June 23, 2026

On June 22, the UK CAA confirmed to ARSA it had corrected its renewal process under the bilateral agreement between the United States and United Kingdom. U.S.-based repair stations holding CAA approval under the bilateral should utilize the link referenced in Section B, Paragraph 3.1.3 of the FAA/UK CAA MAG and follow the process outlined in the guidance.

UK Part 145 approvals are valid for two years. Each applicant is responsible for submitting a renewal application in a timely manner, which should be done 90 days prior to their certificate expiration date. An August 2025 ARSA member query noted the MAG pointed to a non-existent web option. After providing a work around while correcting its resources, the UK CAA has activated the application and renewal portal referenced in the guidance.

ARSA members holding UK approval under the bilateral are encouraged to schedule their application for renewal well in advance of the 90 day mark. To confirm continued acceptability of a UK CAA supplement, use the matrices tracking compliance with the special conditions and supplement guidance (click here for more information).

To download a copy of CAA Form SRG 1783, which is necessary for both initial application and renewal, click here.

To access the current version of the MAG, which CAA officials indicate will be updated in the near future, click here.

ARSA’s new cross-reference matrices are available for U.S.-based repair stations looking to show compliance with the special conditions established under the bilateral agreement between the United States and the United Kingdom.

While the current transition periods allows for American maintenance providers to continue using an EASA dual release through 2024, the UK CAA has begun issuing approvals to FAA certificate holders (a number of ARSA members are already on the short list of approvals granted so far). The association’s tools will help repair stations, with or without existing UK approval, to assess their manual systems.

ARSA’s matrices are constructed exactly as those produced for compliance with the U.S./EU bilateral. For each special condition listed, users input the appropriate references to the RSQM, TPM, FM, form or related procedure or documentation in the Compliance Reference field. When an element does not apply, users explain the non-applicability so potential answers to inspector questions (and supportive reasoning) is readily apparent.

The matrices are available as part of ARSA’s free “tools for members.” To request your updated copy, which is delivered as a .zip file containing all “tools,” complete the order form at arsa.org/publications.

To see a brief overview of the current bilateral agreement between the United States and United Kingdom, members can review the “Legal Brief” in the October 2023 edition of the hotline.

On Dec. 8, the FAA and UK CAA issued a joint statement confirming the January 2023 termination of the Special Arrangement for Continuity in Aircraft Certification Projects.

“The two-year transition period and this associated Special Arrangement will end on 01 January 2023,” the agencies said. “From that date, the provisions of the Special Arrangement will no longer be available, and all validation projects must follow the processes set out in the Implementation Procedures for Airworthiness established between the UK CAA and the FAA.”

To read the statement, click here.

To download the UK CAA/FAA IPA, click here.

Key Documents & Contacts

UK CAA/FAA MIP FAA INFO 22004 Recording of and presentation from FAA Webinar on Nov. 15, 2023 For updated access to documents from the agencies, visit the FAA’s Dynamic Regulatory System (drs.faa.gov), select “Other Documents” and then “International Publications” from the left-hand menu. The UK CAA also publishes documents on its bilateral agreements page. Submit questions about the MIP/MAG to 9-awa-afs-intl-coordinator@faa.gov or call 858-999-7671. UK CAA/FAA IPA

November 17, 2022

On Nov. 15, the FAA hosted a webinar on the Maintenance Implementation Procedures (MIP) and Maintenance Agreement Guidance (MAG) established between the United Kingdom (UK) and United States (US). The agency will begin accepting applications for UK approval of US-based repair stations on Jan. 1, 2023; approval must be held to perform work subject to British rules by the beginning of 2025.

During the webinar, FAA MIP Coordinator Paul Cloutier quickly reviewed the status of the new MIP and MAG. Cloutier explained the Special Conditions outlined in the MAG are “very similar” to those between the United States and European Union, with some “improvements” based on experience between the regulators. Once the new agreements take effect on Jan. 1, 2023, FSDOs will oversee applications by and surveillance of repair stations wishing to obtain UK certification. The MIP allows for a two-year transition period to provide the FAA time to process the expected influx of applications.

Repair stations holding EASA approval under the U.S.-EU bilateral agreement may continue performing work on UK aircraft and articles until Dec. 31, 2024. A UK Maintenance Organisation Approval will be required after New Year’s 2025.

After the overview, Cloutier was joined for Q&A by UK Head of Airworthiness Policy and Rulemaking Neil Williams (a regular participant in ARSA’s Annual Conference). The pair handled questions regarding certification, quality system integration, manual supplements, and maintenance releases. Of particular interest to ARSA members – and topics likely to recur in the association’s advocacy:

(1) The agencies have directed that repair stations cannot issue a so-called “triple release” on an FAA Form 8130-3 simultaneously showing compliance with FAA, EASA, and UK rules. When certificate/approval holders wish to authorize work for return to service under all three systems, they must issue separate dual releases: one under the UK-FAA bilateral and one under the EASA-US requirements. While an enterprising questioner confirmed these could be one document (e.g., printed on the front and back of a single piece of paper), the regulators insist upon duplicative paperwork.

(2) The Repair Station Manual Supplement required for UK approval must be separate from an EASA supplement. ARSA has long pushed to integrate manual content as closely as possible. Not only does such integration support regulatory compliance, it is a practical means to prevent human factors errors by technicians required to jump among and between various documents to find relevant procedures. Stay tuned for updates from the ARSA publications department.

(3) Applications must include a demonstration of need. Williams demurred when asked for specifics, citing interest against being overly proscriptive, but noted a customer letter or listing of orders would be sufficient.

(4) Sub-contractors need not hold CAA approval; they can be managed under existing repair station rules for contract maintenance in § 145.217.

(5) Similar to EASA requirements, the repair station must incorporate both product and procedural audits into its quality system. These audits can be performed together but must be clearly documented according to which elements are tested.

(6) Repair stations with upcoming renewals of their EASA approvals under the U.S.-EU bilateral should proceed on schedule with their European application to continue using that approval for work on UK aircraft and articles.

Repair stations seeking British approval may submit application to their local FSDOs using UK Form SRG 1783*. The fee associated with initial application is £900.

Reference Materials

To watch a recording of the Nov. 15 webinar, click here.

To download the PowerPoint presentation (with speaker notes), click here.

To download the MIP directly from ARSA’s servers, click here.

To download the FAA’s InFO directly from ARSA’s servers, click here.

For updated access to documents from the agencies, visit the FAA’s Dynamic Regulatory System (drs.faa.gov), select “Other Documents” and then “International Publications” from the left-hand menu. The UK CAA also publishes documents on its bilateral agreements page.

Submit questions about the MIP/MAG to 9-awa-afs-intl-coordinator@faa.gov or call 858-999-7671.

*Appropriately, the independence of the United States was codified when the Treaty of Paris was signed in September 1783.

June 2, 2026

On May 28, ARSA Executive Vice President Christian Klein informed congressional staff of an ongoing lawsuit against the FAA alleging violations of the Administrative Procedure Act and the Fifth Amendment to the U.S. Constitution.

The suit alleges the unlawful termination of FAA designees and the improper promulgation and enforcement of rules that deprive those designees of procedural due process. Klein’s message provided professional staff on congressional committees with jurisdiction over aerospace matters with a copy of the class-action complaint and introduced the attorney representing the plaintiffs.

The named plaintiffs brought the suit on behalf of all terminated designees, including designated pilot examiners (DPEs), designated engineering representatives (DERs), and designated mechanic examiners (DMEs). The complaint highlights multiple alleged failures in FAA administrative action resulting in harm to designees, particularly the agency’s position that part 13’s rules establishing due process standards do not apply to individuals serving at the government’s discretion who are not employees or certificate or approval holders.

“The litigation raises important administrative law questions and has implications for the efficiency of the aviation sector, because FAA designees are a vital part of the regulatory compliance ecosystem,” Klein said in his message.

To read the full complaint, filed with the United States District Court for the Middle District of Florida, click here.

Jan. 8, 2025

The FAA has announced an amendment to Order 8900.1, Vol. 6, Chap. 9, Sec. 27 clarifying procedures for aviation safety inspectors (ASIs) who oversee domestic repair stations holding foreign certificates under bilateral aviation safety agreements (BASAs) between the FAA and the Civil Aviation Authority of Singapore (CAAS), the United Kingdom (UK) CAA, and/or the National Civil Aviation Agency of Brazil (ANAC).

Among other things, the updated Sec. 27:

• Provides background on the purposes of BASAs and related Maintenance Implementation Procedures (MIP) and Maintenance Annex Guidance (MAG).
• Describes the various prerequisites ASIs must meet prior to conducting oversight, including FAA electronic Learning Management System (eLMS) course requirements specific to each of the BASAs.
• Explains the interrelationship between ASIs, the FAA Flight Standards Service (AFS) General Aviation Group (AFS 340), and the partnering civil aviation authority, identifying FAA coordinators as primary points of contact between AFS and the foreign CAA and explaining how policy issues and proposed changes to the MIP and MAG are elevated within AFS.
• Details procedures for auditing a repair station pursuant to a MIP.

The Order directs ASIs to use Sec. 27 in conjunction with the applicable MAG between the United States and foreign country, but reminds them the MAG supersedes the order if the two documents conflict.

Similar guidance related to oversight of U.S. repair stations with European Union Aviation Safety Agency (EASA) approval is found at FAA Order 8100 Vol. 6, Chap. 9, Sec. 24. Transport Canada Civil Aviation (TCCA) guidance is in Sec. 22.

August 18, 2008

On July 8, 2008 an ARSA-led coalition of aviation industry representatives sent a letter urging Members of Congress to prevent the industry from suffering punishment due to inaction by the Transportation Security Administration (TSA).

Section 1616 of the “9/11 Commission Recommendation Act of 2007” (P.L. 110-53) and Sec. 611 of VISION 100 (the 2003 Federal Aviation Administration (FAA) reauthorization law) (P.L. 108-176) required the TSA to promulgate repair station security rules. Under those laws, if the TSA does not issue a final rule by Aug. 3, 2008, the FAA will be prohibited from issuing new certificates to foreign repair stations. Although there is an exception for certificate renewals and applications in process, the law will have unintended and negative consequences for U.S. companies seeking to expand operations overseas.

On May 13, TSA Administrator Kip Hawley testified before the Senate Commerce, Science and Transportation Committee that a final rule will not be issued by the Aug. 3, 2008 deadline. Indeed, it appears that the TSA will be hard pressed to issue a Notice of Proposed Rulemaking by that date.

Presented with this fact, ARSA turned its attention to Capitol Hill and, via the letter, sought to bring attention to the punishment looming over the aviation industry. The letter emphasized the important role of foreign repair stations in all aspects of the aviation industry, underscoring the fact that a freeze on foreign repair stations will create negative effects on the aviation community in the U.S. In addition, the letter questioned the logic of punishing private industry for the failings of a government agency.

This letter follows one previously sent by ARSA to TSA Administrator Kip Hawley exhorting the agency to meet the deadline for the final rule.

ARSA thanks those organizations lending support to this effort.

To read the July 8 letter click here.

January 20, 2007

ARSA Managing Director and General Counsel Marshall Filler testified before the Aviation Subcommittee of the Senate Committee on Commerce, Science, and Transportation on June 20, 2007.

The hearing, entitled “Oversight of Foreign Aviation Repair Stations,” focused on the expanding role of international contract maintenance and the capabilities of the Federal Aviation Administration (FAA) to ensure oversight of foreign entities. In addition, the hearing discussed work being completed by so-called “non-certificated repair stations”, both foreign and domestic.

The hearing resulted, in part, from ARSA’s successful efforts to defeat proposed language in the FAA reauthorization bill (S. 1300) that would have mandated drug and alcohol testing of all domestic and foreign repair station employees, and imposed new restrictions on the use of contract maintenance by air carriers.

Other witnesses at the hearing were The Honorable Calvin L. Scovel III, Inspector General, U.S. Department of Transportation, Peggy Gilligan, Deputy Associate Administrator for Aviation Safety, U.S. Department of Transportation, Robert Roach Jr., General Vice President, The International Association of Machinists and Aerospace Workers, Basil Barimo, Vice President of Operations and Safety, Air Transport Association and Tom Brantley, President, Professional Airway Systems Specialists.

Mr. Filler’s written testimony is available here.