CAMO, CAO and Part-145: Who Does What?

CAMO, CAO and Part-145 at a glance

A continuing airworthiness management organisation (CAMO) manages the programme and arrangements that keep an aircraft airworthy. A Part-145 maintenance organisation performs and releases maintenance. A combined airworthiness organisation (CAO) may hold management privileges, maintenance privileges or both, within a narrower aircraft scope. One business can hold more than one approval; its trading name does not tell you which privileges it holds.

“Combined” does not guarantee that a CAO offers every service:

Read the Part-CAO scope provision alongside the current privilege amendments. CAO scope is not synonymous with Part-ML eligibility; the continuing-airworthiness overview explains the wider framework.

What remains with the owner or operator?

M.A.201(a) and ML.A.201(a) start with owner responsibility: no flight unless the aircraft is airworthy, operational and emergency equipment meets the stated conditions, the airworthiness certificate is valid, and maintenance follows the AMP. Their leasing provisions transfer the specified responsibilities to the lessee when the registration document or lease meets the rule’s conditions. Operator-specific duties then depend on the operation.

For a licensed air carrier, M.A.201(e) places responsibility on the operator, with CAMO approval normally part of its AOC and Part-145 maintenance performed under its own approval or a written contract. M.A.201(ea) allows at least two operators within a single air carrier business grouping to share a CAMO only under its conditions, including appropriate approval, a same-group CAMO, the required contract, its place of business and harmonised management systems. This is a defined group arrangement under Regulation 2022/410.

For Part-ML, the responsibility rule ML.A.201 makes a useful distinction. The commercial-training and other operational cases listed in paragraph (e) require CAMO/CAO management, through approval or contract, and approved maintenance. For aircraft outside those cases, paragraph (f) allows the owner to contract management or perform it. A contracted organisation assumes responsibility for properly performing those tasks; that does not erase the remaining duties in ML.A.201.

Maintenance also has its own accountability:

A practical handover from planning to records

A useful handover makes the work, decisions and evidence traceable. The checks below are practical prompts, not prescribed form names. They illustrate a CAMO working with a Part-145 organisation; adapt them to the actual approvals and contracts.

The CAMO’s coordination duty is explicit:

The maintenance-release rule and record-return rule explain the receiving side. See the separate guides for AMP control, reliability monitoring and release and records.

Example: ExampleAir’s CAMO arranges a scheduled check at ExampleMRO. The CAMO coordinates the work against the AMP; ExampleMRO performs it within its Part-145 approval. When ExampleMRO finds an additional defect, it communicates the finding for an agreed action. Its authorised certifying staff issue the CRS when the release conditions are met, and the release and required supporting records return to the customer. The CAMO manages the continuing-airworthiness follow-through; its management role alone does not entitle its staff to sign the maintenance release.

What should the management system and exposition show?

CAMO.A.200 requires accountability, safety policy, hazard and risk management, competent people, documented processes and compliance monitoring, proportionate to the organisation’s size, activities and risks. CAMO.A.305 assigns the accountable manager responsibility for resources and nominated management, safety and compliance functions. The Part-CAMO management-system requirements provide the detailed framework.

The CAME records scope, responsibilities and procedures; its initial issue requires authority approval under CAMO.A.300. A CAO has its CAE and its own CAO.A.100 quality-system requirements. A small CAO may replace the quality system with regular organisational reviews only with authority approval; in that case it cannot contract management tasks to other parties. When checking an arrangement, look for procedures that explain the actual handover, escalation and record custody.

Why the CAME amendment form asks what it asks

Use the CAME branch of Exposition amendment (no prior approval) when preparing a controlled change, beginning with a check of the route. Document identity, current and proposed revisions and changed chapters locate the management-system documentation addressed by CAMO.A.200(a)(5). The reason for the change and references to supporting material let the reviewers assess the affected processes and the relevant documentation under CAMO.A.130(b).

The prior-approval question prevents the form’s title from deciding the route. CAMO.A.130(a) includes changes to certificate scope or approval terms, the specified nominated personnel and their reporting lines, and the procedure for changes not requiring prior approval. Point (b) also covers other applicable prior-approval requirements: apply before the change, provide the relevant documentation and implement only after formal authority approval. Point (c) requires other changes to be managed and notified under the procedure approved by the authority. An internal review cannot replace required authority approval.

The process owner records the proposed change; the responsible manager reviews it, and the compliance monitoring manager records the route and notification evidence. Where prior approval is required, record the referral and obtain it before implementation. These are written follow-up responsibilities within the workspace. This explanation applies to the CAME under Part-CAMO; use the MOE guide for the form’s Part-145 branch.

For the detailed contracting arrangements behind the handover above, see CAMO contracting and subcontracting.

Does the approval include airworthiness reviews?

Check this separately from maintenance and management. CAMO.A.125(e) and CAO.A.095(c) provide additional review privileges subject to approval and their conditions.

A Part-145 organisation can perform reviews and issue an airworthiness review certificate (ARC) only when specifically approved under 145.A.75(f), for Part-ML aircraft, with its principal place of business in a Member State. Current ML.A.901(c)(3) requires this while performing the AMP’s 100-hour/annual inspection, under ML.A.903. It is not a general Part-145 privilege. The 2026/100 amendment supplies the current ML.A.901 text; the ARC guide covers the review and extension rules.

Sources and revision boundary

This guide uses the 2025-09-02 EAR baseline with relevant provisions amended by Regulation 2025/111 and Regulation 2026/100. Their relevant amendments apply from 13 February 2026 and 7 August 2026, respectively. EASA’s September 2025 EAR publication expressly excludes 2025/111, so that publication alone is not the complete current text.