Sofema Aviation Services (SAS) considers key roles for an EASA Part-CAO organisation, with the linked training needs (initial and recurrent).

Reference - Part-CAO = Annex Vd; Part-ML = Annex Vb of Regulation (EU) 1321/2014.

 

Core Roles & Responsibilities in a Part-CAO

 

Accountable Manager (AM)

•  Ensures activities are adequately financed and compliant; nominates the person(s) responsible for day-to-day compliance. Must provide adequate, qualified staffing and recorded qualification assessments.

Nominated Person(s) for Compliance (Sometimes “CAO Manager”/Postholders)

•  Keep the organisation in continuous compliance; expected to have practical experience, comprehensive knowledge of Part-M/Part-ML and the CAE, and at least Level-1 general familiarisation training on relevant types (or equivalent evidence).

Compliance Manager / Compliance Monitoring

•  Runs the quality system or (for a small CAO) the organisational review programme; plans audits/reviews, reports findings, drives corrective action, and keeps records ≥2 years. Remote audits may be used where appropriate.

Continuing Airworthiness Management (CAM) personnel

•  Develop/control the AMP; for Part-ML aircraft, approve the AMP and amendments; ensure maintenance is done to the AMP; ensure ADs/mandatory directives are applied; coordinate scheduled work, replacement of life-limited parts, and component inspections; manage/retain continuing-airworthiness records and maintain accurate mass/balance. 

•  Hold and use current maintenance data per ML.A.401/M.A.401 when performing CAM tasks.

Airworthiness Review Staff (ARS)

•  Meet experience/knowledge/training thresholds; are nominated, supervised for authorisation, kept current, and listed in the CAE.

•  Conduct the ARC per ML.A.903: documented records review (hours/cycles, FM applicability, AMP completion, defect control, ADs, mods/repairs, life-limited parts, proper certification, mass/balance, design conformity), and a physical survey; then issue EASA Form 15c if satisfactory.

Certifying Staff (Maintenance Release)

•  Must meet Part-66 (or accepted national) requirements and know the aircraft/components and CAO procedures; limited one-off/limited authorisations exist in specific circumstances (with training and rechecks). Maintain an up-to-date list of authorisations in the CAE.

Planners / Technical Records / Stores & Tools

•  Plan work compliant with AMP and maintenance data; maintain accurate technical records and evidence for maintenance/CRS; control tooling, calibration, and storage to standards referenced by CAO.A.050/060.

Everyone Performing or Controlling Maintenance

•  Follow ML.A.402 (methods, tools, environment, error-capturing after critical tasks, general verification, documentation).

Part-ML Considerations

•  Part-ML sets responsibilities (ML.A.201), continuing-airworthiness tasks (ML.A.301), AMP rules (ML.A.302), maintenance standards (ML.A.401/402), defects (ML.A.403), and ARC (ML.A.901–907). 

•  It also enables pilot-owner maintenance within limits and defines who may perform ARC (maintenance org/independent certifying staff/CAO/CAMO/authority, depending on context).

For CAOs with ML Aircraft, you will typically:

•  Approve the AMP (instead of authority approval) if you hold CAM privileges.

•  Perform ARCs per ML.A.903 and issue/extend Form 15c (where eligible)

•  Apply ML maintenance standards (data, performance, CRS) and manage pilot-owner maintenance interfaces/notifications.

 

Initial & Recurrent Training Matrix (What “Good” Looks Like)

 

Corporate/Role-based Induction (Initial) and Refresh (Recurrent) 

• Regulatory Framework & CAE: Part-CAO Subpart A; Part-ML core (ML.A.201/.301/.302/.401/.402/.801/.901); organisation procedures in the CAE, including lists and procedures (e.g., B.4 “Qualification, assessment and training of staff”). Refresh when rules/procedures change.

•  Compliance Monitoring: Audit planning, techniques, reporting, corrective action, feedback loop; for small CAOs using organisational review, the review planning and use of Appendix II (to AMC1 CAO.A.100(f)). Recurrent every 24 months or aligned to the audit cycle and changes.

•  Safety/Human Factors Training: While Part-CAO doesn’t require a bespoke HF AMC, EASA’s AMCs for CAMO/145 are accepted good practice: initial safety (incl. HF) for managers, certifying/ support/records/planners/ARS; recurrent every 2 years, content informed by internal reports/audit trends.

 Function-Specific Technical Training 

•  Nominated Person(s)/Postholders: Knowledge of Part-M/Part-ML and CAE; 5 years aviation (≥2 in industry), plus type knowledge evidenced (≥ Part-66 Appx III L1 GF or equivalent). Reassess on scope/type changes.

•  Certifying Staff: Part-66 (or accepted national) plus company procedures; continuation training on new aircraft/tech, changes to AMP, AD trends, and error-capturing for critical tasks. Maintain authorisation currency in the CAE list.

•  Airworthiness Review Staff: Experience/qualification per CAO.A.045; supervised initial AR; maintain recency and refresh on ML.A.903 checklist evolutions, Form 15c completion, and current interpretations.

•  AMP Developers/Analysts: Methods for AMP development/control/review; statistics/reliability (as guided in CAMO AMC—adoptable by CAOs) to evaluate program effectiveness. Recurrent when AMP methodology or data sources change.

Compliance Monitoring Leads: Dedicated training on compliance monitoring requirements, audit techniques, reporting/recording (again, CAMO AMC pattern

1. Part-ML-Specific Modules (for teams working on ML aircraft)

• Part-ML Responsibilities & Tasks: ML.A.201/.301; occurrence reporting timelines (≤72h); roles of CAO vs. owner vs. independent certifying staff; pilot-owner maintenance boundaries and notifications (≤30 days). 

•  AMP Under ML: Default/MIP vs ICA-based AMP; when owner declaration suffices vs when CAO approval is required; recording deviations/additional tasks.

•  ML Maintenance Performance & CRS: ML.A.401/402/801 content, incomplete-maintenance release conditions, and documentation standards.

•  ARC per ML: End-to-end AR process, anticipation (≤90 days), extensions, and Form 15c usage.

 Recurrence Periods & Triggers (Pragmatic)

• Safety/HF: Every 24 months; content steered by internal safety reports and audit findings.

• Compliance Monitoring/Auditor Competence: Refresh at least in line with the audit cycle and when regulations/CAE change.

• ARS & AMP Developers: Refresh with each regulatory/form change or annually if actively performing AR/AMP reviews; ensure “recent experience” is demonstrable.

• Certifying Staff Continuation: When AMP, ADs, type scope, or procedures change, align to company policy based on risk and findings (good practice: annual/biennial).

 Documents & Records That Prove Training/Competence 

• CAE should contain the lists/procedures for training/qualification assessment, authorisation lists, ARS lists, AMP/ARC procedures, etc. Keep quality/organisational-review and audit records ≥2 years.

 

Day-to-Day “Controls That Work” 

• Use an annual (or rolling) audit/review plan covering all Part-CAO/Part-ML elements and subcontracted work; use a feedback system to close findings and brief the AM at least half-yearly.

• Ensure maintenance performance follows ML.A.402 (clean/workmanlike environment, calibrated tools, error capture after critical tasks, final verification).

• For ML aircraft, embed the ML.A.903 checklist in your AR work cards and control the Form 15c issue/extension precisely.

 

Next Steps

Sofema Online (SOL) offers courses on EASA Part CAO - Combined Airworthiness Organisation Regulatory Obligations - Initial and EASA Part CAO - Combined Airworthiness Organisation Regulatory Obligations - Recurrent. Please see our online website, Sofema Online (SOL), or email team@sassofia.com for support.