Ownership handover
Owner-handover records review
An owner-handover records review confirms that an aircraft's records pass completely and consistently to a new owner or managing party at a change of custody. It is used at a change of ownership or when the party managing the records changes under a management arrangement. It checks that the set is complete and current, that AD and LLP status are supported, and that continuity is preserved across the handover so nothing falls between the outgoing and incoming custodians. You receive a handover inventory, a continuity gap list, and the items the outgoing party should resolve before custody passes.
When this review is needed
- Ownership of an aircraft is changing and the records have to pass to the new owner.
- The party managing the records is changing under a management arrangement.
- The incoming custodian wants to confirm what it is inheriting before taking responsibility.
- The outgoing party wants a clean handover that closes its responsibility cleanly.
The problem
A change of custody is where records quietly go missing. The outgoing owner or manager holds parts of the set on its own systems, at its own bases, and in its own filing, and the incoming party inherits whatever is handed across. Without a structured handover, status lists arrive without the source documents behind them, recent entries are still in the outgoing system, and the new custodian discovers months later that continuity broke at the moment of transfer, when the outgoing party is no longer responsive.
What gets reviewed
- Inventory of the complete records set to be handed across
- Currency of AD and LLP status as of the handover date
- Authorized release certificates for components installed before handover
- Maintenance entries from recent work still held in the outgoing party's systems
- Continuity of logbooks and status lists across the custody boundary
- The maintenance program and any open work at the point of transfer
Scope this review
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What gets validated
- The handed-over set is inventoried so nothing the outgoing party holds is left behind
- AD and LLP status is current as of the handover date and supported by evidence
- Entries from recent work in the outgoing party's systems are captured before custody passes
- Component releases are present for parts installed before the handover
- Logbook and status continuity holds across the custody boundary with no missing window
- Open work at handover is documented so the incoming party can pick it up
Evidence normally required
Common discrepancies
- Recent maintenance recorded only in the outgoing party's system and not handed across
- Status lists handed over without the source documents that support them
- Component releases for late installations still held by the outgoing party
- A continuity break in logbooks at the custody boundary
- Open work in progress with no handover note for the incoming custodian
- AD or LLP status not refreshed to the actual handover date
What is at stake
A handover that leaves continuity gaps makes them the incoming party's problem to solve without the outgoing party's cooperation. Maintenance done shortly before transfer can sit unrecorded in a system the new custodian cannot reach, and reconstructing the missing window is slow once the relationship has ended.
How the work runs
Inventory the set
Catalogue the complete records set the outgoing party holds so nothing is left behind at the custody boundary.
Refresh to the date
Confirm AD and LLP status is current as of handover and capture recent entries still in the outgoing system.
Check continuity
Verify logbooks and status lists carry across the boundary without a missing window or unsupported summary.
Action the outgoing party
List what the outgoing party must supply or close before custody passes while it is still engaged.
What the buyer receives
- A handover inventory of the complete set passing to the new custodian
- A continuity gap list covering the custody boundary
- An action list for the outgoing party to resolve before custody passes
Who uses the output
- Incoming owners and managers confirming what they inherit
- Outgoing parties closing their responsibility cleanly
- Records teams establishing the baseline for ongoing custody
How the work fits into the transaction or program
The review runs at the custody boundary so continuity is confirmed while the outgoing party is still engaged and able to supply what it holds. It establishes the records baseline the incoming custodian manages from and closes the outgoing party's responsibility.
Start with a single asset
Start with a single tail and expand once the workflow is proven.
Aircraft-specific considerations
The handover risk concentrates wherever recent activity sits. For an aircraft that has just come through a shop visit or modification, the priority is capturing the new entries and releases before they are stranded in the outgoing party's system.
Jurisdiction-specific considerations
If the handover coincides with a change of operating authority, the review confirms the set is complete and current first, so the separate program or registry work starts from a clean baseline rather than chasing missing recent entries later.
Regulatory limits
The review confirms completeness, currency, and continuity at handover. It does not transfer ownership, make an airworthiness determination, or take on the custodian's recordkeeping responsibility. Those remain with the parties to the handover.
What this review does not cover
- Execution of the ownership or management transfer itself
- Ongoing recordkeeping after the handover is complete
- Any airworthiness determination or regulatory approval
Specific to this review
- A change of custody is the point where recent entries are most at risk, because they often still sit in the outgoing party's system at the moment of transfer.
- The incoming custodian inherits whatever is handed across, so confirming continuity at the boundary is cheaper than reconstructing a missing window afterward.
- Status lists frequently arrive at handover without the source documents, leaving the new custodian holding a summary it cannot yet support.
Sources
U.S. Government (eCFR). Requirement to transfer maintenance records with an aircraft on sale or transfer of ownership.
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.
U.S. Government (eCFR). Maintenance recordkeeping content and approval-for-return-to-service requirements, including 43.9, 43.11, and Appendix B.
Federal Aviation Administration. FAA guidance on making and keeping maintenance records and acceptable recordkeeping practices.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
Frequently asked questions
How is a handover review different from a sale records review?
A sale review prepares records to withstand a buyer's diligence. A handover review confirms the set passes completely and continuously to a new custodian at the moment of transfer, with the focus on continuity across the boundary rather than negotiating leverage.
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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