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GM 21.A.15(c) Updates to the certification programme

ED Decision 2025/016/R

Point 21.A.15(b) recognises that the initial submission of the certification programme may not be fully complete, e.g. due to schedule constraints of the design, analysis and testing activities.

Furthermore, even if the initial submission of the certification programme is complete, it may be necessary to amend it throughout the duration of the project.

The certification programme should be updated and resubmitted to EASA. In particular, updates to the following elements should be provided:

— any complementary information that was not included in the initial submission of the certification programme;

— any change in the intended use or kind of operations of the product itself, or of the aircraft on which the product is installed;

— a change in the key characteristics of the product such as but not limited to any declared limits that are intended to be recorded in the type certificate data sheet (TCDS);

— any change in the product design or its characteristics that may affect the criteria used to assess the likelihood of an unidentified non-compliance with the type-certification basis, operational suitability data (OSD) certification basis or the environmental protection requirements, including the potential impact of that non-compliance on product safety or environmental compatibility, as defined in 21.A.15(b)(6) and 21.B.100(a)(1) to (4);

Note: An update of the DOA dashboard after the first issuance of the certification programme only needs to be considered if there is a significant change in the performance.

— any change to the initial type-certification basis, OSD certification basis or environmental protection requirements, as applicable to the product, regardless whether the change is initiated by EASA or by the applicant;

— any change in the breakdown of the certification programme into compliance demonstration items (CDIs) or in the content of those CDIs;

— any change in the proposed means of compliance, including its/their methodology;

— any change in the structure of compliance documents that may affect the determination of EASA’s level of involvement (LoI), as defined in 21.B.100;

— any relevant change to the design organisation approval (DOA) holder’s personnel (and design organisation (DO) suppliers) who are involved in the project; and

— any changes to the schedule that impact on the EASA LoI.

Following each update to the certification programme as submitted by the applicant, EASA may update the determination of its LoI in accordance with 21.B.100(c).