The blog is co-authored by Eric Geldenhuys, a candidate attorney.

The South African Civil Aviation Authority (SACAA) has enforced a regulatory change affecting the general aviation sector: the strict application of a 12-year engine overhaul requirement for certain aircraft engines, including those manufactured by Textron Lycoming, Teledyne Continental, Pratt & Whitney and Rotax.  The requirement applies regardless of the engine’s condition or flight hours logged.

Although no grounding directives or notices have been issued, affected non-compliant aircraft cannot be flown until they are compliant with the 12-year engine overhaul requirement. 

Former regulatory landscape and withdrawal

For over two decades, Aeronautical Information Circular (AIC) 18.19 exempted certain aircraft owners and operators (Affected Parties) from complying with the 1997 Civil Aviation Regulations (CARs) regarding the manufacturers’ calendar requirements for engine overhaul.  Affected Parties could previously defer the calendar based required engine overhaul and instead maintain and service the affected aircraft based on usage.   

In 2023, the SACAA initiated a review of all previously issued AICs to ensure alignment with the current regulatory framework.  During this review, SACAA determined that AIC 18.19 was not consistent with the 2011 CARS.  As a result, the exemption provided by AIC 18.19 was withdrawn.  In December 2023 – to address the regulatory gap created by the withdrawal and to allow the industry time to prepare for compliance with current regulations – the Director of Civil Aviation exempted Affected Parties from complying with the latest aviation regulations for a period of 360 days, implementing a transitional period.

SACAA’s rationale

The SACAA stated that the withdrawal of AIC 18.19 was necessary to ensure compliance with the latest safety standards and to align with manufacturer’s maintenance requirements; and clarified that AICs cannot supersede the manufacturers’ maintenance requirements.

The SACAA’s mandate is to ensure that all aircraft are maintained in accordance with the manufacturer’s manuals, including adherence to service bulletins and overhaul intervals.

The new regulatory landscape

With the withdrawal of AIC 18.19, Affected Parties are required to comply fully with CAR 43.02.5 and the associated Civil Aviation Technical Standards (CATS) 43.02.5, as well as specific maintenance requirements and recommendations set out by engine manufacturers.

Industry impact

The enforcement of the 12-year overhaul rule is reported to have led to the constructive grounding of non-compliant light aircraft, and to have had an impact on training schools, private operators, tourism, conservation and the broader aviation value chain including maintenance organisations, spare parts suppliers and insurers.  A concern for Affected Parties is the associated costs for engine overhauls. 

The required engine overhauls and costs have also raised concerns about the viability of many operators, and the private and business aviation sector.  While the SACAA maintains that these measures are essential for safety and legal compliance, they are also engaging with industry stakeholders and manufacturers to seek practical solutions.

There are challenges by specific members of the industry to SACAA’s 12-year overhaul requirement, the status of which is being monitored closely.  The enforcement of the 12-year engine overhaul requirement marks a significant shift in South African aviation regulation.  As the industry adapts to these changes, ongoing dialogue between SACAA and stakeholders will be crucial in balancing safety, compliance, and operational viability. Should you require advice on the impact of this requirement please contact Kiasha Nagiah and Eric Geldenhuys.