End-of-lease return
AD status records review for lessors at lease return
This review verifies the Airworthiness Directive position of an aircraft coming back from lease before the lessor accepts it. A records specialist works the AD status list against applicability, method of compliance, and accomplishment evidence during the redelivery window. Findings are split between items the delivered evidence supports and items the lessee still owes. The lessor's asset manager gets an exception log, a document request for each open AD line, and a recommended path to close every item before final acceptance.
When this review is needed
- A redelivery date is set and the lessee has started loading AD status reports into the return data room.
- The lease return conditions call for terminating action or a defined AD compliance state that has to be demonstrated on paper.
- The incoming records team suspects the operator's AD list was maintained under conventions the lease never anticipated.
- The next lessee's authority differs from the current one, so the AD position must hold up under both FAA and EASA reading.
The problem
An AD status list at redelivery is the lessee's summary of its own compliance, produced under its conventions and its maintenance system. Lease return conditions are written against the directive itself: applicability by serial number, repetitive intervals, terminating action. Reconciling one against the other line by line, while the return schedule compresses, is exactly the work a lessor's small technical team rarely has capacity for.
What gets reviewed
- Applicability of each AD on the status list confirmed for the airframe, engine, and APU serial numbers being returned
- Method of compliance on each line checked against what the directive actually permits
- Accomplishment evidence located and matched to every AD shown as complied with
- Repetitive AD lines checked for a current, correctly calculated next-due point
- Alternative methods of compliance verified as approved and applicable to this serial number
- Open and not-applicable determinations reviewed against the lease's return conditions
Scope this review
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What gets validated
- Every AD marked terminated points to evidence of the terminating action, and superseded revisions are never cited as the basis
- Compliance dates and times on the status list agree with the task cards or work orders behind them
- AMOC approvals name this operator or carry authority acceptance that transfers with the aircraft
- Engine and APU AD status reflects the currently installed serial numbers, including any mid-lease swaps
- Not-applicable codings carry a stated reason tied to configuration or effectivity rather than a blank field
Evidence normally required
- The AD status list for airframe, engines, and APU as delivered to the return data room
- The lease return conditions and any agreed records standard
- Task cards, work orders, and logbook entries cited as accomplishment evidence
- AMOC approvals, engineering orders, and SB accomplishment records referenced by AD lines
- Current configuration data for installed engines, APU, and affected components
Common discrepancies
- AD lines closed by reference to an SB whose accomplishment paperwork is absent from the delivered package
- Repetitive inspections shown with a next-due figure carried forward from a superseded revision of the directive
- Engine AD status still reflecting a serial number removed during the lease
- Not-applicable determinations recorded without any stated effectivity basis
What is at stake
An AD line accepted without accomplishment evidence becomes the lessor's problem the day the aircraft is signed for. If the next operator's CAMO rejects the position, the cost of reconstructing evidence lands on the lessor, delivery to the follow-on lessee slips, and the commercial team ends up negotiating compensation for a gap that was visible during the return.
How the work runs
Fix the review baseline
Pull the delivered AD status lists and lease return conditions, and lock the aircraft, engine, and APU serial numbers the review will run against.
Trace each line to evidence
Match every complied-with and terminated AD to accomplishment records, and test applicability codings against configuration data.
Issue the exception log
Deliver open items with per-line document requests early enough for the lessee to respond inside the window.
Support closure to acceptance
Re-verify incoming evidence, update the log, and hand the lessor a defensible AD position for final acceptance.
What the buyer receives
- An exception log listing every AD line that lacks supporting evidence, with the exposure noted per item
- A document request the lessee can action, sorted by which items block technical acceptance
- A closure recommendation for each open line, including where an authority query is the honest answer
- A verified AD status view the lessor can hand to the next lessee's CAMO
Who uses the output
- The lessor's asset manager negotiating final acceptance and any compensation for open items
- The technical-records team tracking closure against the redelivery date
- The marketing and placement team representing AD status to the follow-on operator
How the work fits into the transaction or program
AD status is usually the first records topic contested at a lease return because it carries direct regulatory weight for the next operator. This review runs inside the redelivery window, ahead of the physical inspection findings, and its exception log feeds the broader return-condition negotiation alongside the LLP, repair, and program reviews.
Start with a single asset
Start with a single tail and expand once the workflow is proven.
Jurisdiction-specific considerations
FAA directives under 14 CFR Part 39 and EASA ADs follow different numbering, effectivity language, and AMOC processes, and many leases require the return position to satisfy both. Where the aircraft is moving between registries at return, the review reads each AD line the way the receiving authority will, which regularly changes which evidence counts.
Regulatory limits
The review reports what the delivered records support. It does not determine airworthiness, approve an AMOC, sign any compliance statement, or stand in for the acceptance decision of the lessor or the receiving operator's authority.
What this review does not cover
Specific to this review
- A status list can be internally consistent and still wrong for return purposes if it was maintained against the operator's registry rather than the lease's dual FAA and EASA requirement.
- Mid-lease engine substitutions are the most common reason an otherwise clean AD list fails at redelivery, because engine AD status travels with the serial number and the list often does not.
- Terminating-action claims deserve the earliest attention: they change the return condition permanently, and their evidence is the hardest to reconstruct after the lessee's records staff disband.
- AD evidence requests answered late in the window tend to arrive as summaries rather than source documents, so the request list goes out in the first review pass instead of waiting for a final report.
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
Can the review rely on the lessee's AD status report if their CAMO signed it?
A signed status report shows the operator's conclusion, and it is the right starting document. Return conditions are settled on evidence, though, so each line still gets traced to accomplishment records before the lessor treats it as supported. Signature quality varies far less than the paperwork behind it.
How long before redelivery should this start?
Ninety days is workable for a single aircraft with a responsive lessee. Terminating-action items and mid-lease engine changes take the longest to evidence, so if either is present, earlier is better.
Relevant glossary terms
Related pages
Where this fits
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