ARC Recommendations and CAMO: Preparing for the Authority's Approval

The Airworthiness Review Certificate (ARC) is one of the most critical documents in an aircraft's continuing airworthiness management cycle. For operators and lessors, understanding how a CAMO prepares and manages the ARC recommendation process is essential to avoiding airworthiness lapses, regulatory findings, and costly ground stops.

What Is an ARC and Why Does It Matter?

The Airworthiness Review Certificate confirms that an aircraft has been reviewed and found to be in a satisfactory airworthiness condition at the time of the review. Under EASA regulations (Part-M Subpart I and Part-CAMO), an ARC is valid for one year and must be renewed annually through either a full airworthiness review or, in certain cases, an extension issued by the approved CAMO.

For lessors, the ARC is a key commercial document — an aircraft with a lapsed or suspended ARC cannot be operated commercially, and any gap in ARC validity directly impacts the aircraft's revenue-generating capability and its attractiveness to prospective lessees.

The CAMO's Role in the ARC Process

Under Part-CAMO, an approved CAMO with ARC recommendation privilege can conduct the airworthiness review and issue a recommendation to the competent authority for ARC issuance. The review involves a comprehensive physical inspection of the aircraft and a detailed audit of the aircraft's technical records, including:

• Verification that all maintenance has been carried out in accordance with the approved maintenance programme
• Confirmation that all airworthiness directives (ADs) and mandatory service bulletins have been complied with
• Review of the aircraft's mass and balance documentation
• Verification of all life-limited parts (LLPs) and their remaining cycles/hours
• Confirmation that all modifications and repairs have been properly documented and approved
• Review of the aircraft's Certificate of Registration, Certificate of Airworthiness, and noise certificate
• Verification of the aircraft's weight schedule and equipment list

Common Findings That Delay ARC Issuance

In our experience managing CAMO services across multiple registries — including EASA, Cayman, Bermuda, and 2-Reg — the most common findings that delay ARC issuance fall into three categories:

Preparing for a Smooth ARC Renewal

The most effective way to ensure a smooth ARC renewal is to treat airworthiness review preparation as a continuous process rather than an annual event. Spectrum Technics' CAMO team follows a structured 90-day pre-ARC preparation cycle for all managed aircraft:

• 90 days before ARC expiry: Internal records audit to identify any gaps or discrepancies
• 60 days before: All outstanding maintenance tasks and AD compliance actions scheduled and work orders raised
• 45 days before: Physical aircraft inspection pre-check to identify any findings before the formal review
• 30 days before: ARC recommendation package compiled and submitted to the competent authority
• 14 days before: Authority review and any clarification requests addressed
• ARC issuance: New ARC issued with zero gap in validity

Multi-Registry ARC Management for Lessors

For lessors managing portfolios across multiple registries, the ARC management challenge is compounded by the different requirements and timelines of each competent authority. Spectrum Technics holds CAMO approvals under EASA (MT.CAMO.0105), Cayman (CAY-CAMO-051173), Bermuda (BDA/CAMO/252), and 2-Reg (2-REG.39.164), enabling us to manage ARC recommendations across multiple registries without requiring the lessor to engage separate CAMO providers for each jurisdiction.

This multi-registry capability is particularly valuable during aircraft transitions — when an aircraft moves from one lessee to another under a different registry, the CAMO can manage the de-registration, re-registration, and ARC issuance under the new registry as a single integrated process.

Conclusion

The ARC recommendation process is a core CAMO competency that directly impacts an aircraft's commercial availability. Lessors and operators who work with a CAMO that has robust records management systems, multi-registry approval, and a proactive pre-ARC preparation process will consistently achieve zero-gap ARC renewals and avoid the costly disruptions associated with airworthiness lapses.

Spectrum Technics' CAMO and Subpart I services are designed to provide exactly this level of proactive, integrated airworthiness management — across all registries and throughout the full aircraft lifecycle.