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

AMO and AMO aircraft The instrument uses “AMO” to mean a Part 145 organisation. An “AMO aircraft” is an aircraft for which the AMO provides maintenance services under its exposition. This ties the exemption to the scope of the organisation’s approved maintenance capability.

Authorised maintenance This is a specially defined term in section 3 and is the engine room of the substantive exemption. It comprises three limbs:

(a) line maintenance for the AMO, being maintenance that CASA has approved in the organisation’s exposition as line maintenance; (b) if the AMO holds a category B rating, on-wing maintenance on an installed engine connected with that line maintenance; (c) if the AMO holds a category C rating, on-wing maintenance on an installed aeronautical product connected with that line maintenance.

All of the above are subject to a critical temporal qualifier: the maintenance must be conducted at the location on a temporary basis. The instrument does not define “temporary basis”, leaving it to ordinary meaning and operational context; a prolonged, repeated or seasonal pattern of use at the same location may move the activity outside the exemption.

Unapproved location An unapproved location, in relation to an AMO, means a location that is capable of supporting line maintenance but that is not specified in the AMO’s exposition in accordance with subparagraph 145.A.70(a)10 of the Part 145 MOS (which requires an AMO to list the locations where maintenance may be carried out). The location must therefore be physically suitable but absent from the formal network of approved line stations.

Significant change The exemption interacts with the concept of significant change in subregulation 145.010(2) of CASR. Paragraph (b) of that definition captures a change to a location at which maintenance may be carried out. Paragraph (f) captures a change to the AMO’s procedures. The instrument carefully distinguishes between the two: it exempts the AMO from having to apply for CASA approval of a location change, but it expressly notes that the introduction of procedures required by the exemption is itself a change to procedures under paragraph (f) and still requires CASA’s approval.

Role of the exposition The AMO’s exposition is the central control document. The exemption does not circumvent the exposition; it requires the exposition to be enriched with specific procedures and an authorisation that a kind of maintenance is appropriate for unapproved locations. Only after those exposition amendments are in place and approved (to the extent necessary) can the AMO lawfully rely on the exemption.

The instrument directly affects every AMO that holds a Part 145 certificate and that wishes to deploy line maintenance capability at locations not formally listed in its exposition. This typically includes:

• Regular public transport operators and large charter operators that hold their own Part 145 approvals and maintain their fleets at various ports.
• Independent maintenance organisations that provide line maintenance services under contract to aircraft operators and that may need to dispatch maintenance personnel to locations outside their approved network.
• AMOs that hold category B or C ratings, as the exemption extends to on-wing engine and product maintenance ancillary to line maintenance.

Indirectly, the instrument benefits aircraft operators that rely on AMOs for line maintenance, because it gives those AMOs greater operational flexibility to support aircraft at outstations, diversions, charter destinations or during ad hoc operational surges without requiring a permanent exposition amendment for each location.

CASA is affected as the regulator: the instrument imposes an obligation on AMOs to provide information to CASA on request about any unapproved location used and any maintenance performed there, giving CASA post hoc visibility.

Right to perform authorised maintenance at unapproved locations An AMO that meets all conditions in section 6 has the right to carry out “authorised maintenance” on an AMO aircraft at an unapproved location without breaching the CASR provisions listed in subsection 4(1). This right is not self-standing; it exists only while the conditions are satisfied.

Duty to ensure the exposition authorises the kind of maintenance Condition 6(a) requires that the maintenance must be of a kind authorised by the AMO’s exposition as appropriate to be performed at an unapproved location of that kind. The AMO must therefore have a positive statement in its exposition that a category of line maintenance (e.g. daily checks, transit checks) is suitable for performance at a location that is not an approved maintenance location. A generic line maintenance approval is insufficient; the exposition must specifically contemplate unapproved locations.

Duty to include detailed procedures in the exposition Condition 6(b) mandates that the AMO’s exposition must include detailed procedures for:

• carrying out maintenance of that kind at an unapproved location of that kind;
• record keeping for maintenance of that kind; and
• selecting suitable locations for carrying out maintenance of that kind.

These procedures must be in place before the exemption is relied upon, because condition 6(b) is worded as a present obligation (“must include”). The note following condition 6(b) makes explicit that including such procedures constitutes a change to procedures for the purpose of paragraph (f) of the definition of significant change and requires CASA’s approval under regulation 145.050. The AMO therefore cannot unilaterally amend its exposition to insert the procedures; it must submit a significant change application and receive CASA’s approval. This is the single most important regulatory gateway.

Duty to perform maintenance in accordance with the exposition and management systems Condition 6(c) requires that the maintenance be performed in accordance with the AMO’s quality and safety management systems and the procedures and other conditions applying to the maintenance under the exposition. The exemption does not dilute the AMO’s continuing obligation to operate within its approved systems.

Duty to keep records Condition 6(d) imposes a record-keeping obligation: records of the maintenance carried out must be kept in accordance with the record-keeping procedures in the AMO’s exposition for maintenance of that kind. This ensures that the audit trail for maintenance at unapproved locations is as robust as for maintenance at approved line stations.

Duty to provide information to CASA Condition 6(e) creates an information supply obligation: on request, the AMO must provide CASA with information relating to any unapproved location at which maintenance is carried out, and any maintenance carried out at that location. There is no time limit on this obligation; CASA may seek the information at any time while the exemption is in force and the records are required to be retained.

Exemption from significant change for location Section 5 gives two separate exemptions from the significant change approval process:

• Subsection 5(1) exempts the AMO from subregulations 145.050(1), (2) and (3) of CASR to the extent it carries out authorised maintenance at an unapproved location, meaning the AMO need not apply for or receive CASA’s approval for the location change that would otherwise be triggered by performing maintenance at a new, unlisted location.
• Subsection 5(2) grants an equivalent exemption for maintenance already permitted by paragraph 145.A.75(b) of the Part 145 MOS (maintenance on an unserviceable aircraft or unscheduled line maintenance) when performed at an unapproved location. This removes doubt about whether such activity amounts to a significant change involving a location.

Neither exemption removes the obligation to obtain CASA approval for the introduction of the procedures required by condition 6(b). That separate approval is a prerequisite to reliance on the instrument.

CASA EX19/26 does not itself create offences or civil penalty provisions. It is an exemption instrument that modifies the application of CASR provisions. The enforcement consequence of non-compliance is that the AMO ceases to be covered by the exemption. If an AMO performs maintenance at an unapproved location without satisfying the conditions in section 6, it will be in breach of the underlying CASR requirements from which exemption is conditionally granted. Those underlying requirements are:

• Subparagraphs 145.045(a)(iv) and (v) and paragraph 145.045(b) of CASR, which require maintenance to be carried out at a location acceptable to CASA and in accordance with the exposition; and
• Paragraphs 145.070(1)(d) and (e) of CASR, which limit the privileges of an AMO to maintenance at locations specified in the exposition (subject to any MOS privileges).

Contravention of those provisions is enforceable through the civil penalty and administrative action framework in Parts 11 and 145 of CASR and the Civil Aviation Act 1988. CASA may:

• Impose a pecuniary penalty where a strict liability or civil penalty provision applies.
• Suspend or cancel the AMO’s Part 145 certificate under regulation 145.080 if it is satisfied the organisation has contravened a requirement of Part 145.
• Accept an enforceable voluntary undertaking.
• Issue an infringement notice if the relevant provision is prescribed for infringement notice purposes.

Additionally, failure to comply with condition 6(e) (providing information to CASA on request) means the AMO is not complying with a condition of the exemption, with the consequence that the exemption is not available for the maintenance in question. If CASA requests information and it is not provided, the AMO’s reliance on the exemption for past and future activities at the relevant location would be vulnerable to regulatory action.

Further, condition 6(b)’s requirement that the exposition include the detailed procedures and the associated note that introducing them requires CASA approval under regulation 145.050 means that an AMO that proceeds without that approval has not only failed a condition of the exemption but has also likely contravened the significant change approval requirements of CASR directly, attracting separate exposure.

Civil Aviation Safety Regulations 1998 (CASR) Part 145 The instrument is entirely parasitic on Part 145. It selectively carves out certain requirements while leaving the rest of the Part intact. The exemption under subsection 4(1) applies to the extent that the AMO may carry out authorised maintenance at an unapproved location; all other requirements of Subparts 145.A, 145.B and 145.C continue to apply. This includes, for example, requirements relating to personnel qualifications, tooling, calibration, maintenance data, certification, release to service, and occurrence reporting.

Part 145 Manual of Standards (MOS) The instrument directly references and modifies the effect of several MOS provisions. The definition of “unapproved location” incorporates subparagraph 145.A.70(a)10 of the MOS (the obligation to list maintenance locations in the exposition). The note in subsection 4(1) refers to paragraph 145.A.75(b) of the MOS, which is the existing privilege for maintenance at any location when an aircraft is unserviceable or for unscheduled line maintenance. The instrument does not alter the substantive requirements of Appendix I to the MOS (continuing airworthiness and maintenance standards) but exempts the AMO from provisions that would otherwise limit where the maintenance may be performed.

Regulation 11.160 and 11.205 of CASR The instrument is made under CASA’s general exemption powers in Part 11. Regulation 11.205 allows CASA to exempt persons from compliance with a specified provision of CASR. The exemption is a disallowable legislative instrument for the purposes of the Legislation Act 2003. As such, it is subject to parliamentary scrutiny and potential disallowance during the tabling period. The exemption operates as a temporary modification of the law; it is not an amendment to CASR or the MOS.

Interaction with the definition of “significant change” The instrument explicitly navigates the two limbs of the significant change definition. By exempting the AMO from the requirement to obtain approval for a location change (paragraph (b) of the definition), but confirming that the insertion of new procedures triggers a procedural significant change (paragraph (f) of the definition) that still requires approval, the instrument creates a clear regulatory pathway: first obtain CASA’s approval for the new procedures; then use those approved procedures to perform maintenance at unapproved locations without further location-by-location approval. This preserves CASA’s oversight of the safety framework while removing an administrative burden for operational locations used temporarily.

No interaction with other exemption instruments The instrument does not refer to, amend or revoke any previous CASA exemption. It is self-contained for its three-year duration. AMOs that hold other exemptions (e.g. for emergency services or remote operations) must read them together with this instrument to avoid any inconsistency, but the instrument imposes no additional conflict-of-laws rules.

CASA EX19/26 is a new legislative instrument, signed on 24 February 2026 and commencing on 1 March 2026. It does not replace or amend any earlier exemption. No explanatory statement or accompanying regulatory impact analysis has been provided, so the precise policy motivation cannot be stated from the text of the instrument alone. What is evident from the instrument’s architecture is that CASA has identified a need for Part 145 organisations to have a clearly lawful method of performing line maintenance at locations that do not form part of their permanently approved line station network, particularly where the maintenance is temporary in nature. The instrument’s duration of three years (to 28 February 2029) suggests it may be intended as a trial or sunsetted measure, potentially feeding into future amendments to Part 145 or the MOS if the concept proves workable.

The structure of the exemption indicates that CASA considered the existing MOS provision in paragraph 145.A.75(b) (which already permits unscheduled line maintenance at any location subject to exposition conditions) was insufficient to cover the full range of temporary line maintenance needs. This instrument broadens the scope to cover scheduled line maintenance, provided it remains temporary, while requiring the AMO to establish rigorous site selection and procedural controls. The insertion of a specific information-gathering condition in section 6(e) suggests that CASA intends to monitor the use of unapproved locations actively during the exemption period.

No judicial or tribunal decisions have considered CASA EX19/26. The instrument is new and no litigation is referred to in the text. The following points are, however, areas where future controversy could arise based on the instrument’s drafting.

Interpretation of “temporary basis” The definition of “authorised maintenance” requires the maintenance to be conducted at the location on a temporary basis. The term is undefined. AMOs and CASA may disagree on whether a pattern of use crosses the line into a permanent arrangement. For example, a repeated weekly service at the same airfield over many months could be characterised as permanent in character even if each individual visit is short. The absence of a quantitative threshold (number of days, frequency, or a requirement that the location not appear on a published schedule) leaves room for regulatory friction.

The procedural “chicken and egg” trap An AMO may misread the exemption as self-executing and attempt to use an unapproved location without first obtaining CASA approval of the exposition procedures required by condition 6(b). The note to condition 6(b) makes clear that adding those procedures is a significant change under paragraph (f) of the definition, requiring approval under regulation 145.050. An AMO that bypasses this step will be in breach of both the significant change rules and the conditions of the exemption, and any maintenance performed will be unauthorised. The risk is that an AMO under operational pressure treats the exemption as an immediate permission, only to find its Part 145 privileges jeopardised.

Condition (a) and the interaction with condition (b) Condition 6(a) requires that the maintenance be “of a kind authorised by the AMO’s exposition as appropriate to be performed at an unapproved location of that kind”. This presupposes the exposition already includes such an authorisation, but the instrument does not itself mandate what words the exposition must use. If the AMO’s exposition simply states that line maintenance is appropriate for unapproved locations without explicitly linking that statement to the procedures required by condition 6(b), CASA may take the view that condition 6(a) is not satisfied. Conversely, the approval of the procedures under the significant change process will likely involve CASA examining the entire exposition package, reducing the risk of inconsistent interpretation, but only if the AMO is transparent in its application.

Privilege under section 5(2) and the conditions Section 5(2) exempts an AMO from the significant change requirement for maintenance under paragraph 145.A.75(b) of the MOS at an unapproved location. The conditions in section 6 are expressed to apply only to “the maintenance mentioned in subsection 4(1)”, i.e. authorised maintenance. On a plain reading, the conditions do not apply to the paragraph 145.A.75(b) maintenance covered by the section 5(2) exemption. This means an AMO can conduct unscheduled line maintenance at an unapproved location without complying with section 6, relying only on its existing exposition privileges and the standalone exemption. This asymmetry could create confusion: an AMO performing unscheduled maintenance at an unapproved location does not need the same site selection procedures or record-keeping specific to unapproved locations (though it must still comply with its general record-keeping obligations). An organisation that inadvertently treats all unapproved-location maintenance as subject to the same lighter regime would be non-compliant with section 6 for its authorised maintenance.

1. The exposition procedure change is not exempted. The single most dangerous trap is assuming the instrument removes the need for any CASA approval. The note under condition 6(b) confirms the opposite: adding the required procedures to the exposition is a significant change under paragraph (f) of the definition, and regulation 145.050 applies in full. An AMO must submit an application, pay any applicable fee, and obtain CASA’s written approval before it can satisfy condition 6(b). No maintenance under subsection 4(1) should be performed until that approval is granted.

2. “Temporary” is a live issue. Since the term is not defined, AMOs should set their own internal criteria (e.g. maximum number of consecutive days, maximum frequency per quarter, or a requirement that the location not be used as a scheduled line station). Any such criteria should be reflected in the site selection procedures approved in the exposition. If CASA later determines that use of a location is no longer temporary, the AMO will be outside the exemption and will have been performing maintenance at an unapproved location in contravention of CASR.

3. Authorised maintenance is narrower than “line maintenance” generally. The definition in section 3 is tied to the AMO’s exposition approval of line maintenance tasks. If the exposition approves only certain serial-number tasks as line maintenance, only those tasks may be performed under the exemption. Base maintenance, modification work, or off-wing engine maintenance are not covered. The AMO must cross-check its line maintenance capability list carefully.

4. Record-keeping procedures must be specific. Condition 6(b)(ii) requires detailed procedures for record keeping for maintenance of that kind. A generic reference to the AMO’s standard record-keeping system will not suffice if it does not address the particular challenges of an unapproved location (e.g. field data capture, connectivity, subsequent upload). The exposition must contain bespoke content.

5. Information on request,no limit on scope. Condition 6(e) enables CASA to request information relating to “any” unapproved location and “any” maintenance carried out. There is no materiality threshold. An AMO should have systems that can rapidly identify every instance of maintenance at an unapproved location, including ad hoc attendances by contracted staff, and produce the requested information. Failure to do so means the exemption was not complied with for those events, with the enforcement consequences described above.

6. The exemption expires on 28 February 2029. Any ongoing operational model that relies on the exemption must be transitioned to a permanent approval (by listing the locations in the exposition and obtaining any necessary approvals) before the repeal takes effect. If the instrument is not renewed or replaced, use of unapproved locations after the expiry date will immediately become a breach unless the AMO has regularised its exposition.

7. Interaction with other approvals. The instrument does not override any condition on the AMO’s certificate that may restrict the locations from which maintenance may be provided. If the AMO’s certificate contains a specific condition limiting line maintenance to named ports, that condition will prevail over the exemption. AMOs should check their certificate conditions against the instrument.

For an AMO that intends to rely on CASA EX19/26, the following sequential steps provide a practical compliance pathway.

Step 1: Audit the current exposition Identify whether the exposition already contains any procedures or authorisations that address maintenance at unapproved locations. If it does, assess those against the requirements of the instrument: do they cover the kind of line maintenance proposed, are they sufficiently detailed, and do they include site selection and record-keeping procedures specific to unapproved locations? If not, proceed to Step 2.

Step 2: Develop the detailed exposition content Draft amendments to the exposition that will satisfy each element of condition 6. At a minimum, include:

• A clear statement that specified categories of line maintenance (by task number or description) are authorised as appropriate to be performed at an unapproved location.
• Detailed procedures for carrying out that maintenance at such locations. These should address personnel qualifications and authorisations, tool and equipment requirements, minimum facility and environmental conditions, lighting, weather minima, aircraft ground safety, access to maintenance data, certification responsibilities, and handover procedures.
• Detailed procedures for record keeping. This must cover how maintenance records are generated, verified and preserved in a setting where the AMO’s usual IT infrastructure may not be available, including timing for entering data into the central system and maintaining data integrity.
• A site selection procedure that sets objective criteria for determining that a location is capable of supporting line maintenance and is suitable for the specific task. Criteria may include surface condition, available clearances, availability of firefighting services, security, provision of ground power or stairs, and any limitations on repeated use that preserve the “temporary” character.

Step 3: Integrate the changes into the quality and safety management systems Ensure the procedures are cross-referenced in the AMO’s quality and safety management systems, and that the systems contemplate safety risk assessments and audits of unapproved location activities. This step supports compliance with condition 6(c).

Step 4: Apply for CASA approval of the exposition change Submit an application under regulation 145.050 for approval of a significant change (paragraph (f) - change to procedures). The application should explicitly reference CASA EX19/26 and explain how the proposed exposition amendments satisfy the conditions of the exemption. Provide any supporting safety analysis, risk assessments, and evidence that the procedures are aligned with the MOS.

Step 5: Obtain CASA approval before use Do not perform any maintenance under subsection 4(1) until CASA has approved the exposition amendment. The approval letter or acceptance document should be retained as evidence that condition 6(b) is met. Confirm that the approved exposition matches the authorised maintenance scope.

Step 6: Operate within the approved framework When deploying maintenance to an unapproved location, follow the approved procedures rigorously. Verify before each deployment that:

• The task is line maintenance and is within the approved list.
• Any on-wing engine or product work is consistent with the AMO’s category B or C rating and the exposition.
• The proposed location has been evaluated using the site selection procedure and found suitable.
• The deployment is on a temporary basis; document the justification.
• Maintenance is performed in accordance with the quality and safety management systems.

Step 7: Maintain and supply records Keep all records as required by the specific record-keeping procedures. Implement a system to log every use of an unapproved location, including the date, location identifier (if any), aircraft registration, maintenance performed, and personnel involved. This log will enable compliance with condition 6(e) when CASA makes a request.

Step 8: Manage the expiry date Plan the organisation’s forward network needs well before 28 February 2029. If continued use of a location is desired, submit a permanent exposition amendment to list the location under subparagraph 145.A.70(a)10 of the MOS and remove reliance on the exemption. If the instrument is renewed or replaced, assess the new instrument against the approved procedures.

Step 9: Monitor CASA guidance CASA may issue advisory circulars or policy guidance on CASA EX19/26. AMOs should monitor such material for any refinement of the regulator’s view on “temporary basis”, acceptable site selection standards, or the information supply obligation. Incorporate any changes into the exposition through further significant change applications if required.