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Pilot/owner maintenance under part-ML: rights, obligations and practical implementation

Last updated on 14 April 2025
General aviation in Europe benefits from simplified regulations that allow pilots and owners to carry out certain maintenance work on their aircraft themselves. This possibility is regulated in Annex Vb (Part-ML) of Regulation (EU) No 1321/2014. This article highlights the legal basis, requirements and practical aspects of pilot/owner maintenance.

Legal framework: Part-ML of Regulation (EU) No 1321/2014

Part-ML was introduced to simplify the maintenance requirements for certain general aviation aircraft. It applies to ELA1 and ELA2 aircraft that are not operated commercially. The regulation allows pilots and owners to carry out maintenance work themselves under certain conditions without having to commission a certified maintenance organisation.

In addition to the legal provisions, the European Union Aviation Safety Agency (EASA) provides Acceptable Means of Compliance (AMC) and Guidance Material (GM). These documents provide practical instructions for implementing the regulations, but are not legally binding. They serve as recommended procedures that can be deviated from if the legal requirements are nevertheless met.


Prerequisites for carrying out maintenance work

Pilots and owners who wish to carry out maintenance work themselves must fulfil the following requirements.

  • QualificationThe pilot or owner must have sufficient knowledge and skills to carry out the specific maintenance work safely and correctly.
  • ResponsibilityThe pilot or owner bears full responsibility for the proper execution of the work and the subsequent release of the aircraft for operation.
  • DocumentationAll work carried out must be documented in detail and recorded in the logbook or a corresponding maintenance record.
  • Maintenance programmeThe work must be in accordance with the aircraft's approved maintenance programme.

Scope of authorised maintenance work

Not all maintenance work may be carried out by pilots or owners themselves. EASA has published a list of authorised tasks, which typically include simple and routine work, such as

  • Changing the oil and oil filter
  • Replacing spark plugs
  • Changing air filters
  • Simple electrical repairs, such as replacing light bulbs
  • Voltage test of the battery

More complex work, especially work involving safety-relevant systems, must be carried out by certified maintenance organisations.


Documentation and release

On completion of the maintenance work, the pilot or owner must issue a certificate of release to service confirming that the work has been carried out in accordance with the applicable regulations and that the aircraft is ready for operation again. This certificate should contain the following information.

  • Description of the work carried out
  • Date of realisation
  • Name and signature of the pilot or owner performing the flight
  • Reference to the corresponding maintenance programme

The documentation must be stored carefully, as it must be presented during inspections by the aviation authorities.


Significance for general aviation

The option of pilot/owner maintenance offers several advantages.

  • Cost savings: Maintenance costs can be reduced through in-house labour.
  • FlexibilityPilots and owners can carry out maintenance work independently of the availability of external service providers.
  • Technical understandingDirect contact with your own aircraft promotes technical understanding and sensitivity to the condition of the aircraft.

However, this responsibility also requires a high degree of care and expertise in order not to jeopardise the safety of flight operations.


Further resources

For detailed information and specific instructions, we recommend consulting the following resources.DAeC

Regulation (EU) No 1321/2014: EUR-LexEUR-Lex

Luftfahrt-Bundesamt (LBA): Pilot/owner maintenanceLBA+2LBA+2LBA+2

EASA: Acceptable Means of Compliance and Guidance MaterialAviation Stack Exchange+2EASA+2EASA+2


Source references:
LBA

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