- Jun 30
Airworthiness Records (Part I): Airworthiness Directive Status
- David Lapesa Barrera
Within a continuing airworthiness record system, which provides the basis for tracking and demonstrating the aircraft’s airworthiness status at any point in time, the status of Airworthiness Directives (ADs) is one of the most scrutinised elements during audits and airworthiness reviews, as well as during aircraft transitions, lease returns, and pre-purchase inspections.
Airworthiness regulations set clear expectations, but in practice, the quality of AD control depends on how well the organisation translates those requirements into controlled and compliant records.
The objective is simple: at any point in time, the AD status must provide an unambiguous picture of compliance for each aircraft, engine, propeller, or appliance.
Applicability and Scope
The AD status is not a historical log. It is a live status reflecting the current compliance condition.
Each entry should include:
Identification of the affected product (aircraft, engine, propeller, or appliance)
AD reference, including revision or amendment status
Date of the latest status update
For the purpose of assessing AD status, there is no need to include ADs that have been superseded or cancelled. Where a superseding AD relies on actions from a previous directive, this is addressed through compliance with the current AD and supported by the associated maintenance records.
Recording AD Compliance
Each entry links the AD to its compliance evidence and confirms its current status. This typically includes:
Reference number and revision/amendment
Description, including compliance means (e.g. modification, repair, inspection)
Applicability (aircraft, engine, propeller, or component, as appropriate, including S/N)
Compliance nature (e.g. one-time, repetitive)
Reference to approved service information (e.g. SB, SL, EO), including document type and revision status
Compliance status (e.g. terminated, open, or not applicable)
Date of the Certificate of Release to Service (CRS)
Reference to the associated work package, work order, or technical log entry
Aircraft or component time at embodiment (hours, cycles, or other relevant parameter)
Applicable limits where the AD is subject to scheduled embodiment
Repetitive interval or threshold, where applicable
Reference to Alternative Method of Compliance (AMOC), where applicable
Depending on the nature of the AD, compliance may be achieved through the incorporation of limitations or procedures in approved documentation, rather than through maintenance action. This may include updates to the Aircraft Flight Manual (AFM), Minimum Equipment List (MEL), or Aircraft Maintenance Program (AMP). In such cases, the record should clearly reference the applicable document, including its revision and effective date.
Repetitive AD requirements must be included in the Aircraft Maintenance Program (AMP), supporting the control of compliance intervals.
Special Considerations
Applicability of Airworthiness Directives
Applicability must always be addressed explicitly.
If an AD applies to a type but not to a specific aircraft or component, the record must state:
“Not applicable”
together with the technical reason (e.g. S/N exclusion, configuration status, embodiment of a terminating modification).
From an auditor’s perspective, a missing AD is a finding. A clearly justified “not applicable” is compliance.
Some Airworthiness Directives are applicable only to specific part numbers or serial number ranges. Particular attention must be paid to these cases, as components may have been replaced during the aircraft’s operational life. As a result, applicability cannot be assumed based on the original delivery configuration and must be continuously validated against the current aircraft configuration.
In practice, this requires effective configuration management to ensure affected parts are identified and either controlled, restricted from installation, or verified as compliant prior to installation.
Assessing Applicability for Appliance ADs
Applicability assessment can become less straightforward when dealing with ADs affecting appliances.
In these cases, the directive may not clearly confirm whether the affected part is installed on a specific aircraft type. Determining applicability therefore requires verification against the actual configuration, including part numbers, modification status, and installation records.
As a result, applicability cannot always be determined at a glance and requires in-depth assessment, particularly where it depends on configuration that may change over time.
While internal evaluation records can support this process, including non-applicable ADs in the status with a concise justification often provides a clearer and more transparent overview.
This avoids repeated assessments and makes the status easier to interpret during audits, transitions, and technical reviews.
Where an appliance is subject to installation on the aircraft, its AD status must also be controlled to ensure that any applicable requirements are identified and complied with upon installation.
Note: EASA is replacing the term “appliance” by “non-installed equipment (NIE)”, introducing a clearer distinction between installed components and equipment carried on board.
Method of Compliance
Where an AD allows alternatives, the selected method of compliance must be clearly identified.
This includes:
Which option was selected (e.g. inspection vs modification)
Any deviations approved via Alternative Method of Compliance (AMOC), where applicable
Entries such as “AD complied with” do not provide sufficient detail. The record must allow a reviewer to understand what action was performed without referring to the full work package.
Where part or serial number identification is required, reliance on aircraft records in place of physical verification is only acceptable where explicitly permitted in the AD.
Multi-Part ADs and Conditional Requirements
Multi-part ADs and those requiring ongoing or conditional actions require clear status tracking.
The status must reflect:
Which parts of the AD are applicable
Which parts have been completed
Status of any required inspections or repetitive actions
For ADs requiring inspection-based decisions (e.g. “inspect and repair if necessary”), both the inspection and its outcome must be traceable.
Software Considerations
Where an AD affects loadable software, the status should be sufficiently detailed to identify the software installed on the aircraft, particularly where it is used for operating or controlling aircraft systems.
This typically includes the relevant software standard or version, ensuring that the configuration can be clearly linked to the applicable AD.
Compliance Evidence and Record Structure
In addition to the AD status itself, organisations typically maintain a structured set of compliance evidence to support auditability and airworthiness control. This may be organised as part of a compliance binder or equivalent compliance evidence system, linking each Airworthiness Directive to its supporting documentation.
This ensures that each compliance entry is substantiated by traceable records such as work orders, certificates of release to service, approved maintenance data, and configuration records, providing a complete and auditable compliance trail.
Conclusion
The status of Airworthiness Directives demonstrates that all applicable ADs are identified, assessed, and controlled, with clear compliance evidence.
By linking each directive to its method of compliance, supporting records, and applicable limits, the AD status provides a clear and current view of compliance with these mandatory requirements.
Learn more about continuing airworthiness record systems →
Airworthiness Records Series — Next: Part II – Aircraft Maintenance Program Status (coming soon)
Author
David Lapesa Barrera is the founder of The Lean Airline® and author of The Lean Airline: Flight Excellence and Aircraft Maintenance Programs. His work focuses on lean management, operational excellence, and continuing airworthiness.