Buyer-side induction
Repair and alteration records review at induction for acquisition teams
After closing, an acquisition team inducting its new aircraft has to confirm that every repair and alteration on the airframe carries approved data and a proper return to service. This review maps structural repairs and alterations against damage reports, dispositions, and the approval basis for each one. It is performed at induction, while seller obligations may still be enforceable. The transaction lead gets a repair map keyed to evidence, an exceptions schedule, and a plan to resolve each unsupported item.
When this review is needed
- Closing ran to a deadline and the repair file was accepted with less scrutiny than the deal team wanted.
- The dent-and-buckle chart shows structure the delivered records do not explain.
- An STC or major alteration in the history lacks its approval package in the file received at handover.
- The aircraft is entering its new program and repairs must be classified and substantiated before the first heavy check.
The problem
Repair documentation is the records domain where diligence sampling misses the most, because repairs are scattered through decades of work orders rather than summarized on a status list. After closing, the acquisition team owns whatever the airframe carries: repairs inside SRM limits, repairs that needed engineering approval, and alterations whose data may or may not exist. The window in which the seller can still be compelled to produce documents is closing while the induction schedule advances.
What gets reviewed
- The repair map or dent-and-buckle chart reconciled against repair records
- Each significant repair matched to damage report, disposition, and approved data
- The approval basis identified per repair: SRM within limits, engineering approval, or other approved data
- Major alterations and STCs matched to their approval packages and ICA
- Return-to-service entries confirmed for repair and alteration events
- Recurring-inspection requirements arising from repairs carried into the program
Scope this review
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What gets validated
- Every mapped repair has a documented disposition that cites its approved data
- Repairs claimed as within SRM limits actually fall inside the cited limits for that structure
- Engineering approvals on file match the repair as described in the accomplishment records
- Alterations have complete approval packages, including any required ICA and flight-manual supplements
- The chart and the paper trail describe the same set of repairs, with neither showing items the other lacks
Evidence normally required
- Dent-and-buckle chart or repair map as delivered at closing
- Repair records: damage reports, dispositions, work orders, and approved-data references
- STC and major-alteration packages with associated ICA
- Airframe logbooks and return-to-service entries
- The purchase agreement's records provisions, to frame what can still be demanded of the seller
Common discrepancies
- Chart entries with no corresponding repair record anywhere in the delivered file
- A repair dispositioned as within SRM limits on structure the cited SRM section does not cover
- Alterations embodied years ago whose ICA never entered the maintenance program
- Approved-data references that point to documents the file does not contain
What is at stake
An unsubstantiated repair discovered at the first heavy check stops the check while engineering resolves it, and resolution can mean re-approving the repair or reworking it. At the next sale, unexplained structure on the dent-and-buckle chart invites the buyer's reviewers to assume the worst and price accordingly. Post-closing remedies against the seller expire; the exposure does not.
How the work runs
Reconcile chart and file
Compare the repair map against the delivered repair records in both directions to define the true population.
Substantiate each repair
Match damage, disposition, approved data, and return to service for every significant entry.
Verify alterations
Confirm approval packages and ICA for STCs and major alterations, and check the ICA reached the program.
Split and route findings
Send recoverable gaps toward the seller under the agreement, and carry confirmed data into the program entry.
What the buyer receives
- A repair map keyed line by line to the evidence supporting each entry
- An exceptions schedule stating the substantiation gap and its program impact
- Seller evidence requests drafted while remedies remain live
- Program inputs listing repair-driven recurring inspections for the new operator
Who uses the output
- Transaction leads pursuing post-closing remedies before they lapse
- Due-diligence engineers closing out the acquisition technical file
- The receiving operator's engineering group planning the first heavy check
How the work fits into the transaction or program
This review runs in the seam between closing and program entry, where the buyer still has contractual leverage and the aircraft has not yet absorbed the cost of an unplanned engineering exercise. Its outputs split two ways: exceptions with recoverable documents go back toward the seller, and confirmed repair data flows forward into the maintenance program and the aircraft's permanent file.
Start with a single asset
Organize records and a discrepancy register for diligence.
Jurisdiction-specific considerations
What counts as approved data differs by regime: FAA practice recognizes DER-approved data and field approvals that have no direct EASA equivalent, while EASA repairs may rest on design-organization approvals unfamiliar to FAA-oriented reviewers. The review states the approval basis in the terms of the regime that granted it, then notes where a future registry change would reopen the question.
Regulatory limits
The review establishes what the records substantiate about each repair and alteration. It does not approve repairs, generate or validate repair data, classify damage, or determine airworthiness; engineering dispositions remain with approved design organizations and the authority.
What this review does not cover
- Physical survey of the airframe or non-destructive inspection
- Engineering re-approval of repairs found unsubstantiated
- Negotiating the post-closing claims themselves
Specific to this review
- Repair findings age badly: a document a seller could produce in the month after closing is often unrecoverable a year later when the shop that held it archives or purges its files.
- The dent-and-buckle chart and the repair file drift apart in both directions, so structure with no paper is only half the problem; paper describing repairs absent from the chart also has to be explained.
- ICA from old alterations are a recurring audit finding because the alteration predates the current operator, and each program transition assumed the previous one had captured them.
- Repairs approved under one regime's mechanisms can be perfectly valid yet undocumentable to the standards of another, which matters the day the aircraft changes registry.
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.
Frequently asked questions
Why do this at induction if diligence already sampled the repair file?
Sampling before closing prices the risk; it does not clear it. Induction is when the full population gets reconciled, and it is the last period in which the purchase agreement gives the buyer a practical way to force missing documents out of the seller.
Relevant glossary terms
Related pages
Where this fits
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