Airworthiness

Management of Airworthiness compliance is the responsibility of the aircraft operator, who must appoint an individual in to the position of management, known as the Nominated Airworthiness Technical Representative (NATR).

A Continuing Airworthiness Management Organisation (CAMO) is not required. However, the operator may choose to appoint a CAMO as the NATR if they wish.

The aircraft operator must inform the Aircraft Registry of their NATR. However, the NATR appointment is not subject to Isle of Man Aircraft Registry (IOMAR) approval. This specific contact information is notified to the IOMAR on Form 20 Operator Declaration of Compliance & Delegated Authority Form.

The NATR will be the single point of contact for all matters of airworthiness for the Operator to the IOMAR and will manage the aircraft continuing airworthiness including the compilation of the requirements of the Maintenance Control Manual.

The NATR should be available to the IOMAR during the registration process, they should also provide the information required in Form 3 and Form 9 which are applications for airworthiness surveys, and also Form 100 Aircraft Maintenance Programme Approval Application.

The NATR must review all documents (work packs, tech log pages etc) that have a Certificate of Release to Service (CRS), within 30 days of receipt of the documents being returned from the Maintenance organisation or individual issuing the CRS . This is to ensure an accurate and therefore valid CRS has been made.

For further details on the role of the NATR please refer to Registry Publication 9 (RP9).  

Please see our dedicated on Airworthiness surveys page.

The Isle of Man is not a ‘state of design’ and does not perform type design review or technical validation of a foreign type certificate. However, in accordance with ICAO principles, the Isle of Man recognises by ‘direct acceptance’ the type certificates issued by the following States to meet the listed Certification Specifications:

1. EASA (or the CS of the member states): 

• CS23;
• CS25;
• CS27;
• CS29.

2. FAA (USA):

• 14CFR Subpart C Aircraft Standards;
• Part 23;
• Part 25;
• Part 27;
• Part 29.

3. TCCA (Canada):

• Aviation regulations (CARs) and Standards Part V Airworthiness;
• CAR 523;
• CAR 525;
• CAR 527;
• CAR 529.

4. ANAC (Brazil) subject to the aircraft type design holding an issued TC from either EASA/FAA/TCCA:

• RBHA 23;
• RBHA 25.

5. UK:

• CS23;
• CS25;
• CS27;
• CS29.

The list of Type Certificates already accepted by the IOMAR can be found on our online portal (for a complete list follow the hyperlink and then just click ‘Search’). If your aircraft type does not appear on the list, please contact the Registry Services Team for assistance.

Clients may request that the state of Type Certificate (TC) compliance is changed for the particular aircraft. This is most commonly undertaken at initial registration or immediately prior to deregistration, but may also be requested at other times whilst registered.

Requests for change in TC compliance should be initially made by email to [email protected]. The following information should be considered prior to making the request.

An airworthiness survey must be completed prior to accepting a change to the aircraft’s recorded state of TC compliance.

In addition to the normal survey preparation requirements, the aircraft Operator must also provide:

• all importing State requirements in a clear document (many manufacturers provide a “Change Document” (ASC, SB etc.) that identifies actions needed)
• aircraft compliance documentation back to the point of first civil registration of the State of Issue, for the respective Airworthiness Directives (ADs) applicable to the TCDS of survey, to enable confirmation with those ADs.

Please note that our Flight Operations team must also review and be satisfied with the requirements pertaining to the aircraft’s Operational Approvals and MEL; this may require reissuance of the Operations Specification, MMEL Permission or MEL Approval.

A certificate of release to service (CRS) is necessary to bring a CoA back into force following overhaul, repair, replacement, modification, maintenance or inspection of the aircraft.

Isle of Man Maintenance Organisation Approvals are not needed.

A CRS may be issued by:

1. a person who is acting in their duties as an employee of an organisation that holds either:

• a Title 14 Code of Federal Regulations (CFR) Part 145 certification; or,
• an EASA Part 145 approval; or,
• an EASA Part 145 approval issued by the UK CAA prior to 1 January 2021; or,
• a UK CAA Part 145 approval.

2. a person listed in the maintenance organisation manual of a maintenance organisation that holds:

• an EASA Part M Subpart F or Part CAO approval; or,
• an EASA Part M Subpart F or Part CAO approval issued by the UK CAA prior to 1 January 2021; or,
• a UK CAA Part M Subpart F or Part CAO approval; or,
• an EASA Part CAO approval;

3. the holder of an aircraft maintenance engineer’s licence that has been validated by the IOMAR (line maintenance & defect rectification only - for further information see our pages on licence validations);

• a person authorised by the Department as being competent to issue the certification and who is acting in accordance with the approval (line maintenance & defect rectification only).

For further details on the issuance of a CRS please refer to Registry Publication 9 (RP9).

Unless a defect can be deferred in accordance with an Isle of Man approved Minimum Equipment List, Isle of Man Aircraft Registry (IOMAR) permission is required for an aircraft to commence a flight if any of the equipment required for the intended flight is in a fit condition for use.

Guidance and instructions for this can be found within Registry Publication 9 Airworthiness Management Information, and is applied for by completing Form 68A.

A permission will only be granted using one of the following processes:

• On the basis of a No Technical Objection (NTO) from the TC Holder giving due consideration of the request. Note: an NTO issued by the TC Holder alone does NOT constitute permission to operate the aircraft and is only a supporting document to the issue of a permission certificate by the office of the IOMAR.
• For an aircraft of a type which has an MMEL, where:
     1. the defect is deferrable under the MEL/MMEL, and
     2. the defect rectification interval is a category B, C or D defect, and
     3. the defect has not already been self-extended by an approved RIE process; and
     4. the required extension is up to 100% of the original defect.

For further details on operation with a known defect please refer to Registry Publication 9 (RP9).  

An aircraft must not fly unless it has an Approved Maintenance Programme - guidance and instructions for this can be found within Registry Publication 9 Airworthiness Management Information, and is applied for by completing Form 100 Application for an Aircraft Maintenance Programme (AMP) Approval.

Upon satisfactory level of review, an Approved Maintenance Programme Certificate will be issued by the Isle of Man Aircraft Registry (IOMAR).

If there are any subsequent changes to your Maintenance Programme please follow the guidance in RP9 and submit the relevant application to the IOMAR for review.

The content of Form 100 / 101 and all documents cross referenced from it must be in compliance for the aircraft to be considered airworthy.

There are no Isle of Man legislative requirements regarding the need for a maintenance programme for aircraft that do not hold a current certificate of airworthiness. The IOMAR strongly advocates that stored aircraft are inducted into a storage programme using the relevant approved data from the Type Certificate (TC) Holder. The TC Holder provides operators with detailed aircraft parking procedures and instructions for storage which, if followed, eases the process for subsequently re-gaining a certificate of airworthiness. However, the choice of measures taken is for the aircraft owner/operator to decide.

Aircraft can only operate with one of the following documents that MUST be in place and valid, prior to any flight occurring:

1. Certificate of Airworthiness (CoA). Issued by the IOMAR Registry Services Section for unhindered International Air Navigation of a compliant aircraft;
2. Permit to Fly (PtF). Issued by the IOMAR Airworthiness Section, for un-airworthy aircraft and under limited circumstances;
3. Maintenance Check Flight (MCF) completed by the Operators NATR, prior to the flight whilst the aircraft is un-airworthy by reason of an "open entry of scheduled maintenance”.

Permit to Fly

A Permit to Fly (PtF) may be issued for situations when an aircraft is not fully in compliance with its airworthiness requirements, providing the aircraft is capable of safe flight.

Prior to submitting any application for a PtF, the NATR of the aircraft is advised to contact the Airworthiness Section to discuss the circumstances which have invalidated their CoA, and agree on a course of action.

The need for a PtF must be justified by the applicant to the satisfaction of the Airworthiness Section as being reasonable and necessary.

The Aircraft Registry reserves the right to survey any aircraft prior to the issue of a PtF.

Applications for a PtF shall be made by the submission of a Form 42-Application for a Permit to Fly emailed to the stated address on the form, accompanied by any supporting data discussed and requested at the time of the initial contact.

The Airworthiness Section must be satisfied that the proposed flight(s) enabled by the PtF are safe given the circumstances of the flight(s) on the basis of a No Technical Objection (NTO) from the TC Holder giving due consideration of the request.

The IOMAR will ensure that appropriate limitations and constraints of the flight are specified to assure the aircraft’s safe operation.

A PtF will be issued for a maximum period of 14 days.

Maintenance Flight Check

Aircraft that are required to carry out an in-flight phase for a scheduled task of maintenance under an AMP, or when an AMM maintenance task requires associated flight checking (see RP9 for examples).

Form 36, Maintenance Check Flight Document completed by the NATR, and held in the aircraft records, is an AMC for the requirement of a document to be in place BEFORE a flight takes place.

In all cases, if the IOMAR CoA is detailed as invalid (as described above) acceptance by the NAA of the airspace where the flight will take place, must be obtained.

The PtF (Form 42) or MCF (Form 36) may be used in support of that request for acceptance to the NAA.

For further details on the issuance of a PtF or use of a Maintenance Check Flight Document (Form 36) please refer to Registry Publication 9 (RP9). 

Modification and repair data provided by the Type Certificate Holder, Supplemental Type Certificate Holder or Design organisation and/or those approved under the regulations of the state of design, EASA – Technical Visa, or Part 21 design data, is considered an acceptable certification standard without the need to apply for a modification or repair approval to be issued by the IOMAR. 

NATR applications for approval of minor modifications can be made  using Form 35 Application for Approval of a Modification.

“Minor” is defined as: a change that has a negligible, or no appreciable, effect on the mass, balance, structural strength, reliability, operational characteristics or other characteristics affecting the airworthiness of the aeronautical product. Consequently, such changes must not involve:

• amendment of the TC nor the issuance of an STC;
• changes to primary or secondary pressurised structure;
• changes to material specification;
• changes to operating procedures or the Flight Manual.

The Isle of Man Aircraft Registry will not issue repair approvals.

For further details on applications for minor modification approvals please refer to Registry Publication 9 (RP9) or the notes on Form 35. 

ICAO specifies that aircraft instruments and equipment including their installation shall be acceptable to the State of Registry.

The following equipment and its associated installation is considered to be acceptable and therefore does not need specific Isle of Man Aircraft Registry (IOMAR) approval; equipment that is:

• listed in the aircraft’s Instructions for Continuing Airworthiness issued or referenced by the TC or STC holder; or
• captured by modification data specified by the TC or STC holder or design organisation and/or those approved under the regulations of the state of design, EASA – Technical Visa, or Part 21 design data; or
• subject to a ‘minor’ Modification Approved issued by the IOMAR ; or
• not used by the flight crew to control the flight path, or is not installed in the aircraft, subject to the equipment:
  • not affecting the airworthiness of the aircraft, even in the case of failures or malfunction; and
  • if used by a flight crew member, being:
    • readily operable or accessible from the station where the flight crew member that needs to use it is seated; and
    • so arranged as to permit the flight crew member to see any indications readily from their station, with the minimum practicable deviation from the position and line of vision which they normally assume when looking forward along the flight path; and
    • if it is emergency equipment, being easily accessible for immediate use.