CASA EX19/26 — Authorised Maintenance at Unapproved Locations (Part 145 Organisations) Exemption 2026

The instrument introduces and links several defined concepts that determine its operation. The operative definitions are in s 3. Part 145 organisation is a term retained from the Civil Aviation Act 1988 and the regulations and is used throughout (s 3 Note). The instrument defines AMO as a Part 145 organisation and AMO aircraft as aircraft for which the AMO provides maintenance services under its exposition (s 3).

Authorised maintenance is a central, narrowly framed concept. It means maintenance services provided by the AMO in relation to an AMO aircraft that (a) consist of line maintenance for the AMO, and limited on‑wing maintenance where the AMO holds category B (on‑wing engine) or category C (on‑wing aeronautical product) ratings, but only as may be required in connection with the line maintenance; and (b) are conducted at the location on a temporary basis (s 3, authorised maintenance definition). The instrument also notes the CASR Dictionary definition of line maintenance for an AMO, that is, maintenance on an aircraft CASA has approved in the organisation’s exposition as being line maintenance for the organisation (s 3 note). Thus the exemption applies only to those tasks already constituted as line maintenance in the AMO’s exposition or the limited connected on‑wing tasks, and only where the work is temporary.

Unapproved location is defined in relation to an AMO as a location "capable of supporting line maintenance, but not specified as such in the AMO’s exposition as required by subparagraph 145.A.70(a)10 of the Part 145 MOS" (s 3). That definition ties the concept directly to the exposition and to a specific MOS subparagraph. Part 145 MOS is taken to mean the Part 145 Manual of Standards (s 3).

The exemptions operate by suspending certain CASR provisions and the need to apply for CASA approval of a "significant change" in relation to location, but only to the extent that they would prevent the AMO from carrying out the authorised maintenance at an unapproved location (s 4(1), s 5(1) and (2)). The specific CASR provisions exempted are listed (for example subparagraphs 145.045(a)(iv) and (v), paragraph 145.045(b), and paragraphs 145.070(1)(d) and (e)), but the instrument does not reproduce their content; it therefore exempts those provisions only to the described extent (s 4(1)(a) and (b)).

The instrument imposes conditions that are prerequisites for relying on the exemption. These conditions require that the AMO’s exposition authorise the kind of maintenance at that unapproved location (s 6(a)), that the exposition include detailed procedures for conducting such maintenance, for recordkeeping, and for selecting suitable locations (s 6(b)(i)-(iii)), that maintenance be performed in accordance with the AMO’s quality and safety management systems and exposition procedures (s 6(c)), that records be kept in accordance with the exposition’s recordkeeping procedures (s 6(d)), and that the AMO must provide information to CASA, on request, about the unapproved location and the maintenance carried out there (s 6(e)).

A structural tension is present in the instrument between the exemption from the prior approval requirement for "significant change" (s 5), and the instrument’s own note that adding the required exposition procedures is a "change" under the significant change definition and "requires CASA’s approval under regulation 145.050" (s 6(b) note). The instrument therefore creates a narrow operational regime in which AMOs may perform specified temporary maintenance at unapproved locations, subject to exposition governance and CASA information requests, while also signalling that certain exposition changes fall within the existing significant change framework.

Primary affected parties are AMOs, that is, Part 145 organisations, and their customers , specifically AMO aircraft (aircraft for which the AMO provides maintenance services under its exposition) and operators who rely on AMOs to perform line maintenance. The instrument defines these relationships directly (s 3 definitions). An AMO that wishes to make use of the exemption must alter or confirm its exposition procedures where necessary, operate under its quality and safety management systems, and accept the additional administrative obligations imposed by the instrument (s 6).

CASA, and the delegate who made the instrument, are the decision authority and information recipient under the regime. The instrument was made by a CASA delegate (a section manager in the Legal Division) under the cited CASR powers (instrument header and signature block; s 1 and the instrument preamble noting the instrument is made under regs 11.160 and 11.205). CASA retains the ability to request information about unapproved locations and the maintenance performed there (s 6(e)). The instrument does not itself create new enforcement mechanisms, but it conditions the exemption on AMO compliance with the listed conditions and makes the AMO responsible for ensuring that compliance (s 4(2), s 6).

Other affected parties include personnel within AMOs who must carry out on‑wing or line maintenance, and the administrators who maintain expositions and records. Where the AMO holds category B or C ratings, authorised maintenance under the exemption may encompass on‑wing work on installed engines or aeronautical products in support of line maintenance, which will affect technicians authorised to perform that work (s 3, authorised maintenance definition).

Indirectly affected are locations that are "capable of supporting line maintenance" but not currently specified in an AMO’s exposition as approved line maintenance locations. Local airport authorities, hangar operators, lessees of ad hoc locations, and operators of such sites may experience increased commercial opportunities because an AMO can perform authorised maintenance there temporarily (s 3, unapproved location definition; s 4). The instrument does not identify or list particular locations; rather it enables AMOs to select suitable locations in accordance with procedures the AMO must include in its exposition (s 6(b)(iii)).

Finally, the instrument’s temporal scope limits affected parties to those planning operations between 1 March 2026 and 28 February 2029 (s 2). After that date the exemption is repealed, so AMOs and affected third parties must plan for either reversion to the pre‑exemption regime or separate approvals under the CASR framework.

The instrument confers a conditional right on an AMO to perform specified authorised maintenance at an unapproved location by exempting the AMO from particular CASR requirements to the limited extent set out (s 4(1); s 5(1) and (2)). That is a right contingent on compliance with the instrument’s conditions, and it exists only for the instrument’s duration (s 2; s 4(2)). The right is not absolute; it applies only to maintenance that meets the instrument’s authorised maintenance definition and is performed temporarily at a location capable of supporting line maintenance but not specified in the exposition as such (s 3).

The AMO’s duties under the instrument are explicit. The AMO must ensure compliance with the conditions of exemption (s 4(2)). Those conditions include:

• ensuring the maintenance is of a kind authorised by the AMO’s exposition as appropriate to be performed at an unapproved location of that kind (s 6(a));

• including detailed procedures in the exposition for (i) carrying out maintenance of that kind at the unapproved location, (ii) the record keeping for such maintenance, and (iii) selecting suitable locations for carrying out such maintenance (s 6(b)(i)-(iii)). The instrument further records that inclusion of those procedures constitutes a change within the significant change definition and "requires CASA’s approval under regulation 145.050" (s 6(b) note);

• performing maintenance in accordance with the AMO’s quality and safety management systems and the relevant exposition procedures and other exposition conditions (s 6(c));

• keeping records of the maintenance in accordance with the exposition’s record keeping procedures for that kind of maintenance (s 6(d));

• providing information to CASA, upon request, relating to any unapproved location at which the maintenance is carried out, and any maintenance carried out there (s 6(e)).

The instrument also creates an exemption from compliance with subparagraphs and paragraphs of CASR that would otherwise regulate where and how maintenance may be conducted (s 4(1)). It also exempts AMOs from applying for CASA approval for a "significant change" in relation to the location in the specific circumstances described, allowing maintenance to be carried out without first applying for or receiving that approval (s 5(1)-(2)). That creates an operational right to commence and perform the authorised maintenance without prior CASA sign off for the location‑related significant change, subject to the conditions.

CASA’s rights are implicit in the instrument’s conditions. CASA retains the right to request information about unapproved locations and maintenance carried out there and to assess compliance with the instrument’s conditions using that information (s 6(e)). The instrument also notes pre‑existing MOS provisions that already allow certain maintenance at unapproved locations in limited circumstances, indicating CASA retains its standard oversight and approval role for those situations outside the exemption’s scope (s 4 note).

Overall the duties imposed on AMOs are administrative and procedural: ensure the exposition authorises and includes procedures for the maintenance at unapproved locations, perform work under existing quality and safety systems, keep records consistent with the exposition, and respond to CASA requests. The right to perform specified authorised maintenance at unapproved locations is conditional on meeting those duties and limited to the defined maintenance types and the instrument’s timeframe.

The instrument itself is an exemption instrument. It does not create new penalty provisions or set out specific sanctions. It operates by temporarily suspending certain CASR requirements to a specified extent (s 4(1); s 5). Because it is an exemption rather than a standalone regulatory instrument setting enforcement rules, the enforcement consequences for non‑compliance with its conditions are not described within the text. The instrument does, however, place an explicit onus on the AMO to "ensure compliance with the conditions of exemption in section 6" (s 4(2)), signalling that reliance on the exemption requires adherence to those conditions.

The instrument gives CASA an express information right: an AMO must provide, on request, information relating to any unapproved location at which the maintenance is carried out and any maintenance carried out at the unapproved location (s 6(e)). That provision establishes a mechanism for CASA oversight and fact finding. An AMO that fails to provide such information would be failing a condition of the exemption (s 6(e)) and a general duty to ensure compliance with the conditions (s 4(2)). The most direct textual consequence is loss of entitlement to rely on the exemption if its conditions are not met; the instrument does not itself set out the legal consequences following loss of exemption.

Because the exemption operates by modifying obligations under the CASR regime, standard CASR enforcement tools and consequences remain relevant where the AMO does not meet its underlying statutory obligations outside the exemption’s scope. The instrument references provisions of CASR (for example subparagraphs 145.045(a)(iv) and (v), paragraph 145.045(b), and paragraphs 145.070(1)(d) and (e); s 4(1)(a) and (b)), as well as regulation 145.050 and the significant change framework (s 5). Those provisions, and other CASR enforcement provisions, lie outside the instrument’s text and therefore govern any enforcement action in the absence of the exemption or if the exemption has been lost. The instrument does not expand CASA’s enforcement powers beyond what the CASR confers; it instead narrows compliance obligations temporarily for AMOs that meet the instrument’s conditions.

The instrument was signed by a CASA delegate (Section Manager Drafting, Legal Division) and is dated 24 February 2026. The delegate status demonstrates that the exemption is an administrative instrument made under delegated regulatory powers (instrument preamble and signature block). That delegated administrative origin reinforces that oversight and enforcement will be through CASA processes rather than through new penalty regimes embedded in the exemption instrument itself.

Practically, the enforcement pathway under the instrument is: AMOs must meet the conditions in s 6 to rely on the exemption (s 4(2)); CASA may request information under s 6(e); if an AMO cannot meet the conditions or does not provide information, the AMO cannot rely on the exemption and may be required to comply with the underlying CASR requirements from which the exemption purports to relieve them (s 4(1), s 5). The instrument’s temporal limit also means that after 28 February 2029 the exemption will no longer be available and normal CASR requirements will reassert full force (s 2).

The instrument expressly interacts with specific parts of the Civil Aviation Safety Regulations 1998 and the Part 145 Manual of Standards. The instrument is made under regulations 11.160 and 11.205 of CASR (instrument preamble). It exempts AMOs from compliance with particular CASR provisions: subparagraphs 145.045(a)(iv) and (v), paragraph 145.045(b), and paragraphs 145.070(1)(d) and (e) (s 4(1)(a) and (b)). The instrument does not reproduce the content of those CASR provisions; it only identifies which provisions are disapplied to the extent necessary to allow authorised maintenance at an unapproved location.

The instrument also interacts with the Part 145 MOS. It uses the MOS to define "unapproved location" by reference to subparagraph 145.A.70(a)10 of the Part 145 MOS (s 3). The instrument repeatedly references paragraph 145.A.75(b) of the Part 145 MOS. The instrument notes that, separately from this exemption, an AMO may already provide maintenance services at an unapproved location under paragraph 145.A.75(b) of the MOS in limited cases (unserviceable aircraft or unscheduled line maintenance), subject to the AMO’s approval and exposition (s 4 note). The instrument also states that Part 145 MOS is the "Part 145 Manual of Standards" (s 3).

The instrument engages the CASR "significant change" provisions. It exempts AMOs from subregulations 145.050(1), (2) and (3) of CASR insofar as those provisions would require the AMO to have applied for and received CASA’s approval for a significant change in relation to the location before carrying out authorised maintenance at an unapproved location (s 5(1)-(2)). The instrument references the definition of "significant change" in subregulation 145.010(2), specifically paragraph (b) and paragraph (f) (s 5 and s 6(b) note). The text also records that the inclusion in an AMO’s exposition of the procedures required by s 6(b) constitutes a change mentioned in paragraph (f) of the definition of significant change and "requires CASA’s approval under regulation 145.050" (s 6(b) note). That note sits alongside the exemption in s 5 that allows carrying out authorised maintenance at an unapproved location without first applying for or receiving CASA approval for the significant change.

In short, the instrument temporarily modifies application of specific CASR requirements and the MOS to permit a defined, temporary practice. It does not amend CASR or the MOS themselves; rather it exempts AMOs from complying with particular CASR provisions in defined circumstances and refers to the MOS to define key elements. The instrument therefore creates a conditional, time‑limited overlay on top of the existing CASR and MOS framework for Part 145 organisations. Because the instrument relies on the existing structure of expositions, quality and safety management systems, and the significant change regime, it interacts with those legal instruments by narrowing the instances in which pre‑approval is required and by imposing exposition and recordkeeping conditions that reference the MOS framework.

Finally, the instrument stipulates that certain terms and expressions have the same meaning as in the Civil Aviation Act 1988 and the regulations (s 3 note). That cross‑reference ensures that statutory definitions and regulatory terminology outside the instrument remain applicable where the instrument uses those terms.

The instrument contains a single, self‑contained text and records its date of execution as 24 February 2026, signed by Daniel Bernard O’Hagan, Section Manager Drafting, Legal Division, as a CASA delegate (instrument header and signature block). The commencement date is 1 March 2026 and the instrument is set to be repealed automatically at the end of 28 February 2029 (s 2). There are no subsequent amendments recorded within the instrument itself.

Because this instrument is an exemption instrument with an express expiry date (s 2), any continuation of its effects beyond 28 February 2029 would require either a new exemption instrument, an amendment of CASR or MOS provisions, or an AMO to obtain the standard CASA approvals that the exemption temporarily displaces. The instrument does not include transitional arrangements beyond its duration; it simply specifies commencement and repeal dates (s 2).

The instrument does not include savings, retrospective application, or modification clauses beyond the stated exemptions and conditions. It does not record prior versions or prior instruments; it is presented as CASA EX19/26, the named instrument. There is no internal amendment provision within the instrument text that would permit unilateral modification during its life; any change to the instrument would require a new instrument or formal amendment process by CASA, not performed by the AMO.

The instrument’s internal notes reference MOS requirements and CASR regulation 145.050 regarding approval of significant changes (s 6(b) note). Those references are not amendments but contextual notes indicating interaction points between exposition changes and existing regulatory approval obligations. The presence of the note has the practical effect of signalling that while the instrument exempts certain procedural requirements, particular exposition changes still fall within the significant change definition under the MOS and CASR. The instrument therefore contains internal cross‑references that could bear on any future amendment or interpretive practice.

In short, the amendment history contained within the instrument is limited to its own creation date and its fixed three‑year lifecycle. No further amendments or historical layers are recorded in the text provided.

The instrument text contains no references to litigation, judicial review, or case law. There are no recorded disputes, court decisions, or administrative appeals contained in the instrument itself. Because the instrument is an administrative exemption issued by a CASA delegate, any legal challenges arising from its operation would be external to the instrument and are not documented in the instrument’s text.

The instrument does not set out dispute resolution procedures or appeal rights specific to its application. It does not purport to modify CASA’s existing statutory powers to enforce or interpret the CASR and MOS, nor does it set out an internal CASA review mechanism in the instrument text. Any challenge to the validity or application of the instrument would therefore proceed by reference to the relevant administrative or judicial review pathways that apply to CASA decisions and instruments under the Civil Aviation Act 1988 and general administrative law, none of which are described in the instrument text.

Because the instrument imposes duties (for example the duty on an AMO to ensure compliance with the conditions in s 6 and to provide information to CASA on request under s 6(e)), disagreements over compliance or interpretation could be subject to enforcement or review through CASA’s existing powers under CASR. The instrument itself does not document any precedent or prior litigation outcomes relevant to those powers.

In sum, the instrument as presented contains no litigation history. Those seeking any litigation record would need to consult external sources, which are beyond the scope of this instrument’s text.

1. Exemption versus exposition change tension: The instrument exempts AMOs from having to apply for, or receive, CASA’s approval for certain "significant changes" in relation to location so that authorised maintenance may be carried out at an unapproved location without prior CASA approval (s 5). Yet the instrument also expressly requires the AMO’s exposition to include detailed procedures for carrying out maintenance at an unapproved location and records in a note that inclusion of those procedures constitutes a "change" under the MOS significant change definition and "requires CASA’s approval under regulation 145.050" (s 6(b) and s 6(b) note). That textual juxtaposition creates a potential interpretive gotcha: the instrument simultaneously provides an operational exemption from prior approval and states that adding the exposition procedures is a change requiring CASA approval. The instrument does not resolve that tension in its terms. Practitioners must therefore read s 5 and the s 6(b) note together and recognise a potential ambiguity in whether the exemption truly obviates the need for CASA approval of the exposition change, or only obviates other aspects of the significant change process.

2. Narrow definition of authorised maintenance: Authorised maintenance is strictly defined. It is limited to line maintenance as approved in the AMO exposition, and only on‑wing tasks connected to that line maintenance where the AMO holds category B or C ratings (s 3, authorised maintenance definition). Work outside that narrow scope , for example major maintenance, shop‑level work, or non line‑maintenance tasks , is not covered by the exemption and remains subject to the normal CASR and MOS obligations. AMOs relying on the exemption must ensure the particular tasks at an unapproved location fall squarely within the authorised maintenance definition.

3. Temporary basis requirement: The authorised maintenance must be conducted at the location on a temporary basis (s 3, authorised maintenance definition). The instrument does not define "temporary". Absent an internal definition, AMOs face interpretive exposure over what duration or frequency of use constitutes temporary, and CASA’s ability to request information under s 6(e) may be used to assess that. AMOs should therefore take care to document the temporary nature of activities in their records and exposition procedures.

4. Exposition content and approval loop: The instrument requires exposition procedures for selecting suitable locations and recordkeeping (s 6(b)(ii)-(iii)). However, the instrument also notes that adding those procedures is a significant change that requires CASA approval (s 6(b) note). That creates a procedural loop: the AMO must have exposition procedures authorising the maintenance at an unapproved location (s 6(a)), but the act of adding those procedures may itself trigger CASA approval requirements. The exemption in s 5 may allow an AMO to proceed without prior approval in relation to location changes, but the instrument text does not provide a clear, standalone mechanism for how to complete the exposition amendment and the CASA approval relationship.

5. Reliance on existing quality and safety systems: The instrument requires AMOs to perform the maintenance in accordance with their quality and safety management systems and exposition procedures (s 6(c)). That places the primary compliance burden on the AMO. CASA retains a right to request information about the location and maintenance (s 6(e)). If an AMO’s quality or safety system is not aligned with the new operational practice, the AMO remains responsible for remedying that gap.

6. Potential operational constraints tied to MOS references: The instrument defines unapproved location by reference to MOS subparagraph 145.A.70(a)10 and cross‑references paragraph 145.A.75(b) of the Part 145 MOS (s 3; s 4 note). Those MOS provisions are not reproduced in this instrument. AMOs must therefore consult the MOS itself to understand the underlying requirements and any limits (for example on facilities, equipment, or approvals) that remain applicable, because the exemption operates only "to the extent" of the cited CASR and MOS interplay (s 4(1)).

7. Time‑limited nature: The exemption automatically lapses on 28 February 2029 (s 2). AMOs that build business models or operational plans around the exemption should plan for the cessation date and for the possibility that normal CASA approvals and MOS compliance will be required thereafter.

8. Information obligations and oversight: The instrument obliges AMOs to provide information to CASA on request about unapproved locations and maintenance carried out there (s 6(e)). AMOs should treat such requests as enforceable conditions of the exemption, and failure to respond would mean inability to rely on the exemption (s 4(2)).

9. Category rating dependencies: The on‑wing element of authorised maintenance is conditional on possession of category B or C ratings (s 3). AMOs without those ratings cannot perform on‑wing tasks under the exemption, even where they might be able to perform other line maintenance functions.

10. Interpretive gaps on scope of disapplied CASR provisions: The instrument lists specific CASR provisions that are exempted to the extent necessary (s 4(1)). Because the instrument does not reproduce their content, determining precisely which practical requirements remain in force requires cross‑checking those CASR sections and the MOS. AMOs cannot assume broad relief from all location or facility obligations without consulting those provisions.

Each of these "gotchas" stems directly from the instrument’s text and cross‑references. They represent interpretive and operational risks an AMO must manage if it intends to rely on the exemption.

Step 1 , Confirm eligibility and scope: Verify that the maintenance activities intended to be carried out at an unapproved location fall within the instrument’s authorised maintenance definition: line maintenance as approved in the AMO’s exposition, and where applicable, on‑wing maintenance on installed engines or aeronautical products only if the AMO holds the relevant category B or C rating and the on‑wing work is required in connection with line maintenance. See s 3 (definitions of AMO, AMO aircraft, authorised maintenance).

Step 2 , Exposition alignment: Ensure the AMO’s exposition explicitly authorises the kind of maintenance in question as appropriate to be performed at an unapproved location of that kind (s 6(a)). The instrument requires the exposition to contain detailed procedures for carrying out that maintenance at unapproved locations, for recordkeeping, and for selecting suitable locations (s 6(b)(i)-(iii)). Draft those procedures before performing maintenance.

Step 3 , Address the significant change note: The instrument’s note records that inclusion of the required procedures in the exposition is a change in procedures under paragraph (f) of the significant change definition and "requires CASA’s approval under regulation 145.050" (s 6(b) note). The instrument also contains an exemption from the need to apply for CASA approval for a significant change in relation to the location so that AMOs may carry out authorised maintenance without first applying or receiving CASA’s approval (s 5). Given this textual juxtaposition, an AMO should document which exposition changes are being made, when they are made, and preserve contemporaneous records showing reliance on the instrument. Maintain internal evidence that the procedures are in place and that work performed at the unapproved location was temporary and conforms to the exemption’s scope.

Step 4 , Operate under existing QMS: Perform all maintenance in accordance with the AMO’s quality and safety management systems and in conformity with the exposition’s procedures and other exposition conditions (s 6(c)). Ensure technicians and supervisors understand the temporary nature of the work, the operational constraints on unapproved locations, and any category rating limits.

Step 5 , Recordkeeping: Keep detailed records of each instance of authorised maintenance at unapproved locations in accordance with the exposition’s recordkeeping procedures for that kind of maintenance (s 6(d)). Because the instrument requires retention of records consistent with exposition procedures, ensure those procedures specify what information must be recorded (location, dates, scope of tasks, personnel, parts used, defect history, temporary arrangements, and any safety checks).

Step 6 , Location selection procedures: Implement and document the exposition’s procedures for selecting suitable locations for carrying out the maintenance (s 6(b)(iii)). Because "unapproved location" is defined as capable of supporting line maintenance but not specified in the exposition, the selection procedures should demonstrate how the location is assessed against capability criteria (equipment, power, safety, access, environmental controls, security, firefighting services if applicable), consistent with the MOS requirements referenced by the instrument.

Step 7 , Information provision readiness: Prepare to provide information to CASA on request relating to any unapproved location and any maintenance carried out there (s 6(e)). Have a nominated point of contact and a repository for the records described in Step 5 so the AMO can respond promptly to CASA information requests.

Step 8 , Demonstrate temporariness: Because the authorised maintenance must be carried out at the location on a temporary basis (s 3, authorised maintenance definition), AMOs should ensure their records and exposition procedures document the temporary nature of the activity (dates, expected duration, reason for temporary arrangement, and confirmation of return to approved locations where applicable).

Step 9 , Consult the MOS and CASR references: The instrument cross‑references subparagraph 145.A.70(a)10 and paragraph 145.A.75(b) of the Part 145 MOS and cites CASR provisions such as 145.045 and 145.070 (s 3; s 4(1) note). Consult those MOS and CASR provisions directly to understand residual obligations, safety standards, and any facility or capability requirements that remain applicable even where specific CASR paragraphs are exempted. The instrument’s effect is to exempt specified requirements "to the extent" necessary; it does not imply wholesale relief from all MOS or CASR obligations.

Step 10 , Plan for the sunset: The exemption expires on 28 February 2029 (s 2). If the AMO intends to continue similar activity beyond that date, plan early. Options include seeking CASA approval for the exposition changes under the standard 145.050 process, securing a separate or renewed exemption from CASA, or ensuring the operations can be transitioned back to approved locations consistent with normal CASR/MOS requirements.

Step 11 , Internal governance and audits: Incorporate the new exposition procedures into internal audits and quality assurance checks. Because the exemption conditions rely on compliance with the exposition and QMS, audit evidence will be central to demonstrating ongoing compliance and responding to CASA information requests.

Step 12 , Limit work to permitted tasks and ratings: Ensure that on‑wing maintenance at unapproved locations is only performed where the AMO holds the relevant category B or C ratings and only as required in connection with line maintenance (s 3). Do not use the exemption as an enabling mechanism for broader types of maintenance.

Following these steps aligns AMO practice with the instrument’s textual conditions and creates an auditable trail to demonstrate reliance on the exemption. The instrument’s information request power and the exposition change note mean AMOs should manage the exposition change process carefully and maintain contemporaneous evidence of compliance while the exemption is in force.