---
title: "GM No 2 to 21.A.165(c) Obligations of holder – Conformity with type design — Annex I, Initial Airworthiness · Avioverse"
description: "Individual configurations are often based on the needs of the customer and improvements or changes which may be introduced by the type-certificate holder."
url: "https://avioverse.aero/regulations/easa/initial-airworthiness/annex-i/section-a-technical-requirements/gm-no-2-to-21-a-165-c-obligations-of-holder-conformity-with-type-design"
---

# GM No 2 to 21.A.165(c) Obligations of holder – Conformity with type design

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

GM Guidance material

## GM No 2 to 21.A.165(c) Obligations of holder – Conformity with type design

Individual configurations are often based on the needs of the customer and improvements or changes which may be introduced by the type-certificate holder. There are also likely to be unintentional divergencies (concessions or non-conformances) during the manufacturing process. All these changes should have been approved by the design approval holder, or when necessary by the Agency.

GM — Regulation (EU) No 748/2012 · ED Decision 2012/020/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.