Registry transfers
AD status review for an FAA to EASA registry transition
An FAA to EASA AD status transition review restates an aircraft's Airworthiness Directive position for the authority that will oversee it next. Lessors, airlines, and acquisition teams run it before a registry change, because an AD list maintained under FAA oversight answers FAA directives, while the EASA-side review will ask about EASA directives and the state-of-design position. The work rebuilds the directive population applicable under the receiving system, maps existing accomplishment evidence onto it, and isolates directives where compliance is real but the proof was never assembled in EASA-facing terms. You receive a restated AD status, an evidence cross-map, and a gap list ordered by what the import or airworthiness-review process will question first.
When this review is needed
- A registry transfer to an EASA member state is planned and the airworthiness review will test the AD position.
- The current AD list tracks FAA directives only, and no one has derived the corresponding EASA-applicable population.
- Accomplishment evidence exists in work orders and task cards but was never packaged directive by directive.
- Superseded and recurring directives show compliance entries that stop at a status line with no method or reference.
The problem
The same physical aircraft carries two different directive histories depending on who is asking. FAA and EASA issue their own ADs, adopt each other's state-of-design directives unevenly, and differ on supersedure chains and compliance-time logic. An AD status that has satisfied FAA-side audits for a decade can therefore be structurally unresponsive to the EASA reviewer's question set, and discovering that during the airworthiness review means rebuilding the position under the worst possible time pressure.
What gets reviewed
- Derivation of the directive population applicable to the airframe, engines, APU, and appliances under the receiving system
- Cross-mapping of FAA and EASA directives covering the same unsafe condition, including supersedure chains on both sides
- Directive-by-directive matching of accomplishment evidence: method, date, utilization at compliance, and authority for the method used
- Recurring-directive verification that next-due tracking survives the translation between systems
- Treatment of alternative methods of compliance approved under FAA authority and their standing after transition
- A prioritized gap list keyed to airworthiness-review exposure
Scope this review
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What gets validated
- The restated directive population covers state-of-design issuances beyond the directives the FAA operator tracked
- Each closed directive cites accomplishment evidence: the record, the method, and the compliance point
- Supersedure chains resolve to the currently effective directive on the EASA side, with prior-revision credit assessed
- Recurring items carry a computable next-due under the receiving system's compliance-time conventions
- AMOC-based closures are flagged wherever their FAA approval does not carry automatic weight after transition
Evidence normally required
- The current AD status report for airframe, engines, APU, and appliances
- Accomplishment records: task cards, work orders, shop reports, and modification certifications behind each closure
- AMOC approvals and any deviation or exemption paperwork
- Utilization history sufficient to verify compliance points and next-due calculations
- The receiving state's import requirements or the reviewing organization's checklist, if available
Common discrepancies
- EASA-applicable directives absent from the status entirely because no FAA counterpart was ever issued
- Closures resting on a status-line entry with the underlying task card never located
- Repetitive-inspection directives whose intervals were tracked in flight hours while the EASA-side directive counts cycles or calendar time
- AMOC closures presented as final where the receiving side treats the underlying directive as still open
What is at stake
AD findings are the ones an importing authority will not negotiate around. An unresolved directive position stalls the airworthiness review certificate, which stalls registration, which holds the delivery or lease start with financing and crews already committed. Even where compliance was genuine, evidence assembled after the fact under deadline tends to be accepted more grudgingly and sampled more deeply.
How the work runs
Re-derive the population
Build the directive list the receiving system will apply across airframe, engines, APU, and appliances, including supersedure resolution.
Map the evidence
Attach accomplishment records to each directive and score the strength of each closure.
Work the divergences
Resolve compliance-time translations, AMOC standing, and directives with no FAA counterpart.
Package for review
Deliver the restated status, cross-map, and gap list in the order the airworthiness review will consume them.
What the buyer receives
- A restated AD status aligned to the directive population the EASA-side review will apply
- An evidence cross-map linking each directive to its accomplishment records
- A gap list with recovery actions, owners, and review-exposure ranking
- A briefing note for the airworthiness-review conversation
Who uses the output
- Continuing-airworthiness managers presenting the AD position at the airworthiness review
- Transition managers sequencing evidence recovery against the registration timeline
- Asset and acquisition teams sizing the cost of directive gaps before commitments harden
How the work fits into the transaction or program
The AD lane usually runs first among transition records workstreams, because directive findings gate the airworthiness review while most other records issues merely complicate it. Its evidence cross-map draws on the same task cards and shop reports the LLP and release-document reviews use, so the three lanes share document recovery instead of issuing competing requests.
Start with a single asset
Confirm the status list matches the underlying evidence.
Jurisdiction-specific considerations
FAA directives are issued under 14 CFR 39 with records kept under 91.417, while the EASA side manages directives through the continuing-airworthiness framework of Regulation (EU) 1321/2014, with import questions shaped by Regulation (EU) 748/2012. The two systems overlap heavily on state-of-design directives and diverge at the edges: appliance ADs, compliance-time conventions, and the standing of FAA-approved AMOCs. The review concentrates on exactly those edges.
Regulatory limits
The review restates status and assembles evidence. It does not perform the airworthiness review, issue or validate any certificate, approve methods of compliance, or determine that any directive is closed; those judgments belong to the reviewing organization and the receiving authority.
What this review does not cover
- Performing inspections, modifications, or other directive compliance actions
- AMOC or exemption applications to either authority
- Conducting the formal airworthiness review itself
Specific to this review
- Appliance and equipment directives are the classic blind spot in transitions: EASA issues directives against equipment that FAA-tracked status lists never carried, so the gap is invisible until the population is re-derived.
- Compliance-time conventions differ enough that a directive can be simultaneously in compliance under FAA counting and overdue under the EASA-side reading of the same history.
- An AMOC is an approval with an issuing authority, and its weight after transition is a question to answer per directive, never an assumption.
- Evidence packaged directive by directive reads faster and samples better than a status list backed by a warehouse of work orders, and reviewers reward the format with narrower sampling.
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
Our FAA AD status is clean and audited, so why would EASA-side review find gaps?
Because it asks a different question. The FAA status answers FAA directives; the EASA-side review applies the EASA directive population, its own supersedure chains, and its own compliance-time conventions. Most of the underlying work transfers, and the review exists to restate and evidence it in the receiving system's terms before someone else discovers the difference.
Relevant glossary terms
Related pages
Where this fits
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