How to Build a CAMO from Scratch Under Regulation (EU) No 1321/2014

Establishing a Continuing Airworthiness Management Organisation (CAMO) from scratch is one of the most demanding organisational projects in aviation. A CAMO is not simply an engineering department—it is a regulated organisation approved to control and ensure the continuing airworthiness of aircraft throughout their operational life.

Under Commission Regulation (EU) No 1321/2014, specifically Annex Vc (Part-CAMO), the organisation must demonstrate to the Competent Authority that it has the structure, personnel, procedures, management system, and technical capability to safely manage continuing airworthiness.

For AOC holders operating under commercial air transport, CAMO approval is not optional—it is a regulatory requirement.

This article outlines the key points required to build a CAMO from the ground up, with direct reference to Regulation (EU) No 1321/2014.

1. Understand the Regulatory Framework

Before building the organisation, management must fully understand the regulatory structure:

• Regulation (EU) No 1321/2014 – Continuing Airworthiness Regulation
• Annex Vc (Part-CAMO) – Requirements for CAMO approval
• Annex I (Part-M) – Continuing airworthiness responsibilities
• Annex II (Part-145) – Maintenance organisation requirements
• Air Operations Regulation (EU) No 965/2012 – Operational interface with the AOC holder
• Applicable AMC (Acceptable Means of Compliance) and GM (Guidance Material)

Many organisations fail at the start by focusing only on manuals instead of understanding how these regulations interact operationally.

Part-CAMO introduces not only compliance obligations, but also management system requirements, risk-based oversight, and compliance monitoring responsibilities.

2. Define the Scope of Approval

As required by CAMO.A.125, the organisation must clearly define the scope of work before applying for approval.

This includes:

• Aircraft types and variants
• Fleet size
• Operational environment
• Commercial Air Transport (CAT) or non-CAT operations
• Airworthiness review privileges
• Permit to Fly recommendation privileges
• Contracted maintenance arrangements

The scope of approval drives manpower requirements, competence needs, system complexity, and Competent Authority expectations.

Trying to obtain an approval scope that is too broad too early is a common strategic mistake.

3. Establish the Management System

One of the biggest changes introduced by Part-CAMO is the requirement for a formal Management System under CAMO.A.200.

This includes:

• Safety policy and objectives
• Hazard identification and risk management
• Compliance monitoring
• Internal occurrence reporting
• Corrective action management
• Safety performance monitoring
• Human factors considerations
• Management review processes

The old “Quality Department” approach is no longer sufficient. Compliance Monitoring must exist, but it must function within a broader management system framework.

This is becoming even more important with the introduction of Part-IS requirements, where CAMOs must also demonstrate stronger control over information security, reporting pathways, and organisational governance. Our guide on Part-IS requirements for CAMOs explains how these new obligations affect continuing airworthiness organisations.

A CAMO without an effective management system may achieve approval, but it will struggle to survive audits.

4. Appoint Nominated Personnel

Under CAMO.A.305, the organisation must nominate responsible persons who are acceptable to the Competent Authority.

Typically this includes:

• Accountable Manager
• Continuing Airworthiness Manager / NPCA
• Compliance Monitoring Manager
• Safety Manager (depending on organisational structure)
• Airworthiness Review Staff (if privileges are requested)

Competence, experience, authority, and independence matter more than job titles.

Authorities will assess whether nominated persons genuinely control the function—not whether they simply appear on an organisational chart.

5. Build the Core CAMO Functions

A functional CAMO must be built around its operational pillars:

Engineering

Responsible for:

• AD and mandatory requirement assessment
• Service Bulletin evaluation
• Reliability programme support
• AMP development and optimisation
• Technical investigations
• Defect control and repetitive defect analysis
• Modifications and repairs management

Planning

Responsible for:

• Maintenance forecasting
• Work package generation
• Check planning
• Maintenance slot coordination
• Forecasting life-limited components

Technical Records

Responsible for:

• Aircraft status control
• LLP tracking
• Compliance records
• Back-to-birth traceability where required
• ARC support records

MCC / Maintenance Control

Responsible for:

• Daily fleet technical control
• Defect management
• Deferred defect monitoring
• AOG support coordination
• Line maintenance control

Materials and Logistics Interface

Even where stores are subcontracted, CAMO must retain airworthiness control over component eligibility and installation status.

Many start-up CAMOs underestimate Technical Records and MCC. These are often where audit findings originate.

6. Develop the CAME

The Continuing Airworthiness Management Exposition (CAME) is required by CAMO.A.300.

The CAME must describe:

• Organisation structure
• Management system
• Responsibilities and authorities
• Contracted activities
• Continuing airworthiness procedures
• Compliance monitoring procedures
• Safety reporting system
• Record-keeping procedures
• Airworthiness review procedures

The CAME must reflect reality.

A beautifully written manual that does not match daily operations creates major exposure during authority audits.

The best CAME is operationally usable, not academically impressive.

7. Control Contracted and Subcontracted Activities

Under Part-CAMO, it is essential to distinguish between contracted activities and subcontracted continuing airworthiness management tasks, because Regulation (EU) No 1321/2014 treats them differently.

Many organisations use these terms interchangeably, but from a regulatory perspective they are not the same.

Contracted Activities

Contracted activities are services performed by external approved organisations that support the CAMO but do not become part of the CAMO approval itself.

Typical examples include:

• Part-145 maintenance organisations performing base or line maintenance
• Component repair organisations
• NDT providers
• Engine repair shops
• External logistics and component support providers
• Specialist repair vendors

These are external service providers working under their own approvals.

Under Part-M and Part-CAMO, the CAMO remains responsible for ensuring that maintenance is properly planned, controlled, and accepted, but these activities are not considered CAMO subcontracting.

The CAMO must retain control of:

• maintenance planning 
• work scope definition
• AD and mandatory compliance decisions
• AMP control
• defect assessment and deferment control
• CRS acceptance and aircraft status management

Outsourcing maintenance does not outsource continuing airworthiness responsibility.

Subcontracted Continuing Airworthiness Management Tasks

Subcontracting under CAMO.A.125(d)(3) refers specifically to certain continuing airworthiness management tasks that may be performed by another qualified organisation under the CAMO’s management system.

AMC1 CAMO.A.125(d)(3) makes it clear that the CAMO must retain ultimate responsibility and should limit subcontracting only to specific CAW tasks.

These typically include:

• Airworthiness Directive assessment and monitoring
• Service Bulletin assessment support
• Maintenance programme development support
• Reliability programme administration
• Technical records administration
• Maintenance planning support
• Engineering support for continuing airworthiness decisions

These tasks remain part of the CAMO system and must be fully controlled through:

• CAME procedures
• Formal contracts
• Pre-subcontract audits
• Competence assessment
• Continuous oversight
• Performance monitoring

The CAMO must employ competent personnel capable of determining what maintenance is required, when it must be performed, by whom, and to what standard. This responsibility cannot be transferred. (easa.europa.eu)

What Cannot Be Subcontracted

Not every CAMO function may be subcontracted.

The CAMO must retain direct control over the management system and organisational accountability, including:

• Compliance monitoring
• Management system oversight
• Safety policy and occurrence reporting control
• Final airworthiness decisions
• Accountability to the Competent Authority
• Nominated Persons’ responsibilities

The regulator will always assess one central question:

Who is actually controlling continuing airworthiness?

If the answer is unclear, the approval is exposed.

The strongest CAMOs demonstrate control through governance, audits, KPIs, escalation paths, and competent internal decision-making—not through contractual wording alone.

8. Build Digital Control Systems

A modern CAMO cannot function effectively on spreadsheets alone.

Critical systems include:

• Maintenance tracking software
• Technical records system
• Reliability monitoring tools
• Defect control platform
• Compliance monitoring tracker
• Task allocation and escalation systems
• Occurrence reporting platform

The authority will not approve software—but they will assess whether your control environment is reliable, traceable, and robust.

System discipline is often more important than software sophistication.

9. Prepare for Authority Approval

Initial approval requires demonstration—not promises.

Expect the Competent Authority to assess:

• Personnel competence
• Procedure effectiveness
• Management system maturity
• Contract control
• Aircraft records quality
• AMP control
• AD/SB management
• Deferred defect oversight
• Organisational interfaces with Flight Ops and Part-145

Pre-application meetings are critical.

The strongest approvals are built through early authority engagement, not through last-minute audit preparation.

10. Build for Scalability, Not Just Approval

CAMOs shall not be built to pass the first audit and then collapse under operational growth.

A strong CAMO must be scalable:

• Standardised procedures
• Clear accountability
• Defined escalation paths
• KPI-driven oversight
• Resource planning for fleet growth
• Succession planning for key postholders

Approval is the beginning, not the objective.

The real challenge starts after aircraft number two.

Conclusion

Building a CAMO from scratch under Regulation (EU) No 1321/2014 requires far more than regulatory knowledge. It requires organisational discipline, operational realism, and management commitment.

Part-CAMO demands a system that can continuously demonstrate control—not just a set of manuals that describe it.

The strongest CAMOs are built on three principles:

1. Regulatory clarity
2. Operational practicality
3. Sustainable oversight

When these three exist together, approval becomes a consequence—not the goal.

That is the true foundation of a successful CAMO.

Frequently Asked Questions (FAQs)