{"id":"F2007L04659","name":"Civil Aviation Order 100.24 (Maintenance Authority) Instrument 2007","slug":"civil-aviation-order-100-24-maintenance-authority-instrument-2007","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":71015,"registerId":"commonwealth-F2007L04659-current","compilationNumber":null,"startDate":"2026-04-02","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Civil Aviation Order 100.24 (Maintenance Authority) Instrument 2007","content":"Civil Aviation Order 100.24\n\nmade under regulation 33B of the Civil Aviation Regulations 1988.\n\nThis compilation was prepared on 26 March 2026 taking into account amendments up to Civil Aviation Orders 100.23 and 100.24 Amendment Instrument 2026.\n\nPrepared by the Legal Services Branch, Legal Division, Civil Aviation Safety Authority, Canberra.\n\nCompilation No. 2\n\nContents\n\nPage\n\n[1A Name of instrument](#_Toc225348326)\n\n[1B Definitions](#_Toc225348327)\n\n[1 Requirements for issue](#_Toc225348328)\n\n[2 Application for maintenance authority](#_Toc225348329)\n\n[3 Issue of maintenance authority](#_Toc225348330)\n\n[Note to Civil Aviation Order 100.24](#_Toc225348331)\n\nCivil Aviation Order 100.24\n\nMaintenance authority\n\n1A Name of instrument\n\n1A.1 This instrument is Civil Aviation Order 100.24 (Maintenance Authority) Instrument 2007.\n\n1A.2 This instrument may be cited as Civil Aviation Order 100.24.\n\n1A.3 A reference in a CASA instrument (being an instrument issued by CASA under a statutory power to issue the instrument) to Section 100.24 of the Civil Aviation Orders is a reference to this instrument.\n\n> Note This Civil Aviation Order is to be read in conjunction with Civil Aviation Order 100.23.\n\n1B Definitions\n\n> Note In this instrument, certain terms and expressions have the same meaning as they have in the Civil Aviation Act 1988 and the regulations. These include aircraft engineer licence, CAR, Director and RPA.\n\nIn this Order:\n\n> maintenance authority means an airworthiness authority to carry out maintenance on aircraft.\n\n> Note airworthiness authority is defined in regulation 2 of CAR as meaning an authority under regulation 33B of CAR.\n\n1 Requirements for issue\n\n1.1 Subject to paragraph 1.1A, unless otherwise approved by the Director, an applicant for a maintenance authority must hold an aircraft engineer licence.\n\n1.1A Paragraph 1.1 does not apply to an applicant for a maintenance authority that is for maintenance on RPA.\n\n1.2 An applicant for such a maintenance authority must submit satisfactory evidence that:\n\n(a) the applicant has been adequately trained for the purpose; and\n\n(b) the applicant has had adequate practical experience of the duties to be performed in relation to the authority; and\n\n(c) the applicant has passed such examinations in relation to the authority as are required or approved for the purpose.\n\n2 Application for maintenance authority\n\nAn application for a maintenance authority must be made using the application form Application for Initial Issue or Amendment to Scope of a Maintenance Authority and it should normally be endorsed by the applicant’s employer in regard to the circumstances in which the authority is intended to be used.\n\n3 Issue of maintenance authority\n\n3.1 A maintenance authority may be issued to an applicant who satisfies the requirements of subsection 1 and who has demonstrated competence to perform the maintenance functions associated with the privileges endorsed in the authority.\n\n3.2 A maintenance authority may be issued in respect of a maintenance function to be performed and certified on a particular aircraft, or a type, series or group of aircraft, engine, systems or installations.\n\n> Note to Civil Aviation Order 100.24\n\n> Note: The Civil Aviation Order (in force under the Civil Aviation Regulations 1988) as shown in this document comprises Civil Aviation Order 100.24 made as indicated in the Table below.\n\n> Note: > Note: Table of Orders\n\n| Year andnumber | Date of registration on FRLI | Date ofcommencement | Application, saving ortransitional provisions |\n| ------------------------------------------------ | ---------------------------------- | ------------------- | --------------------------------------------- |\n| CAO 100.24 Instrument 2007 | 17 December 2007 (see F2007L04659) | 18 December 2007 | |\n| CAO 100.24 2011 No. 1 | 22 June 2011 (see F2011L01190) | 27 June 2011 | |\n| CAOs 100.23 and 100.24 Amendment Instrument 2026 | 25 March 2026 (see - F2026L00317) | 26 March 2026 | |\n\n```html\n

Table of Amendments

ad. = added or inserted am. = amended rep. = repealed rs. = repealed and substituted

Provision affected

How affected

s. 100.24

rs. CAO 100.24 Instrument 2007

Note before subs. 1

rep. F2026L00317

subs. 1A

ad. F2026L00317

subs. 1B

ad. F2026L00317

subs. 1

am. CAO 100.24 2011 No. 1, F2026L00317

subs. 2

am. F2026L00317

subs. 3

am. F2026L00317

\n```","sortOrder":0}],"analysis":{"kimi_summary":{"content_quality":"ok","complexity_score":3,"scope_assessment":{"changed":false,"description":"The legislation remains focused on its original purpose: setting requirements for issuing maintenance authorities. The 2026 amendments were administrative — adding standard naming and definition sections (1A, 1B) and removing an outdated note — rather than expanding scope. The RPA exception in paragraph 1.1A was added in 2011, representing an evolution to cover new technology, but this was a targeted adaptation rather than scope creep."},"complexity_factors":["Very short instrument — only 3 substantive sections plus naming and definitions","Minimal defined terms — only 1 explicit definition ('maintenance authority'), though it references external definitions from the Civil Aviation Act and Regulations","Simple conditional structure — one main exception (paragraph 1.1A for RPA) and one discretionary override ('unless otherwise approved by the Director')","No nested exceptions or complex cross-referencing — reads in conjunction with CAO 100.23 but operates independently","Straightforward application process described in plain language","2026 amendments added structural sections (1A, 1B) and removed a note, but did not increase operational complexity"],"plain_english_summary":"This Order defines who may be granted a Civil Aviation Safety Authority maintenance authority — the official permission to repair and certify aircraft in Australia — by setting qualification standards, required training, practical experience, exams, and application procedures (including employer endorsement). It mainly affects aircraft maintenance engineers and their employers, with a specific exception allowing remote piloted aircraft operators to obtain authority without a full engineer licence. The 2026 amendments reorganised material but didn’t alter core requirements."},"flash_summary":{"complexity_score":3,"scope_assessment":{"changed":true,"description":"Yes. The 2026 amendment added a specific exception (subsection 1.1A) so that the baseline aircraft engineer licence requirement does not apply to applicants for a maintenance authority for remotely piloted aircraft (RPA). Mechanically this relaxes the original blanket licence prerequisite for that category of maintenance authority and replaces it with the existing outcome-based requirements (training, experience, examinations, and demonstrated competence). The change broadens eligibility for RPA maintenance authorities and shifts the compliance and oversight emphasis from possession of a licence to CASA assessment of alternative qualification evidence (see subsections 1.1, 1.1A, 1.2 and 3.1). This is a material scope adjustment because it alters who may be authorised to certify maintenance work for RPAs and how CASA must evaluate applicants in that area."},"complexity_factors":["Short instrument: 1A, 1B, Part 1 (requirements), Part 2 (application), Part 3 (issue) — total ~10 discrete paragraphs/subsections","Few defined terms in-text (maintenance authority, cross-reference to Civil Aviation Act and CAR definitions)","Cross-references to other sources: Civil Aviation Act 1988, Civil Aviation Regulations 1988 (reg 33B), and CAO 100.23 — requires reading in context","Director discretion and open standards: phrases like \"unless otherwise approved by the Director\", \"satisfactory evidence\", and \"demonstrated competence\" introduce regulatory judgement rather than bright-line tests","Conditional exception introduced (subsection 1.1A) creates branching logic: general licence requirement vs RPA exception","Application form and employer endorsement are normative but not prescriptive: use of the specific form and \"should normally be endorsed\" adds non-mandatory guidance","Amendment history (2011 and 2026) and table of amendments requires tracking changes across versions","Scope-limiting language (section 3.2) allows varied granularities (single aircraft, type, series, group, engine, systems) — multiple possible scopes to interpret","Limited procedural detail about how CASA assesses \"satisfactory evidence\" or \"competence\" means external guidance or practice statements are needed to fully understand operational complexity"],"plain_english_summary":"**What this instrument does (mechanically)**\n\n- Establishes the rules CASA (Civil Aviation Safety Authority) uses to issue a *maintenance authority* (an airworthiness authority to carry out maintenance) under regulation 33B of the Civil Aviation Regulations 1988. (See definitions in subsection 1B and the cross‑reference to reg 33B.)\n\n- Sets eligibility requirements for applicants: generally the applicant must hold an aircraft engineer licence unless the Director of CASA approves otherwise (subsection 1.1). The instrument now contains a specific exception: the licence requirement does not apply to an applicant for a maintenance authority for remotely piloted aircraft (RPA) (subsection 1.1A).\n\n- Requires applicants to provide satisfactory evidence that they have adequate training, practical experience, and have passed any required or approved examinations for the authority (subsection 1.2).\n\n- Prescribes the application form to be used (the form named \"Application for Initial Issue or Amendment to Scope of a Maintenance Authority\") and says the application should normally be endorsed by the applicant’s employer to indicate how the authority will be used (section 2).\n\n- Confers discretion on CASA to issue a maintenance authority where the applicant satisfies the listed requirements and demonstrates competence for the privileges to be endorsed (section 3.1). The authority can be limited to a particular aircraft or to a type/series/group of aircraft, engines, systems or installations (section 3.2).\n\n\n**Who this affects**\n\n- Individuals and organisations that perform or certify maintenance on Australian aircraft: current and prospective aircraft engineers, technicians, RPA maintenance personnel, employers who manage or endorse maintenance personnel, and CASA as regulator (see sections 1.1, 1.1A, 1.2, 2 and 3).\n\n- Persons working on remotely piloted aircraft (RPA). The 1.1A exception means RPA maintenance authorities can be issued without the general aircraft engineer licence requirement (subsection 1.1A).\n\n\n**Why it matters (practical consequences and decision-making mechanics)**\n\n- Licensing and eligibility: The order makes an aircraft engineer licence the baseline eligibility requirement for maintenance authorities (subsection 1.1), but preserves Director discretion to approve departures. The 2026 amendment explicitly removes the licence requirement for RPA maintenance authorities (subsection 1.1A). That changes who can apply and how CASA assesses applicants for RPA work.\n\n- Evidence and competence: CASA must be satisfied with training, experience and examination evidence before issuing an authority (subsection 1.2), and the applicant must demonstrate competence for the endorsed privileges (section 3.1). Those are outcome‑focused standards rather than a detailed procedural checklist, which gives CASA judgement over sufficiency.\n\n- Scope control: Authorities may be narrowly tailored to a single aircraft or expressly limited to types/series/groups/engines/systems/installations (section 3.2). That lets CASA or applicants restrict privileges and limits where an authority applies in practice.\n\n\n**Incentives, costs and implementation trade-offs**\n\n- Who pays: Applicants bear the compliance costs (training, examinations, documentation). Employers may incur costs when endorsing and supervising maintainers.\n\n- Who decides and where discretion sits: CASA (the Director) decides whether to accept alternative qualifications or to waive the licence requirement (subsection 1.1 and Director approval language). The instrument leans on CASA’s regulatory judgement rather than mandating a single pathway.\n\n- Effects on private providers and competition: By allowing RPA maintenance authorities without an aircraft engineer licence (subsection 1.1A), the instrument lowers a regulatory barrier for RPA maintenance personnel. That can widen the pool of eligible maintainers and may change the competitive landscape for providers of RPA maintenance services; it also shifts emphasis to CASA assessment of training and experience.\n\n- Administrative and compliance burdens: Outcome‑based requirements (\"satisfactory evidence\" and \"demonstrated competence\") require CASA to exercise judgment and create a need for assessment processes and record‑keeping. That increases regulator workload and could lead to inconsistent decision outcomes unless clear guidance and standardised assessment practices are implemented.\n\n- Substitution and quality control risk: Removing the blanket licence requirement for RPA maintenance authorities creates substitution incentives (licensed engineers versus RPA‑specific technicians). The instrument mitigates this by requiring training, experience and examinations (subsection 1.2), but those are qualitative requirements and enforcement depends on CASA’s operational procedures.\n\n\n**Relevant sections cited**\n\n- Definitions and link to CAR/regulation 33B: 1B (definitions and note to regulation 2 of CAR).\n- Baseline licence requirement and Director discretion: 1.1.\n- RPA exception to licence requirement: 1.1A.\n- Evidence of training, experience and examinations: 1.2.\n- Application form and employer endorsement: 2.\n- Issue, competence requirement and scope of authority: 3.1 and 3.2.\n\n\n**Official purpose statement and testing it**\n\n- The instrument’s effect is to ensure persons who certify maintenance are competent and authorised, while allowing CASA flexibility to approve alternative pathways. The explicit RPA exception introduced by the 2026 amendment appears intended to recognise different qualification pathways for RPA maintenance. Mechanically, this reduces the formal licence barrier for RPA work and replaces it with CASA assessment of training, experience and examinations (subsection 1.1A read with 1.2 and 3.1).\n\n- Trade‑offs: The more permissive route for RPA maintenance increases access and may lower entry costs, but it requires CASA to carry the assessment and oversight burden to maintain comparable standards of airworthiness. That creates implementation risk (need for standardized assessment, record‑keeping, and enforcement) and potential for uneven application if guidance is insufficient.\n\n"},"flash_summary_failed":{"failed":true,"reason":"A positive credit balance is required for all requests, including BYOK, so fallback providers remain available. Add credits at https://vercel.com/d?to=%2F%5Bteam%5D%2F%7E%2Fai%3Fmodal%3Dtop-up to continue.","source":"analysis-cron"}},"importantCases":[],"_links":{"self":"/api/acts/civil-aviation-order-100-24-maintenance-authority-instrument-2007","history":"/api/acts/civil-aviation-order-100-24-maintenance-authority-instrument-2007/history","analysis":"/api/acts/civil-aviation-order-100-24-maintenance-authority-instrument-2007/analysis","conflicts":"/api/acts/civil-aviation-order-100-24-maintenance-authority-instrument-2007/conflicts","importantCases":"/api/acts/civil-aviation-order-100-24-maintenance-authority-instrument-2007/important-cases","documents":"/api/acts/civil-aviation-order-100-24-maintenance-authority-instrument-2007/documents"}}