Cross-border transition
Bilateral agreement evidence review for record acceptance
A bilateral agreement evidence review tests which of an aircraft's records actually cross between two authorities under their bilateral arrangement, and which fall outside its scope and need a direct acceptance path. It is built for lessors, airlines, and acquisition teams moving an asset across authorities. It covers release-document acceptance, design-approval recognition, AD reciprocity, and the conditions and exclusions written into the arrangement itself. You receive a record-by-record acceptance view, a list of items the bilateral does not cover, and the path each uncovered item needs.
When this review is needed
- An aircraft is moving between two authorities and the parties have assumed a bilateral arrangement will carry the records across.
- A release form acceptable to one authority needs confirming as acceptable to the other under the arrangement in force.
- A modification approved under one design authority must be recognized by the receiving authority for the transfer to hold.
- A prior transfer relied on a bilateral path and an item now appears to fall outside what the arrangement actually covers.
The problem
Bilateral arrangements between authorities are read as if they make records portable, but each one defines its own scope, conditions, and exclusions. A release form may be accepted for new production yet treated differently for a used component, a design approval may be recognized only within stated limits, and AD reciprocity may not extend to every directive. A team that assumes the arrangement covers everything finds, late in a transfer, that a specific record sits outside its scope and needs a direct path the arrangement never promised.
What gets reviewed
- The specific bilateral arrangement in force between the two authorities and its stated scope
- Release-document acceptance under the arrangement for new and used components
- Recognition of design approvals and modifications across the two authorities
- AD reciprocity and which directives the arrangement does and does not bridge
- The conditions, limitations, and exclusions written into the arrangement itself
- Records that fall outside the arrangement and the direct acceptance path each one needs
Scope this review
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Send a representative, redacted record set and we will scope the review.
What gets validated
- Each release form on file is checked against the arrangement's acceptance scope for that class of part
- Design approvals relied on are within the recognition limits the arrangement sets
- AD reciprocity is confirmed directive by directive rather than assumed across the board
- Dual-release components carry the form the receiving authority accepts under the arrangement
- Conditions and exclusions in the arrangement are read against the actual records in the file
- Items outside the arrangement's scope are identified and assigned a direct acceptance path
Evidence normally required
- The bilateral arrangement and any technical implementation procedures between the authorities
- Authorized release certificates for installed and replaced components
- Design-approval and modification records for the airframe and engines
- Current AD status reports for both the exporting and importing authorities
- Component history showing prior changes of custody and release origin
Common discrepancies
- A release form assumed to transfer that the arrangement accepts only for a different class of part
- A design approval recognized under the arrangement but only within limits the configuration exceeds
- An AD the arrangement does not bridge that the receiving authority enforces independently
- A used component whose release is treated differently from a new-production release under the same arrangement
- A record outside the arrangement's scope entirely that the parties had treated as covered
What is at stake
A record assumed to transfer under a bilateral but actually excluded from it can stop a transfer until a direct acceptance path is built, which takes time the deal may not have. The exposure is hidden because the arrangement appears to apply, so the gap is found only when the receiving authority declines the item, by which point the leverage to source an alternative from the exporting side is reduced.
How the work runs
Identify the arrangement
Establish the specific bilateral arrangement and implementation procedures in force between the two authorities.
Test acceptance by record
Check each release, approval, and AD against the arrangement's stated scope, conditions, and exclusions.
Isolate the exclusions
Identify the records that fall outside the arrangement and would need acceptance on their own terms.
Assign acceptance paths
Recommend a direct acceptance path for each uncovered item and flag the conditions that bear on the transfer.
What the buyer receives
- A record-by-record acceptance view showing what the arrangement covers and on what conditions
- A list of items the arrangement does not cover, with the direct acceptance path each requires
- A flag of the conditions and exclusions in the arrangement that bear on the specific transfer
Who uses the output
- Continuing-airworthiness teams confirming what crosses before relying on the arrangement
- Asset and acquisition teams pricing the work to bridge items the arrangement excludes
- Records teams building the direct acceptance path for items outside the arrangement
How the work fits into the transaction or program
The review sits inside a wider transfer so the bilateral path is tested rather than assumed, and it pairs with the export evidence map, since the certificate file rests on which records actually cross. It separates the items the arrangement carries from those that need a direct path, so the team spends effort only where the arrangement leaves a gap.
Start with a single asset
Start with a single tail and expand once the workflow is proven.
Jurisdiction-specific considerations
Bilateral arrangements are specific to the pair of authorities and the scope they negotiated, so an arrangement that smooths a transfer in one direction may treat the reverse direction differently. The review reads the arrangement actually in force between the two authorities in play rather than a general expectation of how such arrangements behave.
Regulatory limits
The review confirms what a bilateral arrangement covers and which records fall outside it. It does not bind either authority, interpret the arrangement on the authority's behalf, make an airworthiness determination, or guarantee that an item the arrangement excludes will be accepted by a direct path.
What this review does not cover
- Negotiation or interpretation of the bilateral arrangement with either authority
- Issuance of any release certificate, design approval, or airworthiness determination
- Physical inspection or conformity survey of the aircraft or components
Specific to this review
- A bilateral arrangement defines its own scope, conditions, and exclusions, so a record acceptable under one arrangement is not portable to a transfer governed by a different pair of authorities.
- Release acceptance can differ between new-production and used components under the same arrangement, so the class of part is checked alongside the form type.
- AD reciprocity is confirmed directive by directive, because an arrangement that bridges most directives can leave specific ones to the receiving authority.
- An item outside the arrangement's scope needs a direct acceptance path that the arrangement never promised, so the exclusions are read as carefully as the inclusions.
Sources
Federal Aviation Administration. Completion and use of FAA Form 8130-3, Authorized Release Certificate, for new and used parts.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
International Civil Aviation Organization. International standards for the airworthiness of aircraft and the framework states use for type and continuing airworthiness.
European Union Aviation Safety Agency. EASA authorised release certificate for components, equivalent in function to FAA Form 8130-3.
Transport Canada. Canadian airworthiness, maintenance records (CAR 605/571), and Airworthiness Directive requirements (CAR 593).
Frequently asked questions
Does a bilateral arrangement make all records automatically acceptable?
No. Each arrangement has a defined scope with conditions and exclusions. Some records cross under it and some do not. The review separates the two so the items needing a direct acceptance path are known before the transfer relies on the arrangement.
Relevant glossary terms
Related pages
Where this fits
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