Registry change
Repair approval data review for a registry change
A registry-change repair approval review checks that every recorded repair and alteration on the aircraft rests on data the receiving authority will accept once the register changes. It is run for the party assembling the transition package, before handover, across the structural repairs and alterations that carry an approval basis. The work traces each repair from its damage disposition to the approved data behind it and to the return-to-service entry that closed it. You receive a repair map keyed to the record set, a gap list flagging repairs whose approval basis will not travel to the new register, and a request set for the substantiation that has to be recovered.
When this review is needed
- An aircraft is moving register and the receiving authority will examine the basis for each structural repair and alteration.
- Repairs were approved under the outgoing authority's data that the new register does not automatically recognize.
- Damage history has accumulated across operators and the dispositions were never consolidated into a single map.
- A handover date is fixed and the team needs to know which repairs lack a portable approval basis.
The problem
A repair approved under one authority's data is not guaranteed to be acceptable under another's, and the difference surfaces on the register change rather than when the repair was done. Structural dispositions pile up over an aircraft's life, spread across work packages, damage reports, and return-to-service entries that were never gathered into one view. The team preparing the transition inherits that scatter and has to prove, repair by repair, that the basis will hold on the new side.
What gets reviewed
- Each structural repair traced from its damage report to the approved data it was accomplished under
- Alterations checked for an approval basis that the receiving authority recognizes
- Return-to-service entries confirmed to close the repair they reference
- Repairs that overlap or interact reconciled so the cumulative effect on the structure is visible
- Approval sources identified where the outgoing register's basis will not carry to the new one
- The consolidated repair history assembled into a single map for the receiving authority
Scope this review
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What gets validated
- Each repair cites approved or acceptable data that applies to the location and damage it addresses
- The return-to-service entry for a repair references the same disposition and data package
- Alterations carry an approval basis the receiving authority will accept, not only the outgoing one
- Overlapping repairs in a structural zone are reconciled rather than treated in isolation
- Any repair without a portable approval basis is identified with the reason it will not travel
Evidence normally required
- The repair and alteration history, including damage reports and dispositions
- Approved data packages and substantiation behind each repair
- Return-to-service entries closing the recorded repairs
- Structural repair manual references and any authority correspondence on the repairs
- Configuration status showing where alterations affect the type design
Common discrepancies
- A structural repair whose approved-data reference cannot be located behind the disposition
- An alteration approved under the outgoing authority with no basis the new register recognizes
- A return-to-service entry that does not match the repair data it purports to close
- Two repairs in the same structural zone never reconciled for cumulative effect
What is at stake
A repair whose approval basis the receiving authority rejects can require re-substantiation, re-approval under the new register's data, or in the worst case removal and rework. Discovering that during acceptance stalls the register change and puts the aircraft into an engineering loop that the deadline never allowed for.
How the work runs
Consolidate the history
Gather every repair and alteration disposition into a single structural map for the aircraft.
Trace each basis
Confirm the approved data behind each repair and whether it is recognized by the receiving register.
Check the closures
Verify each return-to-service entry matches the repair and data it claims to close.
Scope the non-portable items
Flag repairs whose basis will not travel and define the re-substantiation the new register will need.
What the buyer receives
- A consolidated repair map tying each disposition to its approval basis and closure entry
- A gap list flagging repairs whose basis will not carry to the receiving register
- A document request set for the substantiation and approval data still to be recovered
Who uses the output
- Certification and engineering staff deciding how a repair's basis is made acceptable to the new register
- Asset managers gauging which repairs could force re-substantiation or rework before the change
- Records teams gathering the approval data behind each disposition for the package
How the work fits into the transaction or program
The repair review sits alongside the modification, AD, and LLP strands of the registry-change package, and its findings often feed the certification work the transition can least afford to start late. Where a repair basis will not travel, the gap list defines the re-substantiation scope before the handover date rather than after acceptance opens.
Start with a single asset
Confirm the status list matches the underlying evidence.
Jurisdiction-specific considerations
FAA, EASA, and TCCA accept different data as the basis for a structural repair, so a disposition sound under one register can need a new acceptable basis under another. The review flags repairs whose approval will not carry across and the substantiation the receiving authority is likely to demand.
Regulatory limits
The review reads the repair records and tests whether their approval basis is portable to the new register. It does not approve a repair, develop or approve repair data, return the structure to service, or determine that the aircraft is airworthy.
What this review does not cover
- Developing new repair or alteration substantiation data
- Performing or re-performing any structural repair
- Any airworthiness determination on the repaired structure
Specific to this review
- The portability of a repair basis, not its original soundness, is what decides a register change, because each authority accepts different data.
- Structural repairs interact within a zone, so a disposition that was fine alone can raise a cumulative-effect question once the full history is mapped.
- Re-substantiation is engineering work with a long lead, so repairs without a portable basis are the transition items most worth surfacing early.
Sources
U.S. Government (eCFR). Maintenance recordkeeping content and approval-for-return-to-service requirements, including 43.9, 43.11, and Appendix B.
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
Does a repair approved under our current authority automatically transfer to the new register?
Not necessarily. Each authority accepts different data as the basis for a structural repair, so a disposition sound under the outgoing register can require a new acceptable basis under the receiving one. The review identifies which repairs need re-substantiation before the change so the engineering lead time does not fall on the deadline.
Relevant glossary terms
Related pages
Where this fits
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