How to Properly Declare an Aircraft Maintenance Programme (ML.A.302)

If you operate under Part-ML and declare your own Aircraft Maintenance Programme (AMP) under ML.A.302(e) — without a CAMO — you must ensure the programme is complete, based on the Minimum Inspection Programme (MIP) and, where applicable, Instructions for Continuing Airworthiness (ICA), and that it is properly declared and followed. This article covers how to declare an AMP correctly: MIP vs ICA, declared vs approved AMP, common mistakes, and a practical minimum structure so your declaration stands up to audit.

1. Regulatory Context

ML.A.302 requires that the aircraft be maintained in accordance with an Aircraft Maintenance Programme (AMP) that is either approved (e.g. by a CAMO/CAO) or declared by the owner in accordance with the regulation. ML.A.302(e) permits the owner to declare an AMP when the applicable rules allow (e.g. non-commercial operations under Part-NCO), without contracting a CAMO.

The AMP must be based on:

• The Minimum Inspection Programme (MIP) — the minimum set of inspections and tasks defined for the aircraft type (e.g. in AMC or in the type certificate data). AMC1 ML.A.302(d) addresses the use of the MIP. The AMP cannot do less than the MIP.
• Where applicable, the Instructions for Continuing Airworthiness (ICA) from the Design Approval Holder (DAH). The AMP should incorporate or be not less restrictive than the ICA. See MIP vs ICA Under Part-ML.

The legal basis is Commission Implementing Regulation (EU) No 1321/2014 (Part-ML). EASA’s Part-ML page provides the official framework.

2. Practical Interpretation

MIP vs ICA

Declared vs approved AMP

Practical minimum AMP structure: The AMP should at least (1) identify the aircraft and programme version, (2) list all tasks and intervals derived from MIP and, where applicable, ICA, (3) address AD compliance and life-limited components, (4) define which tasks, if any, are pilot-owner tasks (ML.A.803), and (5) be dated and declared (or approved) in line with national procedures.

3. Common Owner Mistakes

• Declaring an AMP that does not meet the MIP. Doing fewer or less frequent tasks than the MIP is not permitted and is a common audit finding.
• Ignoring ICA when it exists. For many types, the AMP should incorporate or be not less restrictive than the DAH’s ICA; omitting it can lead to insufficient maintenance and findings.
• No written declaration or wrong scope. The declaration must be explicit (e.g. written, dated, aircraft identified) and must cover the actual programme being used.
• Using an outdated or generic programme. The AMP must be current for the aircraft and type; copying a generic document without tailoring and updating leads to gaps and findings.
• No revision control. When the AMP is updated, the declaration or approval must reflect the current version; old versions should be retained for records.

4. Risk Analysis

What could go wrong? An inadequate AMP (below MIP, missing ICA elements, or not actually followed) means the aircraft is not maintained in accordance with Part-ML. That can result in findings, grounding, and unairworthiness. In the event of an incident, the owner may face liability for not having a proper programme.

Who is liable? The owner (ML.A.201). Even with an approved AMP managed by a CAMO, the owner remains responsible for continuing airworthiness; with a declared AMP, the owner is directly responsible for the programme’s adequacy and application.

How do findings occur? Auditors check that the AMP exists, is declared or approved, is based on MIP/ICA, and is being followed. Missing tasks, wrong intervals, or no clear declaration are typical findings. See 12 Most Common Part-ML Audit Findings.

5. Checklist (minimum AMP structure)

• MIP — All MIP tasks and intervals are included; nothing less restrictive.
• ICA — Where applicable, ICA is incorporated or the AMP is not less restrictive than ICA. See MIP vs ICA.
• ADs (AD vs SB) — Process for establishing AD applicability and compliance is defined; ADs are tracked.
• Life-limited parts / component limits — Addressed in the AMP with tracking and replacement/overhaul criteria.
• Pilot-owner tasks — If used, a clear list (e.g. appendix) of tasks the pilot-owner may perform and sign (ML.A.803).
• Declaration — Written declaration in accordance with ML.A.302(e) and national procedures (date, aircraft, programme identification).
• Revision control — Version and revision date; procedure for updates and retention of superseded versions.
• Records — AMP and declaration retained for the required period; available for audit.

6. FAQ

What is the minimum I must include in my AMP?

At minimum: (1) identification of the aircraft and programme, (2) all tasks and intervals from the MIP, (3) where applicable, tasks/intervals from ICA (or not less restrictive), (4) AD compliance process and life-limited part control, (5) if you use pilot-owner maintenance, the list of permitted tasks, and (6) a proper declaration (or approval) per ML.A.302(e) and national rules.

Can I use only MIP without ICA?

Only if the applicable regulations and the type allow it. For many types, the DAH’s ICA is the reference for continuing airworthiness; the AMP should incorporate or be not less restrictive than ICA. Using only the bare MIP when ICA exists may be insufficient and can be an audit finding. See MIP vs ICA Under Part-ML.

Summary: Declaring an AMP under ML.A.302(e) means committing to a programme that meets MIP and, where applicable, ICA. The declaration must be explicit (written, dated, aircraft identified), and the AMP must include tasks, intervals, AD process, life limits, and — if used — pilot-owner tasks. Keep revision control and retain records for audit.