Chapter 9: Continuing Airworthiness: CAR-M, CAR-ML and CAR-CAMO

What “continuing airworthiness” means

CAR-M defines continuing airworthiness as all of the processes ensuring that, at any time in its operating life, the aircraft complies with the airworthiness requirements in force and is in a condition for safe operation. CAR-M (Issue 3, effective 1 January 2025; Rev 1 July 2026) is the standard for all aircraft except “light aircraft” not used by an air operator, which follow CAR-ML. Organisations managing continuing airworthiness are approved under CAR-CAMO (or CAR-CAO for non-complex GA). The foreword ties this to Rule 50A (conditions for the C of A remaining in force) and to annual airworthiness reviews.

Who is responsible? — M.A.201

Occurrence reporting — M.A.202

The responsible person or organisation reports any identified condition of an aircraft or component that endangers flight safety to DGCA and to the type design / STC holder (and, under a contract, to the owner, operator and CAMO/CAO) — as soon as possible and no later than 72 hours after identifying the condition.

The continuing airworthiness tasks — M.A.301

1. pre-flight inspections;
2. rectification of defects and damage affecting safe operation, using approved data and taking account of the MEL and CDL;
3. all maintenance per the AMP;
4. release of all maintenance (Subpart H — CRS);
5. for complex aircraft and AOC aircraft, analysis of the effectiveness of the AMP;
6. compliance with every applicable AD, operational directive with an airworthiness impact, DGCA continuing airworthiness requirement and DGCA immediate safety measures;
7. modifications and repairs per M.A.304;
8. giving the pilot (or the operator) the current mass and balance statement;
9. maintenance check flights when necessary.

The Aircraft Maintenance Programme — M.A.302

• Every aircraft is maintained to an AMP; the AMP and every amendment are approved by DGCA. An aircraft is maintained to only one approved programme at a time.
• It must comply with DGCA instructions and the instructions for continuing airworthiness of the TC, STC, repair and ITSO holders; it may add tasks or propose escalated intervals backed by review data — but safety-related task escalation can never be indirectly approved.
• It contains all maintenance to be done, with frequencies, and tasks linked to the type and specific operations.
• For complex aircraft whose AMP is based on MSG logic or condition monitoring, it includes a reliability programme (also required for single-engine aeroplanes in scheduled commuter service).
• It is periodically reviewed against operating experience, DGCA instructions and new manufacturer data.

ADs, mandatory modifications and repair data

• M.A.303 — any applicable AD must be carried out as required, unless DGCA specifies otherwise. Since CAR-M Issue 2, ADs issued by the State of type design are mandatory unless DGCA advises otherwise.
• CAR Sec 2 Series M Part I — mandatory modifications and inspections, based on Rules 49D, 50A and 52. When India is not the State of design, operators comply with the State of design's ADs within the stipulated time unless DGCA says otherwise; DGCA declares as mandatory only those ADs, alert SBs and instructions that affect safety. At C of A issue for a newly imported type, the operator certifies that all State-of-manufacture ADs are complied with. Service bulletins are not automatically mandatory — the operator reviews them and decides.
• M.A.304 — damage is assessed and modifications and repairs are carried out using data approved by DGCA or by an approved CAR-21/EASA/FAA design organisation (AAC 1 of 2017).
• Under CAR-CAMO, a CAMO for complex/AOC aircraft must have a procedure to assess non-mandatory modifications and inspections using its safety risk management process.

Records and the technical log — M.A.305 and M.A.306

The aircraft continuing airworthiness record system comprises the aircraft, engine and propeller logbooks and log cards for life-limited parts. It records the CRS for all maintenance and shows the status of ADs, modifications and repairs, AMP compliance, life-limited parts and time-controlled components, the mass and balance report and deferred maintenance.

On a change of operator or owner, the records are transferred (M.A.307). M.A.306 — for CAT, other commercial operations and FTOs, the operator uses a technical log system approved by DGCA containing flight information, the current CRS, the current maintenance statement (next scheduled and out-of-phase maintenance due), all outstanding deferred defects that affect operation, and maintenance support guidance.

Defects — M.A.403

• A defect that seriously hazards flight safety must be rectified before further flight.
• Only authorised certifying staff decide, using maintenance data, whether a defect seriously hazards flight safety and whether it can be deferred — except where the MEL is used by the pilot or certifying staff.
• Other defects are rectified as soon as practicable and within the limits of the maintenance data or MEL.
• Any defect not rectified before flight is recorded in the record system or technical log (and made known to the crew).

Components — M.A.501 to M.A.504

• Classification (M.A.501): serviceable (CA Form 1 or equivalent), unserviceable, unsalvageable, standard parts, materials — installed only if in satisfactory condition and specified in the maintenance data.
• Component maintenance (M.A.502) by appropriately approved organisations.
• Life-limited parts and time-controlled components (M.A.503) must not exceed their approved limits.
• Segregation (M.A.504): unserviceable and unsalvageable components segregated; unsalvageable parts prevented from re-entering the supply chain (mutilation).

The airworthiness review and ARC — M.A.901 and M.A.902

• An airworthiness review of the aircraft and its records is carried out periodically; on completion an ARC is issued (CA Form 15a by DGCA, 15b by a CAMO or CAO). Validity: one year.
• Controlled environment — during the preceding 12 months the aircraft was continuously managed by one CAMO/CAO and maintained by approved organisations.
• For AOC aircraft and aircraft above 2 730 kg in a controlled environment, the managing CAMO/CAO (with the privilege) may issue the ARC and extend it at most twice, for one year each — so a full review is needed at least every three years. For aircraft of 2 730 kg and below not used by an AOC holder, any CAMO/CAO chosen by the owner may do so.
• Outside a controlled environment (or if the CAMO lacks the privilege), DGCA issues the ARC on the CAMO's recommendation. DGCA reviews itself where there is a potential safety risk.
• An extension may be anticipated by up to 30 days, and the physical survey by up to 90 days, without losing continuity of the review pattern.
• An ARC becomes invalid if suspended or revoked, if the C of A is suspended or revoked, if the aircraft leaves the register or the C of R is invalid, or if the TC is suspended or revoked. An aircraft must not fly if the airworthiness certificate is invalid or it does not meet CAR-M, is not in conformity with type design, was operated beyond limits, or had an accident/incident or non-compliant modification without corrective action.

CAR-ML — light aircraft

• For non-complex light aircraft (aeroplanes up to 2 730 kg, rotorcraft up to 1 200 kg / 4 occupants, other LA2) not used by an AOC holder.
• The owner is responsible (ML.A.201); for commercial ATOs and commercially used balloons/sailplanes the operator must be (or contract) a CAMO/CAO and use approved maintenance organisations; private owners may contract a CAMO/CAO or manage continuing airworthiness themselves.
• CRS by approved organisations, independent certifying staff or the pilot-owner (Chapter 6); CRS entered in records within 30 days.
• In DGCA's CAR-ML the airworthiness review and ARC (valid 1 year) are performed by DGCA (ML.A.901).

CAR-CAMO — the Continuing Airworthiness Management Organisation

Privileges — CAMO.A.125

• Manage the continuing airworthiness of listed aircraft (for AOC aircraft, the approval is part of the AOC and the aircraft must be listed on both).
• Subcontract limited CAW tasks to organisations working under its management system.
• Extend an ARC under M.A.901(f); develop the AMP for CAR-ML aircraft for DGCA approval.
• If additionally approved, carry out airworthiness reviews, issue ARCs and make recommendations (CAMO.A.125(e)).

People — CAMO.A.305 and CAMO.A.310

• Accountable manager with corporate authority to finance all CAW activities; promotes the safety policy; nominates the person(s) responsible for continuing airworthiness management, the compliance monitoring manager and the safety manager.
• For an AOC holder, the accountable manager is the airline's accountable manager, and the person responsible for continuing airworthiness (the CAM) must not be employed by the operator's contracted CAR-145 organisation unless DGCA agrees.
• Airworthiness review staff (CAMO.A.310): at least 5 years' continuing airworthiness experience; a CAR-66 licence or aeronautical degree (or 5 more years' experience instead); formal maintenance training; a position with appropriate responsibilities; accepted by DGCA after a supervised review; recent experience.

Continuing airworthiness management — CAMO.A.315

• Develop and control the AMP (with reliability programme where required); give owners a copy.
• Ensure modification and repair data comply with M.A.304; assess non-mandatory modifications (complex/AOC aircraft).
• Send aircraft to appropriately approved maintenance organisations; order maintenance, supervise and coordinate decisions.
• Where the CAMO is not itself a maintenance organisation, manage the written maintenance contract with the CAR-145 organisation.

The CAMO works to its Continuing Airworthiness Management Exposition (CAME) — AAC 2 of 2025 is DGCA's user guide for writing one. Like CAR-145 Issue 3, CAR-CAMO requires a management system with SMS and compliance monitoring (AAC 4 of 2024).

Chapter summary

• Owner (or lessee) responsible; AOC operator must be a CAMO and use CAR-145. Pre-flight inspection by pilot needs no certifying staff.
• Report safety-endangering conditions to DGCA and the design holder within 72 hours (M.A.202).
• AMP approved by DGCA; reliability programme for MSG-based complex aircraft; periodic review; no indirect approval of safety-task escalation.
• State-of-design ADs mandatory unless DGCA says otherwise; SBs not automatically mandatory.
• Records: tech log 36 months; CRS/detailed records ≥ 36 months; 12 months after withdrawal. Tech log for commercial operators, approved by DGCA.
• Serious defects fixed before flight; only certifying staff decide deferral (except MEL use).
• ARC valid 1 year; CAMO/CAO in a controlled environment may extend twice (1 year each); CA Form 15a (DGCA) / 15b (CAMO/CAO).
• CAMO: AM + CAW, compliance and safety managers; ARS need 5 years' CAW experience + licence/degree; CAME (AAC 2 of 2025).