Directive compliance trail
Airworthiness Directive status review for an EASA to FAA transfer
Moving from an EASA register to the FAA means the AD status list is rebuilt around a different authority's directives. This review checks whether the compliance evidence behind the current status can support that rebuild: applicability determinations, accomplishment records, method-of-compliance references, and the alternative means of compliance relied on along the way. A records specialist performs it during transition planning, before the buyer or US-side reviewer sees the package. It delivers an AD evidence map, a gap list, and document requests focused on the items 14 CFR 91.417 recordkeeping scrutiny will surface.
When this review is needed
- The transition plan calls for restating the AD status against FAA directives and the mapping has not started.
- The current status cites EASA ADs and state-of-design directives without linking them to their FAA counterparts.
- Accomplishment evidence for older ADs lives in prior operators' archives and retrieval takes months.
- The buyer's technical team has asked how repetitive-inspection ADs were tracked and wants the raw evidence.
The problem
AD lists maintained under EASA cite the directives the European system tracks, which overlap with FAA directives without matching them one for one. Numbering differs, effective dates differ, and some FAA ADs have no EASA twin at all for this type. The status list itself transfers easily; the evidence underneath does not, because each restated line needs accomplishment proof, and proof for a directive complied with fifteen years ago under a different operator is exactly the document nobody kept handy.
What gets reviewed
- Current AD status list mapped to the corresponding FAA directives for airframe, engines, APU, and appliances
- Accomplishment evidence pulled and verified for each restated line, prioritized by directive criticality
- Method-of-compliance references checked against the directive text and revision in force at accomplishment
- Repetitive ADs verified for interval tracking continuity across operator changes
- Alternative means of compliance (AMOC) approvals identified, with their applicability to this serial number
- Terminating actions confirmed with the modification or repair records that embody them
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What gets validated
- Each status line claiming compliance carries a dated accomplishment record naming the aircraft or component serial
- The compliance method recorded matches an option the directive actually offered at that revision
- Repetitive-inspection due points recompute correctly from the last accomplishment and utilization data
- AMOC approvals in the file were issued by the appropriate authority and cover this serial number
- Directives claimed not applicable have a recorded applicability basis, none dismissed by configuration assumption
Evidence normally required
- Current AD status list for airframe, engines, APU, and appliances
- Accomplishment records: work orders, task cards, logbook entries, and shop reports
- AMOC approvals and any deviation or exemption correspondence
- Modification and repair records supporting terminating actions
- Utilization data for recomputing repetitive-inspection due points
Common discrepancies
- Status lines marked complied-with that trace only to a summary from a prior tracking system, with no primary record
- FAA directives applicable to the type that never appeared on the EASA-maintained list
- Repetitive ADs whose interval basis shifted between calendar and flight-hour tracking during an operator change
- Terminating action claimed through an SB whose accomplishment record covers a different aircraft in the fleet
What is at stake
Any restated AD line without accomplishment evidence defaults to open, and open ADs stop everything: the aircraft cannot be returned to service under the new operator's program until each is closed or shown compliant. Late discovery means emergency document hunts, repeated inspections for directives already done, and in the worst cases invasive work to re-verify terminating action the records could not prove.
How the work runs
Map the directive sets
Pair each line of the EASA-maintained status with the applicable FAA directive and note unmatched items both ways.
Pull the evidence
Retrieve accomplishment records for restated lines, starting with structural, engine, and repetitive directives.
Test each claim
Verify method, revision, serial applicability, and due-point arithmetic for every evidenced line.
Deliver the restatement basis
Issue the evidence map, gap list, requests, and the worksheet for the FAA-basis status build.
What the buyer receives
- An AD evidence map linking each restated directive line to its accomplishment proof
- A gap list ranked by criticality and by how hard the missing evidence is to recover
- Document requests directed to the operators and shops holding primary records
- A restatement worksheet the receiving records team can carry into its FAA-basis status
Who uses the output
- The incoming US operator's maintenance and records organization building the FAA-basis AD status
- Technical-records leads managing the transition document flow
- Buyer-side auditors verifying compliance claims during the transaction
How the work fits into the transaction or program
The AD strand runs early in an EASA to FAA transition because evidence recovery from prior operators sets its pace. Its findings interact with the modification review, since terminating actions live in the modification file, and with the LLP review where directives impose life or inspection limits on tracked parts.
Start with a single asset
Confirm the status list matches the underlying evidence.
Jurisdiction-specific considerations
Under the EASA system the aircraft followed EASA ADs and state-of-design directives; on the FAA register, 14 CFR Part 39 directives govern and 91.417 defines the records the operator must hold. The two directive sets diverge in numbering, applicability logic, and occasionally substance, so the status is restated rather than transferred. Where an EASA AD was complied with using a method the parallel FAA directive words differently, the review flags the line for method reconciliation instead of assuming equivalence.
Regulatory limits
The review examines records. It does not determine AD applicability on behalf of any operator or authority, does not approve compliance methods or AMOCs, does not close any directive, and does not make an airworthiness determination. Compliance responsibility sits with the operator under the directive itself.
What this review does not cover
- Physical inspection to verify accomplishment of any directive
- Engineering assessment of compliance methods or AMOC development
- Ongoing AD tracking after the transition completes
Specific to this review
- Restating a status is where hidden gaps surface: a line can be genuinely compliant under the EASA directive and still lack the record the FAA-basis line needs, because different revisions asked for different evidence.
- Repetitive ADs suffer most from operator changes, since interval baselines migrate between tracking systems and the original accomplishment date quietly becomes an assumption.
- Fleet-level compliance summaries from large operators are the weakest evidence class; auditors want the entry for this serial number, and fleet paperwork rarely decomposes cleanly.
- An AD complied with by terminating SB is only as strong as the SB accomplishment record, so the AD and modification files must agree before either is delivered.
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.
U.S. Government (eCFR). Export airworthiness approval requirements and special requirements of an importing authority.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
Frequently asked questions
Can the existing EASA AD status simply be handed to the FAA-side reviewer?
It can be handed over, but it will not be accepted as the status. The FAA-basis list must cite Part 39 directives, and every line needs evidence that stands on its own. The existing status is the starting index for the restatement, and its real value is the accomplishment records behind it.
Relevant glossary terms
Related pages
Where this fits
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