Part-ML (Light Aircraft Continuing Airworthiness)

Part-ML is contained in Annex Vb to Commission Regulation (EU) No 1321/2014 and provides a lighter, proportionate set of continuing-airworthiness rules for the general-aviation end of the fleet. It was introduced to remove the disproportionate paperwork that full Part-M imposed on small, privately or club-operated aircraft, and it has applied since March 2020.

Applicability is defined by mass, occupancy and how the aircraft is used. Part-ML covers aeroplanes of 2,730 kg maximum take-off mass or less, rotorcraft of 1,200 kg MTOM or less certified for a maximum of up to four occupants, and other ELA2 aircraft such as sailplanes, balloons and small airships. Crucially, the aircraft must not be listed on the air operator certificate of an air carrier — the moment an aircraft is flown on a commercial air transport AOC, the full Part-M regime applies instead. This is the same ELA1/ELA2 population that most aeroclubs, owner-operators and smaller training organizations actually fly.

The centre of Part-ML is the Aircraft Maintenance Programme (AMP). Under the rule an owner has two routes. The AMP can be approved indirectly by the CAMO or Combined Airworthiness Organisation (CAO) that manages the aircraft, or — the genuinely simplifying option — the owner can issue an owner-declared AMP under ML.A.302, taking personal responsibility for its content without needing a competent-authority or organizational approval. The AMP can be built on the Minimum Inspection Programme that EASA publishes in the AMC to Part-ML, tailored to the specific type. Mandatory items such as airworthiness directives can never be deviated from, whichever route the owner chooses.

Pilot-owner maintenance is a further alleviation. A person who is both the owner and holds a valid pilot licence for the type may carry out a defined list of limited, low-risk tasks — routine visual inspections and simple servicing — but is barred from complex tasks, major component work, AD embodiment, tasks needing special tooling, and anything affecting systems required for IFR flight. The airworthiness review is likewise streamlined: an Airworthiness Review Certificate can be issued by the competent authority, by an approved CAMO/CAO, or by an appropriately authorized independent Part-66 certifying staff member, and reviews may be conducted with fewer formalities than under Part-M Subpart I.

The contrast with the FAA system is instructive. The FAA does not have a Part-ML equivalent; instead it lets certificated pilots perform a fixed list of preventive-maintenance items under 14 CFR Part 43 Appendix A, while scheduled inspections (annual, 100-hour) and returns to service follow 14 CFR Part 43 and Part 91. Part-ML achieves a comparable reduction in burden through the owner-declared AMP and a lighter review, rather than through a preventive-maintenance carve-out.

For European aeroclubs, owner groups and small ATOs, Part-ML is usually the regime that actually governs the training and club fleet. Most single-engine trainers and light twins used for PPL and early IR work fall under the ELA1/ELA2 mass and occupancy limits, so the organization manages them under Part-ML rather than full Part-M. That distinction matters commercially: Part-ML's owner-declared AMP and lighter review cut the administrative load, but it only holds while the aircraft stays off a commercial air transport AOC. A combined ATO/AOC operator that moves the same airframe onto its AOC pulls it into Part-M, with heavier documentation and CAMO obligations.

The alleviations do not remove the need for disciplined records. Even with an owner-declared AMP, someone has to prove that every scheduled task was done on time, that AD status is current, and that the ARC is valid before each flight. High-utilization training aircraft reach calendar and hour limits far faster than the private aircraft the regime was designed around, so a school running trainers under Part-ML still needs the same tight tracking a Part-M fleet needs — just with a lighter approval framework sitting on top of it.

Aviatize's Maintenance Control module tracks each aircraft's Aircraft Maintenance Programme, calendar and flight-hour intervals, AD status and Airworthiness Review Certificate expiry, whether the aircraft is managed under Part-ML with an owner-declared AMP or under full Part-M. Alerts fire well before a task or review comes due, so a club or ATO can keep light aircraft flying without drifting past a deadline.

Because the same fleet can sit under Part-ML for club flying and shift to Part-M when placed on an AOC, Aviatize keeps one continuous digital record per airframe. Maintenance Execution captures the work performed and the release to service, and Digital Data & Records holds the evidence an owner or auditor needs to show the aircraft was maintained in accordance with its declared programme.