DOA handbook, MOE and CAME with AI: what EASA requires

The design organisation handbook, the maintenance organisation exposition and the continuing airworthiness management exposition are the three documents on which an EASA organisation approval rests: each describes the organisation, its scope, its nominated persons and the procedures by which it complies with its Part, and each opens with a signed commitment that the organisation will work to it at all times. Part 21 requires the handbook under point 21.A.243, Part 145 the MOE under point 145.A.70, Part-CAMO the CAME under point CAMO.A.300, and the AMC to each gives the layout. The content, however, has to describe the organisation as it is, which is why expositions built from a template are the ones that produce findings. This guide sets out what each document must contain, how amendments are approved, the seven steps that produce a document the organisation can be audited against, and what an AI teammate can draft while the signature, the nominations and the amendment decisions stay with the accountable manager or the head of the design organisation.

Three documents, one obligation

The three rules were written at different times, but since Regulation (EU) 2022/201 brought the design management system into Part 21 they follow the same pattern: a required content list, a statement by the person accountable, initial acceptance by the authority, and a duty to keep the document current under a controlled amendment route.

What the DOA handbook must contain

Point 21.A.243(a) requires the handbook to describe, directly or by cross reference, the organisation, its relevant policies, processes and procedures, the type of design work and the categories of products, parts and appliances in the terms of approval, and, where relevant, the interfaces with and control of partners and subcontractors. Where flight tests are conducted, a flight test operations manual is required as well, with six defined contents. Point 21.A.243(b) adds the statement of how compliance is demonstrated for parts designed by partners or subcontractors, point (c) the duty to amend, and point (d) the statement of qualifications and experience of the management staff and the other persons who make decisions affecting airworthiness.

AMC1 21.A.243(a) turns that into twenty items. They fall into five groups.

• Scope and organisation: the tasks that can be performed under the approval by general area, technology and listed types, the departments and the names of those in charge, the assigned responsibilities and delegated authority with a chart of the design management system, and the human resources, facilities and equipment.
• Design and certification procedures: how the organisation identifies, documents and shows compliance of a design or a change, how it classifies changes as major or minor and approves minor changes, how it classifies and approves production deviations and repairs, and how it controls and informs staff of changes to drawings, specifications and procedures.
• Records and continuing airworthiness: the recording system for the type design, the means of compliance and the compliance documentation, the record-keeping under 21.A.5, the collection and analysis of in-service problems under 21.A.3A, the establishment and control of the ICA and of the operational suitability data.
• People: the DO-authorised signatories and the nominated persons under 21.A.33 and 21.A.35, and the tasks, competency and responsibility of the Office of Airworthiness.
• Management system: the system monitoring that keeps the design management system effective, the safety policy and objectives, the internal safety reporting scheme, the safety management procedures, and the signed statement.

For an organisation that designs only minor changes and minor repairs, AMC2 21.A.243(a) gives a shorter table of contents in two parts: Part 1 the organisation, from the binding statement and the amendment procedure through scope, charts, staff, certifying personnel, independent system monitoring and the safety management system; Part 2 the procedures for classification and approval of minor changes and repairs, control of subcontractors, failures and defects, coordination with production, documentation control and record-keeping.

What the MOE and the CAME must contain

Point 145.A.70(a) requires the maintenance organisation exposition to include, directly or by reference, seventeen items: the accountable manager's statement, the safety policy and objectives, the titles and names of the nominated persons and their duties including the matters on which they deal directly with the authority, the organisation chart, the list of certifying staff, support staff and airworthiness review staff with their scope of authorisation, the manpower resources and the system for planning staff availability, the facilities at each approved location, the scope of work relevant to the terms of approval, 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 commercial operators served, subcontracted organisations, approved locations, contracted organisations and approved alternative means of compliance.

Point CAMO.A.300(a) requires the continuing airworthiness management exposition to contain fourteen: the same statement, the safety policy, the scope of work, manpower and planning, the nominated persons with their duties, accountabilities, responsibilities and authorities, the organisation chart, the staff authorised to issue airworthiness review certificates and recommendations and, where applicable, permits to fly, the facilities, the internal safety reporting scheme, the compliance procedures including the management system key processes, the control of contracted and subcontracted activities, the continuing airworthiness management, airworthiness review and permit to fly procedures, the procedure for changes not requiring prior approval and the CAME amendment procedure, and the lists of approved maintenance programmes, maintenance contracts and alternative means of compliance. The text of CAMO.A.300 with its AMC outline is quoted on the rule point page.

The layouts in AMC1 145.A.70(a) and AMC1 CAMO.A.300 are the vocabulary auditors use, so the chapter numbers matter. The MOE has a general part, thirty-three maintenance procedures, seven line maintenance procedures, twenty-two management system procedures, the customer part and the supporting documents; the CAME has Part 0 general with the two change procedures and the AltMoC procedure, fourteen continuing airworthiness management procedures, eleven management system procedures, the contracted maintenance part and the airworthiness review part. A different structure is allowed, but only with an index that shows where each required subject is found.

Where drafting goes wrong

• A template that describes another organisation. Nominated persons, locations, ratings and procedures copied from an exposition written for a different scope. The procedures are not followed because they were never the organisation's, and the audit finds the gap between the document and the floor.
• Procedures that restate the rule. A chapter that says the organisation "ensures that maintenance data is current" answers nothing. The rule needs who checks, against what, how often, and where the record is.
• Cross-references without a register. Content included by reference is allowed, but AMC1 145.A.70(d) expects clear cross-references and procedures to manage the referenced documents. A referenced procedure that was revised without the exposition noticing is an exposition that is no longer current.
• Amendments through the wrong route. A change of nominated person or of the terms of approval processed under the procedure for changes not requiring prior approval, when 145.A.85(a) and CAMO.A.130(a) put it in the prior-approval list, and 21.A.247 requires Agency approval of a change of the head of the design organisation before implementation.
• A statement that has outlived its signatory. AMC1 21.A.243(a) asks for the handbook statement to be reissued at the earliest opportunity when the HDO changes; the MOE and CAME statements bear the accountable manager's name.
• Scope creep in the procedures. Procedures for ratings, locations or design work outside the terms of approval, which suggests to the auditor that the work is being done.

Seven steps to draft or rebuild the document

1. Fix the scope and the terms of approval before writing a line. The handbook describes the type of design work and the categories of products in the terms of approval under point 21.A.251; the MOE specifies the scope of work relevant to the terms of approval under point 145.A.20; the CAME states the scope of work relevant to the terms of approval. Every procedure that follows is written for that scope and no wider. A procedure for work the organisation is not approved for is a finding, and a scope the procedures do not cover is another.
2. Map the required items onto the outline in the AMC. Point 145.A.70(a) lists seventeen items, point CAMO.A.300(a) fourteen, and AMC1 21.A.243(a) twenty for the handbook. AMC1 145.A.70(a), AMC1 CAMO.A.300 and AMC2 21.A.243(a) give the layouts. Build a table with one row per required item, the outline chapter that carries it and the rule point it satisfies. Where a different format is used, for example one exposition for more than one approval, both AMCs require an index or cross-reference annex that shows where each subject is found.
3. Write the organisation part from facts, not from a template. Nominated persons with titles and names, their duties and the matters on which they deal directly with the authority, the organisation chart with its lines of accountability, the manpower planning system, the facilities at each approved location, the lists of certifying staff, authorised signatories or airworthiness review staff with their scope. These items are checked against reality at every audit, so they are written from the organisation as it is on the date of issue, and they are the items most changes touch.
4. Write each procedure as what the organisation does, with the point it satisfies. GM1 145.A.70 states the purpose of the exposition: to show how the organisation intends to comply with the Annex and to give personnel the information and procedures they need to perform their duties. A procedure that paraphrases the rule does neither. Each procedure names who does what, in which order, with which record, and cites the point of the Part and the AMC it answers, so that the compliance monitoring function and the auditor can trace it both ways.
5. Build the register of documents included by reference. All three rules allow content directly or by reference. AMC1 145.A.70(d) asks for clear cross-references to any separate document, manual or electronic file and for procedures to manage them; the handbook may include the flight test operations manual or keep it separate, and the safety management processes may sit in a separate manual. Keep one register of referenced documents with their issue and the chapter that references them, so that an amendment to a referenced document is visible from the exposition.
6. Set the two amendment routes and the time frames. For the MOE and the CAME the rule prescribes two routes: changes listed in point 145.A.85(a) or CAMO.A.130(a) and any other change the Annex says needs approval go to the competent authority before implementation, while all other changes are managed and notified under a procedure the authority has approved under 145.A.85(c) or CAMO.A.130(c). AMC1 145.A.85 and AMC1 CAMO.A.130 give the time frames: the application at least 30 working days before the intended change, notice of a planned change of nominated person at least 20 working days before. For the handbook, point 21.A.247 requires each significant change to the design management system to be approved by the Agency before implementation, on the basis of the proposed changes to the handbook, and GM1 21.A.247 lists what counts as significant.
7. Sign the statement, submit, and keep the document current. The MOE and the CAME open with a statement signed by the accountable manager, countersigned by the chief executive officer when they are not the same person, that the organisation will at all times work in accordance with the Annexes and the approved exposition. The handbook carries the statement in AMC1 21.A.243(a), signed by the head of the design organisation and countersigned by the senior company manager, and reissued when the head of the design organisation changes. The initial issue of the MOE and the CAME is approved by the competent authority, the handbook is furnished to the Agency, and all three must be amended as necessary to remain an up-to-date description of the organisation.

What AI can draft and what the accountable manager keeps

An exposition is mostly derivation: from the rule's content list, the AMC's layout, the terms of approval, the organisation's existing procedures and its records of who does what. A language model working only from those documents, and citing the point behind every chapter, can produce the first complete draft and every subsequent amendment package. The commitments in the document are not derivation, and the rule places them with named people.

The conditions that make this safe are the ones in Can AI be trusted for aviation compliance documentation?: a corpus limited to the Part at its current amendment, the AMC and the organisation's own controlled documents; a citation on every drafted paragraph; a boundary that keeps the master copy of the exposition under its own amendment procedure, as the guide on the AI assistant for Part 145 and CAMO organisations describes; and a review record showing who accepted each chapter.

How Wingman360 Teammate applies this

The organisation-approvals workflow in Wingman360 Teammate starts from the Part and its AMC at the current amendment, the terms of approval and the organisation's existing procedures and records that its administrators have ingested. It maps the required items onto the AMC outline, drafts the chapters and the procedures with the rule point cited on each, compiles the cross-reference register, and, when a regulation or the organisation changes, drafts the amendment package with the route the rule prescribes. The person responsible for the exposition reviews every chapter; the accountable manager or the head of the design organisation signs the statement and decides the submission. The same approved knowledge base answers staff questions from the exposition once it is in force. Each deployment is a dedicated single-tenant instance in the organisation's own cloud or on-premise, with a local model option so that no procedure leaves the network. What else it drafts is on the maintenance organisations and design and production organisations pages.