Maintenance & repair · AS9110
MRO quality systems built around the maintenance operation.
Connect maintenance planning, competent people, technical records and release controls into a system your team can run and demonstrate.
Start with a free 15-minute discussion. Scope and fees follow an assessment.
What usually goes wrong.
Airline and lessor audits keep finding the same things
Your regulator may be satisfied, but customer audits are not. This gap is almost always found in records, sub-tier control, or human factors, rather than in the actual maintenance work itself.
Technical records that don't survive scrutiny
The work itself was done correctly, but retrieval is slow, amendment status is unclear, or the record simply cannot prove what the auditor is asking about.
Certifying staff authorisations drift
Scope of authorisation, continuation training, and competence evidence gradually fall out of step with who is actually signing the releases.
Subcontracted maintenance you can't fully evidence
Work that is sent outside is approved only informally, or the evidence that comes back does not match what Clause 8.4 actually expects you to hold.
Repeat error findings
Shift handover, fatigue, and workload keep producing the same category of finding, across different auditors. This is a structural problem, not a training problem.
Moving to AS9110 from ISO 9001 or AS9100
You already have a system in place, but it was built for a different activity altogether. Carrying it across without a proper gap map is exactly how organisations end up arriving at audit unprepared.
What AS9110 asks for that AS9100 does not.
Seven areas account for most of the gap when a maintenance organisation is measured against AS9110C rather than against a manufacturing standard.
Work orders, task cards, and the release chain: evidence that the maintenance actually performed matches what was authorised, and that the record clearly reflects this.
Fatigue, shift handover, and error capture. Findings in this area are common, and are rarely closed simply by writing another procedure - rather, the actual working pattern needs to be examined.
Control of the data you work to, and the records you hand back to the customer: amendment status, retention, legibility, and traceability under audit.
Tool and equipment control, calibration recall, and shelf-life-limited materials, all managed within a live hangar environment rather than simply on a spreadsheet.
Qualification, authorisation scope, and continuation training for the people who actually sign the release - with evidence of real competence, rather than just attendance.
Alignment with International Civil Aviation Organization (ICAO) Annex 19 safety-management expectations, along with whatever your regulator specifically requires of your Safety Management System (SMS).
Clause 8.4 applied to subcontracted tasks: who you are sending work to, how they were approved in the first place, and how you prove the work came back exactly right.
Where MRO audits actually find you.
Four areas account for most customer and regulatory findings in a live hangar environment - this is about the operation itself, not just the paperwork behind it.
CAR-145, issued by the Directorate General of Civil Aviation (DGCA), is the regulatory permission that allows you to release aircraft to service. AS9110C is the voluntary quality standard that your OEM, airline, and lessor customers judge you against instead. The two run on overlapping evidence, so rather than maintaining a maintenance organisation exposure sheet, quality manual, and audit schedule twice over, we build these once and map them to both. Gaps usually surface where CAR-145 compliance is assumed to satisfy AS9110C by default. It does not.
Shelf-life-limited consumables and materials that are tracked only by spreadsheet in a live hangar tend to drift out of date faster than the spreadsheet itself gets updated. What the system actually needs is a positive control - expiry flagged at the time of receipt, blocked at the point of issue, and reconciled on a fixed cycle - rather than a register that someone checks only when they happen to remember.
Calibration recall for tooling and test equipment is one of the most common findings in MRO audits, simply because the tool that is overdue is still sitting in the toolbox, looking identical to the one that is current. Recall needs to be physically enforced at the point of use, rather than just logged in a register.
Subcontracted maintenance tasks need documented approval of the sub-tier provider, verification criteria agreed upon before the work goes out, and evidence retention that proves the work came back matching exactly what was authorised. Informally-approved subcontractors are, by far, the single most common Clause 8.4 finding across maintenance environments.
Recurring findings recur because the structure produces them.
Four systems-led disciplines are used to find and fix that structure - with AI-assisted analysis applied where it genuinely improves speed and discipline: mapping audit evidence, spotting process gaps, and structuring corrective-action follow-up.
Systems Thinking
Understanding why your recurring findings keep recurring - and how to actually make them stop, by fixing the structure rather than blaming operators or tools.
System Dynamics Modelling
How delays, feedback, and incentives drive quality behaviour over time - and where just one small change can move the whole system.
Critical Thinking
We separate the certificate from the actual capability, and test every assumption an auditor will test - before they get the chance to.
Design Thinking
We build the system around your people, culture, and behaviour, so that quality survives real production - rather than just audit day.
How to assess the evidence behind an advisory approach.
Every AS9110C consultant will tell you that your hangar is close to ready. Before you sign anything with them, ask them to actually show you the evidence - rather than just tell you.
"Your CAR-145 approval basically covers AS9110C."
It does not. CAR-145 is the regulatory permission that allows you to release aircraft to service, whereas AS9110C is a separate, voluntary standard that your airline, lessor, and OEM customers use to judge you, based on different evidence altogether. Ask them specifically which one you are being assessed against.
"We'll tighten up your technical records."
Ask them how, exactly. Amendment status, retention, legibility, and traceability under audit are four separate failure points - a consultant who cannot name which one is your actual gap has not diagnosed anything yet.
"Calibration is under control."
The most common finding in a Maintenance, Repair and Overhaul (MRO) audit is an overdue tool still sitting in the toolbox, looking exactly like a current one. "Under control" should mean physically enforced at the point of use, rather than just logged on paper - ask to actually see it enforced.
"We've done AS9100 work - MRO is basically the same."
It is not the same. Human factors, technical records, and certifying-staff competence are maintenance-specific areas that a manufacturing-only consultant has simply never audited before. Ask them which hangars they have worked in, and what exactly they found there.
This is for you if…
Who you'd actually be working with.
Former Country Quality Leader, Boeing India (AS9100D scope: 9 sites, 5,000+ engineers). IAQG/Probitas-authenticated AS9100D auditor.
Boeing · Schneider Electric · ABB · safety-critical field engineering
Former Country Quality Leader · AS9100D Management Representative
AS9100D certification scope - one of the largest Boeing operations outside the continental US
Authenticated AS9100D aerospace auditor
Aerospace new product introduction - advanced product quality planning and production part approval
Certified CMMI Practitioner (ISACA) on the current V3.0 model
Trainer in Systems Thinking, System Dynamics Modelling, Critical Thinking and Design Thinking
Start small, prove value, then scale.
There is no year-long contract before we both actually know your real gaps.
15-Min Readiness Diagnostic
Free · where you are, what blocks approval, and an honest read on fit.
Flight Plan Workshop
Half or full-day on-site · gap snapshot and dated route map · fixed fee, quoted before booking.
Certification Advisory Retainer
Alongside you through readiness, implementation and audit preparation · scoped after the workshop.
One advisory, three aerospace quality standards.
Manufacturing, maintenance, and distribution are all audited against different standards, but by the same OEM supplier-quality teams. Please pick the one that actually matches what you do.
AS9110C is the system. These are the licences to work in India.
For a maintenance organisation in India, the certificate and the regulatory approval are two different tests run by two different bodies. The same operating system has to satisfy both, and keep doing so between surveillance visits.
| Authority | What it covers | Who needs it | Where AS91XX fits |
|---|---|---|---|
| DGCA - CAR-145, CAR-M and CAR-147 | Civil maintenance. CAR-145 is the approval of maintenance organisations under Rule 133B of the Aircraft Rules 1937 (accountable manager, quality manager, certifying staff, facilities, procedures and release). CAR-M covers continuing airworthiness management; CAR-147 covers maintenance training organisations. | MRO providers, component repair shops, CAMO functions and training organisations serving Indian operators and lessors. | AS9110C and CAR-145 test the same things - competence and authorisation, human factors, tooling and calibration control, part traceability and release - but CAR-145 is the licence to work. Build one system that satisfies both and keep it running between audits. |
| DGAQA (Directorate General of Aeronautical Quality Assurance, Department of Defence Production, MoD) | Government quality assurance and final acceptance of military aircraft, UAVs, aero-engines, airborne systems, avionics, armaments and consumables across design, production, repair, overhaul and life extension. DGAQA also approves firms and their quality management systems, and carries out capacity assessment and registration of firms and test laboratories. | Any supplier whose product is accepted by a Government QA representative: direct MoD suppliers, DPSU sub-tiers, repair and overhaul shops on military stores, test laboratories. | DGAQA registration is a capacity and QMS assessment followed by product acceptance on the floor. An AS9100D or AS9110C system gives the evidence structure; what DGAQA tests is whether the inspection, traceability and non-conformance records hold up at acceptance. |
| CEMILAC (Centre for Military Airworthiness and Certification, DRDO) | Military airworthiness. Type certification and design evaluation of military aircraft, aero-engines, airborne stores, software and electronic hardware under the MoD document DDPMAS, delivered through its Regional Centres for Military Airworthiness (RCMAs). Type approval carries the authority to produce the item under RCMA supervision. | Firms that design, develop, modify or produce airborne items for the Indian Air Force, Navy, Army aviation, DRDO programmes or the DPSUs. | The RCMA samples a working configuration-control, traceability and qualification record. AS9100D, with DO-178C / DO-254 evidence for software and electronics, is what that record is usually built on, but the certificate alone is not the approval. |
| MoCA, DGCA and QCI - Drone Rules 2021 | Unmanned aircraft. A drone model needs a Type Certificate before it can be manufactured, imported or operated in India. The prototype is tested by a certification body approved by the Quality Council of India (currently TQ Cert, UL India and Bureau Veritas); DGCA issues the certificate. The rules allow 60 days for the certification body and 15 days for DGCA once the file is complete. | Drone and UAS OEMs, and the parts, motors, batteries, airframe and software suppliers feeding them. | The Type Certificate certifies the design. Repeatable production, configuration control and traceability are what keep an OEM's certificate valid and what its suppliers are audited for. AS9100D-style process ownership is the shortest route to that. |
Questions we're asked first.
Is AS9110 different from AS9100, or an add-on to it?
AS9110C is a separate standard, built on the same ISO 9001 foundation, but with the manufacturing requirements replaced by maintenance-specific ones. If you overhaul, repair, or maintain aircraft or components, AS9110C is the correct standard for you - not AS9100D. Organisations that both manufacture and maintain sometimes hold both certifications, scoped to their different activities.
Do we need AS9110 if we already hold a national maintenance approval?
They actually do two different jobs. Your CAR-145 approval is the regulatory permission that allows you to release aircraft to service. AS9110C, on the other hand, is a voluntary quality-management standard that customers - airlines, lessors, OEMs, and defence buyers - use to judge how well you actually run the organisation behind that approval. Many MROs hold both, and since the evidence overlaps heavily, building one well also reduces the effort needed for the other.
We're already AS9100 certified. Can we move to AS9110?
Yes, and this is actually a common route for organisations whose work has shifted from build to maintenance. Much of your existing system carries over - the gap is usually concentrated in maintenance process control, technical records, human factors, and certifying-staff competence. The diagnostic identifies which of these are real gaps for you specifically, rather than simply assuming all four apply.
How long does AS9110C readiness take?
The route map gives you actual dates after the workshop, rather than a guess before it. As a rough anchor: a manufacturer moving from ISO 9001 to AS9100D typically plans for 6–9 months. An MRO adds maintenance-specific processes on top of that same foundation, so please plan for at least the same duration, and longer still if technical records and human-factors practice need to be rebuilt.
Do you issue the AS9110 certificate?
No - and this is deliberate. Suriyavaan is an independent advisory led by an auditor-practitioner, rather than a certification body. Building your system and then also auditing it would be a clear conflict of interest. We build the system that passes your certification body's audit, and most clients simply keep the certification body they already use.
What does this cost?
The diagnostic itself is free. The Flight Plan Workshop is a fixed fee, quoted before you book. Advisory retainers are scoped only after the workshop - so that you know your actual gaps, and the full cost, before committing to anything long-term. Engagements are sized for Micro, Small and Medium Enterprises (MSMEs), rather than for OEM-level budgets.
Ready to find out what's blocking approval?
Book a free 15-minute diagnostic with us. You will get an honest read on your readiness, the likely blockers, and the most practical next step forward - whether or not we end up working together.
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