FAA–EASA Maintenance Approval: Review the Annex, Supplement, and Manuals Together
An organisation working under both FAA and EASA maintenance approval arrangements can have several authoritative documents in play: regulations, the bilateral maintenance annex, implementation guidance, approval certificates, supplements, manuals and local procedures. The danger is collapsing them into one “Part 145” search result and missing which authority, approval or edition a paragraph belongs to.
This is a document-review workflow, not an interpretation of a particular organisation's privileges. It shows how a future multi-authority Aviation.Bot library could make the source trail easier to inspect.
Keep the source families distinct
The FAA–EU Maintenance Annex Guidance (MAG) and Maintenance Annex are specific cross-border source material. The FAA's AC 145-9A discusses the Repair Station Manual (RSM) and Quality Control Manual (QCM). On the EASA side, Part-145 and its AMC/GM belong to the continuing-airworthiness rule set and a maintenance organisation uses its MOE.
An MOE and an RSM/QCM are not interchangeable names for the same approved artifact. The annex and guidance do not remove the need to verify each approval, the relevant supplement, scope of work and the current official edition. Record the MAG change level and date used for the review; the FAA page currently points to Change 10, effective 10 October 2025, but a later change may supersede it.
Start with one operational question
Take a bounded scenario: a maintenance team wants to check whether a planned job at a named site is covered by the relevant approval and documented procedure. The reviewer should identify the product and work scope, the site, the applicable approval and supplement, and the controlled manual sections. Do not ask a model, “Are we FAA/EASA compliant?”
The review set may include:
- the official FAA and EASA provisions relevant to the job;
- the applicable version of the FAA–EU annex and MAG;
- the organisation's approval certificates and scope limitations;
- the current MOE, FAA supplement, RSM/QCM and relevant local procedures;
- training, authorisation and quality records that support the specific process.
The reviewer should decide which items are authoritative for the question. A guidance document, regulation, approval condition and internal procedure play different roles even when they mention the same operation.
A useful comparison output
| Decision point | Source or document | What to record |
|---|---|---|
| Authority and edition | FAA/EASA rule, annex and MAG | Issuer, version, date, exact section and whether it applies to this review. |
| Approval boundary | Certificates and scope | Site, rating/work scope, limitations and reviewer confirmation. |
| Controlled process | MOE, supplement, RSM/QCM and procedure | Exact sections, revision status and any difference that needs a human decision. |
| Supporting evidence | Authorisation/training/quality record | Record ID, owner, status and what remains unavailable in the review sample. |
| Decision | Qualified owner | Accepted position, required action, rationale and sign-off. |
This is not a claim that the listed documents always have to be changed together. A good review may conclude that no controlled edit is needed, provided that conclusion is supported by the right source and approval evidence.
The planned Aviation.Bot workflow
The proposed Aviation.Bot external library would hold searchable official FAA and EASA source material with source identity and edition information. A user could combine those sources with the organisation's selected documents in the web app by upload, or in the desktop app through a local folder. The assistant could then find candidate passages across both jurisdictions and draft a comparison table with citations to the originals.
That would reduce time spent finding scattered source files and checking cross-references, if the relevant editions and documents are present and the retrieval works for the task. It does not make approval systems equivalent or decide privileges. A reviewer still confirms source currency, applicability and the organisation's controlled-document status. An online external library also means this is not a fully offline workflow; private-document and AI-provider data paths must be chosen separately.
This is one example of the cross-country research work that a curated library could support. Broader comparisons across national authorities should use the same source/version discipline rather than assuming that a similar title means the same requirement.
For an EASA-only example, read the Part-145 MOE change-impact matrix.
Library status: Multi-authority Aviation.Bot libraries and the joined web/desktop workflow are under construction. Join the Early Access list on Aviation.Bot to hear when they become available. The current beta has narrower coverage.