Can an AI assistant write our maintenance organisation exposition?

It can draft it, section by section against the outline in AMC1 145.A.70(a), and it can draft an amendment when a regulation changes by listing the paragraphs that cite the changed clause. Under point 145.A.70(b) the initial issue of the MOE is approved by the competent authority, and under point 145.A.70(c) amendments follow the organisation's own approved procedures. The draft therefore always passes through the person responsible for the exposition and, where required, the authority.

Is it acceptable to hold the exposition and procedures in an AI system?

The exposition may be published by electronic data processing, as AMC1 145.A.70(c) and AMC2 CAMO.A.300(c) note, provided it is disseminated to everyone who needs it. An assistant that reads the controlled document and cites it is one more way of disseminating it. The controlled document stays where it is, under its own amendment procedure. The assistant is a reader, not the master copy.

What about maintenance data that belongs to the manufacturer or the customer?

The same rules apply as for any other use of that data. Point 145.A.45(g) requires the organisation to keep the maintenance data it controls up to date, and point CAMO.A.325 lets a CAMO use data provided by the owner or operator under a contract and keep it only for the duration of that contract. The knowledge base must follow the same revision control and the same contractual limits, which is another reason ingestion has to be a controlled step and the deployment has to sit inside the organisation.

Does using an assistant change our record-keeping obligations?

No. Point 145.A.55 still requires the detailed maintenance records and the certificate of release to service to be retained for three years, and management system, contracting and subcontracting records for five years. An answer from the assistant is not a record unless the organisation files it as one. What changes is that a reviewer can find the record that supports a finding in seconds, with the clause it satisfies.

What is the first thing a Part 145 organisation should use it for?

Retrieval from its own procedures during audits and findings. Questions such as which MOE paragraph covers subcontractor control, which list shows the staff authorised to release this component, or what the procedure is when maintenance data is found ambiguous, have a checkable answer in a controlled document. Start there, measure the citations, and extend to drafting when the team trusts the retrieval.

Does EASA NPA 2025-07 set requirements for an AI assistant in a Part 145 organisation?

Not in the way it is often summarised. NPA 2025-07, published on 10 November 2025, proposes detailed specifications on AI trustworthiness for AI-based systems that a risk assessment finds to be high-risk under the EU AI Act and that are classified as Level 1 or Level 2. Maintenance organisations and CAMOs are among the stakeholders it names, and whether a document assistant falls within its scope depends on that risk assessment. The NPA does not prescribe an approved corpus, a citation format or audit logs for office assistants. The controls that apply to an assistant over your exposition today are the ones in Part 145 itself, points 145.A.45, 145.A.55 and 145.A.70, and your own procedures.

Does the same approach work for an FAA repair station?

Yes. A certificated repair station keeps a repair station manual whose contents are set by 14 CFR 145.209 and a quality control manual under 14 CFR 145.211, both in a form acceptable to the FAA and both revised under procedures that notify the responsible Flight Standards office. Those two manuals and the procedures they reference are the corpus, and the same ownership, boundary and review conditions apply.

Insights

AI assistant for EASA Part 145 and CAMO organisations

Name: Wingman360 Teammate
Author: Lavionic

What an AI assistant can do inside a maintenance organisation or a CAMO: answer staff questions from the MOE or CAME with the paragraph cited, draft amendments and audit responses for review, and where the line sits under points 145.A.70, 145.A.45, 145.A.55, 145.A.200 and CAMO.A.300. With six steps to introduce one.

Oguz HicdurmazFounder and Managing Director, Lavionic GmbHPublished 5 September 2026Updated 20 September 202611 min read

An AI assistant for a Part 145 maintenance organisation or a continuing airworthiness management organisation is a system that answers staff questions from the organisation's own approved documents, the maintenance organisation exposition or the continuing airworthiness management exposition, the procedures they incorporate by reference, the applicable maintenance data and the records, and shows the paragraph each answer came from. It drafts procedure text, amendments and audit responses for a nominated person to review. It does not hold the approval, release anything to service, or sign. The exposition is the right place to start because the regulation prescribes what it contains and the AMC prescribes how it is laid out, so an assistant built on it answers questions that already have a controlled answer.

The exposition is already the corpus

Point 145.A.70(a) requires a maintenance organisation to establish and maintain an MOE that includes, directly or by reference, seventeen items: the accountable manager's statement, the safety policy, the nominated persons and their responsibilities, the organisation chart, the list of certifying staff with their scope of authorisation, manpower and facilities, the scope of work, the procedure for changes not requiring prior approval, the MOE amendment procedure, the procedures by which the organisation ensures compliance with the Annex, and the lists of operators, subcontractors, locations, contracted organisations and alternative means of compliance. Point CAMO.A.300(a) requires the equivalent fourteen items of a CAME.

AMC1 145.A.70(a) and AMC1 CAMO.A.300 then give the outline of an acceptable exposition. GM1 145.A.70 states the purpose: to specify the scope of work and show how the organisation intends to comply, and to provide all the information and procedures its personnel need to perform their duties. Complying with its contents keeps the organisation in compliance with the Part. That is the definition of a corpus worth building an assistant on. The questions staff ask every day, who may release this, which procedure covers that, what we do when the data is wrong, are answered somewhere in the exposition or in a document it references. Drafting or rebuilding the exposition itself, and the amendment routes under 145.A.85 and CAMO.A.130, are covered in the guide on the DOA handbook, MOE and CAME.

MOE, AMC1 145.A.70(a)	CAME, AMC1 CAMO.A.300
Part 1, General: statement, safety policy, personnel, chart, staff lists, resources, facilities, scope, change and AltMoC procedures	Part 0, General organisation, safety policy and objectives
Part 2, Maintenance procedures, 2.1 to 2.33, from supplier evaluation to the line or base assessment of a work scope	Part 1, Continuing airworthiness management procedures, 1.1a to 1.13, from the technical log to maintenance check flights
Part L2, Additional line maintenance procedures	Part 3, Contracted maintenance
Part 3, Management system procedures, including compliance monitoring at 3.8	Part 2, Management system procedures, including compliance monitoring at 2.8
Part 4, Relationship with customers and operators	Part 4, Airworthiness review procedures, and Part 4B, Permit to fly procedures
Part 5, Supporting documents: sample documents and the lists of subcontractors, locations, contracted organisations and AltMoC	Part 5, Supporting documents: sample documents and the lists of review staff, subcontractors, contracts, maintenance programmes and AltMoC

One detail in both AMCs matters for the design of an assistant. An organisation that uses a different format, for example one exposition serving several approvals, should provide an index or a cross-reference annex showing where each subject is found. That cross-reference is exactly the map an assistant needs, and producing and maintaining it is one of the first tasks an assistant can take on.

Ten questions staff ask, and where the answer lives

Question	Where the controlled answer is	Rule behind it
Does this change need prior approval?	MOE 1.10 and 1.11, CAME 0.5 and 0.6	145.A.70(a)(10) and 145.A.85; CAMO.A.300(a)(11)(iv), CAMO.A.115 and CAMO.A.130
The maintenance data is ambiguous. What do I do?	MOE 2.27	145.A.45(c): record it in the internal safety reporting scheme and notify the author of the data
Who is authorised to release this component?	MOE 1.6, list of certifying staff with scope of authorisation	145.A.70(a)(6)
What counts as applicable maintenance data?	MOE 2.8	M.A.401(b): authority and Agency material, airworthiness directives, instructions for continuing airworthiness from the design approval holder, component manufacturer instructions acceptable to that holder, and data issued under 145.A.45(d)
May we modify a maintenance instruction?	The procedure specified in the MOE	145.A.45(d): only under an MOE procedure, with equivalent or improved standards demonstrated and the author informed
How long do we keep these records?	MOE 2.14 and 3.22, CAME 1.3 and 2.10	145.A.55: three years from the certificate of release to service for maintenance records, five years for management system and contract records
Which subcontractors may we use?	MOE 5.2 and 2.1, CAME 5.3	145.A.70(a)(14) and 145.A.75(b); CAMO.A.125(d)(3)
Is this a critical maintenance task, and what error capture applies?	MOE 2.23, L2.7	145.A.48 and the MOE procedure
How do we decide on a non-mandatory modification?	CAME 1.6	CAMO.A.315(b)(4): a procedure using the safety risk management process of CAMO.A.200(a)(3)
When is the next audit of this activity due?	MOE 3.8.1, CAME 2.8.1	AMC2 CAMO.A.200(a)(6): every aspect verified every year, a cycle that may be extended by up to 100 percent with a risk assessment and the authority's agreement

Every row has the same shape. The question is answered by a paragraph in a controlled document, the paragraph exists because a clause requires it, and the person asking needs the paragraph now, not a summary. An assistant that returns the paragraph and its reference is doing the job. One that paraphrases without a reference is adding a step, because the reader still has to find the paragraph to trust the answer.

What the assistant may do and what nominated persons keep

Task	Assistant	Nominated person
Answering a procedure question	Returns the paragraph of the current issue with its reference, and says when the exposition is silent	Acts on it
Amending the exposition after a regulation change	Lists every paragraph that cites the changed clause and drafts the revised text	Reviews it, issues the amendment under 145.A.70(c) or CAMO.A.300(c) and obtains approval where the procedure requires it
Preparing for an audit	Maps each item of the audit plan to the procedure and the records that evidence it	Performs the audit; the independence required by AMC1 CAMO.A.200(a)(6) is a property of the auditor, not the tool
Answering a finding	Drafts the response with the clause, the procedure and the corrective-action record cited	Determines root cause, decides the corrective action, signs
Checking consistency	Finds staff on the certifying list without a matching authorisation record, procedures referenced but not listed, subcontractors used but not in Part 5	Resolves the discrepancy
Building the cross-reference index	Generates and maintains the index that AMC1 145.A.70(a) asks for when a non-standard format is used	Confirms it
Issuing a certificate of release to service, an airworthiness review certificate or a recommendation	Nothing	Certifying staff and airworthiness review staff, within their scope of authorisation
Safety risk decisions and deputising for a nominated person	Nothing, beyond retrieving the procedure and the record	The persons nominated under 145.A.30 or CAMO.A.305, as the exposition states

Why a general chatbot is the wrong tool for this

The documents that answer these questions are not on the internet. A general assistant has never read your MOE, your work order system or the contracts in your Part 5, so it answers from other organisations' expositions and from whichever revision of Part 145 dominated its training data. Three properties of the regulation make that unacceptable rather than merely unhelpful.

The exposition must describe the organisation as it is now. Points 145.A.70(b) and CAMO.A.300(b) require it to be amended as necessary so that it remains an up-to-date description. An assistant must therefore answer from the current issue only, and forget the previous one the day the amendment is issued.
Maintenance data must be current and readily available. Points 145.A.45(f) and (g) and M.A.401(c) make the organisation responsible for that. A tool that mixes revisions or answers from a manual it found elsewhere breaks a requirement the organisation is audited on.
The records are protected. Point 145.A.45(e) requires electronic work card databases to be adequately protected against unauthorised alteration and backed up within 24 hours. Anything placed next to those records has to meet the same bar, which rules out a service whose users can change what it knows and whose data leaves the organisation.

The conditions that make an assistant safe in this setting are the four set out in Can AI be trusted for aviation compliance documentation?: a controlled corpus, citations at paragraph level, a boundary users cannot cross, and review that leaves a record.

How to introduce it, in six steps

Define the corpus from the exposition outwards. Start with the current issue of the MOE or CAME and every procedure, manual and list it incorporates by reference, then add the regulation and its AMC and GM at the revision your organisation works to, and the maintenance data the organisation controls. Leave out superseded issues, drafts and anything the organisation has not approved.
Give the knowledge base the same owner as the exposition. AMC1 145.A.70 and AMC2 CAMO.A.300 expect the organisation to designate the person responsible for monitoring and amending the exposition. That person, or the compliance monitoring function, approves what enters the knowledge base and when an issue is replaced, so the assistant can never be ahead of or behind the controlled document.
Make everyday use read-only. Staff ask questions and receive cited answers. They cannot upload, edit or delete what the assistant knows. Ingestion is a separate, privileged step performed by the owner under a procedure, in the same way that only a nominated person may issue an amendment of the exposition.
Start with compliance monitoring. Use the assistant first to prepare the independent audit and to answer findings: which procedure covers the audited activity, which clause the finding cites, which records show the corrective action. The compliance monitoring function already checks every answer against the source, so it is the safest place to measure whether the citations hold.
Measure citation accuracy before extending the scope. Take a sample of real questions from the last months, run them through the assistant and have the compliance monitoring function open every citation. Record the proportion that point to the right clause of the right issue. Extend the assistant to drafting only when that proportion is one the organisation is prepared to defend to its authority.
Describe AI-assisted drafting in the exposition. Add a short procedure that says which documents the assistant may draft, that every draft is reviewed by the person who would have written it, and that the reviewer checks the citations before the draft enters the amendment process. Decide under your own change procedure, the one required by point 145.A.70(a)(10) or point CAMO.A.300(a)(11)(iv), whether that amendment needs prior approval.

How Wingman360 Teammate applies this

In Wingman360 Teammate the compliance monitoring manager, or whoever the organisation nominates, ingests the current MOE or CAME, the procedures it references, the Easy Access Rules at the applicable revision and the maintenance data the organisation controls. Nothing enters the knowledge base without that person's approval, and a superseded issue leaves it when the amendment is issued. Every other user asks questions and receives answers drawn only from that knowledge, with the paragraph reference and a link to open it, and the system says so when the exposition does not answer. The drafting workflows produce exposition amendments, audit responses and organisation-approval documents for review, and nothing is signed by the system. Each deployment is a dedicated single-tenant instance in the organisation's own cloud or on-premise, with a local model option so that neither the exposition nor customer data leaves the network.

Frequently asked questions

Can an AI assistant write our maintenance organisation exposition?: It can draft it, section by section against the outline in AMC1 145.A.70(a), and it can draft an amendment when a regulation changes by listing the paragraphs that cite the changed clause. Under point 145.A.70(b) the initial issue of the MOE is approved by the competent authority, and under point 145.A.70(c) amendments follow the organisation's own approved procedures. The draft therefore always passes through the person responsible for the exposition and, where required, the authority.
Is it acceptable to hold the exposition and procedures in an AI system?: The exposition may be published by electronic data processing, as AMC1 145.A.70(c) and AMC2 CAMO.A.300(c) note, provided it is disseminated to everyone who needs it. An assistant that reads the controlled document and cites it is one more way of disseminating it. The controlled document stays where it is, under its own amendment procedure. The assistant is a reader, not the master copy.
What about maintenance data that belongs to the manufacturer or the customer?: The same rules apply as for any other use of that data. Point 145.A.45(g) requires the organisation to keep the maintenance data it controls up to date, and point CAMO.A.325 lets a CAMO use data provided by the owner or operator under a contract and keep it only for the duration of that contract. The knowledge base must follow the same revision control and the same contractual limits, which is another reason ingestion has to be a controlled step and the deployment has to sit inside the organisation.
Does using an assistant change our record-keeping obligations?: No. Point 145.A.55 still requires the detailed maintenance records and the certificate of release to service to be retained for three years, and management system, contracting and subcontracting records for five years. An answer from the assistant is not a record unless the organisation files it as one. What changes is that a reviewer can find the record that supports a finding in seconds, with the clause it satisfies.
What is the first thing a Part 145 organisation should use it for?: Retrieval from its own procedures during audits and findings. Questions such as which MOE paragraph covers subcontractor control, which list shows the staff authorised to release this component, or what the procedure is when maintenance data is found ambiguous, have a checkable answer in a controlled document. Start there, measure the citations, and extend to drafting when the team trusts the retrieval.
Does EASA NPA 2025-07 set requirements for an AI assistant in a Part 145 organisation?: Not in the way it is often summarised. NPA 2025-07, published on 10 November 2025, proposes detailed specifications on AI trustworthiness for AI-based systems that a risk assessment finds to be high-risk under the EU AI Act and that are classified as Level 1 or Level 2. Maintenance organisations and CAMOs are among the stakeholders it names, and whether a document assistant falls within its scope depends on that risk assessment. The NPA does not prescribe an approved corpus, a citation format or audit logs for office assistants. The controls that apply to an assistant over your exposition today are the ones in Part 145 itself, points 145.A.45, 145.A.55 and 145.A.70, and your own procedures.
Does the same approach work for an FAA repair station?: Yes. A certificated repair station keeps a repair station manual whose contents are set by 14 CFR 145.209 and a quality control manual under 14 CFR 145.211, both in a form acceptable to the FAA and both revised under procedures that notify the responsible Flight Standards office. Those two manuals and the procedures they reference are the corpus, and the same ownership, boundary and review conditions apply.

Sources

Easy Access Rules for Continuing Airworthiness (Regulation (EU) No 1321/2014), September 2025 revision, European Union Aviation Safety Agency. Annex II (Part 145) points 145.A.30, 145.A.45, 145.A.55, 145.A.65, 145.A.70, 145.A.200 with AMC1 145.A.70(a); Annex Vc (Part-CAMO) points CAMO.A.200, CAMO.A.300, CAMO.A.315, CAMO.A.325 with AMC1 CAMO.A.300 and AMC2 CAMO.A.200(a)(6); Annex I (Part-M) point M.A.401
Commission Regulation (EU) No 1321/2014 on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, as amended, including Regulation (EU) 2020/270 (Part-CAMO) and Regulation (EU) 2021/1963 (Part 145 management system)
EASA NPA 2025-07, Artificial intelligence trustworthiness, European Union Aviation Safety Agency, 10 November 2025. Part (A) section 2.1.2 on affected stakeholders and Part (B) DS.AI.010 on scope
14 CFR 145.209, Repair station manual contents, Federal Aviation Administration, Title 14 Code of Federal Regulations
14 CFR 145.211, Quality control system, Federal Aviation Administration, Title 14 Code of Federal Regulations

All documents cited on this site, with revision and date checked, are listed in the sources register; terms are defined in the glossary.

About the author

Oguz Hicdurmaz

Founder and Managing Director, Lavionic GmbH

Senior aerospace engineer with more than 20 years in manned and unmanned aircraft certification, airworthiness compliance and safety engineering. EASA Part 21 certification basis development, airworthiness management plans and compliance verification.

LinkedIn profile

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