Are most radio repairs not legally possible in EASA-land?

I was chatting yesterday to an old hand in this game…

The only way to legally repair any “radio” box in EASA-land is by an EASA 145 company whose approval includes that type of product. Example.

So what about the large number of little avionics repair shops all over the place? They have these options:

• have an “alliance” with a 145 holder who generates the paperwork and “under whose supervision” the shop works (there is a theoretical audit trail, which makes it gold plated)

• the client doesn’t need certification (legal for an N-reg aircraft, in general terms, because while an A&P cannot repair instruments he has the authority to inspect an item and return it to service)

• the whole job is done off the books

• the aircraft is non CofA (homebuilt, UL, etc)

All above are very common.

Last two things I had repaired came with forms: one had an unrelated name on the top which was a competitor of said company and the other I know the work was done by a one-man band.

It is a poor state of affairs, which restricts choice, drives prices up, and props up the EASA-1 “rent my 145 laser printer for €xx per page” form generation which consequently means an EASA-1 means almost nothing in concrete terms and is roughly equivalent to an MOT back in the good old days when you could buy it down the pub for £20