Civil Aviation Order 100.24 (Maintenance Authority) Instrument 2007

The instrument revolves around a small set of tightly defined administrative concepts. Each is expressed in the Order and cross-referenced to regulatory definitions where indicated.

• Maintenance authority. Defined in the Order as an "airworthiness authority to carry out maintenance on aircraft" (s 1B definition). That ties the Order to the CAR definition of airworthiness authority and to the substantive regime under regulation 33B of the Civil Aviation Regulations 1988, the statutory head of power under which this CAO is made (header).

• Aircraft engineer licence. The Order uses this term in eligibility requirements (s 1.1) and notes that it has the same meaning as in the Civil Aviation Act 1988 and the regulations (note to 1B). The licence functions here as the principal default credential that entitles applicants to be considered.

• Director. The Order references the Director in two discrete ways. First, it allows the Director to approve an exception to the licence requirement ("unless otherwise approved by the Director", s 1.1). Second, the Director is the addressee of the note that the Order is to be read with CAO 100.23 and is the authority whose approval will be decisive in issuing maintenance authorities (s 3.1 evidences the Director’s authority to issue on demonstration of competence). The Director therefore plays the central administrative decision role.

• Satisfactory evidence / adequate training / adequate practical experience / examinations / demonstrated competence. These are the qualitative thresholds the Order requires of applicants (s 1.2, s 3.1). The Order does not prescribe metrics, curricula, timeframes, or objective percentages. The words are phrases of administrative judgement that delegate assessment to CASA or the Director.

• Scope of authority. The Order explicitly contemplates granular scoping of privileges. A maintenance authority may be issued for maintenance functions certificated on a particular aircraft, or a type, series or group of aircraft, or for engines, systems or installations (s 3.2). This permits rights to be narrowly or broadly framed and signals that scope is an instrument feature.

• Application form and employer endorsement. The Order mandates a specific application form by name (s 2) and states it "should normally be endorsed by the applicant’s employer" in respect of the intended circumstances of use. "Should normally" is an advisory standard rather than an absolute precondition.

These concepts create the administrative mechanism: applicants assemble specified evidence, complete a prescribed form, and either hold an aircraft engineer licence or obtain Director approval where applicable. The Director assesses the evidence against qualitative standards and issues a scoped maintenance authority where competence is demonstrated (s 1.1-1.2; s 2; s 3.1-3.2). The Order does not define enforcement, renewal, recordkeeping or appeal procedures within its text; those items are absent from the instrument and would be governed elsewhere.

This Order affects three principal groups directly, and others indirectly.

• Applicants for maintenance authorities. The primary affected group are individuals or entities seeking an airworthiness authority to carry out maintenance on aircraft. The Order prescribes what those applicants must demonstrate: usually an aircraft engineer licence (s 1.1), satisfactory evidence of training, practical experience and examinations (s 1.2), completion of the specified application form (s 2), and demonstration of competence to perform the privileges applied for (s 3.1). Applicants for RPA maintenance authorities are treated differently; the licence requirement does not apply (s 1.1A).

• Employers of maintenance personnel. The Order states that the application "should normally be endorsed by the applicant’s employer" in regard to the circumstances in which the authority is intended to be used (s 2). That places an expectancy on employers to participate in endorsing applications, and thus affects employer administrative practices and oversight. Employers are potential certifiers of the deployment context of the authority even though endorsement is framed as normally rather than mandatory.

• The Director and CASA. The Director exercises decision-making discretion under the Order in approving exceptions to the licence requirement (s 1.1) and in issuing maintenance authorities upon demonstration of competence (s 3.1). CASA as the issuing agency is the administrative body implementing the Order. The instrument is a CASA instrument by design (1A.3 and header) and was prepared by CASA’s Legal Services Branch in the compilation note.

Indirectly affected parties include:

• Operators and owners of aircraft. The scoping options (s 3.2) mean maintenance privileges can be restricted to particular aircraft, types, engines or systems. Owners and operators will be affected by which personnel gain authorities and the scope of those authorities, because maintenance authority scope governs who can certify maintenance actions.

• Training providers and examination bodies. The Order requires applicants to show adequate training and examinations (s 1.2). Although the Order does not specify curricula, the demand for "adequately trained" applicants places compliance and certification burdens on trainers and may drive service offerings.

• RPA sector participants. Subsection 1.1A removes the aircraft engineer licence requirement for maintenance authority applicants for RPA. That change affects accessibility of authorities in the RPA market and may alter the supply of approved maintainers for RPAs.

Who pays and who decides. Applicants pay the direct costs of training, examinations, and preparing application materials, and may pay for employer time to provide endorsement. The Director (acting through CASA administrative processes) decides whether to approve exceptions and whether competence has been demonstrated (s 1.1; s 3.1). The Order does not prescribe user fees, penalties or other financial transfers within its text; it confines itself to eligibility and application mechanics.

The Order establishes a concise set of duties for applicants and corresponding administrative rights for CASA and the Director. Those duties and rights are procedural and evidentiary rather than prescriptive technical maintenance duties.

Applicant duties

• Licence duty (default). Applicants must hold an aircraft engineer licence as a precondition for a maintenance authority unless the Director approves otherwise (s 1.1). This is the principal gatekeeping duty in the instrument.

• Evidence duty. Applicants must submit "satisfactory evidence" that they have been adequately trained, have had adequate practical experience of the duties to be performed in relation to the authority, and have passed such examinations as are required or approved for the purpose (s 1.2(a)-(c)). These are continuing applicant duties at the point of application; the Order does not specify ongoing or periodic evidence after issue.

• Application form duty. Applications must be made using the named form "Application for Initial Issue or Amendment to Scope of a Maintenance Authority" (s 2). The form is the procedural vehicle and likely collects the evidence specified in s 1.2.

• Employer endorsement expectation. The application should "normally" be endorsed by the applicant's employer regarding the intended circumstances of use (s 2). This creates an expectation that applicants will secure employer engagement in the process.

Rights and administrative powers

• Right to be issued a maintenance authority. Where an applicant satisfies the requirements in s 1 and has "demonstrated competence" to perform the maintenance functions associated with the privileges endorsed in the authority, a maintenance authority "may be issued" (s 3.1). The legal entitlement is therefore conditional on satisfying the Order’s requirements and demonstrating competence.

• Scope specification right. A maintenance authority may be issued for a particular aircraft, or a type, series or group of aircraft, engine, systems or installations (s 3.2). That gives applicants the right to obtain narrowly or broadly scoped privileges, dependent on the evidence and competence demonstrated.

• Director’s approval power. The Director may approve exceptions to the licence prerequisite (s 1.1). This is an administrative discretion enabling case-by-case departures from the default licence duty.

Operational duties not specified

• The Order does not set duties relating to renewal, suspension, cancellation, recordkeeping, the content of "competence" tests, or continuing professional development. Those matters are not detailed in the instrument and therefore are not obligations within this CAO text. Any such duties must be found elsewhere in the regulatory framework or in CASA policy.

The form of duties (qualitative evidentiary standards, employer endorsement expectation, Director discretion) allocates the practical compliance burden to applicants and employers while retaining assessment and final issuance as administrative decisions performed by the Director/CASA. The Order frames rights to receive an authority as contingent on administrative assessment of competence and evidence rather than as automatic upon meeting defined numeric criteria.

The Order itself contains no penal provisions, specified sanctions, or express enforcement mechanisms. It does not create offences nor specify penalties for non-compliance within its text. It sets eligibility criteria and procedural steps for issuance of maintenance authorities but does not describe what happens if someone acts outside an issued authority, nor does it prescribe administrative sanctions such as suspension, cancellation or fines.

What the instrument does provide, and how enforcement is implicated, is limited to administrative discretion and gateway control. The Director has the capacity to approve exceptions to the licence requirement (s 1.1) and to issue an authority where competence is demonstrated (s 3.1). Those clauses vest CASA with gatekeeping power: control over who holds maintenance authority is the primary enforcement lever implicit in the Order.

Because the Order does not set penalties or enforcement processes, enforcement of compliance with maintenance authority requirements falls outside the instrument and must instead be located in other parts of the Civil Aviation Act, the Civil Aviation Regulations, or CASA regulatory practice. The Order’s silence on penalties means two practical consequences for operators and applicants:

• Enforcement through licencing and authorisation. The main practical enforcement mechanism is prospective: only those issued authorities under the Order are entitled to the privileges; CASA can deny, limit or refuse to issue authorities based on the evidentiary criteria (s 1.2; s 3.1). This is a preventive control rather than a prescribed sanction post-breach.

• Reliance on broader regulatory regime for sanctions. Actions for individuals or organisations who operate without the proper authority, or who misrepresent evidence in applications, would be addressed under other instruments or legislative provisions outside this Order. The Order gives no procedural detail on investigations, notice, appeals, or administrative review.

Given the Order’s administrative focus, practitioners concerned with penalties and enforcement must consult the Civil Aviation Act 1988 and the CAR for statutory offence provisions and CASA’s enforcement policies. The Order itself is silent on appeals and does not define how the Director’s discretionary approvals might be reviewed. The absence of internal enforcement detail increases the importance of cross-referencing the broader aviation regulatory regime when advising clients on enforcement risk.

The Order expressly situates itself within the broader regulatory framework and links to other instruments and statutory definitions. The text contains explicit cross-references and notes that signal where substantive requirements and definitions are located.

• Regulation 33B of the Civil Aviation Regulations 1988. The instrument header states it is made under regulation 33B of the CAR. That identifies the statutory power permitting CASA to issue such an instrument. The Order’s substantive effect must therefore be read as an instrument exercising the authority conferred by regulation 33B.

• Definitions in the Civil Aviation Act and regulations. The Order notes that certain terms have the same meaning as in the Civil Aviation Act 1988 and the regulations (note to 1B). It specifically points to regulatory definition of "airworthiness authority" in regulation 2 of the CAR by noting that maintenance authority means an airworthiness authority and that airworthiness authority is defined in regulation 2 of CAR (1B note). This creates a dependency: the Order’s defined terms draw meaning from the Act and the CAR.

• Relationship with CAO 100.23. The Order contains a note directing reading in conjunction with Civil Aviation Order 100.23 (note after s 1A.3). That indicates the two CAOs form a pair or a linked set and that obligations or definitions relevant to maintenance authorities may be present in CAO 100.23.

• Application of named forms and CASA instruments. Section 2 mandates a form by precise title. The instrument is itself a CASA instrument (1A.3), so the named form and any accompanying CASA guidance, checklists, or processes issued under CASA authority will interact operationally with the Order’s requirements.

• Amendment instruments and legislative history. The compilation note and Table of Amendments show that this CAO has been amended multiple times, most recently by the CAOs 100.23 and 100.24 Amendment Instrument 2026. Those amendments altered subsections and introduced a specific carve-out for RPA applicants (see Table of Amendments and s 1.1A). Practitioners must therefore read the instrument as amended and consult the amendment instrument texts and the CAR for contemporaneous changes.

Because the Order does not itself specify enforcement measures, renewal, appeals or other procedural safeguards, those matters will be governed by the Civil Aviation Act, applicable regulations and CASA policy instruments. The Order’s cross-references place it as an administrative node that depends on definitional and enforcement scaffolding in the Act and the CAR, and operational detail in other CAOs such as 100.23 and in CASA administrative forms and guidance.

In practice, advisers and compliance officers must treat this instrument as one link in a chain: it sets eligibility and scoping mechanics but presupposes statutory offence regimes, evidence standards, and administrative review mechanisms contained in the broader aviation legislative framework. The Director’s approval powers in s 1.1 and s 3.1 are exercised within that larger statutory environment.

The compilation and the embedded Table of Amendments provide the instrument’s amendment chronology through to March 2026. The compilation was prepared on 26 March 2026 and expressly states it takes into account amendments up to the Civil Aviation Orders 100.23 and 100.24 Amendment Instrument 2026. The Table of Amendments identifies three primary instrument events.

• Original instrument: CAO 100.24 Instrument 2007. The table records the original CAO 100.24 Instrument 2007, registered 17 December 2007 and commencing on 18 December 2007 (Table of Orders). This is the originating instrument for the CAO title and initial provisions.

• Amendment in 2011: CAO 100.24 2011 No. 1. The table records an amendment instrument dated 22 June 2011 and commencing 27 June 2011. The Table of Amendments notes that subsection 1 had been amended by CAO 100.24 2011 No. 1, although the compilation does not reproduce the 2011 text in isolation. The entry in the Table of Amendments summarises "subs. 1 am. CAO 100.24 2011 No. 1" indicating a prior adjustment to the eligibility subsection.

• Comprehensive amendment in 2026: CAOs 100.23 and 100.24 Amendment Instrument 2026. The most recent entry is an amendment instrument registered 25 March 2026 and commencing 26 March 2026. The Table of Amendments shows a series of changes attributed to F2026L00317. The 2026 instrument:

  • Replaced the prior CAO 100.24 Instrument 2007 as indicated by "s. 100.24 rs. CAO 100.24 Instrument 2007".
  • Repealed the "Note before subs. 1" (not further reproduced) as "rep. F2026L00317".
  • Added subsections marked 1A and 1B (ad. F2026L00317).
  • Amended subsections 1, 2 and 3 (subs. 1 am., subs. 2 am., subs. 3 am. F2026L00317).

Operationally, the major textual changes visible in the compilation are the insertion of s 1.1A, which explicitly states that the licence requirement in s 1.1 does not apply to applicants for a maintenance authority that is for maintenance on RPA (s 1.1A). The Table of Amendments marks this insertion as part of the 2026 amendment package. The compilation’s Note to CAO 100.24 also includes a Table of Orders summarising the dates of registration and commencement for each instrument in the chain: 2007 original, 2011 amendment, and 2026 amendment instrument.

For practitioners this history shows a CAO that has been periodically revised, with the 2026 amendment effecting substantive structural changes (replacement of the 2007 text and addition of new subsections). The compilation’s explicit cross-references to amendment identifiers (F2026L00317 and F2011L01190) provide traceability to the amending instruments for those requiring the detailed amendment texts or legislative instruments on FRLI. The compilation does not, within its own text, set out transitional, saving or application provisions beyond the table entries; the Table of Orders shows no explicit transitional provisions recorded in the compilation.

The instrument as compiled contains no judicial decisions, case citations, or a litigation history. The text does not reference any court decisions, nor does it include any section summarising judicial interpretation or precedent. The Table of Amendments records only administrative amendment instruments and dates, not litigation.

The absence of litigation references in the text has implications for legal advisers and compliance professionals. Specifically:

• No instrument-level judicial interpretation. Since the CAO itself contains no case citations and no litigation history, practitioners cannot rely on judicially articulated definitions, standards, or applications of the specific phrases used in this CAO (for example, "adequately trained", "adequate practical experience", "satisfactory evidence", or "demonstrated competence") from within this instrument. Any authoritative interpretation would have to be sourced from other parts of the statutory regime if cases exist there, or from administrative decisions or CASA guidance.

• Reliance on administrative decision records and regulatory guidance. In practice, interpretation and operational application of the qualitative standards in ss 1.2 and 3.1 is likely to be found in CASA administrative determinations, internal guidance, or policy instruments rather than in judicial determinations referenced in this CAO. The CAO does not itself create a body of precedential decisions.

• Potential uncertainty where statutory phrases are qualitative. The instrument’s use of qualitative evidence standards without numeric thresholds (see s 1.2 and s 3.1) means that in the absence of instrument-level case law, decision-makers and applicants must ground expectations on CASA practice and Director decisions. Where disputes arise about whether sufficient evidence was presented or whether competence was demonstrated, resolution would proceed under the broader administrative law framework and relevant statutory appeal or review routes, none of which are specified in this CAO.

For these reasons, advisers should treat the CAO as setting procedural eligibility points and look to CASA's application processing records, policy documents, or other statutory materials for examples of how the qualitative thresholds are applied in practice. Where contentious decisions occur, the CAO itself does not record outcomes or settled judicial positions; any litigation involving the application of these provisions would have to be identified outside this instrument.

Several features of the Order can produce compliance traps, interpretive uncertainty, or operational friction. These are concrete mechanics in the text that practitioners should note.

• Qualitative standards without objective metrics. Section 1.2 requires "satisfactory evidence" of "adequate" training and "adequate practical experience" and passing "such examinations ... as are required or approved." These are qualitative, delegated standards without published quantitative thresholds in this CAO. Without defined timeframes, curriculum benchmarks, or pass marks in the instrument itself, applicants may find acceptance depends heavily on CASA discretionary judgement and the Director’s interpretation.

• "Should normally be endorsed" is expectation not obligation. Section 2 states the application form "should normally be endorsed by the applicant’s employer" in regard to intended use. The word "should" sets an expectation but not an absolute prerequisite. That creates uncertainty for applicants without employer support; it signals difficulty may be encountered but does not definitively prevent grant. Practitioners should not assume the absence of endorsement is fatal, but should note the likely evidentiary and practical consequences.

• Director discretion to waive licence requirement. Section 1.1 permits the Director to approve exceptions to the default licence requirement. The instrument does not prescribe criteria or process for seeking that approval. Applicants relying on a waiver must engage with the Director and cannot assume a standardised, transparent pathway unless CASA provides separate guidance.

• RPA carve-out changes access. Section 1.1A excludes applicants for RPA maintenance authorities from the licence requirement. That creates a differential treatment between conventional aircraft maintenance and RPA maintenance. The carve-out may increase accessibility for the RPA sector but also means different competency baselines will apply across sectors. The CAO does not specify alternative competency metrics for RPA applicants within its text.

• No renewal, recency or CPD provisions. The Order does not address duration of a maintenance authority, renewal criteria, recency-of-experience requirements, currency checks, or continuing professional development obligations. Absent these provisions, the scope and lifespan of an issued authority is unclear from the instrument alone.

• No enforcement or appeal mechanics in the CAO. The Order contains no penalties or prescribed appeal processes. If an application is refused, or an authority is suspended or cancelled under other instruments, the CAO provides no local procedural specifications. Practitioners must look beyond the CAO for remedies and consequences.

• Scope can be narrowly tailored. Section 3.2 allows authorities to be confined to a particular aircraft or limited groups of types, engines, systems or installations. This means applicants may receive only narrowly framed privileges, which can constrain operational deployment of maintenance personnel and require multiple authorities for varied fleets.

• Application form specificity. The CAO requires a particular form by title (s 2). Using an incorrect form or an incorrectly completed form risks delay or rejection; practitioners should ensure the exact named form is used.

• Amendment history and replacement. The 2026 amendment replaced the 2007 instrument and altered subsections. Practitioners relying on historical practice must confirm they are working with the current, compiled text. The Table of Amendments references F2026L00317; reliance on obsolete text could misstate eligibility conditions.

These "gotchas" are structural features of the text rather than external policy risks. They mostly derive from qualitative standards, discretionary clauses and omissions. Addressing these requires engagement with CASA processes, securing employer endorsement where practicable, preparing comprehensive evidence packages for training and experience, and where applicable seeking Director approval in advance of application.

Compliance under this CAO is procedural and evidence-focused. The Order prescribes the steps and the kinds of proof required to obtain a maintenance authority. A practical compliance pathway consistent with the instrument’s text is as follows.

1. Confirm the target activity and whether the licence duty applies. Determine whether the maintenance authority sought is for RPA. If it is for RPA, s 1.1A states that the aircraft engineer licence requirement in s 1.1 does not apply. For non-RPA maintenance authorities, the default position is that applicants must hold an aircraft engineer licence (s 1.1). If an applicant does not hold such a licence but believes they have equivalent competence, they must engage with the Director for an approval, because s 1.1 allows exceptions "unless otherwise approved by the Director."

2. Assemble satisfactory evidence as required by s 1.2. Prepare documentary evidence demonstrating:

   • Adequate training for the maintenance authority sought (s 1.2(a)).
   • Adequate practical experience of the duties to be performed (s 1.2(b)).
   • Results of required or approved examinations relevant to the authority (s 1.2(c)). Since the CAO does not specify precise standards, provide comprehensive evidence such as course certificates, supervised practical logs, employer attestations, examination results and any other supporting documentation that speaks to training, experience and examinations.

3. Use the specified application form. Complete the form titled "Application for Initial Issue or Amendment to Scope of a Maintenance Authority" as mandated by s 2. Ensure the form is completed accurately and contains the evidentiary attachments required by s 1.2. Using any other form risks administrative delay or rejection.

4. Seek employer endorsement where available. Section 2 states the application "should normally be endorsed by the applicant's employer" regarding the circumstances in which the authority will be used. Where possible, obtain a formal employer endorsement describing the duties, aircraft types and operational contexts in which the authority would be exercised. Where an employer is unable or unwilling to endorse, document the reasons and include alternative evidence of intended use or independent client arrangements.

5. Demonstrate competence for scoped privileges. Section 3.1 requires demonstration of competence "to perform the maintenance functions associated with the privileges endorsed in the authority." Prepare evidence and, if requested, arrange assessments, practical demonstrations or supervised checks that align with the scope sought. If seeking a broad scope under s 3.2 for types, series or groups, provide evidence specific to each scope element.

6. If licence waiver is necessary, engage the Director early. Where an applicant lacks an aircraft engineer licence and is not an RPA applicant, s 1.1 allows Director approval. Approach the Director or CASA case officer early to identify the process, criteria and evidentiary needs for approval. Document submissions addressing equivalence to the licence requirement.

7. Anticipate scoped issuance. Understand that a maintenance authority "may be issued" only for the privileges demonstrated. Expect possible limitations to a particular aircraft, type, series, engine, system or installation (s 3.2). If the applicant seeks multi-type privileges, prepare evidence for each.

8. Retain records and check for related obligations. While the CAO does not specify ongoing recordkeeping, applicants should retain training records, experience logs, exam results and employer endorsements. Because enforcement and penalties are outside the CAO text, maintaining comprehensive records will be necessary if challenged under other parts of the aviation regulatory framework.

9. Monitor CASA guidance and related CAOs. The CAO is to be read with CAO 100.23 (note to 1A). Practitioners should check CASA's current forms, published guidance and CAO 100.23 for procedural details not contained in this instrument. Also confirm whether CASA has published criteria or checklists that operationalise the qualitative standards in s 1.2 and s 3.1.

10. Prepare for administrative discretion. Decisions on sufficiency of evidence and competence demonstration are matters for the Director and CASA. Prepare submissions that are factual, well-documented, and targeted at the qualitative standards in the CAO. Where a decision is refused, pursue any available administrative review or appeal processes in the broader legislative framework, noting that those processes are not specified in this Order.

Following these steps aligns practice with the Order’s textual requirements. The central compliance elements are possession (or Director-approved exemption) of an aircraft engineer licence where required, robust documentary evidence of training and practical experience, correct use of the named form, employer endorsement where available, and demonstrable competence matched to the scope sought.