The Short Answer
A US repair station is certificated under 14 CFR Part 145 — there is no separate FAA "EASA Part 145" rule. To work on EU-registered aircraft and components, a US shop obtains EASA approval under the US-EU Bilateral Aviation Safety Agreement (BASA) and its Maintenance Annex Guidance (MAG), documented through an EASA Supplement added to its repair station manual. The shop never stops being a Part 145 station; the EASA layer is a bilateral-agreement and FAA-guidance construct on top of it.
The practical output is a dual release — one release document (commonly an FAA Form 8130-3 completed per the MAG, the alternative being a separate EASA Form 1) that approves an article under both airworthiness systems. The FAA records floor is fixed by 14 CFR §145.219(c): keep the required records at least 2 years from the date the article was approved for return to service. The EASA side generally expects longer retention through the MAG and customer contracts. Most audit findings here are documentation failures — an untraceable release, a signer with no recorded EASA authorization, or work that does not match the controlled EASA Supplement.
"EASA Part 145" gets used loosely in the US MRO world, and it causes real confusion in audit prep. A US shop holds a 14 CFR Part 145 certificate and, separately, an EASA approval granted through the bilateral. The two systems share a backbone — traceability of work and parts to approved data — but they sit in different rulebooks. Getting the records right means knowing which obligation comes from the FARs (verifiable in the 14 CFR Part 145 text) and which comes from the bilateral.
This article keeps that line bright. The FAA recordkeeping rules — chiefly 14 CFR §145.219 and the §43.9 content standard — are stated as regulation. Everything EASA, MAG, and BASA is described as bilateral-agreement and FAA guidance, cautiously, without inventing CFR section numbers for it. If you want the FAA-only records picture first, start with our Part 145 recordkeeping breakdown and the Part 145 audit binder guide.
The bilateral is guidance and agreement — not the FARs
Do not cite a 14 CFR section for the MAG, the EASA Supplement, EASA Form 1, or the dual-release statements. Those are governed by the US-EU bilateral and FAA/EASA guidance. The only things in this topic that come from the Federal Aviation Regulations are your underlying Part 145 obligations — the manual (§145.207), its contents (§145.209), the quality control system (§145.211), inspection and release (§145.213), and recordkeeping (§145.219). This article verifies those against the CFR and treats the rest as bilateral practice.
How the Layers Fit: CFR on the Bottom, Bilateral on Top
Think of EASA approval at a US shop as a stack. The Federal Aviation Regulations are the foundation. The bilateral agreement and its guidance are layered on top — they do not replace the FARs, they add EASA-specific procedures the shop documents and follows.
The 14 CFR Part 145 foundation
Everything starts with the FAA repair station certificate and the rules that come with it. These are verifiable, numbered CFR sections:
- §145.207Repair station manual. The shop must prepare, follow, keep current, and make available a repair station manual acceptable to the FAA.
- §145.209Repair station manual contents. Sets the contents (a)–(k); paragraph (i) requires a description of the required records and the recordkeeping system used to store and retrieve them.
- §145.211Quality control system. Requires a QC system acceptable to the FAA and a quality control manual covering inspection, technical data, calibration, and corrective action procedures.
- §145.213Inspection of maintenance / release. Requires inspection before return to service and certification of airworthiness on the maintenance release; (d) limits final-inspection/release signoff at a US shop to an appropriately certificated Part 65 mechanic or repairman.
- §145.219Recordkeeping. Records in English demonstrating Part 43 compliance; a copy of the maintenance release to the owner/operator; retention at least 2 years from return-to-service approval; records available to the FAA and the NTSB.
The US-EU BASA and the MAG
The United States and the European Union maintain a Bilateral Aviation Safety Agreement (BASA). For maintenance, the operative document is the Maintenance Annex Guidance (MAG) — the agreed guidance that lets the FAA grant a US Part 145 shop EASA approval, and lets EASA-approved shops release work into the US system, without each authority re-certificating the other's facilities from scratch.
The MAG is guidance under the bilateral, not a Federal Aviation Regulation. It sets out the EASA special conditions a US shop must meet, how dual release works, and what the EASA Supplement to the manual must address. When this article describes a MAG requirement, it is describing bilateral practice — which is why you will not see a CFR cite attached to it.
The EASA Supplement and dual-release procedures
The shop's repair station manual is required by §145.207, and its contents by §145.209. To hold EASA approval, the shop adds an EASA Supplement to that manual — the section that documents the MAG-driven, EASA-specific procedures: dual-release handling, EASA work-order control, EASA special conditions, and the designation of who may sign the EASA side.
The supplement is a bilateral/MAG construct grafted onto a CFR-required document. The shop must follow it, keep it current, and control its revisions — the same discipline §145.207 imposes on the rest of the manual. Where a US-only shop ends at Layer 1, a dual-approved shop must keep all three layers in agreement, and its records have to prove it.
Note on Form numbers: FAA Form 8130-3, EASA Form 1, and the EASA Supplement are not CFR provisions. They are forms and documents defined by FAA guidance and the bilateral. We describe how they are used, but we do not attach a 14 CFR citation to them — and you should be cautious of any source that does.
Dual Release: One Article, Two Airworthiness Systems
A dual release is the single most important concept in EASA-approved US maintenance — and the one auditors probe hardest, because it is where the two systems meet on one piece of paper.
What a dual release is
A dual release approves an article for return to service under both the FAA and EASA airworthiness systems at the same time, on a single release document. In US practice this is commonly an FAA Form 8130-3 completed per the MAG — the FAA block is completed as usual, and the EASA block and any required statements are completed so the document is acceptable on the EU side. The alternative is issuing a separate EASA Form 1. Either way, the shop must hold current EASA approval to release the EASA side.
When you need it
You need a dual release when the article is destined for an EU-registered aircraft or an EASA-regulated operator that requires EASA-acceptable release paperwork. Domestically you do not: a §43.9-compliant maintenance release satisfies the FAA, and even the 8130-3 is not required by Part 145 for a domestic release — §145.213(b) requires certifying airworthiness on the maintenance release but prescribes no form. The dual release exists to satisfy a customer or registry on the EU side, layered on top of the FAA obligation you would have had anyway.
What it sits on top of — the §43.9 backbone
A dual release is only as strong as the work order beneath it. The underlying FAA maintenance record still has to meet 14 CFR §43.9(a) — a description of the work performed (or a reference to data acceptable to the FAA), the date of completion, the name of the performer if different from the approver, and the signature, certificate number, and kind of certificate of the person approving return to service. If the §43.9 content is incomplete, the dual release rests on a defective foundation regardless of how cleanly the EASA blocks were filled in. (Note: §43.9 covers maintenance, preventive maintenance, rebuilding, and alteration — it does not cover inspections, which carry their own content rule at §43.11.)
Who can sign each side
On the FAA side, §145.213(d) provides that at a US-based repair station, only an employee appropriately certificated as a mechanic or repairman under Part 65 is authorized to sign final inspections and maintenance releases. The EASA side adds its own authorization through the bilateral process — the people the shop has designated and the EASA approval recognizes under the MAG. A signer needs standing on both sides to sign a dual release. The cleanest way to prove that is a combined authorized-signatory roster that ties each name to both their Part 65 certificate and their EASA-side authorization.
A common misconception, corrected
Holding an FAA 8130-3 capability does not, by itself, let you issue an EASA release. The EASA side requires holding EASA approval through the bilateral and following your EASA Supplement. A shop that completes the EASA blocks on an 8130-3 without that approval has not issued a valid dual release — it has created a non-conforming document that fails on the EU side and invites questions on the FAA side too.
FAA Form 8130-3 vs EASA Form 1
Same job — proving a released article traces to approved data — under two different authorities. Here is how they line up. Both are forms defined by FAA/EASA guidance and the bilateral, not by any CFR section.
FAA Form 8130-3
Authority: FAA (United States).
Name: Authorized Release Certificate / Airworthiness Approval Tag.
Function: Documents that a part or component was inspected and found in a condition for safe operation relative to approved data.
Domestic Part 145 requirement? No — not required for a domestic maintenance release (§145.213(b) prescribes no form). Customary for parts and required for export and dual release.
Dual release: Can carry the dual release when completed per the MAG to satisfy both the FAA and EASA blocks.
EASA Form 1
Authority: EASA (European Union).
Name: Authorised Release Certificate (EASA Form 1).
Function: The EU equivalent of the 8130-3 — release of a component traced to approved data for the EASA system.
Issued by a US shop? Only if the shop holds EASA approval under the bilateral; used as the alternative to a dual-completed 8130-3.
Governed by: EASA guidance and the MAG — not 14 CFR. Do not attach a CFR cite to it.
The records consequence
Whichever form is used, the records job is the same: the release has to be retained and it has to correlate to the work order by part number and serial number. An auditor on either side traces the part from the aircraft or stock back to the release back to the work order back to receiving inspection. A clean form with no link to the work order is as much a finding as a missing form. This is the same traceability chain described in our 8130-3 parts traceability guide and life-limited parts records guide.
The FAA Records Floor: What §145.219 Actually Says
The EASA side has its own retention expectations under the MAG, but the FAA minimum is fixed and verifiable. Three subsections of §145.219 do the work.
Records demonstrating Part 43 compliance
"A certificated repair station must retain records in English that demonstrate compliance with the requirements of part 43. The records must be retained in a format acceptable to the FAA."
The 2-year retention floor
"A certificated repair station must retain the records required by this section for at least 2 years from the date the article was approved for return to service."
This is the FAA floor. For EASA dual-release work, the MAG and EU customers generally expect longer retention — a dual-approved shop should set one policy that satisfies the longest applicable requirement. See our aviation records retention schedule.
Available to the FAA and the NTSB
"A certificated repair station must make all required records available for inspection by the FAA and the National Transportation Safety Board."
The FAA-side production duty runs to the FAA and the NTSB. EASA's ability to review records tied to its approvals comes through the bilateral oversight arrangement — a separate, parallel access expectation, not part of §145.219(d).
Six Record Types a Dual-Approved Shop Lives and Dies On
Each row separates the FAA obligation (verifiable CFR) from the bilateral layer (MAG/EASA practice) and names the audit finding it prevents.
Work Order (FAA maintenance record)
14 CFR §145.219(a) + §43.9What's Required
Records, in English, demonstrating Part 43 compliance. For maintenance the §43.9(a) content applies: a description of the work performed (or a reference to data acceptable to the FAA), the date of completion, the name of the person performing the work if other than the approver, and the signature, certificate number, and kind of certificate of the person approving return to service. This is the FAA backbone the EASA release sits on top of.
Retention
2 years from date article approved for return to service (§145.219(c)) — the FAA floor
Audit Finding Prevented
Approving signature missing certificate number or kind of certificate; vague work description. Each deficient work order is a separate §145.219(a) finding — and it weakens the dual release built on it.
FAA Form 8130-3 (Authorized Release Certificate)
FAA practice / bilateral (not Part 145-mandated domestically)What's Required
The FAA authorized release certificate. Not required by Part 145 for a domestic maintenance release — §145.213(b) requires certifying airworthiness on the maintenance release but prescribes no form. Customary for parts/components and required for export and for bilateral dual release. For dual release, the 8130-3 is completed per the Maintenance Annex Guidance (MAG) so it satisfies both the FAA block and the EASA block. Should correlate to the work order by part and serial number.
Retention
2 years FAA minimum; EASA-side retention is generally longer under the MAG/customer
Audit Finding Prevented
Released part cannot be traced to its 8130-3 in the records, or the dual-release blocks/statements were not completed as the MAG directs. Inspector flags untraceability and a non-conforming release.
EASA Form 1 (EU authorized release certificate)
Bilateral / EASA (not a 14 CFR document)What's Required
The European Union equivalent of FAA Form 8130-3. A US shop holding EASA approval may instead issue a dual release on a single 8130-3 per the MAG; an EASA Form 1 is the alternative when a separate EU release is used. Because it is a bilateral/EASA document, its content and completion rules come from the MAG and EASA guidance, not from any CFR section — do not cite a 14 CFR provision for it.
Retention
Per MAG/EASA expectations and customer contract — generally longer than 2 years
Audit Finding Prevented
EASA-side release missing or not correlated to the work order; the shop issued an EU release without holding current EASA approval. Treated as a bilateral non-conformity.
EASA Supplement to the repair station manual
Bilateral / MAG (manual itself: 14 CFR §145.207 + §145.209)What's Required
The section a dual-approved shop adds to its repair station manual to hold EASA approval. Documents the EASA-specific procedures the MAG requires (dual-release handling, EASA work-order control, EASA special conditions). The repair station manual is required by §145.207 and its contents by §145.209; the EASA Supplement layered onto it is a bilateral/MAG construct, not a CFR section. The shop must follow it and keep it current, with revision records.
Retention
Current revision controlled; superseded revisions retained per the shop QC policy
Audit Finding Prevented
Work performed does not match the procedures in the controlled EASA Supplement, or the supplement is out of date / its revisions are not controlled.
Receiving inspection records
14 CFR §145.211(c)(1)(i)–(ii)What's Required
Quality control documentation that incoming material is inspected for acceptable quality and that each article receives a preliminary inspection, per the QC manual. For dual-release work, source and conformity verification at receiving is what lets the shop stand behind both the FAA and EASA sides of the release.
Retention
2 years (tied to the work order using the part); longer for EASA-side traceability
Audit Finding Prevented
A part on a dual release has no corresponding receiving inspection record — an open traceability gap that undermines the release on both sides.
Certifying-staff / authorized-signatory roster
14 CFR §145.213(d) (FAA side) + bilateral (EASA side)What's Required
Evidence that each person signing a release is authorized to do so. FAA side: §145.213(d) — at a US repair station, only an appropriately certificated Part 65 mechanic or repairman signs final inspections and maintenance releases. EASA side: the individuals the shop has designated and the EASA approval recognizes under the MAG. A combined roster ties each signer to both authorities.
Retention
Kept current; tied to the records of the work each person signed
Audit Finding Prevented
A dual release signed by someone with no recorded EASA-side authorization, or whose Part 65 certificate / scope does not cover the work. Both authorities can question every affected release.
Related: Part 145 & FAA Aviation Compliance
What an Auditor Cross-Checks on Dual-Release Records
An audit of EASA dual-release work runs the same traceability logic as an FSDO §145.219 records review, plus the EASA-specific layer the MAG adds. The sequence is predictable — here is what gets pulled and in what order.
Dual-release work order sample pull
The auditor selects a sample of completed dual-release work orders and checks each against the §43.9(a) four-element content standard — work description or data reference, completion date, performer name where applicable, and the approving signature with certificate number and kind of certificate. A defective §43.9 entry undermines the dual release built on it.
How to pass this step cleanly: A clean §43.9 work order is the foundation of every defensible dual release. Get the FAA backbone right first; the EASA layer cannot rescue a defective base record.
Release-document trace — 8130-3 / EASA Form 1 to work order
For each released part, the auditor traces from the release document (the dual-completed 8130-3 or the EASA Form 1) back to the work order and forward to where the part was installed, matching part number and serial number across documents. A release that does not correlate to its work order is a traceability finding on both sides.
How to pass this step cleanly: Keep a cross-reference that links each release document to its work order and receiving inspection by part and serial number. Auditors from either authority follow the same trace.
EASA Supplement conformity check
The auditor confirms the dual-release work actually followed the procedures documented in the controlled EASA Supplement to the repair station manual — EASA work-order control, special conditions, and dual-release handling. Work that diverges from the current supplement, or a supplement whose revisions are not controlled, is a bilateral non-conformity.
How to pass this step cleanly: Treat the EASA Supplement with the same revision discipline §145.207 imposes on the rest of the manual. The version in use on the shop floor must match the controlled, current version.
Signatory authorization — both sides
The auditor cross-checks the name on each dual release against authorization on both sides: the Part 65 certificate that §145.213(d) requires for the FAA release, and the EASA-side authorization the shop designated under the MAG. A signer missing standing on either side calls every release they signed into question.
How to pass this step cleanly: Maintain one combined authorized-signatory roster tying each signer to their Part 65 certificate and EASA-side authorization, with effective dates. It pre-answers this check for both authorities.
Receiving inspection and parts source
For parts on the sampled releases, the auditor verifies a receiving inspection record exists (per the QC manual under §145.211) and that source/conformity was verified. A dual release on a part with no receiving inspection record is an open traceability gap that weakens the release on both systems.
How to pass this step cleanly: Receiving inspection is where dual-release traceability is won or lost. No part should reach a dual release without a receiving record linked to it.
Retention check — FAA floor and EASA-side expectation
The auditor confirms records meet the §145.219(c) 2-year FAA minimum and, for EASA dual-release work, the generally longer retention the MAG and EU customers expect. Discarding dual-release records at the FAA floor can satisfy the FAA while breaching the EASA-side expectation.
How to pass this step cleanly: Set one retention policy keyed to the longest applicable requirement and run it on a per-article clock from the return-to-service date. Do not optimize for the FAA 2-year floor on work that has an EASA side.
See how your records score before either authority does
FileFlo's FAA readiness score reviews your record documentation across the §145.219 areas an FSDO inspector checks — work orders, release traceability, receiving inspection, signatory authorization, and retention — and surfaces the gaps that also weaken your EASA dual-release paperwork. Takes under 10 minutes.
Check Your FAA Readiness Score — FreeReconciling Two Retention Clocks
The single biggest records trap for a dual-approved shop is treating the §145.219 2-year minimum as the answer. For EASA work it is the wrong number to optimize for.
Trap 1: The FAA floor is not the EASA expectation
§145.219(c) sets a 2-year FAA minimum from return-to-service approval. The MAG and EU operators generally expect dual-release records to be kept materially longer, and a part can travel with its EASA Form 1 / dual 8130-3 far beyond two years. Discarding dual-release records at the FAA floor can leave you compliant with the FAA but exposed on the EASA side.
Trap 2: The clock runs from return-to-service approval, not the work date
The §145.219(c) clock starts on the date the article was approved for return to service — the date of the approving signature — which can fall later than the date the work was physically performed. Purging by work date alone risks disposing of records still inside the mandatory window, on either side.
The practical answer: one policy, keyed to the longest requirement
Rather than run two clocks, set a single retention policy that satisfies the longest applicable obligation — the FAA floor, the EASA-side expectation under the MAG, and any customer contract — and run it on a per-article basis from the return-to-service date. Digital storage makes the extra years essentially costless, and it removes the risk of disposing of a record an FAA inspector, an EASA-side audit, an operator, or an insurer later needs.
How this connects to the rest of your Part 145 records
EASA dual release does not change the FAA fundamentals — it sits on top of them. The quality control system at §145.211, the manual at §145.207 and its contents at §145.209, inspection and release at §145.213, and recordkeeping at §145.219 are the foundation the EASA Supplement and dual release are layered onto. A weakness in any of them flows straight into your EASA work.
For the FAA-only records picture, see our Part 145 recordkeeping requirements, the Part 145 audit binder inspectors ask for, and how dual-release parts paperwork ties into FAA Form 337 major repair and alteration records and airworthiness directive compliance records.
Where a Document Intelligence Platform Fits in Dual-Approval Records
FileFlo is a compliance document intelligence platform — a read-only proof layer that sits alongside the maintenance stack and makes the records you already have audit-ready. It does not perform maintenance, hold your repair station certificate, issue 8130-3 tags or EASA Form 1, or grant EASA approval; those come from your certificated personnel and the FAA/EASA bilateral process. It handles the document compliance layer those systems leave exposed.
For a dual-approved shop specifically, FileFlo classifies inbound documents (work orders, 8130-3 and EASA Form 1 releases, receiving inspection records, certifying-staff rosters, EASA Supplement revisions) against the right requirement, flags incomplete §43.9 elements before they become findings, tracks both the §145.219(c) 2-year FAA clock and any longer EASA-side retention you configure, links releases to their work orders and receiving records by part and serial number, and assembles an audit-ready binder organized the way a records review actually proceeds — for an FSDO inspector or an EASA-side audit. What takes a quality manager a full day to assemble by hand before an audit takes under 60 seconds in FileFlo.
Classify FAA and EASA-side documents
Upload any work order, 8130-3, EASA Form 1, receiving record, or EASA Supplement revision — FileFlo classifies it against the right requirement and flags missing §43.9 elements before an auditor does.
Dual-release traceability cross-reference
Release documents, work orders, and receiving inspection records are linked by part number and serial number, so the trace an auditor on either side follows is surfaced on one screen.
Two-clock retention tracking
Per-article retention clocks run from the return-to-service date — both the §145.219(c) 2-year FAA floor and a longer EASA-side / customer policy you configure. Records nearing disposal surface in the 90/60/30-day queue.
Audit binder for either authority
Generates a records packet organized the way a §145.219 review proceeds — work orders, release traceability, receiving inspection, signatory authorization, and retention — usable for an FSDO inspector or an EASA-side audit.
FileFlo does not issue airworthiness releases, grant EASA approval, perform maintenance, or run your quality or safety program. It keeps the documents that prove those systems exist and are maintained — audit-ready, at the moment an FAA or EASA-side auditor asks. It does not replace your accountable manager, quality manager, certificated personnel, or the bilateral approval process.
Pricing: Starter $89/month, Professional $299/month. 5-day free trial, no credit card required. Learn more at FileFlo for Part 145 Repair Stations.
Frequently Asked Questions
Is "EASA Part 145" a separate FAA regulation a US repair station has to follow?
No. A US repair station is certificated under 14 CFR Part 145 — that is the only set of repair-station rules in the Federal Aviation Regulations. There is no FAA rule called "EASA Part 145." EASA Part 145 is the European Union maintenance organization regulation, and a US shop does not become EU-certificated. Instead, under the US-EU Bilateral Aviation Safety Agreement (BASA) and its Maintenance Annex Guidance (MAG), the FAA can issue a US Part 145 repair station EASA approval through a supplement to the repair station manual — the EASA Supplement. The shop stays under 14 CFR Part 145; the supplement and the MAG are bilateral-agreement and FAA-guidance documents layered on top, not additional CFR sections.
What is the EASA Supplement to the repair station manual, and is it required by CFR?
The EASA Supplement is a section a US Part 145 repair station adds to its repair station manual to obtain and hold EASA approval under the bilateral agreement. It documents the additional EASA-specific procedures the MAG requires — items such as how the shop handles dual release, how it controls EASA work orders, and how it meets the EASA special conditions. It is not a 14 CFR requirement: the repair station manual itself is required by 14 CFR §145.207 and its contents by §145.209, but the EASA Supplement exists because of the BASA/MAG, not the FARs. In practice, the supplement is reviewed and accepted through the FAA per the bilateral process, and the shop must follow it the same way it follows the rest of its manual.
What is the difference between FAA Form 8130-3 and EASA Form 1?
Both are authorized release certificates that document a part or component was found in a condition for safe operation, but they are issued under different airworthiness authorities. FAA Form 8130-3 (Authorized Release Certificate / Airworthiness Approval Tag) is the FAA document; EASA Form 1 is the European Union equivalent. They serve the same function — traceability of a released article to approved data — for their respective systems. Under the US-EU bilateral agreement, an FAA-certificated repair station that also holds EASA approval can issue a dual release on a single FAA Form 8130-3 by completing it to satisfy both the FAA block and the EASA block per the MAG, rather than issuing a separate EASA Form 1. The mechanics of which boxes to complete and what statements to add are set by the MAG, not by any CFR section.
What is a "dual release" and when does a US repair station need one?
A dual release is a single release document — typically an FAA Form 8130-3 completed per the MAG — that approves an article for return to service under both FAA and EASA airworthiness systems at the same time. A US Part 145 repair station needs a dual release when the article it maintained is destined for an EU-registered aircraft or an EASA-regulated operator that requires EASA-acceptable release paperwork. The shop must hold EASA approval (via the bilateral process and its EASA Supplement) to issue the EASA side. Domestically, no dual release is needed — a §43.9-compliant maintenance release suffices for the FAA, and even the 8130-3 is not required by Part 145 for a domestic release; §145.213(b) requires certifying airworthiness on the maintenance release but prescribes no form.
Do EASA-approved repair stations have to keep records longer than the §145.219 2-year minimum?
Often, yes — but the longer clock comes from the bilateral agreement and the customer, not from 14 CFR. The FAA floor is fixed: 14 CFR §145.219(c) requires retaining the records required by that section for at least 2 years from the date the article was approved for return to service. The MAG and EASA expectations for records tied to EASA dual-release work are generally longer, and EU operators routinely require release records to travel with the part for far longer than 2 years. Because the EASA side is governed by the bilateral/MAG rather than the FARs, treat the §145.219 2-year figure as the FAA minimum and the EASA-side retention as a separate, generally longer obligation set by the MAG and the customer contract. The practical answer for a dual-approved shop is a single retention policy that satisfies the longest applicable requirement.
Who is authorized to sign a dual release at a US repair station?
For the FAA side, 14 CFR §145.213(d) provides that at a US-based repair station, only an employee appropriately certificated as a mechanic or repairman under Part 65 is authorized to sign off final inspections and maintenance releases (foreign repair stations are addressed separately). The EASA side adds its own authorization layer through the bilateral process: the individuals who may sign the EASA portion of a dual release are those the shop has designated and the EASA approval recognizes under the MAG. In practice a dual-approved shop maintains an authorized-signatory or certifying-staff roster that ties each signer to both their Part 65 certificate and their EASA-side authorization, so an auditor from either authority can confirm the person who signed had the authority to do so.
What does an EASA or FAA auditor cross-check on dual-release records?
An audit of EASA dual-release work follows the same traceability logic as a §145.219 FAA records review, plus the EASA-specific layer. An auditor typically: pulls a sample of dual-release work orders; verifies the FAA-side content meets §43.9(a) (work description or data reference, completion date, performer name where applicable, and the approving signature with certificate number and kind of certificate); confirms the release document (8130-3 completed for dual release per the MAG, or EASA Form 1) is present and correlates to the work order by part and serial number; checks that the work followed the procedures in the EASA Supplement; and confirms the signer was authorized on both sides. Missing or mismatched release paperwork and signers without recorded EASA-side authorization are common findings.
Does FileFlo issue 8130-3 tags or grant EASA approval?
No. FileFlo is a compliance document intelligence platform — a read-only proof layer. It does not perform maintenance, hold the repair station certificate, issue 8130-3 tags or EASA Form 1, or grant EASA approval; those come from your certificated personnel and the FAA/EASA bilateral process. What FileFlo does is classify the documents you already generate — work orders, 8130-3 and EASA Form 1 releases, receiving inspection records, certifying-staff rosters, EASA Supplement revisions — against the right requirement, flag incomplete §43.9 elements, track the §145.219 2-year clock and any longer EASA-side retention you configure, and assemble an audit-ready binder for either authority. It is the documentation layer, not the maintenance or certification authority.
Chad Griffith
Founder, FileFlo — compliance document intelligence
FileFlo helps aviation operators and repair stations keep their compliance documents classified, indexed, and audit-ready. This article is a compliance-document perspective on holding EASA approval under the US-EU bilateral — it is not legal, airworthiness, or A&P/IA certification advice, and it is not a substitute for your accountable manager, quality manager, certificated personnel, or an aviation attorney on any specific scenario. FAA recordkeeping requirements are stated from 14 CFR; EASA, MAG, and BASA items are described as bilateral-agreement and FAA guidance.
More Aviation Compliance Resources
Part 145 Recordkeeping Requirements (§145.219)
Work orders · 8130-3 traceability · 2-year retention
Part 145 Audit Binder — What Inspectors Ask For
FSDO surveillance · the records review sequence
PMA Parts Traceability & 8130-3 Records
Approved data · release-tag correlation
FAA Form 337 — Major Repair & Alteration Records
14 CFR §43.9 · Appendix B disposition
Airworthiness Directive (AD) Compliance Records
14 CFR Part 39 · recurring vs one-time
Life-Limited Parts Records Requirements
Back-to-birth traceability · §91.417
Part 91 Aircraft Records Requirements
§91.417 status records · §91.419 transfer
Aviation Records Retention Schedule
How long to keep each record type
Know where your dual-release records stand before the audit
FileFlo's FAA readiness score reviews your record documentation across the areas both an FSDO inspector and an EASA-side audit examine — §43.9 work orders, 8130-3 / EASA Form 1 release traceability, receiving inspection, signatory authorization, and retention. Takes under 10 minutes. No credit card required.
5-day free trial · No credit card required · Starter $89/mo · Professional $299/mo