Owner handover baseline
Airworthiness Directive status review for the owner-managed aircraft file
Owners of managed aircraft usually hold an AD status list produced by the management provider, and this review establishes how much of it the underlying records actually prove. Each AD line is traced from the status list into the evidence an owner holds or can obtain: logbook entries, work orders from maintenance providers, program statements, and the invoices showing what was paid for. Lines marked complied-with without an accomplishment record are isolated, as are recurring ADs whose next-due figures nothing in the file supports. The owner representative receives an exception list to work while provider cooperation is still easy.
When this review is needed
- A sale is in preparation and buyer diligence will test AD lines against accomplishment evidence the owner has never personally held.
- The management relationship is ending and the provider's system, along with its supporting records, is about to become inaccessible.
- The status list shows compliance events the owner's folders evidence only through invoices.
- A new provider needs a verified AD baseline to build its tracking on rather than inheriting the old export on trust.
The problem
Management arrangements split the records three ways: the owner holds folders and invoices, the provider runs the tracking system, and the maintenance shops keep the work packages. The AD list the owner sees is an export from the provider's system, clean and confident, but its compliance entries reference documents the owner may never have received. When the management relationship ends, the owner keeps the aircraft and the list while the system discipline behind the list stays with the provider.
What gets reviewed
- Every line of the AD status list traced toward accomplishment evidence the owner controls or can request
- Method-of-compliance entries checked against the terminating or repetitive nature of each directive
- Recurring ADs and their next-due values tested against the utilization figures in the file
- Superseded and revised directives, confirming the list reflects current directive status
- Work records and invoices matched to the compliance events the list claims
- Applicability of listed directives to this serial number and its installed configuration
Scope this review
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What gets validated
- Each complied-with line has an accomplishment record naming the aircraft, the AD, and the method used
- Repetitive directives show a next-due consistent with the recorded accomplishment and current utilization
- The list's revision basis reflects the current state of FAA and EASA directive publications for the type
- Compliance claimed through an SB is backed by the SB embodiment record, since an invoice alone does not evidence terminating action
- No directive applicable to the installed configuration is missing from the list
Evidence normally required
- The AD status list as exported by the management provider
- Owner-held logbooks and records delivered during the management term
- Maintenance-provider work packages and their release paperwork
- Invoices and program statements covering the claimed compliance events
- Current utilization figures for hours, cycles, and calendar time
Common discrepancies
- A complied-with entry supported only by an invoice line, with no maintenance record of the work itself
- Next-due values computed from utilization figures the owner's own records contradict
- Directives closed by reference to an SB whose embodiment evidence never reached the owner's folders
- Applicable directives absent from the list after a configuration change the tracking system was never told about
What is at stake
At sale, every unsupported AD line is a diligence finding with a price attached, and the burden of proof sits with the seller. A provider change without a verified baseline forces the incoming provider to re-derive compliance from scratch, billed by the hour. Most quietly dangerous of all, a recurring AD with an unsupported next-due can drift past its due point during the handover gap, when no system clearly owns the tracking.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Fix the list and the utilization
Establish the governing list revision and the hours, cycles, and calendar position it must be read against.
Trace each line
Follow every directive from the list into logbooks, work packages, program statements, and invoices.
Classify the exceptions
Separate evidenced lines from asserted ones and flag next-due values that nothing supports.
Issue baseline and request list
Deliver the verified baseline plus a prioritized retrieval list for the outgoing provider and shops.
What the buyer receives
- A line-by-line exception list separating evidenced compliance from asserted compliance
- A request list naming the documents to obtain from providers and shops, prioritized by urgency
- A verified AD baseline summary for the sale file or the incoming provider
Who uses the output
- Owner representatives preparing a sale or winding down a management relationship
- Incoming management or maintenance providers building their tracking from a verified start
- Buyer-side reviewers who will test the same lines during diligence
How the work fits into the transaction or program
AD status is usually the first record a buyer or incoming provider tests, so this review front-loads the hardest part of an owner file handover. Its request list drives the document retrieval from outgoing providers, and the verified baseline becomes the reference point that the LLP and maintenance-status reviews on the same file reconcile against.
Jurisdiction-specific considerations
Under 14 CFR part 39 directives are binding, and 14 CFR 91.417 requires the owner to keep the current status of applicable ADs including method of compliance and the time of next required action. For EASA-registered managed aircraft, Regulation (EU) No 1321/2014 places continuing-airworthiness responsibility with the owner unless contracted to a CAMO. In both systems the obligation follows the owner rather than the provider, which is exactly why a provider's export needs independent verification when the relationship changes.
Regulatory limits
Findings are records exceptions, no more. The review does not perform or certify compliance actions, does not rule on AD applicability as an engineering matter beyond documentary comparison, and disposition of any genuinely open directive belongs to the owner's maintenance organization and authority.
What this review does not cover
- Accomplishing or certifying AD compliance actions
- Legal advice on management-agreement obligations
- Physical inspection of the aircraft to establish configuration
Specific to this review
- The 91.417 status obligation sits with the owner even while a provider maintains the list, so the export inherits none of the provider's system controls once it leaves that system.
- Invoice-backed evidence is common in managed files and weak in diligence, because an invoice proves payment while the buyer wants the record of accomplishment.
- Cooperation from an outgoing provider decays fast after termination, which makes the document request list a time-critical deliverable rather than an administrative one.
- Recurring directives are the real exposure during handover gaps, since nobody's system owns the next-due while the aircraft sits between providers.
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
Our management provider runs an approved tracking system. Is their list not sufficient?
The system's discipline does not travel with the export. A buyer or incoming provider tests evidence, and the moment to gather that evidence is while the outgoing provider still answers the phone. Verification now is cheap; reconstruction after the relationship ends is neither cheap nor quick.
Relevant glossary terms
Related pages
Where this fits
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