Opinion: Does Compliance Role Change If The Government Shuts Down?

The congressional politics surrounding the U.S. federal government shutdown that began Oct. 1 are well covered elsewhere. In aerospace, the government disruption—an ongoing theme in 2025 regardless of the executive branch’s funding—is merely a reminder that compliance is the responsibility of the certificate holder.

An FAA work stoppage ties up numerous projects requiring government action. In early October, the Aeronautical Repair Station Association (ARSA) spent time educating maintenance providers that the compliance date of Change 10 to the Maintenance Annex Guidance (MAG) between the FAA and the European Union Aviation Safety Agency was not one of them.

MAG 10 required the certificate holder to provide a statement to the FAA on whether the repair station had implemented a safety management system (SMS) or would do so on or before Dec. 31. Apparently, the U.S. repair stations were sending updated supplements and statements to untended email inboxes in a bid for FAA inspector “approval.” Multiple concerned members asked ARSA about continuing work for European customers while awaiting agency response. The MAG clearly outlines what the agency should do, but the certificate holder has no power to compel the FAA to do so. What a repair station can do is defend against government inaction by proving its submission was made in an appropriate and timely manner.

All written communications with the government should be documented and chronicled, and the MAG compliance example is a perfect demonstration of why this practice is so important.

The details of the updated MAG are available at arsa.org/mag, and specific guidance regarding SMS implementation language is available for ARSA members. The general lesson is that an agency’s inability to provide “assurance of compliance” cannot interfere with the “act of compliance.” Applicants and certificate holders must comply with the rules, whether purely 14 CFR for domestic repair stations or the requirements established under the bilateral agreements between the U.S. and other jurisdictions. Private industry must uphold the aviation safety rules regardless of the politics of the moment.

This answer serves in one form or another as the basis of ARSA’s member guidance: Applicants and certificate holders must be able to show how they comply with the rules, period. No person can use a government shutdown—or any other intransigence from those supposedly charged with serving the public—to avoid compliance and, more important, knowing how that compliance is demonstrated.

Brett Levanto is vice president of operations of Obadal, Filler, MacLeod & Klein, managing firm and client communications in conjunction with regulatory and legislative policy initiatives. He provides strategic and logistical support for the Aeronautical Repair Station Association.