If a New Zealand-registered aircraft is operating outside New Zealand, most maintenance on it can be performed and certified for release-to-service (RTS) by a foreign maintenance engineer.

Those engineers, however, must hold:

  • an appropriate Part 66 aircraft maintenance engineer licence (AMEL)
  • an equivalent document issued by a contracting State to the International Civil Aviation Organization (ICAO).

Part 66 Aircraft Maintenance Personnel Licensing

The licence needs to include ratings/privileges for the area of maintenance the maintenance engineer is performing. For instance, if they’re carrying out a 100-hour inspection, they need the appropriate ratings/privileges for the airframe and powerplant.

The maintenance has to be performed and certified according to New Zealand’s Civil Aviation Rules.

Note: all New Zealand-registered aircraft must display a ZK precursor, eg, ZK-XYZ, while operating overseas.


The aircraft is to be maintained to the requirements of Part 43 Subpart B – Maintenance, and Part 91 Subpart G – Operator Maintenance Requirements.

Part 43 General Maintenance Rules

Part 91 General Operating and Flight Rules

The maintenance engineer must use the correct maintenance programme for the aircraft, as required by CAR 91.605 – Maintenance programmes and schedules.

If you’re intending to maintain a New Zealand-registered aircraft being used for commercial operations outside New Zealand, you need to get CAA approval of your organisation.

That’s to ensure:

  • the maintenance meets the standards of CAR 43.53 (eg, the maintenance engineer has the current revision of instructions for continuing airworthiness, technical data, adequate tools and facilities, correct documented parts
  • the maintenance engineer is familiar with aircraft type, including related powerplant, propeller and avionics fit – CAR 43.53(a)
  • they understand the demarcation between the tasks they can perform and what tasks must be performed by a Part 145 certificated maintenance organisation – CAR 43.54
  • the LAME has appropriate rating/privilege on their AMEL – CAR 43.101(5) eg, any avionics work
  • they meet the requirements of CAR 43.103 Requirements for certifying RTS, including operational flight check CAR 43.103(c)
  • RTS certifications are correct – CAR 43.105(a)
  • an appropriate duplicate safety inspection of flight control systems is carried out and certified – CAR 43.113
  • maintenance records requirements are met – CAR 43.69
  • engine ground runs are properly recorded – CAR 43.115.

Part 145 Aircraft Maintenance Organisations Certification

What a foreign AMEL holder cannot do

There are two tasks that cannot be performed nor certified by a foreign Part 66 AMEL holder. They must be performed by the holder of a CAA-issued certificate of inspection authorisation (IA) – Part 66 Subpart E.

The two tasks are:

  • Major modifications and repairs must be in accordance with acceptable technical data, and have appropriate IA conformity inspection and certification. Refer to Part 1 for our definition of major modifications and major repairs. IA conformity certification is required regardless of the source of the acceptable technical data. This includes a manufacturer’s service data (bulletins, instruction, and so on). Acceptable technical data is specified in Part 21 Appendix D.

Part 1 Definitions and Abbreviations

Part 21 Certification of Products and Parts

 Ask us about airworthiness

If you have any questions about this topic, use our contact form, or email certification@caa.govt.nz.