Register changes
AD status review for lessors importing an aircraft to a new register
A lessor placing an aircraft with a lessee in another jurisdiction faces a receiving authority that will read the AD records on its own terms. This review prepares that position in advance: it maps the compliance history onto the directives the new state of registry recognizes, verifies accomplishment evidence for the lines the authority is most likely to probe, and pre-drafts the substantiation for anything unusual, such as AMOCs or method deviations. The lessor's transition team receives an import-ready AD file, a mapped status list in the receiving authority's frame of reference, and a short list of exposures with recommended closure routes.
When this review is needed
- The next lease places the aircraft on a register it has never been on, and the AD file was built for a different authority's expectations.
- Deregistration and import dates are fixed in the lease and an authority question cycle would eat the margin between them.
- The compliance history includes AMOCs or alternative methods that the receiving authority has not seen before.
- The aircraft's directives history spans FAA and EASA issuance and nobody has reconciled the two into one defensible position.
The problem
Import reviews are asymmetric: the receiving authority can ask anything, and every question stops the clock. An AD file that satisfied the previous registry perfectly can still generate weeks of correspondence, because the new authority numbers directives differently, treats state-of-design issuances differently, and expects substantiation in its own format. The lessor sits in the middle, paying for a parked aircraft while answers are hunted through archives belonging to a lessee that has already redelivered.
What gets reviewed
- The compliance history translated into the directive set applicable under the receiving state of registry
- State-of-design directives distinguished from state-of-registry adoptions, with differences reconciled
- Accomplishment evidence assembled for high-attention lines: structures, fuel systems, aging aircraft items
- AMOC and deviation history compiled with the approvals and their applicability to this import
- Recurring directive positions restated with next-due points in the receiving authority's terms
- The import file structured to answer the receiving authority's standard document requests
Scope this review
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What gets validated
- Every directive the receiving registry recognizes as applicable has a stated position: complied, recurring, superseded, or not applicable with basis
- Accomplishment records for probed-category ADs are legible, signed, and complete enough to stand alone
- AMOCs relied on remain valid for the new registry or are flagged for re-approval before import
- Supersedure chains are followed to the current directive revision rather than stopping at an old compliance entry
- Directive positions for engines and APU reflect the serial numbers actually delivering with the aircraft
Evidence normally required
- The full AD status lists and compliance archive from the redelivering operator
- The receiving state's applicable directive listing for the type, engines, and appliances
- AMOC grants, deviation approvals, and related correspondence
- Accomplishment records for structural, fuel-system, and other recurrent high-scrutiny ADs
- The transition timetable: deregistration, import review, and lease delivery dates
Common discrepancies
- Directives adopted with modified compliance times by the receiving state, leaving a line compliant on the old register and overdue on the new one
- An AMOC central to the compliance position that has no equivalent acceptance under the receiving authority
- Accomplishment evidence that exists but cannot be tied to the aircraft without the redelivering operator's system context
- A supersedure missed years ago, so compliance is recorded against a directive revision no longer in force
What is at stake
Each unanswered authority query extends the ground time between redelivery and revenue, and lease start dates slip with it. A weak answer invites a broader sample, turning one question into a file-wide examination. In the worst cases the import stalls until a directive is re-accomplished for want of findable evidence, work the lessor pays for twice.
How the work runs
Map the frameworks
Build the receiving registry's applicable directive list and align the existing compliance history against it.
Verify the evidence
Pull and test accomplishment records for the lines the authority is likeliest to question.
Close the deltas
Identify positions that do not survive the mapping and route each to re-approval, re-accomplishment, or substantiation.
Stage the file
Assemble the import package in review order with pre-drafted answers for the predictable questions.
What the buyer receives
- An import-ready AD file organized around the receiving authority's review sequence
- A mapped status list restating the aircraft's position in the new registry's directive framework
- An exposure summary with a recommended closure route and owner for each open point
Who uses the output
How the work fits into the transaction or program
This work runs in the window between redelivery acceptance and the import submission, when the outgoing operator's archive is still reachable and the incoming lessee's authority process has not yet started. A prepared file compresses the authority question cycle, and the exposure summary lets the transition manager sequence fixes against the deregistration date instead of discovering them after it.
Start with a single asset
Start with a single tail and expand once the workflow is proven.
Jurisdiction-specific considerations
14 CFR Part 39 makes directives binding for FAA-registered aircraft, while EASA-registered aircraft answer to EASA-adopted directives under the Regulation 1321/2014 framework; the same physical airplane can therefore owe different paper depending on the register. Import between these systems turns on how each authority treats the other's issuances and approvals, and on evidence formats the receiving reviewer can accept without translation.
Regulatory limits
The review organizes and verifies compliance evidence for presentation. It does not accomplish or close directives, does not obtain AMOC acceptance from the receiving authority, and does not issue any certificate of airworthiness or registration; those outcomes belong to the operator, the shop, and the authorities involved.
What this review does not cover
- Performing or arranging maintenance to close open directives
- Filing the registration or import applications themselves
- Fleet-wide AD management beyond the transitioning aircraft
Specific to this review
- Identical directives can carry different compliance deadlines on different registers, so a compliant aircraft can land on a new registry already late.
- Authorities probe by category, and structures, fuel-tank safety, and aging-aircraft directives draw evidence requests far more often than avionics lines.
- An AMOC is an approval from a specific authority; the receiving registry may accept it, require re-application, or reject the method outright.
- The question cycle is sequential, one answer unlocking the next request, which is why response readiness matters more than file size.
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.
Frequently asked questions
The aircraft was fully compliant at redelivery. What could an import review still find?
Compliance is measured against a register. A register change re-scores the same history against a different directive set, different adopted deadlines, and different approval acceptances, so findings at import are usually mapping problems rather than maintenance problems. They still ground the timetable if discovered late.
Relevant glossary terms
Related pages
Where this fits
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