Aircraft Maintenance

The workshop is only one part of aircraft maintenance. The International Civil Aviation Organization, or ICAO, distinguishes the operator’s continuing responsibility for airworthiness from the organizations that perform or control maintenance. Its explanation of Annex 6 requires operators to ensure that aircraft remain airworthy under procedures acceptable to the country where they are registered. Operators must also employ a person or group responsible for ensuring that maintenance follows the maintenance control manual. s1

For readers encountering Iran’s aviation industry, this distinction helps interpret claims about technical capability. A report that a company has repaired an aircraft describes an activity; evidence about the organization’s approval, the aircraft concerned, and continuing oversight addresses different questions. ICAO’s guidance discusses operators, approved maintenance organizations, and maintenance control organizations separately. It does not certify any particular Iranian company or establish that a named aircraft is fit to fly. s1

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An Iranian aircraft accident investigation report concerning a Mahan Air aircraft records that the airline held both a continuing airworthiness management organization approval, abbreviated CAMO, and an approved maintenance organization approval, abbreviated AMO. The report identifies the relevant Iranian frameworks as CAO.IRI Part-M and Part-145 respectively. This provides a historical example of the distinction between managing continuing airworthiness and performing approved maintenance within Iran’s regulatory system. s2

The record should be read within its historical scope. An investigation’s description of approvals at the time does not establish their validity in October 2026, their complete technical scope, or the capabilities of other Iranian airlines. It also cannot support a nationwide conclusion about maintenance quality. A current account would require the approval certificates and their scope, together with evidence of subsequent oversight. s2

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Foreign export controls add another layer. In September 2022, the United States Bureau of Industry and Security identified Iranian-operated cargo aircraft that it alleged had flown to Russia in violation of US export controls. Its notice expressly addressed maintenance, repairs, spare parts, refuelling, and other services involving listed aircraft under the stated legal conditions. s3

This notice establishes the US agency’s position and the historical enforcement context. It does not establish that every maintenance transaction involving Iran is prohibited, nor does it measure the technical condition of the aircraft concerned. Treating a trade restriction as a safety inspection would confuse different forms of evidence. Conversely, a domestic technical approval does not itself resolve the separate question of whether an international supplier may lawfully provide a particular service. The current legal position requires updated, transaction-specific documentation. s3

The practical reading framework is therefore to ask who manages airworthiness, who performs the work, what approval covers it, and what support restrictions apply. The inspected evidence explains those distinctions but does not yet support a current directory of Iranian maintenance providers. s1s2s3

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