Definition
Part-CAO is contained in Annex Vd to Commission Regulation (EU) No 1321/2014 and was created to simplify the organizational landscape for the general-aviation end of the industry. Before it existed, a small maintenance shop or aeroclub that wanted to both manage airworthiness and turn the spanners had to hold two separate approvals — a CAMO (or Part-M Subpart G) approval for the management side and a Part-145 or Part-M Subpart F approval for the maintenance side — each with its own manual, audits and oversight. Part-CAO collapses those into a single approval with a single management structure, single exposition and single competent-authority oversight.
A CAO can hold either or both of two functions. The continuing-airworthiness management function mirrors what a CAMO does: developing and approving the Aircraft Maintenance Programme, tracking airworthiness directives and modifications, managing records and, where privileged, conducting airworthiness reviews and issuing or recommending the Airworthiness Review Certificate. The maintenance function mirrors what a Part-145 or the former Subpart-F organization does: performing scheduled and unscheduled maintenance and issuing the release to service (CRS) on the aircraft or components. An organization can be approved for just one function or for both combined — hence the name.
The scope is deliberately bounded. A CAO may only work on aircraft that are not classified as complex motor-powered aircraft and that are not listed on the air operator certificate of an air carrier licensed under Regulation (EC) No 1008/2008. In practice that means the same light general-aviation population served by Part-ML — piston singles and twins, light helicopters, sailplanes and balloons. Aircraft on a commercial air transport AOC, and complex aircraft generally, still need a full CAMO plus Part-145 arrangement. Application is made to the competent authority, typically on an EASA Form 2.
Part-CAO suits GA maintenance shops, small ATOs and aeroclubs that want to keep both the airworthiness decision-making and the hands-on work in-house without carrying two parallel approvals. It reduces duplicated procedures and audit effort while preserving the core separation of responsibilities inside the organization. A CAO holding both functions still has to describe, in its single exposition, how the management side decides what maintenance is due and how the maintenance side performs and releases it — the two roles are combined administratively but not blurred technically.
Part-CAO fits alongside the wider continuing-airworthiness picture rather than replacing any of it. The aircraft themselves are still maintained under Part-M or Part-ML, the certifying staff who sign the release to service still hold the relevant Part-66 licence privileges, and the airworthiness review still produces an Airworthiness Review Certificate. What the CAO changes is the shape of the organizational approval that sits over those activities, not the airworthiness standards underneath them. There is no direct FAA analogue: in the US the equivalent activities are covered by a repair station certificate under 14 CFR Part 145 combined with the owner/operator's own airworthiness responsibilities under Part 91, rather than by a single combined organizational approval.
Why It Matters for Flight Schools
For a small European flight school or aeroclub, the choice between a CAO and the CAMO-plus-Part-145 route is a real operational and cost decision. Holding two approvals means two management systems, two sets of procedures and two audit cycles, all resting on a handful of the same people. A single CAO approval lets a school manage the airworthiness of its trainers and perform much of the maintenance under one roof, one exposition and one accountable manager — which is often the difference between keeping maintenance in-house and outsourcing it.
The combined structure does not dilute the underlying obligations. A CAO still has to demonstrate an effective Aircraft Maintenance Programme, current AD status, a proper release to service for every task, and valid airworthiness reviews. When the competent authority audits a CAO, it looks at both the management and the maintenance sides through one lens, so the organization's records have to join up cleanly — the management function's decisions have to trace directly to the maintenance function's completed work.
How Aviatize Handles This
Aviatize's Maintenance Control and Maintenance Execution modules map naturally onto the two halves of a CAO. Maintenance Control handles the management function — the Aircraft Maintenance Programme, interval and life tracking, AD status and airworthiness-review scheduling — while Maintenance Execution captures the work order, the tasks performed and the release to service. Because both live in one system, the audit trail an authority expects from a combined organization stays connected end to end.
For a school or aeroclub running a CAO, Digital Data & Records and Compliance & Auditing keep the exposition-driven evidence in one place, so demonstrating that management decisions and maintenance actions line up becomes a matter of retrieval rather than reconstruction.
Frequently Asked Questions
- What is a Part-CAO approval?
- A Combined Airworthiness Organisation approval, set out in Annex Vd to Regulation (EU) No 1321/2014, lets one organization hold continuing-airworthiness management privileges, maintenance privileges, or both, under a single certificate — for non-complex aircraft that are not on a commercial air transport AOC.
- What is the difference between a CAO and a CAMO plus Part-145?
- A CAMO manages continuing airworthiness and a Part-145 organization performs the maintenance, each under its own approval. A CAO combines those two functions into one approval with one exposition and one oversight cycle, which suits GA shops, aeroclubs and small ATOs working on non-complex aircraft.
- Can a flight school use a Part-CAO for its training fleet?
- Yes, provided the trainers are not classified as complex motor-powered aircraft and are not listed on an air carrier's AOC. A CAO lets a school manage airworthiness and perform much of its own maintenance under a single approval rather than holding separate CAMO and Part-145 certificates.