Import due diligence
Maintenance-program records review for acquisition teams at aircraft import
Acquisition teams use this review to test whether an imported aircraft's maintenance-program status will hold up once the receiving authority and the new operator's program take over. It examines approved program revisions, escalation approvals, bridging analyses, and the source documents behind the compiled status, all before import acceptance. Records specialists perform it during technical due diligence, alongside the broader import records review. The transaction lead receives a program mapping memo, a schedule of open items ranked by due-date exposure, and a chase list for the evidence still needed from the seller.
When this review is needed
- A purchase is timed to an import and the program history determines what tasks come due right after transfer.
- The seller's status relies on interval escalations that may not survive the move to a new operator and authority.
- Program status arrived as a tracking-system export with no approved revision behind it in the data room.
- A lender or investment committee requires program verification before funding the acquisition.
The problem
Program status usually arrives as a tracking-system export, and the approved revision it was compiled against may be several amendments behind what the operator actually flew to, or unavailable entirely. Escalated intervals justified by the seller's reliability data will not automatically follow the aircraft to a new operator. The acquisition team ends up pricing and planning against task due dates that can shift materially once the bridge is applied.
What gets reviewed
- The approved program revision behind the compiled status, matched against what the operator actually flew to
- Escalation approvals and the reliability substantiation supporting each extended interval
- Bridging analysis coverage across airframe, engine, APU, and component tasks
- Source-document references from the status export back to task cards and work orders
- Tasks falling due inside the bridge window and at program transfer
- ICA and supplemental requirements from modifications folded into the program
Scope this review
Tell us the asset, the event, and the evidence in scope, and we will outline a focused first engagement.
Send a representative, redacted record set and we will scope the review.
What gets validated
- The status export identifies the program revision it was compiled against, and that revision exists in the data room
- Each escalated interval has an approval trail, with reversion applied wherever the escalation will not transfer
- Sampled status lines trace to a task card or work order with a matching sign-off date
- The bridging analysis addresses every task family, including component hard times, without silent omissions
- Due-date arithmetic in the status holds when recomputed against utilization since the compile date
Evidence normally required
- The maintenance program status export with its compile date
- The approved program and its revision history from the operating authority
- Escalation approvals and supporting reliability reports
- The draft or completed bridging analysis for the receiving program
- Task cards or work orders for a sampled set of status lines
Common discrepancies
- Status compiled against a program revision nobody can produce
- Escalated intervals presented as baseline, hiding the reversion the buyer will absorb at transfer
- Component hard-time tasks missing from the bridging analysis
- Sampled status lines whose sign-off dates contradict the export
What is at stake
Taking the program history at face value means tasks the buyer believed were mid-interval can come due immediately after import, turning a planned smooth entry into an unbudgeted maintenance input. Escalations that quietly lapse at transfer inflate near-term cost, and a bridging analysis built on an unverifiable status invites the receiving authority to ask questions the seller is no longer around to answer.
How the work runs
Fix the reference set
Confirm the approved program revision and compile date the status claims, and collect escalation and bridging documents.
Sample to source
Trace a risk-weighted sample of status lines to task cards and work orders.
Model the transfer
Recompute due dates with escalations reverted and the bridge applied, exposing what actually comes due.
Report exposure
Deliver the mapping memo, open-item schedule, and evidence requests to the deal team.
What the buyer receives
- A program mapping memo showing how the seller's status translates to the receiving program
- An open-item schedule ranking findings by due-date exposure after import
- An evidence chase list for the seller's team while the transaction still gives leverage
Who uses the output
- The transaction lead pricing near-term maintenance exposure into the deal
- The buyer's CAMO or continuing-airworthiness staff preparing program entry
- Investment committees weighing the maintenance status behind the asset model
How the work fits into the transaction or program
The review runs inside technical due diligence and feeds two downstream steps: the commercial negotiation, where due-date exposure becomes price or escrow, and the program bridge the new operator files with its authority after import. Findings closed before signing cost far less than the same findings discovered at program entry.
Start with a single asset
Organize records and a discrepancy register for diligence.
Jurisdiction-specific considerations
ICAO Annex 6 frames the program obligations most registries implement, but the mechanics differ: an EASA operator's AMP is approved through its CAMO arrangements under Regulation 1321/2014, while a US operator works to the program requirements of its certificate under rules such as 14 CFR 121.380 or 135.439. The review notes which approvals are authority-specific and will need re-establishment after import.
Regulatory limits
This is a document review in support of a purchase decision. It does not approve a maintenance program, grant or transfer escalations, produce the bridging analysis submission, or determine that the aircraft is airworthy under any authority.
What this review does not cover
- Authoring the bridging analysis or the new operator's program
- Negotiating purchase-agreement terms or escrow amounts
- Physical inspection of the aircraft or its components
Specific to this review
- Escalations are approvals granted to a specific operator on its own reliability data; at import they generally reset, so the status should be read with intervals reverted.
- A status export is only meaningful with its compile date and program revision attached; missing either, due-date checks cannot be reconstructed.
- Bridging gaps concentrate in component hard times, which sit outside the headline airframe check cycle and get less attention in data rooms.
- The cheapest moment to obtain missing program evidence is before signing, when the seller's records staff are still motivated to respond.
Sources
U.S. Government (eCFR). Air carrier maintenance recordkeeping and retention requirements under Part 121.
U.S. Government (eCFR). Maintenance recordkeeping and retention requirements for Part 135 operators.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
International Civil Aviation Organization. International standards for aircraft operation, including maintenance program and recordkeeping expectations.
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.
Frequently asked questions
Can we rely on the seller's bridging analysis?
It is a useful starting point, but it was built to support the seller's timeline and may assume escalations and interval credits that will not survive the transfer. The review tests those assumptions line by line so the buyer's program entry plan rests on verified status.
Relevant glossary terms
Related pages
Where this fits
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We will walk through your current state, the records or evidence involved, and a scoped first engagement.
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