Your Airworthiness Review Certificate expires in six weeks. The aircraft is booked solid. Your Head of Maintenance is chasing three other squawks. This is the situation most flight schools find themselves in when ARC renewal becomes urgent rather than planned.
It doesn't have to be that way, but getting there requires understanding what the process actually demands - not just in theory, but in the paperwork trail a reviewer will walk through on the day.
What Part-CAO.A.095 Actually Requires
Under Commission Regulation (EU) 2019/1383, which introduced Part-CAO, the airworthiness review for ELA1 and ELA2 aircraft (and other non-complex types within CAO scope) can be conducted by the CAO itself, provided it holds the appropriate privilege. That's the core of Part-CAO.A.095: the organisation can issue and extend ARCs without going back to the competent authority, as long as the review is carried out by a suitably qualified airworthiness review staff member.
The review is not a rubber stamp on the maintenance record. It's an independent physical survey of the aircraft combined with a records examination. Both elements have to be completed. Skipping or abbreviating either is a non-compliance finding, not an administrative shortcut.
The ARC itself is valid for one year. Part-CAO.A.095(d) allows a one-time extension of up to two months - but only if the aircraft is away from its base or undergoing maintenance at the time of expiry. It's not a grace period for administrative delays. Reviewers and competent authorities read it that way, and so should you.
The Documentation a Reviewer Will Check
When an airworthiness review staff member sits down with your aircraft file, they're reconstructing the maintenance history to confirm the aircraft has been maintained in accordance with its Approved Maintenance Programme and that nothing has been missed, deferred beyond limits, or left undocumented.
In practice, this means having the following in order before the review date:
- The current AMP, including any amendments, with evidence it was followed. If you updated the AMP mid-year and the intervals changed, the reviewer will check that tasks weren't inadvertently skipped in the transition.
- All maintenance release records (CRS entries) since the last ARC. Every scheduled and unscheduled maintenance event needs a corresponding signed release. Gaps in the record - even for minor work - are a finding.
- AD and SB compliance status. For each applicable Airworthiness Directive, you need evidence of compliance or a documented justification for non-applicability. An AD tracking list that hasn't been updated in three months is a red flag.
- Mass and balance documentation, current and reflecting any modifications made since the last review.
- The aircraft technical log, complete with no missing entries. Flight hours since last inspection need to reconcile with the logbook entries and the maintenance record.
- Component life tracking for time-limited parts - life-limited components, on-condition items with defined intervals, and any items with calendar limits. If a propeller overhaul is due at 2,000 hours and your records show 1,998 with no work order raised, the reviewer will note it.
- Defect records and their resolution. Open deferred defects are acceptable only within the limits defined in your MEL (if applicable) or the aircraft's limitations. Unresolved defects with no deferral justification are a stop-the-review issue.
The physical survey runs in parallel. The reviewer will inspect the aircraft for obvious unairworthy conditions, confirm placards and markings are in place, check that the Certificate of Registration and Noise Certificate are on board, and verify the aircraft configuration matches what's in the records.
Where Schools Get Caught Out
Having done this across multiple aircraft types and watched other operators go through the process, the failures tend to cluster in a few specific places.
Maintenance release gaps for line maintenance. A school with high utilisation will have instructors reporting squawks throughout the year. If those defects were fixed informally - an instructor adjusted something, a mechanic tightened a fitting without raising a work order - there's no CRS. The reviewer sees a reported defect with no corresponding release. That's a problem.
AMP amendments that weren't tracked properly. Engine manufacturers and aircraft type certificate holders issue service information regularly. If your AMP references a task interval that was subsequently revised by a mandatory service bulletin, and your records show you followed the old interval, you have a compliance gap even if the aircraft is technically fine.
AD compliance records that exist but can't be found. The AD was complied with two years ago by a previous maintenance organisation. The entry is somewhere in the paper file, or in a system the previous operator used, but it's not in your current records package. Proving compliance retroactively under time pressure is painful. Proving it when the reviewer is sitting in front of you is worse.
The two-month extension being treated as routine. Some schools plan their ARC renewal on the assumption that if they're not quite ready, they'll use the extension. Part-CAO.A.095(d) doesn't work that way. The extension requires the aircraft to be away from base or in maintenance - not that the paperwork isn't finished. Using it incorrectly is itself a finding.
Certifying staff authorisation records being out of date. The reviewer's own qualification to conduct the review needs to be documented. If your CAO's airworthiness review staff authorisation has lapsed or the individual's licence has a recent revalidation that hasn't been recorded in the staff file, the review can't proceed.
The Timeline That Actually Works
Six weeks is not too early to start. Eight weeks is better.
At eight weeks out, pull the full maintenance record and do your own pre-review check against the AMP. Identify any open ADs, any component approaching a life limit, and any deferred defects. Raise work orders for anything that needs to be addressed before the review date.
At six weeks, confirm your airworthiness review staff member's authorisation is current and that they're available. If your CAO uses an external reviewer or has a small certifying staff team, availability can be a genuine constraint.
At four weeks, the aircraft file should be complete. Every CRS entry accounted for, every AD either complied with or documented as not applicable, mass and balance current. If something is missing, four weeks is enough time to track it down without crisis.
The physical survey and records review can then happen at two to three weeks out, leaving time to address any minor findings before the current ARC expires.
ARC Tracking in a Managed System
The administrative side of ARC management - knowing when the certificate expires, which aircraft it applies to, which staff member is authorised to conduct the review - is exactly the kind of thing that gets lost in spreadsheets and wall calendars when a school is operating multiple aircraft across multiple bases.
Planebooker's airworthiness module tracks ARC expiry dates, links them to the aircraft maintenance record, and surfaces upcoming expirations before they become urgent. It won't conduct the review for you, and it won't replace the judgment of your airworthiness review staff. But it means the expiry date isn't something you discover by accident, and the records it tracks - squawks, maintenance releases, component life - are the same records a reviewer will want to see.
For a school with four or five aircraft, that visibility is the difference between a planned review and a scramble.
Before Your Next ARC Is Due
Ask yourself three questions now, not six weeks before expiry:
- Is every maintenance event since the last ARC documented with a signed CRS, including line maintenance and defect rectification?
- Is your AD compliance list current, and can you produce evidence of compliance for every applicable directive?
- Is the airworthiness review staff member who will conduct your review available, authorised, and aware of the date?
If the answer to any of those is "I'd have to check," that's your starting point.