Operator induction
AD compliance status review when an operator inducts an aircraft
Before an inducted aircraft flies under a new operator's certificate, its AD compliance status has to stand up inside that operator's own tracking system. This review checks the delivered AD status list against applicability, accomplishment evidence, and method-of-compliance references so the continuing-airworthiness team can adopt it with confidence. It takes place during induction, ahead of release into service. Deliverables include a verified status list, an exceptions log, and the evidence requests needed to clear each gap.
When this review is needed
- An aircraft is joining the certificate and its AD status was produced by someone else's tracking system.
- The delivered status list mixes FAA and EASA directives from a previous registration.
- Recurring ADs need next-due dates computed in the operator's system and the source intervals are unverified.
- Entry into service is scheduled and the DOM will not sign the aircraft onto the program against an unproven list.
The problem
An incoming AD status list encodes hundreds of applicability decisions made by a prior operator using its own configuration data, its own supersedure handling, and sometimes its own errors. The receiving operator inherits the list but none of the reasoning behind it. Loading it unverified means the operator's compliance position now rests on judgments it never saw, made against a configuration it has not confirmed.
What gets reviewed
- Applicability of each listed AD against this serial number's actual configuration
- Accomplishment evidence behind each complied-with entry
- Method of compliance recorded for each accomplishment, including AMOCs and their approvals
- Supersedure chains resolved so superseded directives do not mask open requirements
- Recurring ADs with intervals and last-done data sufficient to compute next due
- Open and not-applicable entries with the reasoning documented
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
- Not-applicable calls are supported by configuration or effectivity evidence, never asserted alone
- Each terminating action claimed is the terminating action the AD actually specifies
- AMOC approvals on file match the aircraft, the AD revision, and the method used
- Last-done values for recurring items trace to a dated maintenance record
- The list is complete against the current directive index for the type, engines, and appliances
Evidence normally required
- The delivered AD status list for airframe, engines, APU, and appliances
- Accomplishment records: work orders, task cards, logbook entries, release documents
- Configuration data confirming modification and SB status relevant to applicability
- AMOC approvals and any authority correspondence
- Prior operator contact details for evidence requests
Common discrepancies
- Complied-with entries whose only support is the previous operator's own status list
- A superseded AD marked closed while its superseding directive never entered the tracking system
- Recurring items missing last-done dates, making next-due computation impossible
- Not-applicable calls based on a modification the configuration records do not confirm
What is at stake
An AD adopted as complied-with without accomplishment evidence becomes the operator's finding at its next audit, and an applicability call that was wrong for this serial number can leave a directive genuinely open in service. Correcting either after entry into service costs aircraft downtime; correcting it at induction costs a records request.
How the work runs
Screen the list
Run the delivered status against the current directive index for airframe, engines, and appliances to find omissions first.
Verify status calls
Check applicability, accomplishment evidence, and method of compliance for each entry, prioritizing safety-significant and recurring items.
Resolve recurring items
Confirm intervals and last-done data so next-due dates compute correctly in the receiving system.
Hand over a loadable status
Deliver the verified list, the exceptions log, and the evidence requests that clear the remaining gaps.
What the buyer receives
- A verified AD status list ready to load into the operator's tracking system
- An exceptions log with the evidence gap behind each unverified entry
- Evidence requests addressed to the prior operator or records holder
Who uses the output
- Continuing-airworthiness managers accepting the aircraft onto the program
- The director of maintenance signing the induction package
- Records staff loading and maintaining the AD module going forward
How the work fits into the transaction or program
AD verification is usually the pacing item in an induction records review because open findings here can hold the aircraft on the ground. Its output loads straight into the operator's compliance system, and the exceptions log merges with the wider induction gap list so one closure effort covers every records domain.
Start with a single asset
Reconcile maintenance tracking against the underlying records.
Jurisdiction-specific considerations
An aircraft arriving from an EASA registry carries EASA AD history, and the FAA-registered operator must satisfy 14 CFR Part 39 on FAA directives, including any that never applied under the previous registry. The review runs the list against both indexes when a registry change is involved, because the transfer itself changes which directives govern.
Regulatory limits
The review verifies documentary support for the status list. It does not accomplish ADs, approve methods of compliance, grant AMOCs, or determine that the aircraft is airworthy; those remain with the operator, its maintenance providers, and the authority.
What this review does not cover
- Physical inspection to confirm accomplishment on the aircraft
- Engineering evaluation of alternative methods of compliance
- Ongoing AD tracking after induction is complete
Specific to this review
- Applicability errors cluster around configuration-dependent directives, where a prior modification changes whether the AD applies at all.
- Supersedure is the quietest failure mode in AD lists: the superseded directive shows closed, the superseding one was never loaded, and every summary report looks clean.
- Registry transfers reset the governing directive index, so an aircraft can arrive fully compliant with its old authority and still have open items with its new one.
- The cheapest moment to request missing accomplishment evidence is before the prior operator's records team disbands or archives the file.
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 came with a clean status from a well-run operation. Is verification still worth it?
The list reflects that operator's configuration data and interpretation, applied for its own purposes. Induction is the one point where the receiving operator can test those judgments against evidence before they become its own compliance position, and errors found later cost far more to fix.
Relevant glossary terms
Related pages
Where this fits
Talk to an engineer who has done this work
We will walk through your current state, the records or evidence involved, and a scoped first engagement.
Talk through the aircraft, records, evidence, deadline, and next useful step.