Part 66 Manual of Standards Amendment Instrument 2016 (No. 5)

The instrument operates by amending the Manual of Standards for Part 66 (aircraft maintenance engineer licences and related training and competency matters). The central conceptual points in the draft are: standardisation of definitions, clarification of examination and training pathways, additional transitional entitlements, codification of what unit competencies map to which licence privileges, and specification of who may deliver, manage and have approvals for particular training and OJT.

Definitions now added or clarified in section 66.5 include operationally relevant terms. For example, APU is defined as auxiliary power unit, ATA refers to the Air Transport Association of America and is flagged as a commonly used standard publication, and MEA is defined as manufacturing and engineering assessment and flagged as part of the code for nationally endorsed Australian training packages (Schedule 1, item [2]). The inclusion of a COA holder definition identifies a group of organisations (those holding certificates of approval under regulation 30 of CAR 1988) that are expressly able to feature in later training arrangements (see Appendix VII change, item [27]).

Examination and training are reframed. Paragraph 66.A.25(b) now requires that knowledge for licence applicants be demonstrated by an examination “conducted by an MTO” and in accordance with Appendix II or otherwise approved in writing by CASA; the instrument also adds a rule that dash applicability symbols in table rows indicate that knowledge is not required for that category (items [19] and [20]). This ties examination delivery and content explicitly to MTOs and CASA-approved syllabi, making MTOs central to formal knowledge assessment.

OJT is given tighter controls. The substituted paragraph 66.A.55(c) mandates that OJT may only be conducted and managed by maintenance organisations or MTOs approved by CASA, that OJT be supported by a detailed syllabus and recorded in worksheets or logbooks, and that OJT “must be assessed and approved by CASA” (item [25]). The explanatory note indicates CASA’s assessment and approval are guided by Appendix II of the Part 66 Acceptable Means of Compliance document and specific advisory circulars.

Competency mapping is formalised in the replacement Appendix IV and the extensive Appendix VIII table. Appendix IV sets out MEA and other competency units required for categories and subcategories of licences, with explicit X markers indicating the units required for each category, including multiple B1 and B2 subcategories (item [26]). Appendix VIII maps competency units required to remove exclusions E1-E44 (and others) for specific licence categories; it is presented as a large table matching MEA units to labelled exclusions (item [29]).

Transitional and limited grandfathering measures are included. Subparagraph 66.A.20(a)5A grants specific certifying privileges to people who satisfied certain MOS paragraphs between 27 June 2015 and 3 July 2020 and who, but for the repeal of a regulation, would have qualified for earlier ratings; the text itemises the maintenance activities those persons may perform and certify (item [13]). The instrument’s own transitional clause similarly preserves entitlement to new versions of units where a person was immediately entitled to an earlier version (cl 3).

Finally, Appendix IX receives a series of editorial corrections and additions to the Type Certificate holder tables, in some cases inserting additional aircraft/engine combinations and correcting nomenclature (items [30]-[46]).

The instrument affects a set of specific stakeholders identified in the MOS and the amendments:

• Individual licence holders and licence applicants: The amendments change the mapping between competency units and licence categories in Appendix IV and the process for removing exclusions in Appendix VIII (items [26] and [29]). Licence applicants will need to satisfy the revised examination and unit requirements under paragraph 66.A.25(b) (item [19]) and may be affected by the insertion of the dash applicability rule in 66.A.25(ba) (item [20]). The added transitional subparagraph 66.A.20(a)5A directly affects persons who satisfied certain MOS requirements in the period between 27 June 2015 and 3 July 2020 by granting potential certifying privileges if issued a Category B1 licence (item [13]).

• Maintenance training organisations (MTOs): MTOs are explicitly required to conduct examinations (66.A.25(b) substitution) and to deliver OJT only where approved by CASA (66.A.55(c) substituted). The MOS now ties examination conduct to MTOs and requires detailed syllabuses, recorded worksheets or logbooks and CASA assessment and approval of OJT (items [19], [25]). MTOs will have to align course content, examination processes and record-keeping with Appendix IV, Appendix VIII and Appendix II guidance.

• Approved maintenance organisations (AMOs), Part 145 organisations and COA holders: The instrument modifies paragraph 66.A.45(h) and 66.A.55(c) to permit certain AMOs (Appendix references) and COA holders to perform or manage training where consistent with Part 145 MOS or CAR 30 criteria (items [24] and [25]). Appendix VII is modified to add COA holders approved for excluded systems training (item [27]). Consequently, AMOs and COA holders seeking to provide excluded-systems training must obtain appropriate approvals from CASA.

• Employers and certifying engineers: Employers who rely on staff certifying release-to-service will need to map staff competencies against the new Appendix IV and Appendix VIII tables, and where employees rely on the transitional 66.A.20( a )5A privileges, employers must be aware of the limited scope of permitted certification work (items [13], [26], [29]).

• CASA and the Director of Aviation Safety: CASA is given explicit assessment and approval responsibilities for OJT (66.A.55(c)(3) as substituted) and for any written approvals regarding examination and syllabus content (66.A.25(b)). CASA’s role as assessor and approver is made operationally explicit across the amendments (items [19] and [25]).

• Providers and maintainers of specific aircraft types: Changes to Appendix IX (items [30]-[46]) that correct type rating entries or insert new engine/type combinations will affect the mapping of type ratings to licences and endorsements, and thus influence who may be authorised to certify maintenance on particular aircraft types.

Who pays: The instrument itself does not impose explicit monetary fees, but the practical effects flow resource costs to licence applicants and employers (training time, course fees, examinations and paperwork), and to CASA (assessment and approval workload). Those costs arise from the MOS requirements the instrument introduces or clarifies, for example CASA assessment of OJT and MTO-conducted examinations (items [19], [25]). The instrument sets the rules; the financial consequences fall on the operational actors who must implement them.

Who decides: the Director of Aviation Safety made the instrument under regulation 66.015 (signature and authority at the front of the instrument). Operational decisions under the amended MOS (approvals, assessments, and written approvals) are allocated to CASA by the amended paragraphs (notably 66.A.25(b) and 66.A.55(c)).

This instrument amends duties and grants limited rights by reference to the MOS text it alters. Below are the key operational duties and rights created or clarified by the amendments, with section references to the schedule items.

Duties on MTOs and approved organisations

• Conduct examinations: Paragraph 66.A.25(b) (substituted by item [19]) requires an applicant to “demonstrate by examination, conducted by an MTO, knowledge” of the applicable subject modules and items to the corresponding level of knowledge and in accordance with Appendix II or as otherwise approved in writing by CASA. The duty implicit in that text is that MTOs must deliver and administer these examinations to the levels required by Appendix I Part 3 and Appendix II (item [19]).
• Deliver OJT only if approved: Paragraph 66.A.55(c) (substituted by item [25]) requires that on-the-job training may only be conducted and managed by a maintenance organisation, or a maintenance training organisation, approved by CASA to undertake such training. The OJT must be supported by a detailed syllabus, have completion recorded in detailed worksheets or logbooks, and “must be assessed and approved by CASA.” This creates a duty to prepare syllabus materials, maintain records and submit OJT arrangements to CASA for assessment.

Duties on CASA

• Assess and approve OJT: Under substituted 66.A.55(c)(3) CASA must assess and approve OJT programs (item [25]).
• Approve examination/knowledge arrangements: Paragraph 66.A.25(b) conditions knowledge demonstration to be in accordance with Appendix II or “as otherwise approved in writing by CASA.” CASA therefore has a duty to consider and respond to requests for written approvals of alternative arrangements, and the right to approve or withhold such arrangements (item [19]).
• Guide assessments: A Note in item [25] records that CASA’s assessment and approval are guided by Appendix II and Advisory Circular AC 66‑07, indicating that CASA will use those documents as the framework for assessing OJT.

Rights of individuals under transitional rules

• Entitlement to new units: Clause 3 creates a transitional right that if a person was entitled to a unit of competency mentioned in Appendix IV or VIII immediately before commencement and on commencement that unit is replaced by a new version, the person is entitled to the new unit. This is a direct right preserving competence entitlement across versions (cl 3).
• Limited certification privileges for certain historical qualifications: Paragraph 66.A.20(a)5A (inserted by item [13]) gives persons who fulfilled specified MOS paragraphs between 27 June 2015 and 3 July 2020 and who would have qualified under then-applicable regulations the right, when issued a Category B1 licence, to perform maintenance certifications and issue certificates of release to service for a narrowly specified list of maintenance activities on aircraft approved for VFR operations only (items [13], (iv)-(vi)).

Licensing and mapping duties/rights

• Units required for licence categories: Appendix IV (replaced by item [26]) sets the units of competency required for categories and subcategories of licence. This is prescriptive: applicants and employers must ensure the required units are held or obtained to secure the licence privilege for a category/subcategory identified in the table.
• Removal of exclusions: Appendix VIII (substituted by item [29]) establishes which units are necessary to remove particular licence exclusions E1-E44, and maps them to licence categories. That table creates a clear procedural right: if the person completes the listed units, they meet the MOS requirement for removal of the exclusion as per the MOS.

Other duties: The instrument contains multiple editorial amendments that change words such as “condition of” to “condition and” (items [12], [16]) or substitute single words to clarify meaning (item [9]), which impose duties on drafting/practice to interpret the MOS according to the new textual formulations.

Rights and duties not changed here: The instrument does not itself create new penalty provisions nor purport to alter the CASR penalty regime. The instrument is limited to MOS amendments and transitional entitlements. Enforcement and sanctions for non-compliance continue to be located in the governing statutory and regulatory framework; the instrument itself does not specify new monetary duties or criminal penalties.

The instrument does not create new penalty provisions within its text and does not directly specify enforcement mechanisms or sanctions. It is a Manual of Standards amendment instrument made under regulation 66.015 of CASR 1998 (instrument preamble). The MOS is a standards instrument that sets minimum requirements and guidance for meeting the Part 66 regulatory regime. The amendment instrument updates the MOS; it does not include new criminal or civil penalty clauses.

What the instrument does specify that relates to enforcement or oversight:

• CASA assessment and approval obligations: The substituted paragraph 66.A.55(c) requires that OJT “must be assessed and approved by CASA” (item [25]). This places an administrative oversight duty on CASA and implies an enforcement mechanism through approval and withdrawal of approvals. The instrument does not specify the sanctions, but the requirement implicitly empowers CASA to accept or not accept OJT programs.
• Examination approvals and CASA written approvals: Paragraph 66.A.25(b) ties examination arrangements to Appendix II or “as otherwise approved in writing by CASA” (item [19]). CASA’s discretion to approve or reject alternative arrangements functions as an administrative control; the instrument does not specify the outcome for failing to obtain approval, but in practice MOS non‑compliance would be addressed under the broader regulatory enforcement provisions.

Limitations and where to look for enforcement detail:

• The MOS amendments do not replace or modify the Civil Aviation Safety Regulations 1998 (CASR) enforcement or penalty provisions explicitly. Any penalties, licence suspensions, enforcement notices or sanctions would be applied under the CASR or other relevant statutory provisions, not by this MOS amendment instrument itself.
• The instrument’s transitional entitlement (cl 3) and the inserted 66.A.20(a)5A (item [13]) grant certain rights but do not include enforcement schedules for misuse. If a person purports to exercise rights without a required CASA approval or without meeting the MOS as now set, enforcement action would flow from the regulatory rules and CASA’s oversight of licences and approvals.

Practical enforcement mechanism (as implied by the MOS changes):

• CASA’s assessment/approval role, coupled with MTO obligations, creates administratively enforceable checkpoints: MTO-conducted examinations and CASA-approved OJT are gatekeeping processes. CASA can withhold approval, require remediation or refuse to recognise OJT or test results, thereby blocking licence issuance or removal of exclusions. The instrument sets those checkpoints but not the caseload or sanction rules.

In short, the instrument establishes standards, approvals and administrative controls but does not itself create penalty clauses. Enforcement and sanctions remain matters of the regulatory regime (CASR and other aviation orders), which continue to govern penalties for non‑compliance.

This instrument is made under regulation 66.015 of the Civil Aviation Safety Regulations 1998 (CASR) and therefore sits subordinate to CASR and to any acts that give rise to CASR. The preamble states that the Director of Aviation Safety makes the instrument on behalf of CASA under regulation 66.015. The MOS amendments therefore have effect only insofar as they implement Part 66 requirements consistent with CASR.

Directly referenced instruments and laws within the text:

• CAR 1988: The definition of COA holder references a certificate of approval under regulation 30 of CAR 1988 (Schedule 1, item [2]). That cross-reference incorporates a relationship between the old CAR regime and MOS definitions for COA holders.
• CASR 1998 transitional references: The inserted subparagraph 66.A.20(a)5A (item [13]) refers to the operative date of regulation 31 of CAR 1988 (27 June 2015) and to the repeal date of regulation 202.345 of CASR 1998 (3 July 2020) as background for the transitional qualification. Those references indicate that the MOS modifications interact with transitional provisions in CASR and in prior CAR instruments. The MOS therefore relies on the historical operation and repeal of certain regulations to create specific entitlement pathways.
• Part 145 MOS and Civil Aviation Order 104.0: Paragraph 66.A.45(h) as substituted (item [24]) explicitly references an AMO in accordance with section 145.A.37 of the Part 145 MOS, and COA holders in accordance with Civil Aviation Order 104.0 (Certificates of approval , application, grant and conditions), tying the Part 66 MOS roles to maintenance organisation approvals under Part 145 and to CAR 30 COA governance.

Operational interaction points that practitioners must consider:

• Where the MOS requires CASA assessment and approval (for OJT or MTO arrangements), CASA’s powers and duties under CASR and related aviation orders will determine procedural requirements, fees and timelines. The instrument itself defers to CASA for approvals and guidance under Appendix II and relevant advisory circulars (item [25]).
• The MOS changes do not, within this instrument, alter the CASR statutory licence framework but may affect the practical steps applicants must take under CASR to obtain, maintain or extend licence privileges. For example, the substitution of 66.A.25(b) requires MTO-conducted examinations and Appendix II compliance; these are standards that support the regulatory tests used to administer CASR licences.
• The instrument’s transitional entitlement clause (cl 3) and the 66.A.20(a)5A insertion reference prior and repealed regulations; practitioners must therefore consider the interplay of the MOS with the historical regulatory framework , i.e., whether a person’s prior entitlement derived from CAR 1988, the now-repealed regulation or CASR transitional rules. The instrument treats these prior regimes as background facts for entitlement, not as superseded law by itself.

What the instrument does not do:

• It does not purport to amend CASR itself, nor to change the penalties or enforcement powers that the CASR confers. It is an MOS amendment instrument meant to align the MOS with current operating expectations and to record transitional outcomes in light of previous regulatory changes.

In summary: this MOS amendment interacts administratively with Part 145 MOS, Civil Aviation Orders (notably CO 104.0 and historical CAR 1988 provisions), and CASA’s approval powers under CASR. It relies on CASA’s regulatory role under CASR to operationalise the standards.

This particular instrument is identified as Part 66 Manual of Standards Amendment Instrument 2016 (No. 5) and is dated 25 August 2016, signed by Mark Alan Skidmore, Director of Aviation Safety (front matter). It states it is made under regulation 66.015 of the Civil Aviation Safety Regulations 1998 and commences on the day of registration (clauses 1 and 2).

The instrument effects its changes by amending the Part 66 MOS via Schedule 1. The Schedule is structured as numbered line items that either insert, substitute, omit, or otherwise re-letter or reformat specific MOS provisions and Appendices. Relevant cataloguing of the Schedule items shows the instrument addresses both small editorial corrections (for example, changes to nomenclature such as “MD 717-200 (RRD BR700‑715)” or insertion of punctuation) and substantive standard changes (for example, substitution of 66.A.25(b) and 66.A.55(c), and replacement of Appendices IV and VIII). Schedule item numbers range from [1] to [46], with clusters of significant content at items [13], [19], [25], [26], [27] and [29], among others.

Notable internal amendment history items in this instrument include:

• Item [2] inserts and defines a set of terms in section 66.5, updating the MOS lexicon used throughout later provisions.
• Items [3] and [4] insert new Part 2 wording and re-letter existing paragraphs in 66.A.4.
• Item [13] inserts subparagraph 66.A.20(a)5A, a transitional provision linked to dates for prior regulatory regimes (27 June 2015 and 3 July 2020).
• Items [19] and [20] substitute paragraph 66.A.25(b) and add a clarification subparagraph 66.A.25(ba) regarding the dash symbol in applicability tables.
• Item [25] substitutes paragraph 66.A.55(c) to restrict OJT delivery and require CASA assessment/approval.
• Items [26] and [29] substitute Appendix IV and Appendix VIII respectively, replacing competency unit tables with revised mappings.
• Items [30]-[46] make a range of corrections and insertions to Appendix IX Type Certificate holder tables, including the addition of a Boeing 747-400(PW 4000) entry and various nomenclature corrections.

The instrument’s own transitional provision (cl 3) creates a self-contained amendment history effect: it preserves entitlement to replaced units of competency by entitling a person to the new version if they were entitled to the previous version immediately before commencement.

The instrument therefore constitutes a discrete amendment event to the MOS as of 25 August 2016. The Schedule shows a mix of drafting corrections, re-labelling and substantive standard changes that, as a package, update training, examination and certification modalities for Part 66 in the MOS.

The instrument itself does not record any litigation history. It is a standards-amendment instrument and contains no references to court decisions, administrative appeals or litigation outcomes. There are no cases named in the instrument. The MOS changes are administrative and standards-based; the instrument does not include judicial determinations or adjudicative findings.

From the instrument’s content, the conceivable pathways for legal challenge would be external to the instrument: if a person or organisation were aggrieved by a CASA decision arising from application of the amended MOS (for example, a refusal to approve an OJT program, or a decision not to accept an MTO examination), those disputes would be handled under the relevant judicial or administrative review mechanisms existing under CASR and general administrative law. The instrument itself does not specify appeal routes or judicial review processes.

What the instrument does show, however, is where litigation or administrative review might arise:

• CASA assessment and approval of OJT programs is mandatory under the substituted 66.A.55(c) (item [25]). If CASA refused approval or revoked an approval, an affected maintenance organisation or MTO might have grounds for administrative review.
• Paragraph 66.A.25(b) ties examinations to MTO-conducted processes and CASA approvals (item [19]); disputes could arise over the adequacy of an MTO’s examination or CASA’s assessment of equivalence for alternative arrangements.
• Transitional entitlements and interpretation of the dash symbol in applicability tables (66.A.25(ba) inserted at item [20]) could give rise to interpretive disputes between applicants and CASA about whether a given subject or item is required for a particular licence category.

The instrument provides no record of litigation to date. Practitioners seeking litigation history must search court and tribunal records, and administrative appeal records, for cases involving CASA and Part 66 MOS application. Those resources are not contained in this amendment instrument.

The instrument contains several textual and structural changes whose operational effects may be easy to miss. Practitioners should be attentive to these items when advising clients or preparing compliance plans.

1. Dash applicability rule (66.A.25(ba))

• The instrument inserts a new subparagraph that states: “Where the applicability symbol - (a dash) - appears in a row of a column of the table in Part 3 of Appendix I that is for a licence category or subcategory, knowledge of the subject or item mentioned in the same row is not required for the category or subcategory (as the case may be)” (item [20]). If users of the MOS fail to notice this change they may mistakenly require candidates to learn items explicitly marked with a dash. The dash now has a negative rule meaning. Practically, syllabus development and exam design by MTOs must take the dash into account.

2. Examination must be conducted by an MTO (66.A.25(b))

• The substituted paragraph requires that the applicant “must demonstrate by examination, conducted by an MTO, knowledge” of specified subjects (item [19]). This tightens the locus of examination authority and affects candidates who previously expected alternative examination providers or self-assessments. If an applicant relies on an unapproved examination provider, CASA may not accept the result.

3. OJT restricted to CASA‑approved organisations and subject to CASA assessment

• The new wording of 66.A.55(c) limits OJT to maintenance organisations or MTOs approved by CASA, requires detailed syllabuses and recorded worksheets or logbooks, and requires CASA assessment and approval (item [25]). Organisations that previously provided informal OJT may now be excluded unless they secure CASA approval and create the documentary apparatus. The MOS Note points to Appendix II and Advisory Circular AC 66-07 as guidance, which implies a procedural standard that organisations must meet.

4. Transitional 66.A.20(a)5A is narrow in scope

• The inserted subparagraph 5A applies to persons who satisfied particular MOS paragraphs in a particular historical window (27 June 2015 to 3 July 2020) and who, “but for the repeal of regulation 31”, would have qualified for specific former ratings. It then permits issuance of a Category B1 licence and authorises limited certification for VFR-only aircraft and specified systems (iv)-(vi) (item [13]). This is a narrow grandfathering clause; practitioners must verify that an individual’s prior qualifications fall precisely within the MOS paragraphs and dates. Misreading or over-broad reliance on 5A could produce unauthorised certifications.

5. Replacement of Appendix IV and Appendix VIII

• Appendix IV (units required for categories) and Appendix VIII (units for removal of an exclusion) are substantially replaced (items [26] and [29]). The new tables are dense and use specific unit codes and cross-references. Misaligning staff records to the previous appendices may cause organisations to wrongly conclude a person is qualified for a licence or exclusion removal. The table in Appendix VIII is complex and includes many “X” markers; mapping must be done carefully.

6. Small drafting substitutions that change meaning

• Numerous small wording changes exist, for example “condition of” replaced with “condition and” in two places (items [12] and [16]), and substitution of “is” for “was” (item [9]) and re-labelling of paragraphs (items [4] and [5]). Such edits can change the scope of rules. For example, adding “and” broadens the express list of what must be assessed in a module. Practitioners should read the exact text rather than rely on memory of the previous MOS.

7. Type certificate and rating table edits

• Appendix IX receives many edits and insertions (items [30]-[46]). Some are simple typographical corrections but others insert new rows or reorder note references. Failure to incorporate these corrections in type-rating matrices can lead to incorrect assumptions about which endorsements or ratings are required for certain aircraft types.

8. Multiple approvals and overlapping authorities

• The instrument creates multiple points at which CASA approval is required (examination approvals, OJT approvals, COA holder approvals for excluded systems training). Organisations must ensure they obtain the right approvals from CASA. Missing approvals may invalidate training delivery or the basis on which a licence was issued.

9. Reliance on external documents and advisory circulars

• The Note in item [25] explicitly refers to Appendix II of the Part 66 Acceptable Means of Compliance and Advisory Circular AC 66-07 “both of which are amended from time to time.” This means compliance depends not only on the MOS but on external and potentially changing guidance. Organisations need processes to monitor changes to those documents.

10. Transitional clause 3 interplay with Appendix replacements

• Clause 3 entitles persons who were entitled to a unit of competency mentioned in Appendix IV or VIII immediately before commencement to the new unit if the unit is replaced. That right is narrow but can be misapplied if personnel records do not explicitly show entitlement to the earlier unit. Employers should preserve documentary evidence of entitlement to units prior to the MOS change.

In short, the gotchas are mostly about the procedural centralisation of examinations and OJT with MTOs/CASA approvals, the narrowing of informal routes, complex matrix replacements that must be carefully mapped, and a handful of drafting changes that alter meaning in specific contexts.

This section sets out practical steps and a compliance checklist based strictly on the instrument’s text and the MOS amendments it effects. It lists actions for licence applicants, MTOs, AMOs/COA holders and CASA-dependent processes that the MOS now requires or clarifies.

Immediate compliance actions (organisations and individuals)

1. Map current competencies to the revised Appendix IV and Appendix VIII

• Action: For each licence holder or applicant, map existing unit competencies against the new Appendix IV (units required for licence categories) and Appendix VIII (units required for removal of exclusions) as substituted by items [26] and [29].
• Why: Appendix replacements change which MEA units are required for categories and for removing exclusions. Clause 3 preserves entitlement to new units only where the person was immediately entitled to the replaced unit before commencement.

2. Review and update examination and assessment processes

• Action: MTOs must ensure they are prepared to “conduct” the examinations required by substituted 66.A.25(b) and to align module and item assessments with the levels indicated in Appendix I Part 3 and Appendix II (item [19]).
• Why: The substituted paragraph mandates MTO-conducted examinations as the mechanism for demonstrating knowledge. Any alternative arrangement requires written CASA approval under the same paragraph.

3. Revise OJT programmes and documentation

• Action: Organisations delivering OJT must prepare a detailed syllabus of OJT content, implement worksheets or logbook recording templates, and submit OJT programmes to CASA for assessment and approval as required by substituted 66.A.55(c) (item [25]).
• Why: OJT may “only be conducted and managed” by maintenance organisations or MTOs approved by CASA and “must be assessed and approved by CASA.” The MOS Note indicates Appendix II and AC 66-07 guide CASA’s assessment.

4. Obtain CASA approvals where required

• Action: Identify any OJT programs, alternative examination arrangements or excluded-systems training that require CASA written approval and submit applications with supporting documentation in accordance with Appendix II guidance and any relevant advisory circulars.
• Why: Paragraphs 66.A.25(b) and 66.A.55(c) condition key elements on CASA approval.

5. Preserve documentary evidence for transitional entitlements

• Action: For persons who claim the entitlement under 66.A.20(a)5A, collate documents proving they satisfied paragraphs 66.A.25(i), 66.A.30(f) and 66.A.45(j) of the MOS within the 27 June 2015 to 3 July 2020 window and any documents showing the basis on which they would have qualified under the repealed regulation (item [13]).
• Why: The inserted subparagraph sets out a specific, date-limited qualification pathway that will be subject to verification.

6. Update internal compliance manuals, training matrices and HR records

• Action: Revise manuals, competence matrices and human resources records to reflect the new unit codes, new applicability of modules, the dash rule in 66.A.25(ba) (item [20]), and updated Type Certificate information in Appendix IX (items [30]-[46]).
• Why: Accurate records are necessary to demonstrate compliance with MOS requirements and to support licence applications or removal of exclusions.

7. Train assessors and administrators on the dash applicability rule

• Action: Ensure examiners, training managers and certifying staff understand that a dash in applicable tables signifies that knowledge of the subject or item is not required for that licence category (66.A.25(ba), item [20]).
• Why: Misinterpretation of the dash symbol can lead to erroneous assessment demands or rejection of qualifications.

8. Check COA holder approvals for excluded systems training

• Action: If a COA holder is to provide excluded systems training, ensure the COA holder obtains the specific approval referred to in Appendix VII as amended (item [27]).
• Why: Appendix VII was amended to include COA holders approved for excluded systems training.

9. Verify type-rating endorsements and update endorsements lists

• Action: Review Appendix IX edits and correct any internal lists of type ratings, engine combinations or aircraft types used in endorsement processes (items [30]-[46]).
• Why: Appendix IX contains corrections and new rows that can change what endorsement is required for a given licence.

Operational checklist for CASA and regulators

• Adopt procedural forms and guidance for assessing OJT programs per Appendix II and AC 66-07, as the instrument’s Note suggests those guide CASA assessments (item [25]).
• Create a public list or administrative process for processing written approvals under 66.A.25(b).
• Maintain records of approvals and of persons who have transitional entitlements under 66.A.20(a)5A.

Record-keeping and audit

• Keep dated records proving the date and content of training, OJT worksheets/logbooks, MTO examination results, and any CASA written approvals so that a person’s competence entitlements can be demonstrated after the instrument’s commencement (cl 3 and items [19], [25]).
• Employers and MTOs should ensure that records explicitly show unit codes and version numbers for competency units before and after the MOS change to rely on clause 3 if needed.

Practical timing and resourcing

• Organisations should allow sufficient lead time to prepare detailed syllabuses, to record worksheets and to submit OJT programs for CASA assessment. The instrument does not specify timeframes for CASA’s approvals; organisations should plan for administrative lead times and allocate resources for compliance.

In summary, compliance requires: (1) detailed mapping of personnel competencies to the new Appendices, (2) preparation of CASA-approvable OJT materials and record-keeping systems, (3) MTO capacity to conduct the required examinations, (4) documentary proof for any transitional entitlements, and (5) updating of type-rating and endorsement lists. The MOS changes centralise assessment and approval functions with MTOs and CASA, so practical compliance planning should focus on those relationships.