South Africa’s “12-Year Engine” Rule: What, Why and What Comes Next

By Garth Calitz

If you've been following South African general aviation, even just casually, the last few months might have felt like witnessing a slow-motion aircraft incident, a growing issue that suddenly becomes unavoidable.

At the core of this situation is a contentious interpretation and enforcement of a "12-year engine" recommendation, which has caused many owners, operators, maintenance shops, and flying clubs to scramble. I have intentionally refrained from commenting until now, but as we await the judgment, I will attempt to explain what the rule actually entails, why the South African Civil Aviation Authority (SACAA) acted as it did, the real-world impacts on aircraft, the industry, and individuals, the arguments from both sides, and what I believe would be sensible next steps for owners and the regulator.

What is the “12-year engine” rule?

In short, a rule requiring certain piston aircraft engines to be overhauled, inspected or otherwise rendered compliant once they reach 12 years of calendar life, regardless of time in service or hours logged, has been applied in a way that makes the 12-year point a de facto mandatory overhaul date for many engines. Historically, many engine manufacturers have recommended periodic overhauls or inspections at both hours and calendar intervals (manufacturers’ manuals differ), but until recently, South African regulators and industry practice often allowed flexibility, particularly in private/general aviation.

That position changed when the SACAA reviewed older Aeronautical Information Circulars (AICs) and decided that AIC 18.19 (issued in 2006) was not aligned with the Civil Aviation Regulations and needed withdrawal or amendment. The regulator has stated its position that where the CARs and the South African Civil Aviation Technical Standards (SA-CATS) require overhaul intervals, the regulator must ensure operators comply; conversely, the regulator argued it cannot usurp manufacturers’ roles by setting maintenance techniques, which is part of why the AIC was identified for review. The SACAA issued media clarification about the withdrawal and the regulatory background in mid-June 2025.

Why did this turn into the crisis it has?

Three connected dynamics turned a technical regulatory matter into a national aviation headache:

1. Scale and timing. When the grace period around the AIC’s withdrawal lapsed, aircraft with engines older than 12 calendar years were suddenly non-compliant for airworthiness certification unless they had undergone an overhaul, inspection, or other manufacturer-approved process. South African reporting and industry groups put the number of potentially affected general aviation aircraft in the low thousands; commonly cited figures range around 1,300–1,400 aircraft. That’s a huge portion of South Africa’s GA fleet, and many of those aircraft are small privately owned trainers, charters and recreational aircraft.

2. Cost and supply chain constraints. A full engine overhaul isn’t cheap. Owners reported costs running into hundreds of thousands, or even over a million rand for some engines, when factoring in parts, labour and logistical delays. That cost, combined with long manufacturer lead times for parts and overhaul slots (Textron Lycoming and Teledyne Continental were specifically flagged as having extended lead times), meant a large, sudden demand collided with a limited global and domestic overhaul capacity. The result: long waiting lists and grounded aircraft.

3. Legal and governance friction. Industry associations, including an AIC 18.19 Task Team made up of major aviation bodies, argued the SACAA had effectively changed the practical legal position without adequate consultation or without demonstrating a safety case that justified the upheaval. In response, the industry sought urgent legal remedies (injunctions and court applications) to suspend enforcement while the dispute was resolved. The dispute has played out in courts and public fora, amplifying uncertainty.

SACAA’s stated reasons (and their legal framing)

The SACAA’s public explanation, while short on sympathetic detail for owners, has two consistent threads:

• Regulatory alignment and risk: AIC 18.19, dated from 2006 and exempted certain aircraft from conforming to CARs dating from 1997. During a broad review of legacy AICs, the SACAA concluded that AIC 18.19 was not aligned with the CARs and presented legal/liability and safety risks. Withdrawing it, the SACAA says, corrects that misalignment and restores regulatory consistency.

• Limits of the regulator’s role: The regulator also stated it is not a manufacturer and cannot prescribe specific maintenance techniques; the appropriate place for overhaul intervals is the manufacturer’s manuals, and operators should comply with those requirements. In short, the SACAA frames the position as enforcing compliance either with CARs/SA-CATS or with manufacturer requirements, not inventing new maintenance science.

Those statements form the SACAA’s public legal justification. Critics accept the need for safety but argue the SACAA could have, and should have, adopted a more pragmatic transition approach, or applied risk-based exemptions, to avoid grounding aircraft en masse while supply and capacity issues are resolved.

The impact on pilots, businesses and flying clubs

The human and economic fallout is real:

• Grounded aircraft and lost flight training hours. Flight schools and clubs that rely on piston-engined aircraft for primary training reported cancellations, squeezed schedules and reduced revenue. Grounded trainers mean fewer new pilots entering the pipeline — an economy-wide effect that ripples into charter services, maintenance jobs and aviation-support businesses.

• Maintenance workshops are overwhelmed. Local AMOs (Approved Maintenance Organisations) reported being swamped. There are long queues to have engines removed, overhauled or inspected, and some local shops lack capacity for complex overhauls and must send components to the manufacturer or overseas, which adds delay and cost. This is further exacerbated by aircraft that have been grounded during maintenance and cannot leave the AMO premises.

• Economic anxiety and job risk. Industry statements warned of knock-on job losses if aircraft remained grounded for months. That anxiety fueled the legal action seeking temporary suspension of enforcement while a workable path forward is negotiated.

• Owners are facing a tough choice. Sell a once-airworthy aircraft for a fraction of its perceived value? Pay for an expensive overhaul? Or wait in a queue and accept grounded status? For many owner-pilots, the emotional hit is as big as the financial one.

Is the rule justified on safety grounds?

This is where the debate becomes technical and nuanced.

Pro-safety argument: calendar life matters. Some engine components deteriorate with age, even if hours are low, corrosion, seal and gasket degradation, and changes in tolerances, and manufacturers historically provide calendar-based guidance for that reason. Applying a calendar limit can therefore be defensible as a conservative safety policy.

Counterargument (industry): A blanket 12-year mandatory overhaul regardless of engine condition or hours logged is blunt and may not represent the best risk management. Instead, industry advocates suggest conditional inspections, borescope checks, compression tests, oil analysis and other condition-based maintenance that can identify engines fit for continued service without a full overhaul. They also argue that regulators should have made an evidence-based safety case for immediate mandatory overhauls before enforcing them in a way that grounds fleets.

At root, both sides say “safety” — the disagreement is about proportionality, evidence and implementation.

Where the law, manufacturers and the regulator intersect

A central technical point is the allocation of responsibility:

• Manufacturers publish service/overhaul intervals and acceptable maintenance practices in engine manuals and service bulletins.

• Regulators set the legal standards for airworthiness (CARs/SA-CATS) and can accept manufacturer procedures as the standard for compliance.

The controversy arose because a legacy AIC had previously given operators latitude; withdrawing it restored a stricter reading of the regulations. The SACAA argues it was correcting a regulatory mismatch; industry groups argue the regulator moved without sufficient consultation or practical accommodations. This tension between legal correctness and implementation pragmatism is common in safety regulation but can be socially costly when an entire sector is affected quickly.

What happens next? legal and practical paths

There are three broad pathways to resolution:

• Judicial review/court decisions. Industry has sought injunctions and the courts have been involved; these decisions can pause enforcement or clarify the regulator’s obligations. Expect litigation to shape the tempo of any practical fix.

• Regulatory mitigation (temporary exemptions, phased timelines). A pragmatic alternative is for the SACAA to issue narrowly tailored exemptions or transition periods (for specific engine types, for engines with recent condition checks, or for training aircraft), coupled with a clear safety framework for inspections. This buys time while supply chains and AMO capacity expand.

• Industry-led technical solutions. Manufacturers and AMOs can accelerate capacity, offer conditional/limited service options, or develop expedited inspection/repair pathways that restore airworthiness without full overhauls where safe and permitted.

A combination of these, court-mediated pauses and regulator-industry negotiated transition arrangements, would probably produce the quickest relief.

Practical advice for aircraft owners and operators right now

If you own or operate an affected aircraft, here are immediate steps to take:

• Confirm your aircraft’s status. Check the engine’s calendar life, documentation, and any recent inspections or condition-monitoring reports. Don’t rely on memory.

• Speak to your AMO and insurer. Ask about interim inspection options, costs, booking lead times, and whether your insurance covers grounded periods or related losses.

• Follow industry group guidance. CAASA, Aeroclub and other representative groups have been collating legal and technical guidance. Align with reputable groups to ensure you’re not acting on hearsay.

• Keep records. Maintain meticulous paperwork for every inspection, part replacement and communication with SACAA/AMOs — this helps both compliance and any later legal or insurance claims.

• Plan financially. If an overhaul is unavoidable, start getting quotes and exploring loan or finance options early. Some owners may consider selling or replacing engines with serviceable spares, if available and legal.

A few personal closing thoughts

The 12-year engine episode is a classic policy failure in the sense that the underlying safety concern (engine calendar life) is legitimate, but the implementation and timing created excessive social and economic harm. Good regulation must be transparent, risk-proportionate and practically deliverable. When enforcement produces mass grounding, affecting training capacity, businesses and livelihoods, it’s a sign the implementation plan needs to be revisited, even if the regulator’s underlying safety obligations are real.

The healthiest outcome would be a coordinated effort: courts and industry agree on a pragmatic temporary path, SACAA publishes a clear, time-bounded mitigation plan tied to objective inspections, and manufacturers/AMOs work to accelerate backlog reduction. That approach preserves safety while minimising unnecessary collateral damage.