I'm an avionics tech looking to help a customer out with some modifications on their aircraft. We're hoping to change out the old Attitude and Heading indicators with something more modern like the Kelly Mfg RC Allen digital instruments (RCA2610 and RCA1510) in a VFR Bell helicopter.
The major mod section of CAR 571 Appendix A (2)(e)(10) says "affect instruments, or indicators that are installed as part of a system required by the approved type design" so replacing the primary attitude and heading indicators seems to be classified as a major modification. But then I start digging into the Type Certificate (FAA Type Cert: H4SW) and it doesn't seem to list any of the indicators or avionics that are 'required by the approved type design'.
The old indicators are the same size, function and TSO as the new ones we want to put in, but I don't really know what would stop us from doing the install. There would be no changes to the instrument panel or wiring, just an indicator swap. I've seen other aircraft of the same type with the digital indicators on the copilot side, installed using the manufacturers data manual / TSO. We don't have the capacity right now to develop an STC so that's not a route we're considering.
The regulations almost need a law degree to decipher

Thanks in advance!