No, according to Regulation (EU) 2019/779, maintenance workshops are subcontractors of the certified ECM and provide subcontracted maintenance functions. It is the responsibility of the ECM to ensure that the external entities are competent and able to perform the maintenance tasks contracted by the ECM. There are various methods by which the ECM can assess the competence of external bodies. However, external bodies may apply for voluntary certification to provide subcontracted maintenance functions or parts thereof.