Perhaps I am missing something here but;
The owner has been responsible until not for ensuring that the paperwork was up to date, the mods and AD's, service letters and so forth were incorporated as required and that the required maintenance was completed when it was due not to mention that lifed components were changed at the end of their life, not after.
Many countries were very clear in this respect and required owners to be registered with the manufacturer for updates and to have or have the required access to the required manuals which had to be up to date etc.
When it came to the C of A renewal, the maintenance organisation and the owner completed the required paperwork exercise that renewing the C of A mostly was and hey presto the C of A was renewed.
Do we now have lots of owners who did not do the required paperwork, did not have the required information and simply blindly relied on others in the aviation world to look after them?
Do we also then have maintenance organisations who factored a certain amount of paperwork time into the C of A renewal costs who are now saying that they will now charge extra for the same paperwork exercie?
This EASA law is for Harmonisation if in order to harmonise with the standard you need to do lots of extra work then ask yourself why could this be if you were at the required standard?
I hope plenty of UK owners sell their aircraft. I would offer 50% of the value because it is becoming clear that there are lots of owners who did not maintain their paperwork etc to the required standard and if they are selling to avoid the cost, I am going to factor that into any offer.
Like I said, wait 3 to 5 years and see what difference there really is. Like JAR-FCL the answer will be none for bad but few for good.
Regards,
DFC