Who Can Sign a Maintenance Release in Canada?

A maintenance release is the certification, made by signature, that aircraft maintenance was performed to the applicable standards of airworthiness. Per CAR 571.10(1), no person may sign a maintenance release — or let someone they supervise sign one — unless the applicable Standard 571 airworthiness requirements have been met. Except in a specific case allowed by CAR 571.10(4), the release must include the statement "The described maintenance has been performed in accordance with the applicable airworthiness requirements" (CAR 571.10(2)).

Under CAR 605.85(1), no person may conduct — or permit — a take-off in an aircraft that has undergone maintenance unless that maintenance has been certified by a maintenance release signed under CAR 571.10. The release is what closes the loop between "maintenance was performed" and "the aircraft may legally fly again."

There is one broad exception: elementary work. CAR 605.85(4) and CAR 571.10(3) both state that no maintenance release is required for tasks designated as elementary work in the Aircraft Equipment and Maintenance Standards — but CAR 571.10(3) ties that exemption to who performs the task: the pilot, for a glider, balloon, or unpressurized small piston aircraft not operated under Part IV or VII (para. (a)); a person trained and authorized under the flight training unit's or air operator's maintenance control manual (MCM), for aircraft operated under Part IV or VII (para. (b)); or a person trained under a private operator's operations manual, for aircraft operated under Part VI, Subpart 4 (para. (c)). Standard 625, Appendix A confirms its list of elementary-work tasks is exhaustive — "if a task is not listed, it is not elementary work" — and that such work "need not be performed by a holder of an AME licence, or by persons working under an AMO certificate," while also stating that "the owner is responsible for controlling authorizations to persons who may perform elementary work," and that for aircraft operated under Subpart 406 or Part VII, each task must be individually listed in the operator's maintenance control manual or operational manual, with the required training referenced. Everything below concerns work that is not elementary work — i.e., work that does require a maintenance release.

CAR 571.11(1) sets the baseline rule: except for CAR 571.11(2)'s and (7)'s narrow, defined exceptions, only the holder of an AME licence issued under Part IV, "specifying a rating appropriate to the aeronautical product being maintained," may sign a maintenance release. The rating has to match the work — a licence alone, without the applicable rating, is not enough.

Standard 566.03(8)(a) defines what each rating actually covers: M1 (non-turbojet aircraft built to Standard 522/523/523-VLA/527/549 and equivalent standards), M2 (all aircraft not covered by M1, excluding balloons), E (aircraft electronic systems — communication, navigation, auto flight, and related electrical elements of other systems), S (aircraft structures), and Balloons. Standard 566.03(8)(b) additionally gives M1 and M2 holders maintenance-release privileges for turbine-powered helicopters and SFAR 41C aeroplanes. See our M1 vs M2 and E Licence guides for a closer look at what each rating covers.

CAR 571.11(1) already limits who may sign at all, but for aircraft operated commercially the CARs add a further, separate layer: CAR 571.11(3) states that — except as provided in CAR 571.11(7) — no one may sign a maintenance release for an aircraft operated under Part IV or Part VII (or parts intended for it) unless they are authorized to sign, with a rating of a category appropriate to the work performed, under a maintenance policy manual (MPM) established by an approved maintenance organization (AMO) holding a certificate under CAR 573.02 — or, for maintenance performed outside Canada, under an equivalent foreign document established by an organization approved under an applicable international agreement (CAR 571.11(3)(b)).

Standard 573.05 is direct about the consequence: "An AME licence does not automatically qualify an individual to sign a maintenance release under an AMO authority. The authority for a person to sign a release within the AMO's jurisdiction shall be separately granted by the AMO... following specific training in regards to AMO procedures and other regulatory training." Doing the work, and being licensed for that category of work, are necessary — but for Part IV/VII operations, they are not sufficient on their own.

Standard 573.05(1) requires an AMO to issue a formal authorization to each individual it permits to sign a maintenance release — an authorization commonly known as an Aircraft Certification Authority (ACA). A related authorization, the Shop Certification Authority (SCA), covers a narrower case: signing for work performed on parts intended for aircraft installation, under CAR 571.11(2)(c) (Standard 573.05(2)). Standard 573.10(1)(o) further requires the AMO's MPM to identify every person authorized to sign under CAR 573.05.

This requirement is specifically tied to Part IV/VII operation (CAR 571.11(3)) — it does not apply to every maintenance release. See "Why the exact aircraft, task, and context matters" below.

A separate condition applies to transport category aeroplanes and turbine-powered helicopters specifically: CAR 571.11(4) requires the signer to have either completed Minister-approved maintenance training applicable to the specific type of aircraft, engine, or system (paragraph (4)(a)), or to have held an applicable type rating issued by the Minister before August 1, 1999 (paragraph (4)(b)).

CAR 571.11(5) sets out one exception: the holder of an applicable AME licence may sign for any of the specific types of work listed in CAR Schedule III without the type course or the pre-1999 type rating. Whether a given task actually falls on that Schedule III list is itself fact-specific.

Elementary work is exempt from the maintenance release itself, and — per Standard 625, Appendix A — from needing an AME licence or AMO certificate to perform it. It is not exempt from oversight: the owner is responsible for controlling who is authorized to perform it, and CAR 571.10(3) further limits that to specific categories of person tied to how the aircraft is operated (see above). None of the AME-licence, AMO/ACA, or type-training conditions covered elsewhere in this guide apply to elementary work — but confirming a task genuinely is elementary work, and that whoever performs it fits one of CAR 571.10(3)'s categories, comes first.

None of these conditions can be answered from the rating alone. The same person might be able to sign one task and not another, depending on: whether the task is elementary work at all (CAR 571.10(3)); whether the aircraft is operated under Part IV/VII, which brings in the AMO/ACA requirement (CAR 571.11(3)); whether it is a transport-category aeroplane or turbine-powered helicopter, which brings in the type-training requirement (CAR 571.11(4)/(5)); and whether the licence's rating actually covers the aircraft or system involved (Standard 566.03(8)(a)).