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AMC 21.B.100(a) and 21.A.15(b)(6) Level of involvement (LoI) in a certification project for a type certificate (TC), a major change to a TC, a supplemental type certificate (STC), a major repair design or European technical standard order (ETSO) authorisation for an auxiliary power unit (APU)

Available versions for ERULES-1963177438-15171

ED Decision 2019/018/R found in: Initial Airworthiness and Environmental Protection (748/2012) Part-21 Part-21L (Jul 2024)
ED Decision 2025/016/R found in: Initial Airworthiness and Environmental Protection (748/2012) (Nov 2025)

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AMC 21.B.100(a) and 21.A.15(b)(6) Level of involvement (LoI) in a
certification project for a type certificate (TC), a major change to a TC, a
supplemental type certificate (STC), a major repair design or European
technical standard order (ETSO) authorisation for an auxiliary power unit
(APU)

ED Decision 2019/018/R

1.       Definitions

Risk: the combination of the likelihood and the potential impact of a
non-compliance with part of the certification basis.

Likelihood: a prediction of how likely an occurrence of non-compliance with
part of the certification basis is, based on a combination of the novelty and
complexity of the proposed design and its related compliance demonstration
activities, as well as on the performance of the design organisation.

Criticality: a measure of the potential impact of a non-compliance with part
of the certification basis on product safety or on the environment.

Compliance demonstration
item (CDI): a meaningful group of compliance
demonstration activities and data of the certification programme, which can be
considered in isolation for the purpose of performing a risk assessment.

EASA panel: an EASA panel is composed of one or more experts who are
responsible for a particular technical area. Each technical area addressed
during product certification is covered by an EASA panel.

EASA discipline: an EAS447

A discipline is a technical subarea of an
EASA panel.

EASA’s level of involvement
(LoI): the compliance demonstration activities
and data that EASA retains for verification during the certification process,
as well as the depth of the verification.

2.       Background

The applicant has to submit a certification
programme for their compliance demonstrations in accordance with point [21.A.15](#_DxCrossRefBm1649096854)(b). The applicant has to break
down the certification programme into meaningful groups of compliance
demonstration activities and data, hereinafter referred as ‘CDIs’, and provide
their proposal for EASA’s LoI.

The applicant should also indicate the EASA
panel(s) that is (are) affected by each CDI.

This AMC explains:

(a)      how
to propose EASA’s LoI for each CDI as per points [21.A.15](#_DxCrossRefBm1649096854)(b)(6), [21.A.93](#_DxCrossRefBm1649096851)(b)(3)(iii), [21.A.432C](#_DxCrossRefBm1649096984)(b)(6) as well as [21.A.113](#_DxCrossRefBm1649096858)(b); and

(b)      how
EASA will determine its LoI on the basis of the criteria established in point [21.B.100](#_DxCrossRefBm1649096973).

EASA will review the proposal and determine
its LoI. Both parties, in mutual trust, should ensure that the certification
project is not delayed through the LoI proposal and determination.

Additionally, in accordance with point [21.A.20](#_DxCrossRefBm1649096852), the applicant has the obligation
to update the certification programme, as necessary, during the certification
process, and report to EASA any difficulty or event encountered during the
compliance demonstration process which may require a change to the LoI that
was previously notified to the applicant.

In such a case, or when EASA has other
information that affects the assumptions on which the LoI was based, EASA will
revisit its LoI determination.

In accordance with points [21.A.33](#_DxCrossRefBm1649096983), 21.A.447 and 21.A.615,
irrespective of the LoI, EASA has the right to review any data and information
related to compliance demonstration.

Note: This AMC should not be considered to
be interpretative material for the classification of changes or repairs.

3.       Principles
and generic criteria for the LoI determination EASA determines its LoI based
on the applicant’s proposal in view of the risk (the combination of the
likelihood of an unidentified non-compliance and its potential impact). This
is performed after proper familiarisation with the certification project in
three steps:

—
Step 1: identification of the
likelihood of an unidentified non-compliance,

—
Step 2: identification of the
risk class, and

—
Step 3: determination of
EASA’s LoI.

This AMC contains criteria, common to all
EASA panels, for the determination of:

—
any novel or unusual features
of the certification project, including operational, organisational and
knowledge management aspects;

—
the complexity of the design
and/or compliance demonstration;

—
the performance and experience
of the design organisation of the applicant in the domain concerned;

—
the criticality of the design
or technology and the related safety and environmental risks, including those
identified on similar designs; and

—
the data and activities to be
retained by EASA.

Note: Additional
panel-specific criteria are available in further informative material
published by EASA[[39]](#_ftn39).
This material should not be considered to be AMC.

For CS‑23 commuter (or CS‑23 level 4
airplanes as defined in CS‑23 Amdt 5), CS‑25, CS‑27 and CS‑29 aircraft,
all the panel-specific additional criteria should be considered. For the other
products, the panel-specific criteria should only be considered for CDIs that
affect noise, propulsion, development assurance and safety assessment (DASA),
operational suitability data (OSD) and software and airborne electronic
hardware.

The criteria used to determine the
likelihood and the potential impact of an unidentified non-compliance
generally allow a proportionate approach to be applied, in particular in order
to differentiate between CS‑25 and general aviation (GA) aircraft projects.

3.1.    LoI
determination at CDI level

The determination of EASA’s LoI is performed
at the level of the CDI (please refer to [AMC 21.A.15(b)(5)](#_DxCrossRefBm1649096978)).

The applicant should demonstrate that all
the affected elements of the type-certification basis as specified in point [21.B.80](#_DxCrossRefBm1649096853), of the OSD certification basis as
specified in point [21.B.82](#_DxCrossRefBm1649096972), and of
the environmental protection requirements as specified in [21.B.85](#_DxCrossRefBm1649096971), the corresponding means and
methods of compliance, as well as the corresponding certification activities
and data, are fully covered by the proposed CDIs. If the provided data does
not clearly show that this is the case, the applicant should clearly state to
EASA that all the above-mentioned elements are fully covered.

Note: There could be different ways to
‘clearly show’ that all the elements of the certification basis are included
in at least one CDI. For instance, this could be achieved by means of a ‘CDI
reference’ column added in the table that lists all the elements of the
certification basis.

3.2.    Method
for determining the likelihood of an unidentified non-compliance

3.2.1. Principle
The likelihood of an unidentified non-compliance is assessed on the basis of
the following criteria:

—
novelty,

—
complexity, and

—
the performance of the design
organisation.

3.2.2. Novelty

For the purpose of risk class determination,
the following simplification has been made: a CDI may be either novel or
non-novel.

Whether or not a CDI is novel is based on
the extent to which the respective elements of the certification project, as
well as the related requirement or means of compliance, are new/novel to
either the industry as a whole, or to the applicant, including their
subcontractors, or from an EASA panel perspective.

The determination that a CDI is novel may be
driven by the use of new technology, new operations, new kind of
installations, the use of new requirements or the use of new means of compliance.

When an applicant utilises a type of
technology for the first time, or when that applicant is relatively unfamiliar
with the technology, this technology is considered to be ‘novel’, even if
other applicants may be already familiar with it. This also means that a type
of technology may no longer be novel for one applicant, while it may still be
novel for other applicants.

The following list includes some examples:

—
new materials or combinations
of materials;

—
a new application of materials
or combinations of materials;

—
new manufacturing processes;

—
a new or unusual aircraft
configuration and/or system architecture;

—
a novel reconfiguration of
systems;

—
a new interface or interaction
with other parts or systems;

—
the unusual location of a part
or a system, or an unusual construction;

—
a new or unusual use;

—
new functions;

—
new kinds of operations;

—
the potential for new failure
modes;

—
the introduction of a new
threat (e.g. new threats regarding fire, fuel, hydrogen, energy storage
devices, etc.) or a new prevention/detection/mitigation method;

—
new maintenance techniques;

—
novel operating conditions or
limitations;

—
a new human-machine interface
(HMI); or

—
new flight or cabin crew
tasks.

Another consideration is the extent to which the requirements,
means of compliance or guidance have changed or need to be adapted due to
particular novel features of the design.

The following list includes some examples:

—
recently issued or amended CSs
with which the applicant has little or no experience;

—
new or adapted special
conditions;

—
new or adapted equivalent
safety findings;

—
new or adapted deviations;

—
new or adapted guidance or interpretative
material;

—
new or adapted means of
compliance (i.e. other than those previously applied by the applicant) or
unusual means of compliance (different from the existing guidance material
and/or different from industry standard practices), e.g. the replacing of
tests by simulation, numerical models or analytical methods;

—
the use of new or adapted
industry standards or in-house methods, as well as EASA’s familiarity with
these standards and methods;

—
a change in methodology, tools
or assumptions (compared with those previously applied by the applicant),
including changes in software tools/programs; or

—
novelty in the interpretation
of the results of the compliance demonstration, e.g. due to in-service
occurrences (compliance demonstration results are interpreted differently from
the past).

Additional new guidance/interpretative material in the form of new
certification memoranda (CM) may be considered for the determination of
novelty if its incorrect application/use may lead to an unidentified
non-compliance. In the context of novelty, the time between the last similar
project and the current project of the applicant should also be considered.

Regardless of the extent of an
organisation’s previous experience in similar projects, a CDI may be
classified as novel if there are specific discontinuities in the process for
transferring information and know-how within the organisation.

3.2.3. Complexity
For the purpose of risk class determination, the following simplification has
been made: a CDI may be either complex or non-complex. For each CDI, the
determination of whether it is complex or not may vary based on factors such
as the design, technology, associated manufacturing process, compliance
demonstration (including test set-ups or analysis), interpretation of the
results of the compliance demonstration, interfaces with other technical
disciplines/CDIs, and the requirements. The compliance demonstration may be
considered to be ‘complex’ for a complex (or highly integrated) system, which
typically requires more effort from the applicant. The following list includes
some examples:

—
Compliance demonstration in
which challenging assessments are required, e.g.:

—
for requirements of a
subjective nature, i.e. they require a qualitative assessment, and do not have
an explicit description of the means of compliance with that requirement, or
the means of compliance are not a common and accepted practice; this is typically
the case where the requirement uses terms such as ‘subjective’, ‘qualitative’,
‘assessment’ or ‘suitable’/‘unsuitable’

—
in contrast, engineering
judgement for a very simple compliance demonstration should not be classified
as ‘complex’;

—
a test for which extensive
interpretation of the results may be anticipated;

—
an analysis that is sensitive
to assumptions and could potentially result in a small margin of safety;

—
the classification of
structures, depending on the conservatism of the method;

—
an advanced analysis of
dynamic behaviour;

—
a multidisciplinary compliance
demonstration in which several panels are involved and interface areas need to
be managed (e.g. sustained engine imbalance, extended-range twin-engine
operation performance standards (ETOPS), 2X.1309 assessment, flight in known
icing conditions, full authority digital engine control (FADEC)-controlled
engines, etc.);

—
when the representativeness of
a test specimen is questionable, e.g. due to its complexity;

—
the introduction of complex
work-sharing scheme with system or equipment suppliers.

For major changes, the complexity of the
change should be taken into account, rather than the complexity of the
original system.

Whether or not a CDI is complex should be
determined in a conservative manner if this cannot be determined at an early
stage of the certification project. When greater clarity has been achieved,
the complexity may be re-evaluated and the LoI adapted accordingly.

3.2.4. Performance
of the design organisation

The assessment of the level of performance
of the design organisation takes into account the applicant’s experience with
the applicable certification processes, including their performance on
previous projects and their degree of familiarity with the applicable
certification requirements.

For approved design organisations, EASA uses
relevant data to consider the design organisation’s expected performance at an
organisational, panel or discipline level, depending on the availability of
data[[40]](#_ftn40).

This data stems from design organisation
audits, the applicant’s measured level of performance on previous projects,
and their performance during the familiarisation phase. EASA shares this data
with the respective design organisations (in the form of the design
organisation approval (DOA) dashboard).

For each CDI proposed by the applicant, the
DOA holder’s performance associated with the affected disciplines or panels is
to be considered.

If one CDI affects more panels or
disciplines than the others, a conservative approach should be followed in
selecting the lower performance level. As an alternative, that CDI may be
assessed separately for each affected EASA panel or discipline.

If, for a well-established organisation,
there is no shared performance data available at the panel level, it may be
acceptable to propose the overall DOA holder’s performance. If the
organisation or its scope are fundamentally new, the ‘unknown’ level of
performance should be conservatively proposed by the applicant.

The determination of the performance of the
design organisation may also take into consideration information that is more
specific or more recent than the information on the DOA holder’s dashboard,
e.g. experience gained during technical familiarisation with the current
certification project, the performance of compliance verification engineers
and of the affected technical areas, as well as the performance of the design
organisation in overseeing subcontractors and suppliers.

The performance of some applicants’
organisations is not known if:

—
EASA has agreed in accordance
with point [21.A.14](#_DxCrossRefBm1649096927)(b) that the
applicants may use procedures that set out specific design practices, as an
alternative means to demonstrate their capability (excluding European
technical standard order (ETSO) applicants for other than APU, covered by
point [21.B.100](#_DxCrossRefBm1649096973)(b)); or

—
the applicants demonstrate
their capability by providing EASA with the certification programme in accordance
with point [21.A.14](#_DxCrossRefBm1649096927)(c).

In these cases, the assumed level of
performance is ‘unknown’.

Exceptionally, EASA may consider a higher
level of performance for a specific CDI if that is proposed and properly
justified by the applicant.

The following list includes some examples:

—
a CDI with which EASA is fully
familiar and satisfied (from previous similar projects) regarding the
demonstration of compliance proposed by the applicant;

—
if the applicant fully
delegates the demonstration of compliance to a supplier that holds a DOA, the
performance level of the supplier may be proposed.

3.2.5. Likelihood
of an unidentified non-compliance

Assessing the likelihood of an unidentified
non-compliance is the first step that is necessary to determine the risk
class.

The likelihood of an unidentified
non-compliance should not be confused with the likelihood of occurrence of an
unsafe condition as per AMC 21.A.3B(b). In fact, that AMC provides EASA’s
confidence level that the design organisation addresses all the details of the
certification basis for the CDI concerned, and that a non-compliance will not
occur.

The likelihood of an unidentified
non-compliance is established as being in one of four categories (very low,
low, medium, high), depending on the level of performance of the design
organisation as assessed by EASA, and on whether the CDI is novel or complex,
as follows:

<table border="1" cellpadding="0" cellspacing="0" width="494">
<tr>
<td colspan="4" width="494">
Step 1 — Likelihood
 of an unidentified non-compliance
</td>
</tr>
<tr>
<td width="144">
CDI
Performance level of the
 DOAH 
</td>
<td width="113">
No novel aspects,
no complex aspects
</td>
<td width="118">
No novel aspects,
 but complex ones;
Novel aspects, but
 no complex ones
</td>
<td width="119">
Novel and complex
 aspects
</td>
</tr>
<tr>
<td valign="top" width="144">
High
 
</td>
<td width="113">
Very low
</td>
<td width="118">
Low
</td>
<td width="119">
Medium
</td>
</tr>
<tr>
<td valign="top" width="144">
Medium
 
</td>
<td width="113">
Low
</td>
<td width="118">
Medium
</td>
<td width="119">
High
</td>
</tr>
<tr>
<td valign="top" width="144">
Low
 or unknown 
</td>
<td width="113">
Medium
</td>
<td width="118">
High
</td>
<td width="119">
High
</td>
</tr>
</table>

3.3.    Criticality

The second step that is necessary to
determine the risk class is the assessment of the potential impact of a
non-compliance on part of the certification basis regarding the airworthiness
or the environmental protection of the product. For the purpose of risk class
determination, the following simplification has been made: the impact of a
non-compliance can be either critical or non-critical.

Some of the guidance below has been derived
from [GM 21.A.91](#_DxCrossRefBm1649096982), not due to a
major/minor change classification, but because the same considerations may be
applied to determine the effect of a non-compliance on the airworthiness or
environmental protection at the CDI level. It is therefore normal that some of
the CDIs of a major change that consists of several CDIs may be critical, and
others may be non-critical.

The potential impact of a non-compliance
within a CDI should be classified as critical if, for example:

—
a function, component or
system is introduced or affected where the failure of that function, component
or system may contribute to a failure condition that is classified as
hazardous or catastrophic at the aircraft level, for instance for ‘equipment,
systems and installations’, e.g. where applicable as defined in 2X.1309;

—
a CDI has an appreciable
effect on the human–machine interface (HMI) (displays, approved procedures,
controls or alerts);

—
airworthiness limitations or
operating limitations are established or potentially affected;

—
a CDI is affected by an
existing airworthiness directive (AD), or affected by an occurrence (or
occurrences) potentially subject to an AD, a known in-service issue or by a
safety information bulletin (SIB); or

—
a CDI affects parts that are
classified as critical as per CS 27.602/29.602, CS‑E 515, or that
have a hazardous or catastrophic failure consequence (e.g. a principal structural
element as per CS 25.571).

If the classification of the potential
impact of a non-compliance within a CDI as critical is based on the criterion
that the CDI is affected by an AD, then the impact of a non-compliance within
that CDI may be reclassified by EASA as non-critical due to the involvement of
EASA in the continued-airworthiness process.

During the early stages of a project, the
criticality in terms of the potential safety consequence of a failure may not
always be known, but should be conservatively estimated and the LoI should be
subsequently re-evaluated, if appropriate. 3.4. Method for the determination
of risk classes The risk is determined as a combination of the potential
impact of an unidentified non-compliance with part of the certification basis
(vertical axis) and of the likelihood of the unidentified non-compliance
(horizontal axis) using the following matrix. As a consequence, four
qualitative risk classes are established at the CDI level.

<table border="1" cellpadding="0" cellspacing="0" width="530">
<tr>
<td colspan="5" width="530">
Step 2 — Risk
 classes
</td>
</tr>
<tr>
<td valign="top" width="158">
Likelihood
 (see Section 3.2.5)
Criticality
 (see Section 3.3) 
</td>
<td width="93">
Very low
</td>
<td width="93">
Low
</td>
<td width="93">
Medium
</td>
<td width="93">
High
</td>
</tr>
<tr>
<td valign="top" width="158">
Non-critical
 
</td>
<td width="93">
Class 1
</td>
<td width="93">
Class 1
</td>
<td width="93">
Class 2
</td>
<td width="93">
Class 3
</td>
</tr>
<tr>
<td valign="top" width="158">
Critical
 
</td>
<td width="93">
Class 1
</td>
<td width="93">
Class 2
</td>
<td width="93">
Class 3
</td>
<td width="93">
Class 4
</td>
</tr>
</table>

The various inputs and the resulting risk
class determination are of a continuous nature, rather than consisting of
discrete steps. The selected risk class provides the order of magnitude of
EASA’s involvement and is used as a qualitative indicator for the
determination of EASA’s involvement described in Section 3.5 below.

Under specific circumstances, the risk class
that is determined on the basis of the above criteria may be reduced or
increased on the basis of justified and recorded arguments. For a reused and
well-proven item of compliance demonstration for which:

—
the CDI is independent of the
affected product type or model; and

—
the design, operation,
qualification, and installation of the product are basically the same; and

—
the certification process is
identical to one that was used in a modification already approved by EASA,

the CDI may be accepted as being similar, resulting in reduced LoI,
as the likelihood of an unidentified non-compliance is low. Furthermore, when
an identical CDI is reused for the compliance demonstration in a new project,
there is no involvement in the compliance demonstration verification, as the
likelihood of an unidentified non-compliance is very low.

3.5.    Determination
of EASA’s LoI

EASA’s LoI in the verification of compliance
demonstration is proposed by the applicant and determined by EASA in Step 3
on the basis of the qualitative risk class identified per CDI in Step 2,
as well as by applying sound engineering judgement.

EASA’s LoI is reflected in a list of
activities and data, in which EASA retains the verification of compliance
demonstration (e.g. review and acceptance of compliance data, witnessing of
tests, etc.), as well as the depth of the verification. The depth of the
verification for individual compliance reports, data, test witnessing, etc.,
may range from spot checks to extensive reviews. EASA always responds to those
retained compliance demonstration activities and data with corresponding
comments or a ‘statement of no objection’.

In addition, some data that is not retained
for verification may be requested for information. In this case, no ‘statement
of no objection’ will be provided.

It is recommended that an LoI should be
proposed for each of the EASA disciplines involved. Depending on the risk
classes determined in Section 3.4 above, EASA’s LoI in:

(a)     compliance
demonstration verification data; and

(b)     compliance
demonstration activities (witnessing of tests, audits, etc.),

may be as follows:

—
risk Class 1: there is no EASA
involvement in verifying the compliance data/activities performed by the
applicant to demonstrate compliance at the CDI level;

—
risk Class 2: EASA’s LoI is
typically limited to the review of a small portion of the compliance data;
there is either no participation in the compliance activities, or EASA
participates in a small number of compliance activities (witnessing of tests,
audits, etc.);

—
risk Class 3: in addition to
the LoI defined for Class 2, EASA’s LoI typically comprises the review of
a large amount of compliance data, as well as the participation in some
compliance activities (witnessing of tests, audits, etc.); and

—
risk Class 4: in addition to
the LoI defined for Class 3, EASA’s LoI typically comprises the review of
a large amount of compliance data, the detailed interpretation of test
results, and the participation in a large number of compliance activities
(witnessing of tests, audits, etc.).

By default, the following activities require
EASA’s involvement in all cases:

—
initial issues of, and changes
to, a flight manual (for those parts that require EASA approval and that do
not fall under the DOA holder’s privilege);

—
classification of failure
cases that affect the handling qualities and performance, when:

—
performed through test (in
flight or in a simulator); and

—
initial issues of, and
non-editorial changes to, airworthiness limitations.

If the risk assessment (Steps 1 and 2
above) is made on the level of a compliance demonstration activity or on the
level of a document, the risk class provides an indication for the depth of
the involvement, i.e. the verification may take place only for certain
compliance data within a compliance document.

4.       Documentation
of the LoI

The LoI proposal in the certification
programme should include the applicant’s proposal regarding the compliance
demonstration verification activities and data that would be retained by EASA,
as well as the data on which the LoI proposal has been based. For this
purpose, the applicant should appropriately document the analysis per CDI,
considering the above criteria. In cases where the rationale for the
assessment is obvious, it is considered to be sufficient for the applicant to
indicate whether or not a CDI is novel or complex, and whether or not the
impact is critical.

EASA documents the LoI determination by
accepting the certification programme or, if it deviates from the proposal, by
recording its analysis regarding the deviations from the proposal, and
notifies the applicant accordingly.

5.       Sampling
during surveillance of the DOA holder

It should be noted that all the previously
defined risk classes may be complemented by the sampling of project files
during surveillance of the DOA holder, independently from the ongoing
certification project. This is necessary in order to maintain confidence in
the DOA system and to constantly monitor its performance.

---

[[39]](#_ftnref39)    Such additional criteria
are contained as an attachment to the EASA Certification Memorandum (CM)
CM-21.A/21.B-001, available at: <https://www.easa.europa.eu/document-library/product-certification-consultations/cm-21a21b-001>.

[[40]](#_ftnref40)    The ultimate objective is
to define the organisation’s performance at the discipline level.

ED Decision 2019/018/R

1.       Definitions

Risk: the combination of the likelihood and the potential impact of a
non-compliance with part of the certification basis.

Criticality: a measure of the potential impact of a non-compliance with part
of the certification basis on product safety or on the environment.

EASA discipline: an EAS447

A discipline is a technical subarea of an
EASA panel.

EASA’s level of involvement
(LoI): the compliance demonstration activities
and data that EASA retains for verification during the certification process,
as well as the depth of the verification.

2.       Background

The applicant should also indicate the EASA
panel(s) that is (are) affected by each CDI.

This AMC explains:

(b)      how
EASA will determine its LoI on the basis of the criteria established in point [21.B.100](#_DxCrossRefBm1649096973).

EASA will review the proposal and determine
its LoI. Both parties, in mutual trust, should ensure that the certification
project is not delayed through the LoI proposal and determination.

In such a case, or when EASA has other
information that affects the assumptions on which the LoI was based, EASA will
revisit its LoI determination.

Note: This AMC should not be considered to
be interpretative material for the classification of changes or repairs.

3.       Principles
and generic criteria for the LoI determination EASA determines its LoI based
on the applicant’s proposal in view of the risk (the combination of the likelihood
of an unidentified non-compliance and its potential impact). This is performed
after proper familiarisation with the certification project in three steps:

—
Step 1: identification of the
likelihood of an unidentified non-compliance,

—
Step 2: identification of the
risk class, and

—
Step 3: determination of
EASA’s LoI.

This AMC contains criteria, common to all
EASA panels, for the determination of:

—
any novel or unusual features
of the certification project, including operational, organisational and
knowledge management aspects;

—
the complexity of the design
and/or compliance demonstration;

—
the performance and experience
of the design organisation of the applicant in the domain concerned;

—
the criticality of the design
or technology and the related safety and environmental risks, including those
identified on similar designs; and

—
the data and activities to be
retained by EASA.

Note: Additional
panel-specific criteria are available in further informative material
published by EASA[[16]](#_ftn16).
This material should not be considered to be AMC.

3.1.    LoI
determination at CDI level

The determination of EASA’s LoI is performed
at the level of the CDI (please refer to [AMC 21.A.15(b)(5)](#_DxCrossRefBm1649096978)).

3.2.    Method
for determining the likelihood of an unidentified non-compliance

3.2.1. Principle
The likelihood of an unidentified non-compliance is assessed on the basis of
the following criteria:

—
novelty,

—
complexity, and

—
the performance of the design organisation.