Lease transitions
AD compliance status review inside the lease-transition records file
This review tests whether the AD status list in a lease-transition records file holds up against the documents that were actually delivered with the aircraft. A records specialist reads each AD line back to accomplishment evidence in the transition folders, acceptance notes, and open-item trackers, usually during redelivery preparation or a mid-term operator change. Lines that claim compliance without a work record, a method of compliance, or a terminating-action reference are pulled into an exception list. The transition lead receives that list with the source reference for every supportable line and a gap description for every line that is not.
When this review is needed
- Redelivery conditions require an AD status list supported line by line and the incoming operator has started sampling it.
- A mid-term operator change moved records custody and nobody has confirmed the status list still matches the delivered evidence.
- The transition open-item tracker carries AD queries that keep bouncing because the underlying accomplishment records were never located.
- An acceptance deadline is fixed and the lessor wants to know which AD lines will survive scrutiny before the other side finds out.
The problem
An AD status list is a system export, produced at a moment in time by whoever held the aircraft last. The transition file behind it is assembled later, from folder handoffs, scans, and correspondence, and nobody has confirmed the two still describe the same aircraft. Lines marked complied-with may rest on work orders that never made it into the shipment, and the records team discovers this only when the incoming operator asks for one.
What gets reviewed
- Every line on the AD status list mapped to the transition folder location that should hold its evidence
- Method of compliance on each closed AD checked against the referenced SB, repair, or inspection record
- Repetitive ADs checked for last-done and next-due points that the utilization statements can support
- Terminating actions verified against the modification or repair record that ends the repetitive requirement
- Applicability calls sampled against the aircraft, engine, and appliance configuration in the file
- Open-item tracker entries reconciled so AD queries already in dispute are not double-counted
Scope this review
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What gets validated
- A closed AD cites accomplishment evidence that exists in the delivered package, with matching serial effectivity
- Compliance dates and utilization at accomplishment agree between the status list and the source record
- Repetitive intervals restart from an evidenced last-done point rather than an assumed one
- AMOC-based compliance is backed by the approval document at the correct revision
- Superseded ADs are traced so compliance claimed under a prior revision still satisfies the current one
Evidence normally required
- The AD status list as issued for the transition, with its revision date
- Lease-transition folders and any indexed scans of accomplishment records
- Utilization statements covering the compliance dates on the list
- Acceptance notes and correspondence recording queries the other side has already raised
- The open-item tracker in its current state
Common discrepancies
- An AD shown closed by SB accomplishment where the SB work order is absent from the folders
- A repetitive AD whose next-due calculation relies on a last-done date no delivered record supports
- Compliance claimed against a superseded AD revision without a bridge to the current requirement
- Applicability marked not-applicable on configuration grounds the delivered configuration records contradict
What is at stake
Unsupported AD lines stall acceptance faster than almost any other records defect, because no receiving operator will inherit an AD position it cannot evidence. A repetitive AD without a proven last-done point gets recalculated from the most conservative date the records allow, pulling the next action forward. Each line that fails under the other side's sampling also invites deeper sampling of everything else.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Fix the baseline
Lock the status list revision under review and index the transition folders it must be read against.
Trace each line
Read every closed and not-applicable line back to accomplishment evidence, method of compliance, and effectivity.
Test the arithmetic
Check repetitive intervals, last-done points, and terminating actions against the utilization statements.
Report exceptions
Deliver the exception list with evidence locations for supported lines and recovery targets for the rest.
What the buyer receives
- An exception list identifying every AD line the source package cannot support, with the reason
- A cross-reference from supportable lines to their evidence location in the transition file
- A prioritized recovery list naming the record and likely holder for each gap
Who uses the output
How the work fits into the transaction or program
This is one strand of a source review that reads the whole transition file, and the AD strand runs early because its exceptions take longest to recover. Its output lands in the shared open-item tracker beside the LLP and release-document exceptions, and its evidence index shortens the receiving CAMO's own AD assessment after handover.
Jurisdiction-specific considerations
Under FAA oversight, 14 CFR 91.417 requires the current status of applicable ADs, including method of compliance and, for repetitive ADs, when the next action is due, so acceptance teams in FAA contexts read the list against that standard. EASA-managed aircraft carry the equivalent obligation through the continuing-airworthiness records the CAMO maintains under Regulation (EU) 1321/2014. A transition that moves the aircraft between the two systems doubles the exposure, since the receiving side applies its own format expectations to evidence assembled under the other's.
Regulatory limits
This is a records review. It does not determine airworthiness, close or defer an AD, approve an alternative method of compliance, or amend the status list; those actions remain with the operator, its CAMO, and the responsible authority.
What this review does not cover
Specific to this review
- AD status lists are usually exported from the outgoing operator's system days before delivery, so lines can reference records that were pulled from the shipment at the last minute.
- Repetitive ADs produce the most expensive gaps, because a missing last-done record resets the interval to the most conservative evidenced point.
- Terminating action is a frequent silent failure: the list shows the repetitive line closed, and the modification record that terminated it is filed under the SB, where nobody looks.
- Acceptance teams sample AD evidence early because each unsupported line becomes cheaper to dispute the sooner it is raised.
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 incoming operator will run its own AD review. Why run one first?
Because the receiving CAMO's review is designed to protect the receiving side. Running the source review first tells the delivering party which lines will fail, while there is still time to recover records from the shops and prior operators that hold them, and before every gap becomes a negotiated concession.
Does the review re-assess AD applicability?
It samples applicability calls against the configuration records in the file and flags contradictions. It does not perform an engineering applicability analysis or substitute for the operator's own determination.
Relevant glossary terms
Related pages
Where this fits
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