STC certification
Compliance matrix support for an STC program
This review readies the compliance matrix at the center of an STC submittal, so every requirement in the certification basis maps to a means of compliance and to evidence that still supports the claim. It is run for an aircraft modifier or equipment supplier as the submittal is assembled. The work checks that coverage is complete against the basis, that each cited document is the current revision, and that no matrix entry rests on evidence a later change made stale. You receive a gap assessment against the certification basis, an evidence map from each requirement to its supporting record, and a closure plan for the entries whose evidence no longer holds.
When this review is needed
- The submittal is being compiled and the matrix has to show every basis requirement addressed before it goes in.
- The certification basis changed during the program and the matrix still reflects the earlier set.
- Evidence was regenerated after a design change and the matrix may still cite the superseded version.
- The same modification is being submitted to two authorities and the matrix has to satisfy both bases.
The problem
A compliance matrix is a living document treated as a static one. Requirements move as the basis is negotiated, evidence is regenerated as the design settles, and the matrix that once tied them together lags both. Entries end up citing a test report revision that a design change invalidated, or claiming a means for a requirement that the basis later dropped. The matrix looks complete because every row is filled, while some of those rows point at evidence that no longer says what the row claims.
What gets reviewed
- Coverage of every requirement in the current certification basis, with none unaddressed
- The means of compliance assigned to each requirement checked for suitability to the claim
- Each cited evidence document confirmed as the current revision that still supports its row
- Entries invalidated by a later design or basis change flagged and routed to closure
- Cross-referenced evidence shared across rows checked for consistency in every place it appears
- Requirements without an evidence path collected into a closure plan
Scope this review
Tell us the asset, the event, and the evidence in scope, and we will outline a focused first engagement.
Identify what is missing against the means of compliance.
What gets validated
- Every requirement in the current basis appears in the matrix with an assigned means and evidence
- Each cited document is the revision in effect, not one a later change superseded
- The means assigned to a requirement is appropriate to what that requirement demands
- Evidence cited in more than one row supports the claim consistently in each
- No matrix row claims compliance against a requirement the current basis no longer contains
Evidence normally required
- The current certification basis and any issue papers that changed it
- The draft compliance matrix with its current citations
- The evidence documents the matrix references, at their current revisions
- The certification plan defining the intended means of compliance
- The design change history that may have invalidated earlier evidence
Common discrepancies
- A row citing a test report revision that a later design change invalidated
- A requirement in the current basis that never made it into the matrix
- A means assigned that does not actually address what the requirement demands
- The same evidence cited in two rows supporting them inconsistently
What is at stake
A matrix built on stale citations fails at the point of examination: a reviewer opens a cited document, finds it does not support the row, and the confidence in every other row drops. Missing coverage against a changed basis means a requirement reaches submittal with no means assigned, which becomes an open finding that delays the approval. Reconciling the matrix late, under review pressure, costs far more than keeping it current would have.
How the work runs
Pin the current basis
Establish the certification basis as it now stands, including any issue-paper changes.
Check coverage
Confirm every current requirement appears in the matrix with an assigned means.
Revalidate the citations
Open each cited document and confirm it is the current revision that still supports its row.
Plan the gaps
Collect uncovered requirements and stale rows into a closure plan with owners.
What the buyer receives
- A gap assessment of coverage and stale citations against the current basis
- An evidence map from each requirement to its current supporting document
- A closure plan for the rows whose evidence or coverage does not hold
Who uses the output
- Certification leads compiling the matrix into the STC submittal
- Engineering owners responsible for the evidence each row cites
- Program managers tracking how much of the basis is genuinely covered
How the work fits into the transaction or program
The matrix is the index into the whole compliance argument, so this review runs as the submittal is assembled, after the certification plan set the means and the evidence was generated. It pulls together the means-of-compliance map, the requirement trace, and the verification evidence, and its closure plan defines the coverage work that has to finish before the submittal is complete.
Start with a single asset
Reduce finding cycles by checking the package first.
Jurisdiction-specific considerations
An STC pursued under both FAA and EASA bases has to satisfy two requirement sets that overlap but do not match, so the review keeps the matrix able to show coverage against each basis rather than blending them into a single view that satisfies neither authority cleanly.
Regulatory limits
The review reconciles the matrix to the current basis and confirms each row's evidence holds. It does not find compliance, accept a means on the authority's behalf, or grant the STC.
What this review does not cover
- Generating the evidence a row needs or performing the underlying tests
- Negotiating the certification basis with the authority
- Any authority finding of compliance or STC approval
Specific to this review
- A full matrix is not a complete one: every row can be filled while some rows cite evidence a later change made stale.
- The certification basis moves during the program, so coverage has to be checked against the current basis, not the one the matrix was first built against.
- Evidence shared across rows is a frequent failure point, because regenerating it for one row can silently break the others that still cite the old version.
Sources
U.S. Government (eCFR). Type certificates, STCs (Subpart E), TSO authorizations (Subpart O), PMA (Subpart K), and export airworthiness approvals (Subpart L).
Federal Aviation Administration. STC application process, certification basis, and continued airworthiness obligations of an STC holder.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
RTCA. Environmental qualification test categories and procedures referenced by TSO and equipment qualification.
Federal Aviation Administration. FAA type certification process, certification basis establishment, and compliance findings.
Frequently asked questions
The matrix has every row filled. Why review it?
A filled row proves someone assigned a means and a citation, not that the citation still holds. Requirements and evidence both move during a program, so a complete-looking matrix can rest on documents a later change invalidated or on a basis that has since shifted. The review confirms each row against the current basis and current evidence.
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.