Part-M and Part-CAMO are not alternatives. Part-M (Annex I to Regulation (EU) No 1321/2014) sets the continuing airworthiness standard for the aircraft: tasks, the aircraft maintenance programme (AMP), ADs and records. Part-CAMO (Annex Vc) sets the requirements for the organisation that manages that work, and it replaced the old Part-M Subpart G approvals. In practice, a CAMO applies Part-M to each aircraft it manages, under a Part-CAMO approval.
This guide explains who needs a CAMO, what the CAMO must do, how the AMP works under M.A.302, which records Part-M requires, how the FAA handles the same topic, and what software must support. Regulatory references are to the EASA Easy Access Rules for Continuing Airworthiness, revision of September 2025, checked in November 2026. Always confirm against the current text and your competent authority.
From Part-M Subpart G to Part-CAMO
Regulation (EU) 2019/1383 restructured Regulation (EU) No 1321/2014. It became applicable on 24 March 2020. According to the EASA guide for transition to Part-CAO and Part-CAMO (revision November 2021), the result is:
| Annex | Name | What it covers |
|---|---|---|
| Annex I | Part-M | Continuing airworthiness standard for aircraft other than "light aircraft", and for all aircraft used by licensed air carriers |
| Annex II | Part-145 | Approved maintenance organisations, all aircraft and operations |
| Annex Vb | Part-ML | Simpler standard for light aircraft not used by licensed air carriers |
| Annex Vc | Part-CAMO | Continuing airworthiness management organisations, all aircraft and operations |
| Annex Vd | Part-CAO | Combined airworthiness organisations for non-complex aircraft not used by licensed air carriers |
EASA describes the main difference between Part-CAMO and the old Subpart G as the introduction of safety management system (SMS) principles. Existing Subpart G organisations could transition to Part-CAMO with the same scope. They could keep working under the old approval only until 24 March 2022. The original deadline was 24 September 2021, and Regulation (EU) 2021/700 extended it. Since that date, there are no Subpart G organisations left: every CAMO operates under Part-CAMO or, for its limited scope, Part-CAO.
So when people search for "Part-M vs Part-CAMO", the honest answer is: Part-M still applies, as the technical standard. What disappeared is Part-M as an organisation approval for CAMOs.
Who needs a CAMO
Point M.A.201 allocates responsibility. The owner is responsible for continuing airworthiness by default. The type of aircraft and operation then decides whether a CAMO is mandatory:
| Aircraft and operation | Continuing airworthiness management | M.A.201 point |
|---|---|---|
| Air carriers licensed under Regulation (EC) No 1008/2008 | The operator must hold a CAMO approval as part of its air operator certificate, or use a CAMO of the same air carrier business grouping under the conditions of point (ea) | (e), (ea) |
| Complex motor-powered aircraft in other CAT, commercial specialised operations or commercial ATOs and DTOs | A CAMO, either the operator's own or one under written contract | (f) |
| Other complex motor-powered aircraft, for example private business jets | A CAMO, either the owner's own or one under written contract | (g) |
| Other-than-complex aircraft in the commercial operations above | A CAMO or a CAO, own or contracted | (h) |
| Other-than-complex aircraft in non-commercial or limited operations | The owner may contract a CAMO or CAO, or do the tasks itself; the AMP may be handled through a limited contract | (i) |
Light aircraft not used by licensed air carriers follow Part-ML instead of Part-M. EASA's guidance says Part-ML is the only option for them; you cannot apply Part-M to those aircraft voluntarily.
What a CAMO must do
Point M.A.301 lists the continuing airworthiness tasks for every aircraft. They include pre-flight inspections, the rectification of defects taking into account the MEL, all maintenance in accordance with the AMP, the release of maintenance, and compliance with ADs and other mandatory measures. For complex motor-powered aircraft and aircraft of licensed air carriers, they also include the analysis of the effectiveness of the AMP.
Point CAMO.A.315 turns those tasks into duties of the organisation. For every aircraft it manages, the CAMO must in particular:
- Ensure that an AMP, including any applicable reliability programme, is developed and controlled under M.A.302.
- Ensure that data used for modifications and repairs complies with M.A.304.
- For complex motor-powered aircraft and licensed air carriers, have a procedure to assess non-mandatory modifications and inspections, such as service bulletins, using its safety risk management process.
- Send aircraft, engines, propellers and components to an appropriately approved maintenance organisation when necessary.
- Order maintenance, supervise it and coordinate decisions, so that maintenance is properly done and released.
- Take human factors and human performance limitations into account, including in contracted activities.
If the CAMO is not itself a maintenance organisation, it manages the written maintenance contracts with Part-145 organisations. Individual work orders can replace a contract for unscheduled line maintenance and for component maintenance. The procedures for all of this are described in the continuing airworthiness management exposition (CAME).
The aircraft maintenance programme (AMP)
Point M.A.302, as last amended by Regulation (EU) 2023/989, is the core of the topic. The maintenance of each aircraft must be organised in accordance with an AMP.
Content
The AMP must contain details of all maintenance to be carried out, including frequency and any specific tasks linked to the type and specificity of operations. It must demonstrate compliance with:
- Instructions issued by the competent authority.
- The instructions for continuing airworthiness from the type certificate holder and other design approval holders, such as STC holders.
- The applicable provisions of Part-26 (Regulation (EU) 2015/640).
The owner or the CAMO may propose additional tasks. It may also propose escalated intervals, if they are based on data from sufficient programme reviews.
Approval and indirect approval
The competent authority approves the AMP and each amendment. When a CAMO or CAO manages the aircraft, the AMP and its amendments may be approved through an indirect approval procedure. That procedure is part of the CAME and is approved by the authority. It can only be used when the CAMO is under the oversight of the State of registry, unless a contract transfers that responsibility. Indirect approval is not permitted for the escalation of safety-related tasks.
Reliability programme and periodic review
For complex motor-powered aircraft, when the AMP is based on maintenance steering group (MSG) logic or on condition monitoring, the AMP must include a reliability programme. Every AMP is subject to periodic reviews, which keep it valid in the light of operating experience, authority instructions and new or modified instructions from the type certificate and STC holders. In short, the AMP is a living document, and so is the data behind it.
Records under M.A.305
Point M.A.305 defines the aircraft continuing airworthiness record system. The certificate of release to service must be entered no later than 30 days after the maintenance is completed. The records must show the current mass and balance report and the current status of:
- ADs and measures mandated by the competent authority in immediate reaction to a safety problem.
- Modifications and repairs.
- Compliance with the AMP.
- Deferred maintenance tasks and deferred defects.
- Life-limited parts, with the life accumulated against the applicable limit.
- Time-controlled components, with the life since the last scheduled maintenance.
Retention periods apply. For example, the technical log covers 36 months before the last entry, and each life-limited part needs an in-service history record. Corrections must keep the original entry visible. The organisation managing continuing airworthiness must present these records to the authority on request. Part-CAMO adds its own record-keeping requirement for the organisation in CAMO.A.220.
The FAA equivalent: CAMP
The FAA has no CAMO approval. The air carrier itself is responsible. Under 14 CFR 121.367, each Part 121 certificate holder must have an inspection programme and a programme for other maintenance, preventive maintenance and alterations. 14 CFR 121.373 requires a continuing analysis and surveillance system (CASS) to monitor the effectiveness of those programmes, which is similar in purpose to the EASA AMP effectiveness analysis. 14 CFR 121.380 lists the records, including the status of life-limited parts and ADs.
In Part 135, 14 CFR 135.411 splits the fleet by seats. Aircraft with ten or more passenger seats follow the air carrier maintenance programme rules of 135.415, 135.417 and 135.423 to 135.443. Aircraft with nine seats or fewer follow Parts 91 and 43 plus specific Part 135 sections, and may use an approved aircraft inspection programme.
"CAMP" (continuous airworthiness maintenance program) is the colloquial name. AC 120-16G (4 January 2016) describes its 10 elements, from the maintenance schedule and required inspection items to the record-keeping system and CASS. The FAA does not approve the CAMP itself; it authorises it through operations specifications.
What CAMO software must support
No software makes an organisation compliant. The approval belongs to the CAMO, and the software holds the evidence. Use this checklist to evaluate a system for continuing airworthiness management:
- AMP structure: tasks with intervals in flight hours, cycles, calendar time or combinations, with tolerances and applicability by serial number and configuration.
- AMP revisions: traceable revisions, with the source of each change (manufacturer data, authority instruction, reliability review) and the approval reference.
- Forecasting: due dates from real utilisation, and grouping of tasks into work packages for the maintenance organisation.
- AD and SB status: applicability, compliance method, recurring actions and the documented decision on each non-mandatory SB. Our guide to airworthiness directive and SB tracking covers this in detail.
- LLP and time-controlled components: accumulated life against each limit, with back-to-birth history that follows the part between aircraft.
- Deferred items: deferred defects and deferred tasks with their limits, linked to the MEL category where applicable.
- Records: CRS entry within 30 days, retention periods, and corrections that keep the original entry visible.
- Reliability data: defect, removal and finding data that the reliability programme and AMP reviews can use.
- Interface with the Part-145: work packages out, signed task cards and status back, whether the maintenance organisation is in-house or contracted.
Our guide on how to choose aircraft maintenance tracking software develops the general evaluation criteria.
Where SkyPlannerHub fits, honestly
SkyPlannerHub is a cloud ERP/MRO for aviation. Its published modules cover AD, SB and life-limited part tracking by aircraft and component, with alerts before each due date or limit. They also cover aircraft and component history with cycles, hours and airworthiness status, line and base maintenance with work orders and compliance tracking, and stock of parts, tools and consumables with traceability by serial number, batch and certificate.
We do not present SkyPlannerHub as a complete CAMO system. Our public material does not describe AMP management, indirect approval workflows or a reliability programme module. Workflows are configured for each organisation, and our team builds specific features when a process does not fit. If you run a CAMO, bring your CAME procedures and your AMP to a demo, and we will tell you clearly what is covered and what is not.
Frequently asked questions
Is Part-M still in force?
Yes. Part-M (Annex I) remains the continuing airworthiness standard for aircraft that are not under Part-ML. Only its Subpart F and Subpart G organisation approvals ended, on 24 March 2022.
Does every operator need its own CAMO?
No. Licensed air carriers must hold a CAMO approval as part of their air operator certificate, with an exception for airline groups under M.A.201(ea). Other operators and owners of complex motor-powered aircraft can contract a CAMO. Owners of non-complex aircraft in non-commercial operations have more options, including doing the tasks themselves.
Who approves the aircraft maintenance programme?
The competent authority. When a CAMO or CAO manages the aircraft, the authority can approve an indirect approval procedure in the CAME, so the CAMO approves amendments itself. Escalation of safety-related tasks always needs direct approval.
Is the FAA CAMP the same as an EASA AMP?
Not exactly. The AMP is a document approved by the authority. The CAMP is the whole air carrier maintenance programme, with 10 elements described in AC 120-16G, authorised through operations specifications. The maintenance schedule element is the closest equivalent to the AMP task list.
Conclusion
Part-M defines how each aircraft stays airworthy, Part-CAMO defines the organisation that manages it, and the AMP is the document that links the two. The software behind a CAMO must keep the AMP, ADs, SBs, life-limited parts, deferred items and records consistent and auditable. If you want to check how your continuing airworthiness data would work in SkyPlannerHub, talk to our team.