Module 10.1 — Regulatory framework: ICAO, EU, EASA and the Parts
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Exam context
Module 10 is taken by every category. EASA papers (Reg. (EU) 2023/989): A 32 questions / 40 min; B1, B2, B2L, B3 44 questions / 55 min; no essay. UK CAA retained papers: A 32 MCQ, B1/B2 40 MCQ, B3 32 MCQ, each plus one essay (20 min). 10.1 is level 1 — know who does what and how the documents fit together.
The international level — ICAO
- The International Civil Aviation Organization was created by the Chicago Convention (1944); it is a UN specialised agency based in Montreal.
- ICAO publishes Standards and Recommended Practices (SARPs) in 19 Annexes to the Convention. Contracting States must implement Standards or notify differences.
- Annexes most relevant to maintenance:
| ICAO Annex | Subject |
|---|---|
| Annex 1 | Personnel licensing (includes aircraft maintenance licences) |
| Annex 6 | Operation of aircraft (operator maintenance responsibilities) |
| Annex 7 | Aircraft nationality and registration marks |
| Annex 8 | Airworthiness of aircraft |
| Annex 13 | Aircraft accident and incident investigation |
| Annex 16 | Environmental protection (noise, emissions) |
| Annex 19 | Safety management |
- ICAO audits States' safety oversight (USOAP). ICAO itself does not issue licences or approve organisations — States do.
The European level
European Commission (EC)
- Proposes EU legislation; the Basic Regulation is adopted by the European Parliament and Council.
- Adopts implementing and delegated acts (e.g. Reg. (EU) No 1321/2014 and its amendments such as 2023/989), normally based on an EASA Opinion.
- Negotiates bilateral agreements with third countries on behalf of the EU.
European Union Aviation Safety Agency (EASA)
- Established in 2002 (now governed by Regulation (EU) 2018/1139, which replaced Reg. (EC) 216/2008); headquarters in Cologne.
- Main roles:
- drafts rules and submits Opinions to the Commission;
- issues ED Decisions containing CS, AMC and GM (soft law);
- type certification of products (TC, STC), approval of design organisations (DOA) and of some production organisations;
- approves organisations located outside the EU (e.g. third-country Part-145, Part-147, CAMO);
- standardisation inspections of national authorities to ensure uniform application;
- issues airworthiness directives (ADs) for products it certificates;
- safety analysis and research, international co-operation.
Member States and national aviation authorities (NAAs / competent authorities)
- Issue and oversee Part-66 licences (EASA Form 26), approve organisations with their principal place of business in that State (Part-145, Part-147, CAMO, CAO), register aircraft, issue certificates of airworthiness, ARCs (where they perform the review) and permits to fly.
- Perform oversight of the organisations and persons they certify (see 10.8).
- A Member State can be the "competent authority" for several regulatory functions; it may also delegate some tasks to qualified entities.
Bilateral agreements
The EU concludes agreements to accept each other's certificates and avoid duplicate oversight, e.g. the EU–USA BASA (Bilateral Aviation Safety Agreement, with a Maintenance Annex allowing FAA-approved repair stations to hold EASA Part-145 approval with reduced oversight, and vice versa), and agreements with Canada, Brazil, Japan and China. They cover design, production and/or maintenance acceptance to differing extents — always check the scope of the specific annex.
The Basic Regulation (EU) 2018/1139
- Sets essential requirements (Annex II for airworthiness) and the scope of EU competence.
- Applies to civil aircraft designed, produced, maintained or operated in the EU, except:
- aircraft in State service (military, customs, police, search and rescue, fire-fighting, coastguard) — Member States may opt to apply EU rules;
- Annex I aircraft — e.g. historic aircraft (design before 1 January 1955 and production stopped before 1 January 1975, or clear historical relevance), research/experimental aircraft, amateur-built (at least 51 % built by amateurs), ex-military (unless type has an EASA design standard), very light aeroplanes/helicopters with no more than two seats (MTOM up to 300 kg single-seat / 450 kg two-seat landplane), single and two-seat gyroplanes up to 600 kg, replicas, small balloons and airships, aircraft with empty mass (including fuel) up to 70 kg. These remain under national rules (see 10.9).
- Implementing acts relevant to Module 10:
| Regulation | Content |
|---|---|
| (EU) No 748/2012 — Initial Airworthiness | Annex I Part 21 (design, production, certificates, ETSO); Annex Ib Part 21 Light |
| (EU) No 1321/2014 — Continuing Airworthiness | Annex I Part-M; II Part-145; III Part-66; IV Part-147; Va Part-T; Vb Part-ML; Vc Part-CAMO; Vd Part-CAO |
| (EU) No 965/2012 — Air Operations | Part-ARO, ORO, CAT, SPA, NCC, NCO, SPO |
| (EU) No 1178/2011 — Aircrew | Part-FCL (pilot licences), Part-MED |
| (EU) No 376/2014 — Occurrence reporting | Mandatory and voluntary reporting, just culture |
| (EU) 2023/203 and Delegated (EU) 2022/1645 — Part-IS | Information security (cybersecurity), see 10.10 |
Key fact: Regulation (EU) No 1321/2014 annexes: I Part-M, II Part-145, III Part-66, IV Part-147, Va Part-T, Vb Part-ML, Vc Part-CAMO, Vd Part-CAO.
Hard law and soft law
| Document | Status | Issued by |
|---|---|---|
| Basic Regulation, Implementing Rules (IR), Delegated Acts | Binding (hard law), published in the Official Journal | EU legislator / Commission |
| AMC — Acceptable Means of Compliance | Non-binding; using it gives a presumption of compliance with the IR | EASA (ED Decision) |
| AltMoC — Alternative Means of Compliance | Allowed if it achieves compliance; must be approved by / notified to the competent authority | Organisation / authority |
| GM — Guidance Material | Non-binding; explains meaning of a requirement | EASA |
| CS — Certification Specifications | Technical standards for certification of products (CS-23, CS-25 …); they become part of the type-certification basis | EASA |
Rule numbering convention: in the Parts, Section A contains requirements for persons and organisations (e.g. 145.A.30); Section B contains procedures for competent authorities (e.g. 145.B.300).
Occurrence reporting — Regulation (EU) No 376/2014
- Establishes mandatory reporting (listed occurrence categories — the list for maintenance includes, for example, incorrect assembly of parts, serious damage found, failures of primary structure) and voluntary reporting.
- Reports normally within 72 hours of becoming aware.
- Information is stored in national databases and the European Central Repository.
- Protects reporters: just culture — reporters are not to be blamed for unpremeditated or inadvertent infringements, except for gross negligence.
How the Parts fit together
- Part 21 — the aircraft is designed and built (type certificate, production, CofA).
- Part-M / Part-ML — the owner/operator keeps it airworthy (maintenance programme, records, ADs, ARC). Part-ML is the simpler version for light aircraft not used by licensed airlines (aeroplanes up to 2 730 kg MTOM, rotorcraft up to 1 200 kg and max 4 occupants, other ELA2 aircraft).
- Part-CAMO / Part-CAO — the organisations managing continuing airworthiness (Part-CAO can also maintain light aircraft).
- Part-145 — the organisations performing maintenance (mandatory for large aircraft and aircraft used by airlines).
- Part-66 — licences for the certifying staff working in them; Part-147 — training organisations delivering the basic and type courses and exams for Part-66.
- Part-T — continuing airworthiness of third-country registered aircraft used by EU air carriers.
- Air OPS (965/2012) — operators' responsibilities, including MEL and continuing-airworthiness responsibilities; Aircrew (1178/2011) — pilots (e.g. pilot-owner maintenance under Part-ML relies on a pilot licence).
UK note
After 31 December 2020 the UK retained these regulations as UK law ("UK Part-66" etc.) overseen by the UK CAA; the UK did not adopt Reg. (EU) 2023/989. The UK Air Navigation Order 2016 covers national matters. UK Module 10 essays often ask for the relationship between the regulations or the duties of the authority.
Essay tips (UK CAA Module 10)
Prompt examples: "Describe the relationship between ICAO, the regulator and the Parts"; "Explain the status of AMC and GM". Structure: define each body → its main tasks → how its outputs feed the next level (SARPs → Basic Regulation → IRs → AMC/GM) → an example (e.g. Part-66 licence requirements implementing ICAO Annex 1).