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This whitepaper analyses two new European regulations — Commission Delegated Regulation (EU) 2026/56 and Commission Implementing Regulation (EU) 2026/100 — set to take effect on 7 August 2026. Regulation 2026/56 targets Part 21 initial airworthiness, simplifying intra-EU aircraft transfers and introducing formal evaluation programs for imported aircraft with incomplete historical records. Regulation 2026/100 updates the continuing airworthiness framework across Part-M, Part-ML, Part-CAMO, and Part-CAO, shifting authority oversight from hands-on approval to risk-based auditing, empowering approved organisations to issue Airworthiness Review Certificates directly, and aligning occurrence reporting with Regulation (EU) 376/2014.
Key takeaways
- Regulation 2026/56 simplifies intra-EU aircraft transfers and introduces evaluation programs to address gaps in historical airworthiness records
- Regulation 2026/100 enables CAMOs and CAOs to issue ARCs directly without NCA recommendation, increasing organisational accountability
- Authority oversight shifts from compliance-based to risk-based, with NCAs acting as safety auditors rather than technical validators
- Occurrence reporting is unified under a single channel aligned with Regulation 376/2014, eliminating redundant reporting paths
- Just Culture protections are formally extended to the continuing airworthiness sector
- Organisations must update their CAME/CAE documentation, digitise technical records, and retrain Airworthiness Review Staff before the 7 August 2026 deadline
- SMS maturity in Part-CAMO and Part-CAO is the foundation enabling reduced authority involvement
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