ATCO.OR.C.001 Management system of training organisations
Regulation (EU) 2015/340
Training organisations shall establish, implement and maintain a management system that includes:
(a) clearly defined lines of responsibility and accountability throughout the organisation, including direct safety accountability of the accountable manager;
(b) a description of the overall principles of the organisation with regard to safety, referred to as the safety policy;
(c) the identification of aviation safety hazards entailed by the activities of the training organisation, their evaluation and the management of associated risks, including actions to mitigate the risk and verify their effectiveness;
(d) maintaining personnel trained and competent to perform their tasks;
(e) documentation of all management system key processes, including a process for making personnel aware of their responsibilities and the procedure for amending this documentation;
(f) a function to monitor compliance of the organisation with the relevant requirements. Compliance monitoring shall include a feedback system of findings to the accountable manager to ensure effective implementation of corrective actions as necessary;
(g) the management system shall be proportionate to the size of the organisation and its activities, taking into account the hazards and associated risks inherent in those activities.
GM1 ATCO.OR.C.001 Management system of training organisations
ED Decision 2015/015/R
The requirements for the management system of training organisations may be satisfied if the air navigation service provider’s management system/safety management system (SMS) specifically covers the requirements of this Regulation.
AMC1 ATCO.OR.C.001(b) Management system of training organisations
ED Decision 2023/011/R
SAFETY POLICY
The safety policy should:
(a) be endorsed by the accountable manager;
(b) clearly identify safety as the highest organisational priority over commercial, operational, environmental or social pressures;
(c) include a commitment to:
(1) improve towards the highest safety standards;
(2) comply with all applicable legal requirements, meet all applicable standards and consider best practices;
(3) provide appropriate resources; and
(4) enforce safety as the primary responsibility of all managers and staff;
(d) be communicated, with visible endorsement, throughout the organisation;
(e) include safety reporting and just culture principles;
(f) enhance and embed safety culture and safety awareness; and
(g) be periodically reviewed to ensure it remains relevant and appropriate to the training organisation.
[applicable until 3 August 2024 - ED Decision 2015/010/R]
(a) be signed by the accountable manager;
(b) reflect the organisation’s commitment regarding safety, and its proactive and systematic management;
(c) be communicated, with visible endorsement, throughout the organisation;
(d) include safety-reporting principles and procedures, if applicable;
(e) include the organisations's commitment to:
(1) improve towards the highest safety standards;
(2) comply with all applicable legal requirements, meet all applicable standards and consider best practices;
(3) provide appropriate resources;
(4) enforce safety as the primary responsibility of all managers and staff; and
(5) apply just culture principles in accordance with Regulation (EU) No 376/2014 and, in particular, not to make available or use the information on occurrences:
(i) to attribute blame or liability to someone for reporting something that would not have been otherwise detected; or
(ii) for any purpose other than the maintenance or improvement of aviation safety;
(f) clearly indicate which types of operational behaviour are unacceptable, and include the conditions under which disciplinary action would not apply, if applicable;
(g) enhance and embed safety culture and safety awareness; and
(h) be periodically reviewed to ensure it remains relevant and appropriate to the training organisation.
[applicable from 4 August 2024 - ED Decision 2023/011/R]
GM1 ATCO.OR.C.001(b) Management system of training organisations
ED Decision 2023/011/R
(a) The safety policy is the means whereby a training organisation states its intention to maintain and, where practicable, improve safety levels in all its activities and to minimise its contribution to the risk of an aircraft accident or serious incident as far as is reasonably practicable. It reflects the management’s commitment to safety, and should reflect the organisation’s philosophy as regards safety management, as well as become the foundation on which the organisation’s management system is built. It serves as a reminder of ‘how we do business here’. The establishment of a positive safety culture begins with the issuance of a clear, unequivocal direction.
(b) The commitment to apply just culture principles forms the basis for the organisation’s internal rules describing how just culture principles are guaranteed and implemented, after consulting its staff representatives, as required by Article 16(11) of Regulation (EU) No 376/2014.
(c) The safety policy should state that the purpose of safety reporting is to improve safety, not to apportion blame to individuals.
[applicable from 4 August 2024 - ED Decision 2023/011/R]
AMC1 ATCO.OR.C.001(c) Management system of training organisations
ED Decision 2015/010/R
IDENTIFICATION OF AVIATION SAFETY HAZARDS
For training organisations not providing on-the-job training, the hazard identification process may be limited to a demonstration that there are no hazards directly identified. However, the training should be designed so as to ensure future safe operations.
AMC1 ATCO.OR.C.001(d) Management system of training organisations
ED Decision 2015/010/R
PERSONNEL
A training organisation should demonstrate that:
(a) a list of activities with relevant needed competence has been established;
(b) their personnel have the relevant competence needed to fulfil the activities they are required to perform;
(c) their personnel maintain a level of competence through training as appropriate;
(d) their theoretical and practical instructors are qualified in accordance with Part ATCO, Subpart C of this Regulation;
(e) their practical instructors either hold an OJTI endorsement or an STDI endorsement;
(f) their assessors hold an assessor endorsement; and
(g) their synthetic training device instructors and assessors demonstrate knowledge of and receive refresher training in current operational practices.
AMC1 ATCO.OR.C.001(e) Management system of training organisations
ED Decision 2015/010/R
PROCESSES
Training organisations should demonstrate that the management system:
(a) policies, processes and procedures are monitored to ensure they are current and subject to periodic review and amendment, when necessary, to maintain their continued accuracy and suitability;
(b) allows for the impromptu recognition and initiation of improvements to policies, processes and procedures between periodic reviews;
(c) controls, records and tracks changes to all of the management system policy, process and procedure documents;
(d) includes a master record index that lists all the policies, processes and procedures; and
(e) includes as a minimum the following:
(1) master record index;
(2) training provider certificate;
(3) management structure;
(4) staff role profiles including accountabilities and responsibilities;
(5) training manuals, plans and courses;
(6) evidence of regulatory compliance;
(7) change control process;
(8) safety management manual;
(9) course design documents;
(10) instructor/assessor qualification and competence records.
AMC1 ATCO.OR.C.001(f) Management system of training organisations
ED Decision 2015/010/R
COMPLIANCE MONITORING
(a) The implementation and use of a compliance monitoring function should enable the training organisation to monitor compliance with the relevant requirements of this Regulation.
(b) Training organisations should specify the basic structure of the compliance monitoring function applicable to the activities conducted.
(c) The compliance monitoring function should be structured according to the activities of the training organisation to be monitored.
GM1 ATCO.OR.C.001(f) Management system of training organisations
ED Decision 2015/010/R
EXAMPLE OF COMPLIANCE MONITORING SYSTEM
(a) Training organisations may monitor compliance with the procedures they have designed to ensure safe activities. In doing so, they may, as a minimum, and, where appropriate, monitor:
(1) the organisational structure;
(2) the plans and objectives;
(3) the privileges of the organisation;
(4) the manuals, logs and records;
(5) the training standards;
(6) the management system.
(b) Organisational set-up
(1) To ensure that the training organisation continues to meet the requirements of this Regulation, the accountable manager may designate a person responsible for the compliance monitoring function whose role is to verify, by monitoring the activities of the organisation, that the standards required by this Regulation and any additional requirements as established by the organisation are met under the supervision of the relevant head of the functional area. For small training organisations, these identified functions can be fulfilled by the same person.
(2) The person designated for the compliance monitoring function should be responsible for ensuring that the compliance monitoring programme is properly implemented, maintained and continually reviewed and improved.
(3) The designated person responsible for the compliance monitoring function should:
(i) have direct access to the accountable manager; and
(ii) have access to all parts of the training organisation and, as necessary, to any contracted organisation.
(c) Compliance monitoring documentation
(1) Relevant documentation could include the relevant part(s) of the training organisation management system documentation.
(2) In addition, relevant documentation could also include the following:
(i) terminology;
(ii) specified activity standards;
(iii) description of the organisation;
(iv) allocation of duties and responsibilities;
(v) procedures to ensure regulatory compliance;
(vi) compliance monitoring programme, reflecting:
(A) schedule of the monitoring programme;
(B) audit procedures;
(C) reporting procedures;
(D) follow-up and corrective action procedures; and
(E) recording system;
(vii) training elements referred to in paragraph 4(b)
(viii) document control.
(d) Training
(1) Correct and thorough training is essential to optimise compliance in every training organisation. In order to achieve significant outcomes of such training, the training organisation needs to ensure that all personnel understand the objectives laid down in the organisation’s manual.
(2) Those responsible for managing the compliance monitoring function should receive training in this task. Such training could cover the requirements of compliance monitoring, manuals and procedures related to the task, audit techniques, reporting and recording.
(3) Time needs to be provided to train all personnel involved in compliance management and for briefing the rest of the personnel.
(4) The allocation of time and resources needs to be governed by the activities covered by the training organisation.
AMC2 ATCO.OR.C.001(f) Management system of training organisations
ED Decision 2015/010/R
COMPLIANCE MONITORING
The person designated for the compliance monitoring function should be responsible for the review and continuous improvement of the established management system’s policies, processes and procedures. The following tools are essential to the ongoing continuous improvement process:
(a) organisational risk profile;
(b) risk management plan;
(c) coherence matrix;
(d) corrective and preventive action reports; and
(e) inspection and audit reports.
GM2 ATCO.OR.C.001(f) Management system of training organisations
ED Decision 2015/010/R
COMPLIANCE MONITORING
(a) These tools and processes related to the compliance monitoring function are interrelated and help define the continuous improvement efforts of the organisation. For example, any corrective or preventive action report could identify a deficiency or an opportunity for improvement. The person responsible for the compliance monitoring function would then be required to ensure the identified issue was addressed and the corrective or preventive action effectively implemented. The same would be true if the discovery of an issue was identified during an inspection or audit.
(b) The effective implementation of change and the subsequent validation that the change did result in the desired outcome is critical to the continuous improvement process. Simply introducing a well-meaning suggestion for improvement into the organisation without carefully managing that change could have undesirable consequences. It is, therefore, the responsibility of the person in charge of the compliance monitoring function to introduce, monitor and validate improvement efforts.
(c) A simple but effective process to use in managing continuous improvement is known as the plan-do-check-act, or PDCA, approach:
(1) plan — map out the implementation of the recommended change, identifying at least:
(i) those people who will be affected by the change;
(ii) the required measures necessary to mitigate risk; and
(iii) the desired outcome and its intended consequences.
(2) do — execute the implementation plan once all affected groups have accepted the proposal and understand their role in ensuring its success;
(3) check — apply sufficient quality control ‘stage’ checks throughout the implementation phase to ensure any unintended deviations in the execution are identified and addressed without delay; and
(4) act — analyse the results and take appropriate action as necessary.
AMC1 ATCO.OR.C.001(g) Management system of training organisations
ED Decision 2023/011/R
SIZE, NATURE AND COMPLEXITY OF THE ACTIVITY
(a) A training organisation should be considered as complex when it has a workforce of more than 20 full-time equivalents (FTEs) involved in the activity subject to Regulation (EC) No 216/200824Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002 and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1). and its Implementing Rules.
(b) A training organisation with up to 20 FTEs involved in the activity subject to Regulation (EC) No 216/2008 and its Implementing Rules may also be considered complex based on an assessment of the following factors:
(1) the extent and scope of contracted activities subject to the certificate, in terms of complexity; and
(2) the different types of training provided, in terms of risk criteria.
[applicable until 3 August 2024 - ED Decision 2015/010/R]
(a) A training organisation should be considered complex when it has a workforce of more than 20 full-time equivalents (FTEs) involved in activities subject to Regulation (EC) 2018/113925Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common rules in the field of civil aviation and establishing a European Union Aviation Safety Agency, and amending Regulations (EC) No 2111/2005, (EC) No 1008/2008, (EU) No 996/2010, (EU) No 376/2014 and Directives 2014/30/EU and 2014/53/EU of the European Parliament and of the Council, and repealing Regulations (EC) No 552/2004 and (EC) No 216/2008 of the European Parliament and of the Council and Council Regulation (EEC) No 3922/91(OJ L 212, 22.8.2018, p. 1). and its delegated and implementing acts.
(b) A training organisation with up to 20 FTEs involved in the activities subject to Regulation (EU 2018/1139 and its delegated and implementing acts may also be considered complex based on an assessment of the following factors:
(1) the extent and scope of contracted activities subject to the certificate, in terms of complexity; and
(2) the different types of training provided, in terms of risk criteria.
[applicable from 4 August 2024 - ED Decision 2023/011/R]
ATCO.OR.C.001A Information security management system
Regulation (EU) 2023/203
In addition to the management system referred to in point ATCO.OR.C.001, the training organisation shall establish, implement and maintain an information security management system in accordance with Implementing Regulation (EU) 2023/203 in order to ensure the proper management of information security risks which may have an impact on aviation safety.
[Applicable from 22 February 2026 – Regulation (EU) 2023/203]
ATCO.OR.C.005 Contracted activities
Regulation (EU) 2015/340
(a) Training organisations shall ensure that when contracting or purchasing any parts of their activities, the contracted or purchased activity or part of activity conform to the applicable requirements.
(b) When a training organisation contracts any part of its activity to an organisation that is not itself certified in accordance with this Regulation to carry out such activity, the contracted organisation shall work under the terms of approval contained in the certificate issued to the contracting training organisation. The contracting training organisation shall ensure that the competent authority is given access to the contracted organisation to determine continued compliance with the applicable requirements.
AMC1 ATCO.OR.C.005 Contracted activities
ED Decision 2015/010/R
(a) Training organisations may decide to contract certain parts of their activities to external organisations.
(b) A written agreement should exist between the training organisation and the contracted organisation clearly defining the contracted activities and the applicable requirements.
(c) The contracted safety-related activities relevant to the agreement should be included in the training organisation’s compliance monitoring programme.
(d) Training organisations should ensure that the contracted organisation has the necessary authorisation or approval when required, and commands the resources and competence to undertake the task.
GM1 ATCO.OR.C.005 Contracted activities
ED Decision 2015/010/R
RESPONSIBILITY WHEN CONTRACTING ACTIVITIES
(a) Regardless of the approval status of the contracted organisation, the contracting organisation is responsible to ensure that all contracted activities are subject to hazard identification and risk management as required by ATCO.OR.C.001(c) and to compliance monitoring as required by ATCO.OR.C.001(f).
(b) When the contracted organisation is itself certified to carry out the contracted activities, the organisation’s compliance monitoring should at least check that the approval effectively covers the contracted activities and that it is still valid.
ATCO.OR.C.010 Personnel requirements
Regulation (EU) 2023/893
(a) Training organisations shall appoint an accountable manager.
(b) A person or persons shall be nominated by the training organisation with the responsibility for training. Such person or persons shall be ultimately responsible to the accountable manager.
(c) Training organisations shall have sufficient qualified personnel for the planned tasks and activities to be performed in accordance with the applicable requirements.
(d) Training organisations shall maintain a record of theoretical instructors with their relevant professional qualifications, adequate knowledge and experience and their demonstration, instructional techniques assessment and subjects they are entitled to teach.
[applicable until 3 August 2024 - Regulation (EU) 2015/340]
(d) Training organisations shall maintain a record of theoretical instructors with their relevant professional qualifications, including demonstration of adequate knowledge and experience, instructional techniques assessment and subjects they are entitled to teach.
[applicable from 4 August 2024 - Implementing Regulation (EU) 2023/893]
(e) Training organisations shall establish a procedure to maintain competence of the theoretical instructors.
(f) Training organisations shall ensure that practical instructors and assessors successfully complete refresher training in order to revalidate the respective endorsement.
(g) Training organisations shall maintain a record of persons qualified for assessing practical instructors' competence and assessors' competence, in accordance with ATCO.C.045, with their relevant endorsements.
GM1 ATCO.OR.C.010(b);(c) Personnel requirements
ED Decision 2015/010/R
(a) Training organisations may nominate the person responsible for training and a person or persons subordinate to him or her as chief training instructor(s)/unit responsible training officer(s).
(b) Usually, training organisations nominate only one person responsible for training.
(c) Prerequisites, typical function and responsibilities of the person responsible for training may be:
(1) to have extensive experience in instructing for all types of ATC training and possess sound managerial capability;
(2) to have overall responsibility for ensuring satisfactory integration of all training provided and for supervising the progress of the persons undertaking training;
(3) to be responsible for coordinating and delegating the contact to the competent authority in training-related issues; and
(4) to be ultimately responsible to the accountable manager.
(d) Prerequisites, typical functions and responsibilities of the chief training instructor(s)/unit responsible training officer(s) may be:
(1) to have extensive experience in instructing for all types of ATC training and possess sound managerial capability;
(2) to have responsibility for ensuring satisfactory training is provided and for supervising the progress of the persons undertaking training in the areas that have been delegated by the person responsible for training; and
(3) to report to the person responsible for training.
ATCO.OR.C.015 Facilities and equipment
Regulation (EU) 2015/340
(a) Training organisations shall have facilities allowing the performance and management of all planned tasks and activities in accordance with this Regulation.
(b) The training organisation shall ensure that the synthetic training devices comply with the applicable specifications and requirements appropriate to the task.
(c) During on-the-job training instruction, the training organisation shall ensure that the instructor has exactly the same information as the person undertaking OJT and the means to intervene immediately.
AMC1 ATCO.OR.C.015(a) Facilities and equipment
ED Decision 2015/010/R
(a) General areas
A training organisation should have access to facilities appropriate to the size and scope of the intended operations provided in an environment conducive to learning.
(b) Training areas
For training organisations providing theoretical training, the facilities should also include sufficient suitably equipped classroom areas.
GM1 ATCO.OR.C.015(a) Facilities and equipment
ED Decision 2015/010/R
(a) General areas
These facilities should include general areas, which consist of sufficient:
(1) office space for managerial and administrative as well as training staff;
(2) rooms for study and testing;
(3) library facilities; and
(4) storage areas, including secure areas for training and personnel records.
(b) Training areas
For training organisations providing practical training, the facilities should also include sufficient:
(1) rooms for briefing and debriefing; and
(2) suitably equipped rooms for practical training.
AMC1 ATCO.OR.C.015(b) Facilities and equipment
ED Decision 2015/010/R
SPECIFICATIONS FOR SYNTHETIC TRAINING DEVICES
(a) Synthetic training devices classifications
Synthetic training devices used for training should be classified according to one of the following classifications:
(1) simulator (SIM);
(2) part-task trainer (PTT).
(b) Synthetic training device (STD) criteria
If an STD is used for training, it should be approved by the competent authority as part of the course approval process for any training plan. Training organisations should demonstrate how the STD will provide adequate support for the intended training, in particular, how the STD will meet the stated objectives of the practical training exercises and enable the performance objectives to be assessed to the level determined in the training programme.
This demonstration and the related documentation should include the following relevant criteria:
(1) the general environment, which should provide an environment in which STD exercises may be run without undue interference from unrelated activities;
(2) the STD layout;
(3) the equipment provided;
(4) the display presentation, functionality, and updating of operational information;
(5) data displays, including strip displays, where appropriate;
(6) coordination facilities;
(7) aircraft performance characteristics, including the availability of manoeuvres, e.g. holding or instrumental landing system (ILS) operation, required for a particular simulation;
(8) the availability of real-time changes during an exercise;
(9) the processes by which the training organisation can be assured that staff associated with the training conducted with the use of an STD are competent;
(10) the degree of realism of any voice recognition system associated with the STD; and
(11) where a simulator is an integral part of an operational ATC system, the processes by which the training organisation is assured that interference between the simulated and operational environments is prevented.
The extent to which the STD achieves the above criteria will be used to determine the adequacy of the STD for the proposed use. As a general principle, the greater the degree of replication of the operational position being represented, the greater the use will be possible for any particular training.
(c) STD used for pre-on-the-job training
When an STD is used for pre-on-the-job training and the training time is counted as operational training, the STD classification should be a full-size replica of a working position, including all equipment, and computer programmes necessary to represent the full tasks associated with that position, including realistic wind at all levels to facilitate SRA. In the case of a working position at a tower unit, it includes an out-of-the-tower view.
Regulation (EU) 2015/340
(a) Training organisations shall retain detailed records of persons undertaking or having undertaken training to show that all requirements of the training courses have been met.
(b) Training organisations shall establish and maintain a system for recording the professional qualifications and instructional techniques assessments of instructors and assessors, as well as the subjects they are entitled to teach, where appropriate.
(c) The records required in points (a) and (b) shall be retained for a minimum period of five years subject to the applicable national data protection law:
(1) after the person undertaking training has completed the course; and
(2) after the instructor or assessor ceases to perform a function for the training organisation, as applicable.
(d) The archiving process including the format of the records shall be specified in the training organisation's management system.
(e) Records shall be stored in a secure manner.
AMC1 ATCO.OR.C.020(a);(b) Record keeping
ED Decision 2015/010/R
Training organisations should maintain the following records:
(a) Records of persons undertaking training:
(1) personal information;
(2) details of training received including the starting date of the training, as well as the results of the examinations and assessments;
(3) detailed and regular progress report forms;
(4) certificate of completion of training courses.
(b) Records of instructors and assessors:
(1) personal information;
(2) qualification records;
(3) records of refresher training for instructors and assessors;
(4) assessment reports;
(5) instructional and/or assessment time records.
Training organisations should submit training records and reports to the competent authority as required.
ATCO.OR.C.025 Funding and insurances
Regulation (EU) 2015/340
Training organisations shall demonstrate that sufficient funding is available to conduct the training according to this Regulation and that the activities have sufficient insurance cover in accordance with the nature of the training provided and all activities can be carried out in accordance with this Regulation.
AMC1 ATCO.OR.C.025 Funding and insurances
ED Decision 2015/010/R
SUFFICIENT FUNDING
To demonstrate compliance with the requirement on the availability of sufficient funding, training organisations may be required to present an economic study identifying the minimum amount necessary to ensure that the training is conducted in accordance with the applicable requirements.
AMC2 ATCO.OR.C.025 Funding and insurances
ED Decision 2015/010/R
SUFFICIENT INSURANCE COVER
To demonstrate compliance with the requirement on sufficient insurance cover, training organisations may be required to provide a deposit of an insurance certificate or other evidence of valid insurance.
The insurance cover should be established by taking into account the nature of the training provided, the frequency and the fees applicable to the training courses.