- Repetitive AD next-dues reconstruct correctly from last-done dates and the utilization figures the package itself reports
- Terminating actions claimed through SB embodiment are supported by the embodiment record, at the SB revision that actually terminates
- Directives from the importing authority are dispositioned, even where the disposition is that assessment is pending
Evidence normally required
- The AD status list for airframe, engines, APU, and appliances
- Accomplishment records: task cards, work orders, and shop reports cited by closures
- Configuration, modification, and SB status data used for applicability calls
- The importing authority's directive listing or the means to derive it
- Utilization data current to the package date
Common discrepancies
- A closure inherited through two prior operators whose only evidence is its presence on earlier status lists
- An AD closed by SB embodiment where the record shows an earlier SB revision that does not terminate the directive
- Next-due values computed from a utilization snapshot months older than the one the package reports
- Importing-state directives on appliances, such as fire bottles or slides, that no one screened because airframe and engine lists got all the attention
What is at stake
One AD line the authority questions suspends the whole application while evidence is assembled, and every round-trip with an authority adds weeks. A recurring directive with an unsupportable next-due forces conservative re-inspection on the receiving side. Lines that fail in front of a counterparty get priced, and the price of an open AD is always set by the pessimistic reading.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Fix the list and its date
Take the status list at a defined data date and reconcile its utilization basis.
Trace closures and calls
Verify accomplishment evidence for closures and the basis behind each not-applicable determination.
Screen the importing registry
Run the importing authority's directive population against the aircraft and disposition each item.
Package the substantiation
Deliver the exception list and the substantiation index formatted for the authority response.
What the buyer receives
- An exception list keyed line by line to the AD status list, with the missing or defective evidence named
- A substantiation index the authority-response file can cite directly
- A screening summary for the importing registry's directives with dispositions and open assessments
Who uses the output
How the work fits into the transaction or program
The AD section anchors the import and export package because most authority questions land there first. This review runs after the status summaries are compiled and before anything is submitted, and its substantiation index shortens every later exchange, with the authority and with the counterparty alike.
Jurisdiction-specific considerations
FAA and EASA issue directives independently, and adoption is not symmetric: a directive existing on one side may have no counterpart, a different applicability, or a different compliance time on the other. The registry change makes the importing side's population mandatory reading, and 14 CFR 39 or its EASA equivalent frames what compliance means once the aircraft arrives.
Regulatory limits
The review does not determine AD applicability on behalf of any operator, does not approve alternative methods of compliance, and does not declare the aircraft airworthy. It reports which lines of the status list the package can prove and which it cannot.
What this review does not cover
Specific to this review
- Directive populations diverge most on appliances and engines, where the certificating authority may differ from both the exporting and importing registries.
- A status list is dated evidence; regenerating it the week of submission catches directives issued mid-transition, which authorities notice when a list's date predates a recent directive.
- Closures documented only as lines on inherited status lists degrade with each transfer: reconstruction usually still succeeds from the second-hand list and fails from the third.
- Authorities rarely question the longest list; they question the line that disagrees with another package section, so cross-section reconciliation prevents more findings than deeper AD research does.
- An AD closed by component replacement depends on the component records, which means a weak component section quietly undermines a clean-looking AD list.
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
The aircraft has flown for years under the current registry with this AD list. Why would it fail now?
The registry change changes the audience. A list adequate for continuing operation under one authority now has to satisfy a second authority's directive population and an importing inspector reading it cold. Lines never questioned in service get questioned at import, and the ones that fail are almost always inherited closures with no local evidence behind them.
Relevant glossary terms
Related pages
Where this fits
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