---
title: "21.A.112B Demonstration of capability — Annex I, Initial Airworthiness · Avioverse"
description: "An applicant for a supplemental type-certificate shall demonstrate its capability by holding a design organisation approval, issued by the Agency in…"
url: "https://avioverse.aero/regulations/easa/initial-airworthiness/annex-i/section-a-technical-requirements/21-a-112b"
---

# 21.A.112B Demonstration of capability

Annex I · Regulation (EU) No 748/2012 · EAR revision 27 Nov 2025

IR Implementing rule

## 21.A.112B Demonstration of capability

(a) An applicant for a supplemental type-certificate shall demonstrate its capability by holding a design organisation approval, issued by the Agency in accordance with Subpart J.

(b) By way of derogation from point (a), as an alternative procedure to demonstrate its capability, an applicant may seek Agency agreement for the use of procedures setting out the specific design practices, resources and sequence of activities necessary to comply with this Subpart.

(c) By way of derogation from point (a), in the case of products referred to in point 21.A.14(c), an applicant may demonstrate its capability by obtaining the Agency's acceptance of its certification programme established in accordance with point 21.A.93(b).

IR · 21.A.112B — Regulation (EU) No 748/2012 · Regulation (EU) 2019/897 · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

GM Guidance material

## GM1 21.A.112B Demonstration of capability

DEMONSTRATION OF CAPABILITY FOR SUPPLEMENTAL TYPE CERTIFICATE (STC) CASES

See also AMC 21.A.14(b) for the details of the alternative procedures.

The following examples of major changes to type design (ref.: 21.A.91) are classified in two groups. Group 1 contains cases where a design organisation approved under [Part 21](https://avioverse.aero/glossary/easa/part-21) Subpart J (‘Subpart J DOA’) should be required, and Group 2 cases where the alternative procedure may be accepted. They are typical examples but each STC case should be addressed on its merits and there would be exceptions in practice. This classification is valid for new STCs, not for evolution of STCs, and may depend upon the nature of the STC (complete design or installation).

| Product                                                                                                                                                                                                                                                                                                                                                               | Discipline      | Kind of STC                                                                                         |   | Group |
| --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------- | --------------------------------------------------------------------------------------------------- | - | ----- |
| All aircraft                                                                                                                                                                                                                                                                                                                                                          |                 |                                                                                                     |   |       |
|                                                                                                                                                                                                                                                                                                                                                                       | OSD             |                                                                                                     |   |       |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Major stand-alone change to any OSD constituent                                                     |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 |                                                                                                     |   |       |
| Products for which an alternative procedure may be accepted according to 21.A.14(b)                                                                                                                                                                                                                                                                                   | All disciplines |                                                                                                     | 2 |       |
|                                                                                                                                                                                                                                                                                                                                                                       |                 |                                                                                                     |   |       |
| CS-23 (products where a Subpart J DOA is required for TC)                                                                                                                                                                                                                                                                                                             |                 |                                                                                                     |   |       |
| Notes: 1) An STC which leads to a reassessment of the loads on large parts of the primary structure should be in Group 1. 2) ‘2/1’ means that an assessment of consequences in terms of handling qualities, performance or complexity of demonstration of compliance may lead to classification in Group 1.                                                           |                 |                                                                                                     |   |       |
|                                                                                                                                                                                                                                                                                                                                                                       | Aircraft        |                                                                                                     |   |       |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Conversion to tail wheel configuration                                                              |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Auxiliary fuel tank installations                                                                   |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Glass fibre wing tips                                                                               |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Fairings: nacelle, landing gear                                                                     |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Gap seals: aileron, flap, empennage, doors                                                          |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Vortex generators                                                                                   |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Spoiler installation                                                                                |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Increase in MTOW                                                                                    |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       | Structures      |                                                                                                     |   |       |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Stretcher installation                                                                              |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Change to seating configuration                                                                     |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Windshield replacement (heated, single piece, etc.)                                                 |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Lightweight floor panels                                                                            |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Ski installations                                                                                   |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       | Propulsion      |                                                                                                     |   |       |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Engine model change                                                                                 |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Fixed pitch propeller installation                                                                  |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Constant speed propeller installation                                                               |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Installation of exhaust silencer                                                                    |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Installation of graphic engine monitor                                                              |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Installation of fuel flow meter                                                                     |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Accessory replacement (alternator, magnetos, etc.)                                                  |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Inlet modifications: oil cooler; induction air                                                      |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       | Equipment       |                                                                                                     |   |       |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Avionics upgrades (EFIS, GPS, etc.)                                                                 |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Engine instrument replacements                                                                      |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Carburettor ice detection system                                                                    |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Autopilot system installation                                                                       |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Wing tip landing light; recognition lights                                                          |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | WX radar installation                                                                               |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Aeromedical system installations                                                                    |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | De-icing and anti-icing system installations                                                        |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Emergency power supply installations                                                                |   | 2     |
| CS-25                                                                                                                                                                                                                                                                                                                                                                 |                 |                                                                                                     |   |       |
|                                                                                                                                                                                                                                                                                                                                                                       | Cabin Safety    |                                                                                                     |   |       |
| Note: Basically, all changes related to cabin configuration should be in Group 2.                                                                                                                                                                                                                                                                                     |                 | Cabin layout (installation of seats (16G), galleys, single class or business / economy class, etc.) |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Floor path marking                                                                                  |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Crew rest compartment                                                                               |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Change of cargo compartment classification (from class D to class C)                                |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       | Structure       |                                                                                                     |   |       |
| Note: An STC which leads to a reassessment of the loads on large parts of the primary structure should be in Group 1.                                                                                                                                                                                                                                                 |                 | Cargo door                                                                                          |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Change from passenger to freighter configuration                                                    |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       | Avionics        |                                                                                                     |   |       |
| Notes: For CS-25 products, the existence of an [ETSO](https://avioverse.aero/glossary/easa/etso) is not taken into account for the classification. The impact on aircraft performance, and influence of aircraft performance are criteria to assess the classification. Subjective assessment of human factors is considered for determination of the classification. |                 | CVR                                                                                                 |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | VHF                                                                                                 |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | NAV (ADF, VOR, GPS, BRNAV)                                                                          |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Autopilot, HUD, EFIS, FMS                                                                           |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | DFDR                                                                                                |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Meteo radar                                                                                         |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | ILS Cat 3                                                                                           |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | RVSM                                                                                                |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | TCAS, EGPWS                                                                                         |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | GPWS                                                                                                |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       | Powerplant      |                                                                                                     |   |       |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Auxiliary fuel tanks                                                                                |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Thrust reverser system                                                                              |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Hushkit                                                                                             |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Fire detection                                                                                      |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Fuel gauging                                                                                        |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Change of engine or propeller                                                                       |   | 1     |
| CS-27 or CS-29                                                                                                                                                                                                                                                                                                                                                        | All disciplines |                                                                                                     |   |       |
| Note: 2/1 means that an assessment of consequences in terms of handling qualities and performance may lead to classification in Group 1.                                                                                                                                                                                                                              |                 | Replacement of main rotor or tail rotor blades                                                      |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Autopilot                                                                                           |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Engine type change                                                                                  |   | 1     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | GPS installation                                                                                    |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Jettisonable overhead raft installation                                                             |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Utility basket installation                                                                         |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Nose or side mount camera installation                                                              |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Passenger access step installation                                                                  |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Protection net & handle installation (parachuting)                                                  |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | VIP cabin layout                                                                                    |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Navigation system installation                                                                      |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Fuel boost pump automatic switch-on installation                                                    |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Decrease of maximum seating capacity                                                                |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Agricultural spray kit installation                                                                 |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Long exhaust pipe installation                                                                      |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Flotation gear installation                                                                         |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Wipers installation                                                                                 |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Engine oil filter installation                                                                      |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Skid gear covering installation                                                                     |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Gutter installation (top pilot door)                                                                |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Cable cutter installation                                                                           |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Auxiliary fuel tank fixed parts installation                                                        |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Cabin doors windows replacement                                                                     |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Radio altimeter aural warning installation                                                          |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Standby horizon autonomous power supply                                                             |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Fire attack system                                                                                  |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Hoisting system installation                                                                        |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | External loads hook installation                                                                    |   | 2     |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Emergency flotation gear installation                                                               |   | 2/1   |
|                                                                                                                                                                                                                                                                                                                                                                       |                 | Heating/demisting (P2 supply)                                                                       |   | 2     |

GM · GM1 21.A.112B — Regulation (EU) No 748/2012 · ED Decision 2021/001/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

[All rules in SECTION A — TECHNICAL REQUIREMENTS](https://avioverse.aero/regulations/easa/initial-airworthiness/annex-i/section-a-technical-requirements)

Consolidated from the EASA Easy Access Rules (revision 27 Nov 2025, extracted 13 Oct 2026) for convenience. Not the official publication — verify against the Official Journal of the European Union and the EASA publications before operational use.
