AD/BEECH 35/73 - Circuit Breaker Toggle Switches

The Directive organises its requirements around a small set of structural concepts: applicability by model/serial number and part number, mandatory replacement, prohibition on re‑use or re‑installation of the affected P/Ns as initial fit or replacement spare, reliance on a manufacturer service bulletin for the technical method of replacement, acceptance of FAA‑approved AMOCs to that service bulletin, and explicit compliance times anchored to the Directive’s effective date.

Applicability combines two filters. The first is the aeroplane model and serial range as listed in Table 1. The only model and serial range shown in Table 1 is V35B, D‑9069 through D‑10403. The second filter is the installed part: the directive applies to those aeroplanes that "have any circuit breaker toggle switch with a part number (P/N) 35‑380132‑1 through 35‑380132‑53 installed." Both elements matter: the aircraft must be within the listed model/serial range and must have a switch with a P/N in that numerical range to bring the aircraft within the AD’s field.

The technical remedy is prescriptive: replace the older P/Ns 35‑380132‑1 through 35‑380132‑53 with improved P/Ns 35‑380132‑61 through 35‑380132‑113 "as specified in Raytheon Aircraft Company (RAC) Recommended Service Bulletin SB 24‑3735, Issued: August 2005." The Directive thereby makes compliance conditional on following the manufacturer’s technical procedure. The Directive expressly recognises later revisions of that RAC SB as compliant, provided the FAA has approved them as an Alternate Method of Compliance (AMOC) to FAA AD 2008‑13‑17. That creates an interlocking compliance path: CASA’s Directive requires compliance with RAC SB 24‑3735, and subsequent FAA AMOC approvals of SB revisions are acceptable to CASA for meeting this Directive’s equivalent requirements.

Two timing elements are present. First, Requirement 1 must be completed "Within the next 24 months after the effective date of this Directive." The effective date is stated as 25 September 2008; the Directive text separately states that CASA "extends compliance by 13 months until 25 September 2010" relative to the FAA’s earlier compliance schedule (the FAA’s final compliance time was 6 August 2009). Second, Requirement 2's timing is immediate in the flight‑safety sense: the prohibition on installing old P/Ns as an initial fit or replacement spare applies "Before further flight after the circuit breaker toggle switch has been replaced in accordance with Requirement 1." In practice that means an aircraft on which replacements are carried out must not be returned to flight if the older P/Ns are re‑installed as new spares.

The Directive states a safety rationale: FAA reports of overheating "of certain circuit breaker toggle switches used in various electrical systems" in a broad set of Beech models, and that "Failure of the circuit breaker toggle switch could result in smoke in the cockpit and the inability to turn off the switch." The Directive also records administrative treatment: a draft was posted for public comment and no comments were received, and the document is signed and dated as a CASA Directive.

Primary legal addressees are the operators, owners and maintenance organisations responsible for the aeroplanes within the Directive’s Applicability: V35B serial numbers D‑9069 through D‑10403 that have any circuit breaker toggle switch with a P/N in the range 35‑380132‑1 through 35‑380132‑53 installed. The Directive’s applicability language ties regulatory duty to the combination of aircraft identity (model and serial) and installed part number; an aeroplane outside the listed serial range, or within the serial range but without an affected P/N fitted, is not covered by the Directive as printed.

Maintenance organisations, certifying staff and engineers who perform the replacement work are subject to the technical requirement that the replacement be "as specified in Raytheon Aircraft Company (RAC) Recommended Service Bulletin SB 24‑3735, Issued: August 2005," or to later approved revisions of that SB accepted via FAA AMOC. Those performing maintenance are therefore required to follow the RAC SB procedure or an FAA‑approved alternative for compliance with CASA’s requirements.

Parts suppliers and inventory controllers are affected by Requirement 2, which provides: "Circuit breaker toggle switches P/N 35‑380132‑1 through 35‑380132‑53 may not be installed on any aeroplane as an initial fit or as a replacement spare." That provision constrains the availability and use of specified spare parts as initial fits or replacement spares for the aeroplanes within the Directive’s applicability, and therefore affects procurement, inventory, and installation practices for spare parts on affected aircraft.

Raytheon Aircraft Company is referenced because its service bulletin is the specified method for replacement; FAA is implicated because the Directive accepts FAA‑approved AMOCs to the RAC SB as valid for CASA compliance. CASA itself is the issuing authority. The Background section lists a wider universe of Beech models in which FAA had observed overheating incidents (F33, F33A, F33C, G33, V35B, A36, A36TC, B36TC, 95‑B55, D55, E55, A56TC, 58, 58P, 58TC, G58 and 77), but the Directive’s Applicability is narrower and limited to those aeroplanes/serials in Table 1 with the affected P/Ns installed. The Directive therefore affects a subset of the aircraft types mentioned in the background narrative.

Who pays: the Directive imposes replacement obligations on the aeroplane (practical responsibility lies with the owner/operator and the maintenance provider), so the direct compliance cost (parts and labour to replace the switches in the specified P/N range with improved P/Ns) falls to those parties. The Directive does not specify cost recovery mechanisms, subsidies, or other financial assistance. Who decides: CASA issued the Directive and determines its terms; FAA‑approved AMOCs to RAC SB revisions are recognised by CASA as acceptable alternatives, creating a cross‑jurisdictional decision point administered by the FAA. The Directive does not identify any other decision‑maker.

Duties

• Identification duty: Operators/maintenance personnel must determine whether their aeroplane is within the Directive’s Applicability, i.e., whether it is a model and serial listed in Table 1 and whether it has any circuit breaker toggle switches with P/N 35‑380132‑1 through 35‑380132‑53 installed. The Directive’s Applicability wording makes this a pre‑condition of the obligations that follow.

• Mandatory replacement duty (Requirement 1): For applicable aeroplanes that have any of the listed P/Ns fitted, the Directive requires replacement "Unless previously accomplished" with specified improved P/Ns (35‑380132‑61 through 35‑380132‑113) "as specified in Raytheon Aircraft Company (RAC) Recommended Service Bulletin SB 24‑3735, Issued: August 2005." The duty is framed as mandatory except where the RAC SB action has already been performed prior to the Directive.

• Prohibition on installation (Requirement 2): The Directive imposes an immediate prohibition on installation of the older P/Ns on any aeroplane "as an initial fit or as a replacement spare." That is an ongoing obligation: affected P/Ns must not be used for initial fitting or as replacement spares on any aeroplane after the Directive takes effect and after replacement in accordance with Requirement 1 on each aeroplane.

• Timing duty: Compliance timing is explicit. Requirement 1 must be carried out "Within the next 24 months after the effective date of this Directive." The effective date is declared as 25 September 2008; consequently, the deadline for Requirement 1 under this Directive is 25 September 2010. Requirement 2 has immediate operational timing: it applies "Before further flight after the circuit breaker toggle switch has been replaced in accordance with Requirement 1."

• Method of compliance duty: The Directive ties the replacement work to the manufacturer's Service Bulletin, requiring replacement "as specified in" RAC SB 24‑3735. That creates a duty to adopt the technical method in that SB or use later revisions that the FAA has approved as AMOCs.

Rights and discretions recognised in the text

• Prior accomplishment allowance: The Directive explicitly recognises the possibility that the RAC SB action may already have been performed. The text states "Unless previously accomplished," which preserves the position of an owner/operator who already replaced the switches under RAC SB 24‑3735 prior to the Directive. The Directive thus does not require redundant work where the SB procedure has already been completed.

• Acceptance of FAA‑approved AMOCs: The Directive allows that "Later revisions of the above SB, approved by the United States Federal Aviation Administration (FAA) as an Alternate Method of Compliance (AMOC) to FAA AD 2008‑13‑17, are considered acceptable for compliance with the equivalent Requirements of this Directive." This gives operators an alternative compliance pathway where the FAA has approved a revision of the RAC SB as an AMOC, and the operator can rely on that FAA approval to satisfy CASA’s Directive rather than strictly using the original August 2005 SB text.

What the Directive does not state as rights or duties

• The Directive text does not set out enforcement procedures, penalties, or appeal mechanisms. It does not specify how operators should document prior accomplishment, who audits compliance, or what evidence will be accepted by CASA as proof of compliance. Those operational and enforcement details are not contained in the Directive as presented.

• The Directive does not specify cost recovery rights for operators who must purchase the improved P/Ns and have them fitted. It likewise does not give express discretion to delay beyond the prescribed compliance windows other than through FAA‑approved AMOCs to RAC SB revisions.

The Directive text supplied does not include express statutory penalties, criminal sanctions, or a detailed enforcement regime. The body of the Directive sets mandatory technical and timing requirements, but it does not set out monetary penalties, suspension regimes, certificate actions, or prosecution pathways. The document likewise does not include administrative procedural details such as the manner of CASA verification, recordkeeping obligations, inspection regimes, or notice and appeal procedures applicable in the case of non‑compliance.

What the Directive does provide by content and implication

• The document is an Airworthiness Directive issued by CASA and framed as a safety requirement. CASA is the issuing authority and thus is the body that has published the Directive and declared the effective date (the cover text shows the signature "James Coyne, Delegate of the Civil Aviation Safety Authority" dated 8 August 2008). As a CASA instrument, it is an enforceable regulatory instrument in the Australian civil aviation safety framework; however, the provided text does not reproduce the enabling provisions or statutory references that set out CASA’s enforcement powers or the specific penalties that may attach to failure to comply.

• The Directive makes compliance conditional on following RAC SB 24‑3735 (or FAA AMOC‑approved later revisions). Non‑compliance with an AD normally has operational consequences for airworthiness, including that the aeroplane cannot be treated as compliant with applicable airworthiness directives; the text here does not articulate the administrative consequences or the steps CASA would take in response to non‑compliance. The Directive similarly does not indicate whether CASA will issue a notice of grounding, restriction on flight operations, or pursue administrative action.

• The Directive’s lack of specified penalties or enforcement mechanics in the printed text means that practitioners must look to the broader CASA regulatory framework and the statutory instruments that empower CASA to enforce airworthiness directives to determine actual enforcement options and potential penalties. Those broader sources are not contained in the Directive text supplied here.

Because the Directive does not spell out enforcement measures or penalties, anyone needing authoritative information on enforcement consequences must consult the relevant CASA legislation and enforcement policies beyond the Directive itself. The Directive does, however, create an explicit technical and timing obligation whose non‑fulfilment would logically raise airworthiness compliance issues under CASA’s regulatory regime.

The Directive explicitly references and aligns with external instruments: Raytheon Aircraft Company (RAC) Recommended Service Bulletin SB 24‑3735 (Issued: August 2005) and the United States Federal Aviation Administration (FAA) Airworthiness Directive FAA AD 2008‑13‑17 (Amdt 39‑15580). The Directive states that later revisions of RAC SB 24‑3735 that the FAA approves as an Alternate Method of Compliance (AMOC) to FAA AD 2008‑13‑17 "are considered acceptable for compliance with the equivalent Requirements of this Directive." That creates a cross‑recognition mechanism where FAA action approving a service bulletin revision as an AMOC is accepted by CASA as a valid compliance route to satisfy CASA’s own Directive.

The Directive records that it "follows the intent of the FAA Directive" but has been revised in two respects: to "allow prior accomplishment" and to extend compliance by 13 months (until 25 September 2010) compared with the FAA’s final compliance time of 6 August 2009. This expressly documents a deliberate divergence in compliance timeline between CASA and the FAA AD. Effectively, CASA has created a local compliance schedule that is less onerous in timing than the FAA’s timeline, while still preserving technical alignment through the RAC SB and FAA AMOC process.

Because the Directive makes compliance conditional on a manufacturer service bulletin, RAC SB 24‑3735 operates as the technical method of compliance. Any later revision of that SB must be approved by the FAA as an AMOC to FAA AD 2008‑13‑17 before CASA will accept it as equivalent. Therefore, the interaction chain is: CASA AD refers to RAC SB; FAA AD and FAA AMOCs to RAC SB revisions are referenced and accepted by CASA as equivalent compliance. For operators, this means that changes to RAC SB that have FAA AMOC status are relevant to CASA compliance.

The Background paragraph lists a broad set of Beech models in which FAA had observed overheating incidents. CASA’s Directive, however, constrains its Applicability to the model and serials in Table 1. That demonstrates that CASA treats the FAA’s investigative and AD materials as informative but adopts a limited application tailored to the aircraft in Australia and to the particular serial range listed in Table 1. Thus, FAA outputs influence CASA action but do not automatically extend to identical scope without CASA’s separate determination.

The Directive does not reference other Australian legislation, regulatory instruments, or statutory provisions that govern enforcement, recordkeeping, or penalties. Therefore, the reader must consult the broader CASA statutory framework and civil aviation legislation to determine the statutory basis for enforcement, audit, and penalties. The Directive itself establishes technical obligations which must be read alongside those broader legislative instruments to obtain the full regulatory picture.

The document itself records two specific amendment‑style adjustments relative to the FAA material it follows:

1. Prior accomplishment allowance: The Directive states it "follows the intent of the FAA Directive" while being "revised to allow prior accomplishment, as the RAC service bulletin was issued in 2005 and may have already been accomplished." The phrase "Unless previously accomplished" in Requirement 1 operationalises this allowance by exempting aeroplanes where the RAC SB action had already been carried out prior to the Directive.

2. Extension of compliance time: The Directive expressly extends the compliance period relative to the FAA AD. The text explains that "The Directive also extends compliance by 13 months until 25 September 2010, the final compliance time required by the FAA was 6 August 2009." The Directive’s Compliance section translates that extension into the statement that Requirement 1 must be completed "Within the next 24 months after the effective date of this Directive." The effective date is recorded as 25 September 2008, which produces the 25 September 2010 deadline that the Directive records.

Administrative provenance and timestamps in the Directive

• The RAC service bulletin used as the technical compliance method is identified as "RAC Recommended Service Bulletin SB 24‑3735, Issued: August 2005."

• A draft version of the Directive was "posted for public comment on the Civil Aviation Safety Authority (CASA) internet site on 9 July 2008," and the Directive states that "As of the date that this Directive was made, no comments or objections have been received by CASA."

• The Directive is signed by James Coyne, Delegate of the Civil Aviation Safety Authority, and dated 8 August 2008. The effective date is stated in the Directive text as "This Airworthiness Directive becomes effective on 25 September 2008."

• The Directive cites FAA AD 2008‑13‑17 Amdt 39‑15580 as related material in a Note.

No later amendments to this CASA Directive are included in the supplied text. The Directive does, however, expressly accept later revisions of RAC SB 24‑3735 if those revisions are approved by the FAA as AMOCs to FAA AD 2008‑13‑17. Any actual amendment to the CASA Directive itself, or any rescission, extension beyond the recorded 24‑month window, or other change, is not reflected in the document provided.

If an operator relies on a RAC SB revision, the relevant amendment history to track operational compliance would include FAA AMOC approvals to RAC SB revisions (as referenced), but the Directive does not list any specific later SB revisions or FAA AMOC approvals by date or identifier in the supplied text.

The supplied Directive text does not include, recite or reference any litigation or court decisions. It contains no report of legal challenges, judicial review, appeals, or disputes concerning the Directive, its content, or its issuance. The document records administrative steps (draft posted for public comment on 9 July 2008 with no comments received), but it contains no statement about any legal proceedings or outcomes.

Because the Directive text itself does not address litigation history, practitioners seeking authoritative information on any legal challenges or precedent would need to consult external legal records, tribunal decisions, or court databases. None of those external records are included in the material supplied here, and the Directive does not suggest any such litigation exists.

In the absence of litigation records in the Directive text, an operator or adviser should assume that there is no litigation referenced or incorporated into this specific instrument, but should also note that absence of a statement in the document is not proof that no litigation exists in other fora. For the purposes of compliance and risk management, however, the Directive itself imposes technical requirements (replacement, prohibition on installation of old P/Ns), deadlines, and the acceptance of FAA‑approved AMOCs; any legal disputes about those obligations would need to be traced through external legal filings and CASA administrative records not contained in the Directive.

The Directive is short and technically specific, but it contains several features that can create practical pitfalls for operators and maintenance organisations. These are concrete points where misunderstanding or misapplication of the text could lead to non‑compliance.

1. Applicability is conjunctive (model/serial AND installed P/N). The Applicability wording requires both that the aeroplane is among the models/serials listed in Table 1 and that it "have any circuit breaker toggle switch with a part number (P/N) 35‑380132‑1 through 35‑380132‑53 installed." Operators must therefore check both the serial number against Table 1 and the installed part numbers. The Background lists many Beech models in which FAA saw overheating incidents, but the Directive’s Applicability is narrower. Misreading the Background as extending the Applicability to all those models would be an error.

2. The only Table 1 entry shown is V35B, D‑9069 through D‑10403. If an operator of another Beech model relies on the broad Background list, they may wrongly assume the AD applies to their aircraft. The Directive’s operational reach is the specific Table 1 listing; therefore careful cross‑checking of serial numbers and P/Ns is essential.

3. Part number ranges are specific and non‑overlapping. The Directive distinguishes old P/Ns (35‑380132‑1 through 35‑380132‑53) and improved P/Ns (35‑380132‑61 through 35‑380132‑113). Operators must identify exact P/Ns fitted to switches. Misidentifying a P/N or relying on partial or informal labelling could lead to failure to comply.

4. Requirement 2’s timing language can be misread. The Compliance row states: "For Requirement 2 - Before further flight after the circuit breaker toggle switch has been replaced in accordance with Requirement 1." Practically, Requirement 2 is a standing prohibition on installing old P/Ns as initial fit or replacement spare. The timing phrase could be misinterpreted as only applying at the moment of return to service after replacement; the safer reading is that once replacement is done, the aircraft must not carry or have fitted an older P/N as an initial fit or spare before the aircraft flies again. Operators should not treat Requirement 2 as permissive or as applying only to that single immediate flight cycle.

5. Prior accomplishment relief requires proof. The Directive exempts "Unless previously accomplished" but does not set out what documentary proof is required. Operators who claim prior accomplishment should ensure they retain and can produce maintenance records that specifically reference RAC SB 24‑3735 or otherwise show the required replacement was carried out in a manner equivalent to the SB. The Directive does not prescribe the documentary form of proof, so practitioners should anticipate CASA or an inspector requesting maintenance records.

6. AMOC dependence on FAA approval. The Directive allows later revisions of RAC SB 24‑3735 provided they are "approved by the United States Federal Aviation Administration (FAA) as an Alternate Method of Compliance (AMOC) to FAA AD 2008‑13‑17." That introduces a coordination risk: a RAC SB revision without FAA AMOC approval is not automatically acceptable to CASA under this Directive. Operators must verify FAA AMOC status before relying on a revised SB.

7. Timeline divergence between CASA and FAA. CASA extended the compliance period to 25 September 2010, while the FAA final compliance time was 6 August 2009. Operators operating across jurisdictions or under multiple regulatory umbrellas must be careful which deadline applies in which regulatory environment. The CASA Directive sets the Australian compliance deadline; the FAA AD sets a different schedule. Misapplication of the wrong compliance deadline can create regulatory exposure outside Australia.

8. No enforcement details in the text. The Directive does not specify penalties or enforcement processes. That absence can create uncertainty about how CASA will verify compliance, what evidence will be accepted, and what procedural steps follow non‑compliance. Practitioners should not assume leniency or the absence of enforcement; they should plan to demonstrate compliance proactively.

9. Parts availability and compatibility assumptions are not addressed. The Directive mandates replacement with the specified improved P/Ns "as applicable" but does not address how to handle situations where improved P/Ns are backordered, obsolete, or require panel modification. Any deviation from RAC SB technique must be supported by an FAA AMOC that the Directive accepts. Operators need to factor parts procurement lead times into compliance scheduling.

10. Documentation gap: The Directive does not prescribe how compliance is to be recorded in the maintenance log, certificate of release to service, or continuing airworthiness records. Operators should therefore adopt clear internal documentation protocols that reference the RAC SB and the CASA AD to produce a defensible record if inspected.

Each of the above is grounded in the Directive’s text: the Applicability and Requirements headings; the P/N ranges; the RAC SB reference and AMOC acceptance; the compliance timing; the Background; and the lack of penalty/enforcement detail. Practitioners should treat the Directive’s concise language as mechanically binding and address these practical items in maintenance planning and audit trails.

Step‑by‑step actions an owner/operator or maintenance organisation should take to achieve compliance with the Directive as printed:

1. Confirm applicability

   • Check aircraft model and serial number against Table 1. The Directive’s Table 1 lists model V35B, serial numbers D‑9069 through D‑10403. The Directive applies only to aeroplanes in that serial range that have an affected P/N installed.
   • Inspect and identify installed circuit breaker toggle switches. Determine whether any installed switch has P/N 35‑380132‑1 through 35‑380132‑53. Only aircraft that both appear in Table 1 and have one or more of the listed P/Ns fitted fall within the Directive.

2. Verify prior accomplishment

   • If the RAC SB action (RAC SB 24‑3735, Aug 2005) was completed prior to the Directive, the Requirement 1 obligation is framed as "Unless previously accomplished." Locate and assemble maintenance records that demonstrate the RAC SB action was completed, showing dates, part numbers removed and fitted, and the maintenance release or certifier identification. Although the Directive does not prescribe exactly what proof CASA will accept, retain contemporaneous work orders and logbook entries that refer to RAC SB 24‑3735 to show prior accomplishment.

3. Plan replacement in accordance with RAC SB 24‑3735

   • For aircraft that require action, plan to "replace all circuit breaker toggle switches P/N 35‑380132‑1 through 35‑380132‑53 with an improved circuit breaker toggle switch, P/N 35‑380132‑61 through 35‑380132‑113, as applicable, as specified in Raytheon Aircraft Company (RAC) Recommended Service Bulletin SB 24‑3735, Issued: August 2005."
   • Obtain and follow the technical instructions in RAC SB 24‑3735. The Directive makes the SB the specified replacement method. If you intend to use a later revision of the SB, confirm whether that revision is approved by the FAA as an AMOC to FAA AD 2008‑13‑17. The Directive only accepts RAC SB revisions that have FAA AMOC approval.

4. Schedule work within the Directive’s compliance window

   • The Directive prescribes for Requirement 1: "Within the next 24 months after the effective date of this Directive." The effective date is recorded as 25 September 2008, yielding a compliance deadline,under this Directive,of 25 September 2010. Plan parts procurement and maintenance slotting to meet that date. If the operator intends to rely on a RAC SB revision that requires FAA AMOC approval, ensure that approval timeline is accounted for.

5. Prevent prohibited re‑installation

   • Requirement 2 states: "Circuit breaker toggle switches P/N 35‑380132‑1 through 35‑380132‑53 may not be installed on any aeroplane as an initial fit or as a replacement spare." Update procurement, parts inventory and maintenance procedures to ensure that none of the old P/Ns are used for new installations or as spares. Communicate the prohibition to parts custodians and maintenance planners.

6. Document compliance

   • Record the replacement work in the aircraft maintenance log/book with reference to CASA AD/BEECH 35/73 and RAC SB 24‑3735 (including SB revision/date where applicable). Records should show parts removed, parts fitted (with P/N), date of work, certifying engineer/mechanic, and any FAA AMOC reference if a revised SB was used. Although the Directive does not prescribe the form of records, maintaining a clear audit trail will be necessary to demonstrate "Unless previously accomplished" or compliance if inspected.

7. Liaise with regulatory and technical authorities where deviations are needed

   • If the RAC SB procedure cannot be followed exactly for technical or logistic reasons, obtain a documented, approved alternative. The Directive indicates that later revisions of RAC SB 24‑3735 that the FAA approves as AMOCs are acceptable to CASA; however, it does not authorise other variations. Seek FAA AMOC approval for any alternative method tied to the RAC SB if intending to rely on CASA’s acceptance of FAA AMOCs, and retain documentation of that FAA approval.

8. Confirm the aircraft’s status before flight

   • After replacement work, apply Requirement 2 in practice by verifying that no prohibited P/Ns are fitted as initial fits or replacement spares before the aeroplane carries out any further flight, consistent with the Compliance wording "Before further flight after the circuit breaker toggle switch has been replaced in accordance with Requirement 1." Ensure the certifying release confirms compliance.

9. Consider inventory control and procurement changes

   • Update spare parts lists, procurement orders and vendor agreements so that P/N 35‑380132‑1 through 35‑380132‑53 are not ordered or supplied as spares for any aeroplane. If stock of older P/Ns exists, segregate and identify it so it cannot be inadvertently installed. The Directive places an explicit prohibition on their use as initial fit or replacement spare.

10. Monitor for FAA AMOC revisions and RAC SB updates

• Because the Directive accepts FIA‑approved AMOCs to RAC SB revisions as compliant, maintain a watch on FAA AD and SB AMOC notices. If a later RAC SB revision gets FAA AMOC approval that affects the replacement method or parts used, ensure that approval is documented and that maintenance records reference the specific FAA AMOC.

These steps flow directly from the Directive’s Applicability, Requirements, RAC SB reference, AMOC acceptance clause, and Compliance timetable. The Directive does not specify record formats, penalties, or appeal processes, so practitioners should align the above steps with their own compliance management systems and the wider CASA regulatory framework.