Regulation (EU) No 748/2012, Annex I (Part 21), Subpart B
21.A.20: demonstration of compliance and the compliance documents
Point 21.A.20 governs the demonstration of compliance once the certification programme is accepted: the applicant demonstrates compliance with the certification basis, provides the means by which it was demonstrated, reports difficulties that affect the risk assessment or the level of involvement, records the justifications in compliance documents, and declares compliance at the end. AMC 21.A.20(c) says what each compliance document contains.
The text
Verbatim, with the point markers of the source. Page furniture and footnotes are left out.
(a) Following the acceptance of the certification programme by the Agency, the applicant shall demonstrate compliance with the type certification basis, operational suitability data certification basis and environmental protection requirements, as established and notified to the applicant by the Agency in accordance with points 21.B.80, 21.B.82, 21.B.85, and shall provide the Agency with the means by which such compliance has been demonstrated.
(b) The applicant shall report to the Agency any difficulty or event encountered during the process of demonstration of compliance that may have an appreciable effect on the risk assessment under point 21.A.15(b)(6) or on the certification programme, or may otherwise necessitate a change to the level of involvement of the Agency previously notified to the applicant in accordance with point 21.B.100(c).
(c) The applicant shall record justifications of compliance within the compliance documents as referred to in the certification programme.
(d) After completion of all demonstrations of compliance in accordance with the certification programme, including any inspections and tests in accordance with point 21.A.33, and after all flight tests in accordance with point 21.A.35, the applicant shall declare that:
1. it has demonstrated compliance with the type-certification basis, operational suitability data certification basis and environmental protection requirements, as established and notified by the Agency, following the certification programme as accepted by the Agency; and
2. no feature or characteristic has been identified that may make the product unsafe for the uses for which certification is requested.
(e) The applicant shall submit to the Agency the declaration of compliance provided for in point (d). Where the applicant holds an appropriate design organisation approval, the declaration of compliance shall be made in accordance with Subpart J and submitted to the Agency.
1. Compliance documentation comprises one or more test or inspection programmes/plans, reports, drawings, design data, specifications, calculations, analyses, etc., and provides a record of the means by which compliance with the applicable type-certification basis, the operational suitability certification basis and environmental protection requirements is demonstrated.
2. Each compliance document should normally contain:
— the reference of the certification specifications, special conditions or environmental protection requirements addressed by the document;
— substantiation data demonstrating compliance (except test or inspection programmes/plans);
— a statement by the applicant declaring that the document provides the proof of compliance for which it has been created; and
— the appropriate authorised signature.
3. Each compliance document should be unequivocally identified by its reference and issue date. The various issues of a document should be controlled and comply with point 21.A.55.
What it means in practice
The point runs in five steps. Under (a) the applicant demonstrates compliance with the basis established under points 21.B.80, 21.B.82 and 21.B.85 and gives the Agency the means by which it did so. Under (b) it reports anything that changes the risk assessment made under point 21.A.15(b)(6) or the level of involvement notified under point 21.B.100(c). Under (c) it records the justifications of compliance in the compliance documents the programme named. Under (d), after all demonstrations, inspections and flight tests, it declares that compliance was demonstrated following the accepted programme and that no unsafe feature was found. Under (e) it submits that declaration, through Subpart J when it holds a design organisation approval.
AMC 21.A.20(c) turns "compliance document" into a checklist. The document names the certification specifications, special conditions or environmental requirements it addresses; it carries the substantiation data, except when it is a test or inspection programme; it contains the applicant's statement that it provides the proof of compliance it was created for; and it bears the authorised signature. It is identified by reference and issue date, and its issues are controlled under point 21.A.55.
The practical consequence is that a compliance document is not a report with a compliance paragraph added at the end. The requirement reference, the statement and the signature are structural, and a missing one is a finding.
Where Wingman360 Teammate uses it
Compliance documents are one of the drafts on the design and production page: the AI teammate drafts the skeleton with the requirement reference, the substantiation section and the statement, from the organisation's own template. The signature stays with the authorised person.
Sources
- Easy Access Rules for Initial Airworthiness and Environmental Protection (Regulation (EU) No 748/2012), July 2024 revisionEuropean Union Aviation Safety Agency. Point 21.A.20 and AMC 21.A.20(c) quoted from the consolidated text, pages 131 to 133; checked 2026-09-20
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