Commission Delegated Regulation (EU) 2025/20

Cover Regulation

COMMISSION DELEGATED REGULATION (EU) 2025/20

of 19 December 2024

supplementing Regulation (EU) 2018/1139 of the European Parliament and of the Council by laying down requirements for the safe provision of ground handling services and for organisations providing them

Regulation (EU) 2025/20

THE EUROPEAN COMMISSION,

Having regard to the Treaty on the Functioning of the European Union,

Having regard to Regulation (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 3922/91¹⁴, and in particular Article 39(1), points (d) and (e) thereof,

Whereas:

(1)Regulation (EU) 2018/1139 establishes the essential requirements for the safe provision of ground handling services and organisations providing them at the Union aerodromes within the scope of that Regulation. Article 37(2) requires providers of ground handling services to make a declaration regarding their capability to discharge their responsibilities associated with the safe provision of ground handling services.

(2)To ensure a total-system approach and guarantee a baseline for safety in all aviation-related activities, and in line with the principle of subsidiarity, detailed rules for the provision of ground handling services and the privileges and responsibilities of organisations providing them should be laid down.

(3)Pursuant to Article 4 of Regulation (EU) 2018/1139, those rules are to reflect the state of the art and best practices in the field of ground handling; take into account the applicable International Civil Aviation Organization (‘ICAO’) Standards and Recommended Practices (‘SARPs’) and worldwide ground handling operation experience, as well as scientific and technical progress in the ground handling domain; be proportionate to the size and complexity of the ground handling activities; and provide for the necessary flexibility for customised compliance.

(4)The Regulation should ensure a level playing field for the provision of ground handling services for all organisations providing those services, including self-handling by aircraft operators, at aerodromes within the scope of Regulation (EU) 2018/1139.

(5)For aircraft operators performing self-handling or aerodrome operators providing ground handling services, which already have management system structures required under other Union regulations in the aviation sector, the ground handling requirements should be easy to integrate so as to create minimum disruptions to the established system of organisations and national competent authorities. Therefore, this Regulation should be aligned as much as possible particularly with Commission Regulations (EU) No 965/2012¹⁵ and (EU) No 139/2014¹⁶, as the ground handling domain is an interface between air operations and aerodrome operations, and therefore the management systems as regulated by these acts should be aligned and the necessary cross-references established.

(6)This Regulation does not cover those ground handling activities that are already regulated by other acts, such as flight dispatch, load control, and ground supervision, which are covered by Regulation (EU) No 965/2012, marshalling of aircraft, which is covered by Regulation (EU) No 139/2014, or oil handling, which is covered by Commission Regulation (EU) No 1321/2014¹⁷.

(7)In line with the proportionality principle, with regard to self-handling by aircraft operators, this Regulation should only apply to self-handling activities by aircraft operators performing commercial air transport operations with complex motor-powered aircraft. It is considered that Regulation (EU) No 965/2012 sufficiently addresses the safety risks of self-handling activities performed by operators conducting any operations that are not commercial air transport operations, either with complex or with other-than-complex motor-powered aircraft.

(8)The measures provided for in this Regulation should improve and promote the safety of ground handling services and a safety culture within the organisations providing such services. Therefore, the requirements laid down in this Regulation should provide the necessary tools and a description of the process for organisations to implement a safety reporting system, to help them collect and analyse the safety data obtained from those reports, and to establish and foster a safety culture with each individual employed in their organisation.

(9)With this Regulation, ground handling organisations are to assume full responsibility for the safe provision of services, their operations, and control the operational risks of their activities, while aircraft operators continue to remain responsible for the safety of the aircraft and for the flight, while aerodrome operators continue to remain responsible for the safe operation of aerodromes. Therefore, ground handling organisations should develop and implement a management system with effective safety management processes capable of identifying and managing the safety risks, including those arising from interfaces with the aircraft operators and the aerodrome operators, through the application of adequate and proportionate mitigation measures.

(10)The management system developed and implemented by ground handling organisations should be proportionate, scalable to the size and complexity of their organisation and activities, and should cover the management of safety, management of changes, safety reporting, training of personnel, records and documentation, maintenance of ground support equipment used, identification of safety-related interfaces with other stakeholders involved in ground handling activities, operational procedures, and compliance monitoring. Ground handling organisations should strive to develop and foster an organisational safety culture, in which employees understand their individual importance in the aviation safety chain and contribute actively to maintaining and improving the level of safety in their daily operational tasks. This Regulation contains provisions to support organisations to develop and cultivate a healthy reporting culture.

(11)To ensure a common approach in addressing the safety risks arising from the interfaces between ground handling, aircraft and aerodrome operations, and to promote a common understanding of hazards and risks, ground handling organisations, aircraft operators and aerodrome operators should have the same safety information and safety data when these are relevant for them and when these information and data may affect the safety performance of either organisation. To achieve this, such organisations should be able to share among themselves relevant safety information, as well as information resulting from occurrence reports or oversight inspections and audits.

(12)Ground handling services, provided to an aircraft at an aerodrome, are an interface in themselves between aircraft and aerodrome operations. The safety risks arising from this situation should be properly acknowledged through a regulatory framework for the interaction between organisations, so as to enable them to identify those operational interfaces having an effect on safety and apply proper mitigation measures to minimise the risks in operation. At the same time, ground handling organisations should be able to discuss safety on an equal ground with the other stakeholders involved in those operational interfaces and provide them with the possibility to apply their own operational procedures if they are based on their safety risk management processes and if this is agreed with the aircraft operator to which they provide services.

(13)To ensure a smooth transition from the existing national regulations of the Member States to this Regulation, it is necessary to provide ground handling organisations that are already operating at the time when this Regulation becomes applicable with sufficient time and minimum conditions to shift from the existing national regulations of the Member States to this Regulation.

(14)Training of ground handling operational personnel is one of the most important measures for mitigating the safety risks in ground handling activities. Ground handling organisations should ensure that all operational personnel involved in ground handling activities are competent to provide those services. The competence of the operational personnel should always be maintained. Therefore, this Regulation establishes minimum requirements regarding the training and assessment programme for the safety-relevant personnel to ensure that they develop and maintain the competencies necessary to perform their tasks safely and effectively.

(15)To support the mobility of personnel across ground handling organisations and to reduce the training costs upon re-training of a new employee that has already achieved the required qualifications at the previous employment, ground handling personnel should be able to easily provide proof of training already completed. The ground handling organisation should therefore provide to the employee a copy of respective training records, upon request, which should enable the easy assessment and mutual recognition of training across organisations subject to this Regulation.

(16)Flight safety and safe provision of ground handling services depend heavily on the use of functional, properly maintained ground support equipment. The functionality of the equipment used for the provision of ground handling services should be ensured by the application of a maintenance programme, including preventive maintenance, developed and applied in accordance with instructions and manuals of the equipment manufacturer. The rules should also be technology-neutral, to allow innovations and a smooth adoption of new technologies at a fast pace, while keeping an environmentally friendly approach towards the choice of ground support equipment. At the same time, the rules should provide the possibility for organisations to adopt and implement practices and business models that minimise aerodrome congestion and make aerodrome operations safer and more efficient, such as equipment pooling or a safety stack model, where the aerodrome specificity allows for the implementation of such business models.

(17)This Regulation should ensure a pragmatic and balanced approach between prescriptive and performance-based rules. Flexibility in the approach towards requirements on operational procedures for ground handling services is a key to achieving the safety objectives. Therefore, it is essential that the requirements covering the operational procedures remain performancebased and rely on the voluntary application of industry standards and good practices, as well as operational procedures well established by aircraft operators and ground handling organisations.

(18)The essential requirements in Annex VII, point 4.1(c) to Regulation (EU) 2018/1139 mandate that organisations provide ground handling services in accordance with the operational instructions and procedures of the aircraft operators. The operational procedures for the same ground handling service and to the same type of aircraft may differ significantly between aircraft operators, and this increases the risk of human error as it could lead to aircraft damage and endanger flight safety. The essential requirements in Annex VII point 4.2.3 to Regulation (EU) 2018/1139 require that ground handling organisations develop their own operational procedures for the provision of ground handling services. This Regulation enables ground handling organisations to apply their own operational procedures if this is agreed by the aircraft operator. Furthermore, this Regulation makes ground handling organisations formally accountable and responsible for the safety of their own services by the application of an effective safety management system. This should also support ground handling organisations in developing, assessing, discussing and agreeing with the aircraft operators on common operational procedures that are safe for both parties. All these elements, placed in several requirements, should improve the existing level of trust between the aircraft operator and its provider of ground handling services, and lead towards a harmonisation of the operational procedures.

(19)This Regulation should further ensure that it provides solid elements for organisations to improve their analysis of causes of events identified through their own compliance monitoring processes or through the national competent authority oversight, and also to improve their safety reporting culture. At the same time, the Regulation should also provide a framework for the provision by the national competent authorities of direct and consistent feedback on reported ground handling events directly to the ground handling organisations.

(20)It is necessary to provide sufficient time for the ground handling industry and national competent authorities to implement the new regulatory framework after the entry into force of this Regulation, therefore a transition period of 3 years should be provided for its deferred applicability and a transition period of 6 years should be provided for the deferred applicability of the requirements covering the information security management.

(21)The requirements laid down in this Regulation are based on Opinion No 01/2024¹⁸ issued by the Agency in accordance with Article 75(2), points (b) and (c), and Article 76(1) of Regulation (EU) 2018/1139.

(22)In accordance with Article 128(4) of Regulation (EU) 2018/1139, the Commission consulted experts designated by each Member State in accordance with the principles laid down in the Interinstitutional Agreement of 13 April 2016 on Better LawMaking¹⁹,

HAS ADOPTED THIS REGULATION:

Regulation (EU) 2025/20

This Regulation establishes common requirements for the provision of ground handling services and organisations providing them at aerodromes within the scope of Regulation (EU) 2018/1139.

Regulation (EU) 2025/20

1.This Regulation shall apply to the ground handling organisations that provide any of the ground handling services specified in paragraph 2 at one or more aerodromes within the scope of Regulation (EU) 2018/1139.

2.This Regulation shall apply to the following services provided to aeroplanes:

(a)passenger handling, including passengers with reduced mobility, including safety aspects of passenger and baggage acceptance at the aerodrome, safety of passengers during boarding and disembarkation using ground support equipment and during transit or transfer, and ground transportation of passengers between the aerodrome terminal and the aircraft;

(b)baggage handling, including baggage identification, sorting, building, transfer, arrival and reclaim;

(c)the following aircraft servicing activities:

(i)operation of ground support equipment (GSE) used for ground handling services, including loading and unloading of catering, and the movement of those GSE on the apron and around the aircraft;

(ii)aircraft refuelling and defuelling, namely into-plane fuelling services at the aerodrome;

(iii)aircraft toilet servicing;

(iv)potable water servicing;

(v)aircraft exterior cleaning;

(vi)aircraft de-icing and anti-icing;

(d)the following aircraft turnaround activities:

(i)activities upon aircraft arrival, including aircraft securing on the ground;

(ii)loading and unloading of baggage, cargo, mail, catering, and loading supervision;

(iii)activities upon aircraft departure;

(iv)aircraft towing and pushback;

(e)the following cargo and mail handling at an aerodrome:

(i)cargo acceptance on behalf of the aircraft operator;

(ii)final build-up and storage;

(iii)final weighing and tagging of unit load devices;

(iv)final checks before air transportation;

(v)ground transportation of cargo and mail between the point of final checks and the aircraft.

3.This Regulation shall not apply to the following activities and organisations performing them:

(a)marshalling of aircraft;

(b)flight dispatch tasks performed by flight dispatchers as defined by Regulation (EU) No 965/2012;

(c)load control tasks related to load planning, mass and balance calculations, load control messages and communications, and issuance of load control documents;

(d)ground supervision;

(e)oil handling for the aircraft (including replenishment, servicing) performed by maintenance organisations approved under Regulation (EU) No 1321/2014, other organisations compliant with Regulation (EU) No 1321/2014, and other maintenance organisations holding an approval issued in compliance with ICAO Annex 8 Chapter 6;

(f)aircraft exterior cleaning when performed by maintenance organisations approved under Regulation (EU) No 1321/2014, other organisations compliant with Regulation (EU) No 1321/2014, and other maintenance organisations holding an approval issued in compliance with ICAO Annex 8 Chapter 6 and the activity is included in the organisation’s maintenance manual;

(g)any other ground handling activity when performed by a maintenance organisation approved under Regulation (EU) No 1321/2014, other organisations compliant with Regulation (EU) No 1321/2014, and other maintenance organisations holding an approval issued in compliance with ICAO Annex 8 Chapter 6 for the purpose of aircraft maintenance;

(h)ground transportation of passengers and crew members when this is the only service provided by an entity;

(i)self-handling, when performed by aircraft operators performing any of the following types of operations:

(i)commercial air transport operations with other-than-complex motor-powered aircraft;

(ii)any flight operations with complex or other-than-complex motor-powered aircraft that are not commercial air transport operations;

(j)handling of passengers with reduced mobility, or ground transportation of passengers and crew members, or both, when these are the only ground handling services provided by an aerodrome operator with its own personnel, not cumulated with other ground handling services provided by that aerodrome operator.

ED Decision 2025/007/R

PROVISION OF GH SERVICES FROM AN OFF-AIRPORT LOCATION

Organisations providing GH services from a location other than an aerodrome subject to Regulation (EU) 2018/1139 and its delegated and implementing acts are not subject to Commission Delegated Regulation (EU) 2025/20. The services provided by such organisations are included in the management system of the aircraft operator as contracted activities and are regulated by Regulation (EU) No 965/2012, particularly point ORO.GEN.205 thereof.

Examples of these services:

(a)passenger and baggage acceptance, at off-airport locations,

(b)load control (load planning and production of related documents).

ED Decision 2025/007/R

PASSENGER HANDLING

The safety aspects of passenger handling covered by Commission Delegated Regulation (EU) 2025/20 are the following:

(a)dangerous goods in passenger baggage or on the person upon acceptance at checkin at the aerodrome;

(b)insertion of the correct information related to passenger and baggage acceptance into the departure control system, for load control purposes (i.e. mass and balance calculations, load planning);

(c)ground transport between the airport terminal and the aircraft;

(d)safety of passengers on the apron and around the aircraft during boarding and disembarkation;

(e)passenger boarding and disembarkation using GSE, including passenger boarding bridges (PBBs).

All aspects above include passengers with reduced mobility (PRMs).

ED Decision 2025/007/R

GROUND SUPPORT EQUIPMENT

The following items of GSE are within the scope of Commission Delegated Regulation (EU) 2025/20, regardless of their level of automation (requiring or not requiring human intervention). The list is based on IATA Airport Handling Manual (AHM):

(a)lifting and elevating equipment:

(1)aircraft tail stand,

(2)belt loader, with or without inhold conveyor system,

(3)catering vehicle,

(4)aircraft exterior cleaning equipment,

(5)deicing/antiicing vehicle/equipment,

(6)elevating work platform or equipment,

(7)forklift,

(8)loader (lower deck or main deck),

(9)maintenance stairs,

(10)mobile passenger boarding ramps,

(11)passenger stairs,

(12)PBBs,

(13)boarding vehicle for PRMs;

(b)servicing equipment:

(1)aircraft air conditioning unit (ACU)

(2)aircraft fuelling dispenser (pump),

(3)aircraft fuelling truck or cart,

(4)aircraft heating unit,

(5)aircraft start unit (ASU)

(6)ground power unit (GPU)

(7)lavatory service equipment,

(8)potable water service equipment;

(c)towing equipment, including remote controlled vehicles:

(1)tractor for baggage, cargo or aircraft equipment,

(2)aircraft towing or pushback vehicle (tractor, tug, truck),

(3)towbar,

(4)towbarless tractor,

(5)interchangeable tow bar heads;

(d)transporting equipment:

(1)bus (for passengers or crew),

(2)car, van or pick-up truck,

(3)cart or dolly (for baggage, cargo, unit load device (ULD) or aircraft equipment),

(4)fuelling truck,

(5)temperaturecontrolled cargo dolly,

(6)temperaturecontrolled cargo truck,

(7)trailer (for baggage, cargo, ULD or aircraft equipment),

(8)truck (for baggage, cargo, ULD or aircraft equipment),

(9)ULD transporter (to move ULD to/from high loaders);

(e)other equipment used to provide GH services:

(1)aircraft chocks,

(2)aircraft cones,

(3)retractable stanchions, passenger guiding systems and parts thereof.

ED Decision 2025/007/R

ACTIVITIES UPON AIRCRAFT ARRIVAL

The following activities take place before and after an aircraft is parked at the stand:

(a)prior to aircraft arrival:

(1)checking the aircraft stand for any FOD;

(2)checking the conditions of the surface stand for any ice, snow, etc.;

(3)preparing the necessary GSE, chocks and cones outside the equipment restraint area;

(4)ensuring that the necessary personnel are available for aircraft arrival activities and remain outside the aircraft manoeuvring path and within the safety zones;

(b)after the aircraft has been parked:

(1)securing the aircraft on the ground by putting chocks on the aircraft wheels and setting out safety cones to mark the equipment restraint area;

(2)performing a walkaround upon aircraft arrival to inspect the aircraft fuselage, doors and engine cowlings/propellers for any damage;

(3)giving clearance for the positioning of the necessary GSE (air conditioning unit, ground power unit, passenger stairs or boarding bridges, etc.).

ED Decision 2025/007/R

ACTIVITIES UPON AIRCRAFT DEPARTURE

These activities include, but are not limited to:

(a)removing the PBB and any other external equipment and vehicles from the aircraft and the equipment restraint area (ERA);

(b)verifying that aircraft doors and panels are properly closed;

(c)conducting an aircraft walkaround;

(d)checking for FOD;

(e)ensuring the availability of towing/pushback equipment;

(f)ensuring that all persons and equipment are outside the aircraft danger areas;

(g)any other activity necessary in accordance with the GH organisation’s procedures and the local aerodrome operator’s procedures.

ED Decision 2025/007/R

CARGO AND MAIL HANDLING IN A CARGO WAREHOUSE

(a)Cargo handling is a complex activity that involves various entities responsible for different segments of cargo preparation and transport. Not all those entities are included in the scope of Commission Delegated Regulation (EU) 2025/20. For example, the following entities are excluded from the scope of the Regulation:

(1)organisations that do not perform activities listed in Article 2(2) of Commission Delegated Regulation (EU) 2025/20 at the premises of an aerodrome within the scope of Regulation (EU) 2018/1139;

(2)organisations like freight forwarders or shippers;

(3)organisations that only transport cargo on the ground from one location/warehouse to another before being checked for acceptance for air transport.

(b)The GH activities related to cargo and mail handling usually occur in a cargo warehouse. Like the entities involved in the cargo transport chain, not all cargo warehouses are included in the scope of Commission Delegated Regulation (EU) 2025/20.

(c)Only the cargo warehouses that are located at an aerodrome or adjacent to it and that are responsible for final cargo checks and acceptance before the cargo is loaded on the aircraft are included in the scope of Commission Delegated Regulation (EU) 2025/20.

(d)Furthermore, only the safetyrelated activities occurring in a cargo warehouse that may have an impact on the safety of the flight are included in the scope of Commission Delegated Regulation (EU) 2025/20.

ED Decision 2025/007/R

ORGANISATIONS OUTSIDE THE SCOPE OF COMMISSION DELEGATED REGULATION (EU) 2025/20 THAT OPERATE GSE AROUND THE AIRCRAFT

(a)Organisations that move GSE to and from the aircraft or connect GSE to the aircraft to complete their tasks but are outside the scope of Commission Delegated Regulation (EU) 2025/20 are not required to declare their activities. However, as the operation of GSE is included in the scope of the Regulation, it is subject to oversight by the competent authority responsible for the oversight of the safe provision of GH services at the aerodrome of operation. The GSE and its operation are subject to compliance with the safety and maintenance requirements of Commission Delegated Regulation (EU) 2025/20.

(b)Examples of GH services that may use GSE in close proximity to the aircraft: aircraft interior cleaning and inflight services.

(c)GSE moved to and from the aircraft for aircraft maintenance purposes is covered by Regulation (EU) No 1321/2014.

ED Decision 2025/007/R

MARSHALLING OF AIRCRAFT

(a)Organisations that provide aircraft marshalling services are required to comply with the requirements of Regulation (EU) No 139/2014 applicable to aircraft marshalling.

(b)If such organisations also provide GH services that are included in the scope of Commission Delegated Regulation (EU) 2025/20, this Regulation is applicable to them and they are expected to declare their activities in accordance with Subpart ORGH.DEC, except for the marshalling services.

ED Decision 2025/007/R

FLIGHT DISPATCH

Although the term ‘flight dispatch’ is included in the definition of ‘ground handling’ in Regulation (EU) 2018/1139, Commission Delegated Regulation (EU) 2025/20 does not regulate those activities or their providers for the following reasons.

(a)The flight dispatch function is linked to the operational control system of an aircraft operator and is therefore considered a flight operations function, which is covered by Regulation (EU) No 965/2012 and the associated AMC and GM. This function may be outsourced to a thirdparty service provider.

(b)The term ‘flight dispatcher’ is defined in Regulation (EU) No 965/2012 and ICAO Annex 6, both regarding air operations, as an individual with specific qualifications and training compliant with ICAO Annex 1 who has specific tasks in the operational control system of the aircraft operator, including to support, brief or assist the pilotincommand in the safe conduct of the flight. The flight dispatcher function is considered a typical ‘flight operations’ function. The flight dispatcher’s tasks and responsibilities can be found in Regulation (EU) No 965/2012.

(c)The term ‘dispatcher’ is also used in ground operations, but it is not defined. For ground operations, the dispatcher performs a GH function that confirms to the aircraft operator’s flight dispatcher or the flight crew that all GH activities have been completed and that, from a GH perspective, the aircraft is prepared to leave the stand. Other terms may be used to describe this function, such as ‘ramp coordinator’ or ‘ramp supervisor’.

(d)Although the meaning of the term may be clear in the mind of the user, it is not always clear to others whether the user is referring to the function explained in point (b), related to the operational control system, or to the ground function explained in point (c). The confusion generated by the use of the same term to indicate two different functions may persist, as one usually associates a term only with tasks in the domain with which one is more familiar — that is, either air operations or ground operations, but rarely both. This may have safety implications due to the numerous interfaces between air operations and GH for operational procedures on the ground.

(e)To avoid the confusion described above, it is recommended that GH organisations avoid using the terms ‘flight dispatch’ or ‘(flight) dispatcher’ when describing typical GH tasks to prepare an aircraft for departure.

ED Decision 2025/007/R

LOAD PLANNING, LOAD CONTROL MESSAGES AND COMMUNICATIONS, AND ISSUANCE OF LOAD CONTROL DOCUMENTS

(a)The scope of Commission Delegated Regulation (EU) 2025/20 does not cover the provision of load planning services, mass and balance calculations or load control messaging and communications, or the issuance of related documents. These activities are included in the scope of Regulation (EU) No 965/2012. When outsourced to a thirdparty provider, the responsibility for the safety of these services is covered by point ORO.GEN.205 of Regulation (EU) No 965/2012.

(b)The load control function is specific to the operator’s fleet and operational context. It may be performed by an organisation at an aerodrome or outside an aerodrome or by the personnel of the aircraft operator itself.

(c)The load control process is classified into two distinct phases:

(1)Phase 1: mass and balance (M&B) calculations, load planning, load control communications and messaging, and issuance of load control documents (load sheet, loading instructions/report (LIR) or notification to captain (NOTOC) when necessary). These activities may be executed from an aerodrome or a remote location.

(2)Phase 2: load control communication — that is, verification of load against the loading instructions and communication of any lastminute changes to the mass and balance documentation. These activities take place at an aerodrome, as part of the preparation of the aircraft for departure.

(d)The aircraft operator is responsible for ensuring the compliance of activities included in phase 1 — that is, mass and balance calculations, load planning, load control communications and messaging, and issuance of load control documents — with the relevant requirements of Regulation (EU) No 965/2012. This applies at all times, regardless of whether these tasks are performed by the aircraft operator itself or outsourced as a contracted activity. These activities are overseen by the competent authority of the aircraft operator.

(e)The GH organisation is responsible for the activities included in phase 2, which take place on an aircraft, at the aerodrome. These activities are overseen by the competent authority for GH of the aerodrome where they are performed.

ED Decision 2025/007/R

GROUND SUPERVISION

(a)Ground supervision may be contracted by an operator as an individual service. It is usually associated with ground administration services provided by a GH organisation on behalf of the operator.

(b)This service includes the supervision and/or coordination of one or more GH activities on behalf of an operator, which may be performed by one or more providers of GH services.

(c)Organisations that provide ground supervision are required to comply with the relevant requirements of Regulation (EU) No 965/2012.

(d)If such organisations also provide other GH services that are included in the scope of Commission Delegated Regulation (EU) 2025/20, the Regulation is applicable to them. They are expected to declare their activities in accordance with Subpart ORGH.DEC, except for the ground supervision services and any other GH services listed in Article 2(3) of the Regulation.

(e)Ground supervision comprises activities such as:

(1)providing official representation for the contracting aircraft operator in relation to the aerodrome authorities or other organisations operating at that aerodrome, issuing disbursements on behalf of the aircraft operator, and ensuring the provision of office space for representatives of the operator;

(2)setting key performance indicators for operational performance;

(3)organising workflows and conducting operational planning;

(4)reporting incidents, accidents and near misses;

(5)activating and coordinating emergency responses, in accordance with the operator’s procedures;

(6)communicating with the aircraft operator;

(7)handling, storing and administering ULDs;

(8)supervising operational functions in the areas of:

(i)passenger and baggage handling,

(ii)ramp handling,

(iii)load control;

(9)any other administrative services requested by the aircraft operator.

(f)Ground supervision does not include a GH organisation’s management of its own activities.

(g)Ground supervision does not imply that the individual performing this function will replace, when necessary, an individual performing a GH operation.

(h)A person responsible for ground supervision may act on behalf of more than one aircraft operator to ensure the safe delivery of the services by GH organisations.

ED Decision 2025/007/R

OIL HANDLING

(a)Aircraft oil handling means replenishing the aircraft’s oil. Like any other activity related to aircraft maintenance, it is subject to Regulation (EU) No 1321/2014, on continuing airworthiness, as a maintenance task, and therefore exempted from compliance with Commission Delegated Regulation (EU) 2025/20. Oil handling is performed by personnel of a maintenance organisation approved under Regulation (EU) No 1321/2014 or compliant with ICAO Annex 8 Maintenance of Aircraft, when it is performed on thirdcountry registered aircraft by organisations that are not subject to Regulation (EU) No 1321/2014. This task may also be performed by the flight crew for those aircraft for which oil handling is mentioned in the aircraft flight manual, as part of the pre-flight inspection as indicated in AMC M.A.301(a), paragraphs 2 and 3, to the abovementioned Regulation.

(b)Aircraft may be replenished with oil either by aircraft operator personnel or by a contracted thirdparty provider that holds approval in accordance with the requirements mentioned above.

Regulation (EU) 2025/20

For the purpose of this Regulation, the following definitions apply:

(1)‘ground handling organisation’ means one of the following:

(a)a stand-alone ground handling organisation or a ground handling organisation that is part of a single ground handling organisation business grouping;

(b)an aerodrome operator providing ground handling services;

(c)an aircraft operator providing ground handling services to itself or within a single air carrier business grouping (self-handling);

(2)‘single ground handling organisation business grouping’ means two or more ground handling organisations providing services in more than one Member State and are registered in territories to which the Treaties apply, which facilitate the harmonisation of their management systems and main organisation processes for the purpose of compliance with this Regulation, including applying the same policies, processes and procedures to the components of their management systems such as the safety management, documentation, compliance monitoring, management of changes, training of ground handling personnel, operational procedures, and maintenance programme for ground support equipment;

(3)‘passenger handling’ means activities related to any kind of assistance to arriving, departing, transfer or transit passengers, including, where applicable, passenger and baggage acceptance, travel documents and flight tickets check, boarding pass issuance, gate activities, passenger boarding and disembarkation;

(4)‘ground support equipment (GSE)’ means a motorised or non-motorised mobile vehicle, apparatus or piece of equipment that is designed, built and used for the provision of ground handling services on the movement area of an aerodrome;

(5)‘baggage handling’ means a process consisting of several steps covering baggage sorting, baggage build, baggage transportation from the sorting area to the aircraft and vice versa, gate delivery baggage, baggage arrival, mishandled baggage, baggage reconciliation;

(6)‘into-plane fuelling service’ means delivery of fuel to an aircraft;

(7)‘aircraft de-icing’ means a ground procedure by which frost, ice, snow or slush is removed from an aircraft in order to provide uncontaminated surfaces. The process can combine de-icing and anti-icing performed in two steps;

(8)‘aircraft anti-icing’, means a ground procedure that provides protection against the formation of frost or ice and accumulation of snow or slush on treated surfaces of the aircraft for a limited period of time (holdover time);

(9)‘aircraft turnaround’ means a coordinated process of activities associated with the handling of an aircraft, its passengers, baggage, mail and cargo, occurring in a predetermined time interval between the aircraft arrival and its departure;

(10)‘aircraft loading’ means stowing load or unit load devices (ULDs) on board the aircraft in accordance with the loading instructions;

(11)‘baggage’ means the personal property or other articles of a passenger or crew member carried on a flight;

(12)‘cargo’ or ‘freight’ means goods or property that are carried on an aircraft, other than baggage, mail, company material, company mail, and in-flight supplies, which are not consumed or used during flight;

(13)‘mail’ means dispatches of correspondence and other items, other than the aircraft operator’s mail, tendered by and intended for delivery to postal services in accordance with the rules of the Universal Postal Union (UPU);

(14)‘aircraft towing’ means the forward movement of an aircraft in service or out of service by using external power of ground support equipment that supports the aircraft’s nose landing gear or is attached to it;

(15)‘aircraft pushback’ means the movement of an aircraft from a nose-in parking position by using external power of ground support equipment. The operation may involve a towbar;

(16)‘unit load device (ULD)’ means a device for grouping and restraining cargo, mail and baggage for air transport that is either an aircraft container or a combination of an aircraft pallet and an aircraft pallet net, which is designed to be directly restrained by the aircraft cargo loading system (CLS);

(17)‘load control’ means a process under the responsibility of the aircraft operator, to ensure that the aircraft is safely and efficiently loaded before each flight;

(18)‘organisation providing ground handling services in more than one Member State’ means a ground handling organisation or a self-handling aircraft operator that provides services at aerodromes in more than one Member State and is overseen by more than one competent authority. It includes organisations that may or may not be part of a single ground handling organisation business grouping or of a single air carrier business grouping;

(19)‘audit’ means a systematic, independent and documented process for obtaining evidence and evaluating it objectively to determine the extent to which requirements are complied with;

(20)‘inspection’ means, in the context of compliance monitoring and oversight, an independent and documented conformity evaluation by observation and judgement accompanied, as appropriate, by measurements, testing or gauging, in order to verify compliance with applicable requirements; whereas an inspection may be part of an audit, but may also be conducted outside the normal audit plan, in particular, to verify the closure of a certain finding;

(21)‘dangerous goods (DG)’ means articles or substances which are capable of posing a hazard to health, safety, property or the environment and which are shown in the list of dangerous goods in the Technical Instructions or which are classified according to those Instructions;

(22)‘ICAO Technical Instructions’ means ICAO Doc 9284 ‘Technical Instructions for the Safe Transport of Dangerous Goods by Air’;

(23)‘notification to captain (NOTOC)’ means accurate and legible written information provided to the commander or pilot-in-command concerning dangerous goods shipments or other special cargo that is to be carried on board the aircraft;

(24)‘just culture’ means just culture as defined in Article 2, point 12, of Regulation (EU) No 376/2014 of the European Parliament and of the Council²⁰;

(25)‘aircraft handling’ means all the ground handling activities and communications occurring on the movement area, including aircraft refuelling and defuelling, aircraft de-icing and anti-icing, replenishing with potable water, toilet and wastewater services, catering handling, aircraft cleaning services, provision and operation of ground support equipment, aircraft access, securing of aircraft on the ground, aircraft loading and unloading, aircraft pushback or towing, equipment attachment and removal, operation of vehicles and equipment in the immediate vicinity of the aircraft;

(26)‘passenger boarding bridge’ means a telescopic corridor that extends from an airport terminal to an aircraft for the passenger boarding and disembarkation;

(27)‘turnaround coordination’ means a ground handling function with a safety role, which coordinates the ramp handling activities and ends with the release (dispatch) of a flight upon the completion of the ground handling services to the aircraft on the apron;

(28)‘cargo compartment’ means the area of an aircraft that may be used for the transport of cargo, and/or baggage;

(29)‘equipment restraint area (ERA)’ means a safety buffer area around the aircraft, which shall remain free from obstruction and foreign object debris before and after aircraft arrival and departure and during aircraft manoeuvring to and from the parking stand, except for the ground support equipment and personnel required for manoeuvring;

(30)‘loading instructions’ means a set of instructions supporting the person supervising the aircraft loading in ensuring the correct and safe loading of the aircraft;

(31)‘mass and balance documentation’ means documents containing data about the aircraft mass and balance, centre of gravity, aircraft load, notification to captain (NOTOC) for dangerous goods, loading instructions, load information.

ED Decision 2025/007/R

TERMS USED IN THE ACCEPTABLE MEANS OF COMPLIANCE AND GUIDANCE MATERIAL

For the purpose of the AMC and GM to Regulation (EU) 2025/20, the following definitions apply:

ED Decision 2025/007/R

GROUND HANDLING ORGANISATION

(a)GH services may be provided by different types of organisations. When the terms ‘organisation providing GH services’, ‘ground handling service provider’ (GHSP) or ‘GH organisation’ are used in Commission Delegated Regulation (EU) 2025/20 and the associated AMC and GM, they are understood to cover all organisations identified in Article 3, definition (1) unless it is clearly specified otherwise in the Regulation.

(b)A provider of GH services that is contracted by another GH organisation to provide any GH service listed in Article 2(2) is considered a GH organisation and therefore subject to Commission Delegated Regulation (EU) 2025/20.

(c)A freight forwarder is not considered a GHSP. Freight forwarding is not included in the definition of GH services in Regulation (EU) 2018/1139. If a freight forwarder provides a GH service listed in Article 2(2) of Commission Delegated Regulation (EU) 2025/20, the requirements for contracted activities will apply, either under Regulation (EU) No 965/2012 (point ORO.GEN.205), when its services are contracted directly by an aircraft operator, or under Commission Delegated Regulation (EU) 2025/20 (point ORGH.MGM.205), when its services are contracted directly by a GH organisation.

ED Decision 2025/007/R

AERODROME OPERATOR PROVIDING FACILITIES AND INFRASTRUCTURE OUTSIDE THE SCOPE OF COMMISSION DELEGATED REGULATION (EU) 2025/20

(a)An aerodrome operator may provide certain centralised infrastructure or equipment for the provision of GH services, such as centralised baggage sorting infrastructure, deicing facilities and PBBs.

(b)When the aerodrome operator provides such equipment or facilities but its personnel are not involved in their operation, that aerodrome operator does not fall within the scope of Commission Delegated Regulation (EU) 2025/20. The aerodrome operator providing training on the operation of the facilities and infrastructure provided to the GH organisations is not considered a GH organisation and is not required to declare itself as such in accordance with the Regulation.

(c)When the aerodrome operator’s own personnel are also involved in the operation of the facilities or infrastructure, that operator is considered a GH organisation and shall comply with Commission Delegated Regulation (EU) 2025/20.

ED Decision 2025/007/R

AIRCRAFT OPERATOR PROVIDING GH SERVICES

(a)The term ‘aircraft operator’, when used in relation to selfhandling, should be understood as an aircraft operator that may or may not be part of a single air carrier business grouping unless specified otherwise.

(b)A selfhandling aircraft operator providing GH services to other aircraft operators that are not part of the same single air carrier business grouping is considered to be a GH organisation as identified in paragraph 1(a) of Article 2 of Commission Delegated Regulation (EU) 2025/20. In such a case, the Regulation is fully applicable to such an organisation.

SINGLE AIR CARRIER BUSINESS GROUPING

(c)A single air carrier business grouping refers to two or more air operator certificate (AOC) holders whose PPoB is in a territory to which the EU Treaties apply. Those AOC holders may or may not facilitate the harmonisation of their management systems and operations for the purpose of applying the requirements for selfhandling in a harmonised way. The management systems and operations include policies, processes and procedures for GH, training of personnel performing GH activities, ground operations procedures, and the maintenance programme for GSE.

(d)This concept is used in Commission Delegated Regulation (EU) 2025/20 for situations where an aircraft operator provides GH services not only to itself through selfhandling but also to other aircraft operators that are part of the same business grouping. The application of this concept serves several purposes:

(1)to avoid the duplication of GH requirements;

(2)to enable AOC holders performing selfhandling, including providing GH services to aircraft operators that are part of the same business grouping, to identify the competent authority to which they should submit a declaration; and

(3)to enable effective and efficient oversight, including cooperative oversight.

ED Decision 2025/007/R

SINGLE GROUND HANDLING ORGANISATION BUSINESS GROUPING

The concept of single GH organisation business groupings is used in Commission Delegated Regulation (EU) 2025/20 for situations where a GH organisation has several branches that are registered in more than one Member State but belong to the same parent company. In such cases, it is necessary to establish that such organisations should be regarded as part of a single business grouping and should have a single PPoB — the one where the parent company is located. The application of this concept serves several purposes:

(a)to avoid the duplication of GH requirements for the same organisation;

(b)to avoid multiple oversight audits and inspections with the same scope — the organisation’s management system — and to enable effective and efficient cooperative oversight; and

(c)to enable GH organisations to identify to which competent authority they should submit a declaration.

ED Decision 2025/007/R

AIRCRAFT GROUND DEICING AND ANTI ICING

ICAO Doc 9640 provides the following definitions for the terms ‘antiicing’, ‘deicing’ and ‘deicing/antiicing’.

(a)‘Antiicing’ is a precautionary procedure by which clean aircraft surfaces are protected against the formation of ice and frost and the accumulation of snow and slush for a limited period.

(b)‘Deicing’ is the process that removes ice, snow, slush or frost from aircraft surfaces.

(c)‘Deicing/antiicing’ is a procedure combining both the deicing process and the antiicing process and that can be performed in one or two steps.

(1)‘Onestep deicing/antiicing’. Heated antiicing fluid is used to deice the aircraft and remains on the surfaces to which it is applied to provide antiicing capability.

(2)‘Twostep deicing/antiicing’. This procedure contains two distinct steps: the first step, deicing, is followed by the second step, antiicing, as a separate fluid application.

ED Decision 2025/007/R

AIRCRAFT TOWING

(a)Towing can be done using a towbar or a towbarless tractor. The GSE may be attached to the main landing gear. Depending on the type of towing vehicle, the operation may involve direct steering from the flight crew compartment by authorised personnel who are in the flight crew compartment at the time of taxiing.

(b)Aircraft towing may have different purposes:

(1)Aircraft maintenance. This operation is performed with no passengers or cargo and with minimum fuel on board the aircraft. This falls outside the scope of Commission Delegated Regulation(EU) 2025/20, as stated in Article 2(3)(g).

(2)Operational/dispatch. This is towing of an aircraft to/from the terminal gate or parking area to/from a remote parking area, with or without passengers, cargo or fuel on board.

ED Decision 2025/007/R

AIRCRAFT PUSHBACK

(a)Nosegearcontrolled pushback includes either the towbar method, where the rearward movement and steering of the aircraft are controlled by a vehicle and towbar attached to the nose gear, or the towbarless method, where a vehicle is attached directly to the nose gear.

(b)Maingearcontrolled pushback involves using a vehicle that grasps the aircraft’s maingear tyres to provide rearward movement, while directional control is provided from the flight deck using the nosewheel steering system.

Regulation (EU) 2025/20

The conditions and procedures for organisations providing ground handling services to declare their capability and the availability to them of the means, to discharge the responsibilities for the safe provision of services as referred to in Article 37(2) of Regulation (EU) 2018/1139, shall be as set out in Annexes I and II to this Regulation.

Regulation (EU) 2025/20

Organisations already providing ground handling services on 27 March 2025 shall submit a declaration in accordance with point ORGH.DEC.100 of Annex I to this Regulation from 27 March 2028 – 1 year = 27 March 2027, in accordance with a plan established and agreed with their competent authority as identified in point ORGH.GEN.105 of Annex I to this Regulation.

Regulation (EU) 2025/20

1.This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union.

2.It shall apply from 27 March 2028.

3.However, point ORGH.MGM.201 of Annex I to this Regulation shall apply from 27 March 2031.

Regulation (EU) 2025/20

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Brussels, 19 December 2024.

For the Commission

The President

Ursula VON DER LEYEN

Annexes

ANNEX I — RESPONSIBILITIES OF GROUND HANDLING ORGANISATIONS REGARDING THE SAFE PROVISION OF SERVICES AND CONDITIONS AND PROCEDURES FOR THE DECLARATION (PART-ORGH)

SUBPART GEN — GENERAL REQUIREMENTS

Regulation (EU) 2025/20

This Annex establishes requirements on the following:

(a)responsibilities of the organisations listed in Article 3 definition (1) of this Regulation, which provide ground handling services at one or more aerodromes within the scope of Regulation (EU) 2018/1139;

(b)conditions and procedures for the declaration by those organisations.

Regulation (EU) 2025/20

(a)The competent authority responsible for receiving declarations from an organisation providing ground handling services at an aerodrome within the scope of Regulation (EU) 2018/1139 shall be the authority designated by the Member State where the aerodrome is located.

(b)A single ground handling organisation business grouping or a self-handling aircraft operator that has its principal place of business in a Member State and provides ground handling services in more than one Member State shall submit a declaration to the competent authority designated by the Member State where the organisation’s principal place of business is located.

(c)The principal place of business of a single ground handling organisation business grouping referred to in point (b) shall be determined based on all of the following criteria:

(1)it is the place where the corporate financial functions are exercised; these comprise all financial activities that are necessary to manage and maintain the organisation viable and financially fit;

(2)it is the place where the accountable manager, who holds the ultimate accountability for safety within their organisation, exercises their role;

(3)it is the effective and actual centre of control from where business development and continuity, strategy, and planning activities affecting the single ground handling organisation business grouping as a whole are managed on a regular basis.

ED Decision 2025/007/R

DECLARATION BY GH ORGANISATIONS HAVING THEIR PRINCIPAL PLACE OF BUSINESS OUTSIDE THE TERRITORIES TO WHICH THE TREATIES APPLY

Point ORGH.GEN.105(a)’s scope of application includes GH organisations that provide services in more than one Member State, either as an independent organisation or as part of a single GH organisation business grouping, and whose principal place of business (PPoB) is outside the territories to which the Treaties apply.

Such GH organisations submit a declaration to the competent authority of each Member State where they provide services.

ED Decision 2025/007/R

GH ORGANISATIONS’ PRINCIPAL PLACE OF BUSINESS

(a)For GH organisations providing services in more than one Member State and GH organisations that are part of a single GH organisation business grouping, which have a PPoB in a territory to which the Treaties apply, the entry point for all the information related to their declarations and GH activities at all EU aerodromes within the scope of Commission Delegated Regulation (EU) 2025/20 is considered to be the competent authority of the Member State where the PPoB is located.

(b)The following criteria are used to identify an organisation’s PPoB:

(1)All financial operations and decisions affecting an organisation as a whole, including the operational aspects, enabling the organisation not only to receive funds and profits and reward shareholders, but also to fulfil its obligations and make due payments. These obligations and payments range from costs associated with personnel and facilities to those related to compliance with contractual, tax or any other financial obligations; the payment of dividends, salaries, employment benefits and investment decisions. These financial management functions require planning and management of the funds of the organisation, which cannot be artificially dissociated from the operations of that organisation. These functions are therefore essential to running a business and are a strong indicator of where its headquarters is and where its management takes place, and to which system of law it has the closest link.

(2)The principal control of an organisation’s operational activities entails managing operational decisions of the organisation on a regular basis. A place from where the supply of services is monitored and managed is indicative of the organisation’s place from which it controls the operations.

(3)The organisation’s accountable manager is ultimately accountable for safety. The accountable manager is responsible for ensuring that all activities can be financed and carried out in accordance with the applicable requirements and that the organisation is adequately structured and staffed with suitably qualified personnel. With the ultimate responsibility for safety and compliance visàvis the competent authority, it is recommended that the accountable manager either reside permanently in the country where the PPoB is or demonstrate to the satisfaction of the competent authority that there are suitable means in place to discharge their responsibilities in full while not residing at the PPoB.

(4)The organisation’s key personnel (persons accountable for operations, safety, compliance monitoring, training, etc.) controlling and coordinating daily operational activities that ultimately lead to meeting the safety objectives of the EU aviation safety acquis.

(5)The head office is the place where all decision-making that affects the development of the entire corporate administration and coordination of the necessary actions takes place on a daily or regular basis.

(6)The records regarding the operational and financial decisions affecting the direction, control, planning, coordination and corporate financing of the organisation’s activities and operations, within the scope of the applicable regulations, are always tangible and potentially subject to physical inspection and/or assessment by the competent authority.

(c)The PPoB for aircraft operators performing self-handling is determined in accordance with Regulation (EU) No 965/2012.

Regulation (EU) 2025/20

(a)The ground handling organisation shall be responsible for the safe provision of services in accordance with all the following:

(1)Regulation (EU) 2018/1139 and its delegated and implementing acts;

(2)its declaration submitted pursuant to Article 37(2) of Regulation (EU) 2018/1139;

(3)the procedures for local operation contained in the aerodrome manual, as referred to in point 4.1(b) of Annex VII to Regulation (EU) 2018/1139, which are applicable to it as aerodrome user;

(4)the operational procedures and instructions of the aircraft operator related to ground handling services, when provided or, when not provided, in accordance with the ground handling organisation’s operational procedures.

(b)The ground handling organisation shall establish a ground handling manual in accordance with point ORGH.DOC.110 and shall operate in accordance with it.

(c)The ground handling organisation shall establish standards and objectives for the safe performance of ground handling activities and develop operational procedures to achieve them. It shall also define the functions necessary to perform those activities, including the associated decision-making, authority, tasks and responsibilities of those functions.

(d)The ground handling organisation shall ensure that all personnel involved in ground handling activities:

(1)are properly trained and have demonstrated their competence to perform the assigned tasks before being allowed to exercise their duties unsupervised, and that they maintain their competence;

(2)are aware of their responsibilities and understand their role and how their duties are related to the safety of aerodrome and air transport operations.

(e)When using any ground support equipment (GSE) to perform ground handling activities, the ground handling organisation shall establish and implement a maintenance programme for its GSE.

ED Decision 2025/007/R

COMPLIANCE WITH APPLICABLE REQUIREMENTS

(a)The GH organisation should conduct regular reviews of the applicable requirements with which it declares compliance, to ensure that its processes, procedures and documentation remain up to date. The relevant elements of these reviews should be reflected in its annual activity report.

(b)In conducting such reviews, the GH organisation should:

(1)ensure that any changes in the applicable requirements, standards and documents or new requirements applicable to it are identified and assessed for inclusion in its management system; and

(2)be able to provide evidence of such reviews and the assessments referred to in point (1).

Regulation (EU) 2025/20

A ground handling organisation may start operating at an aerodrome when it fulfils both the following conditions:

(a)formal arrangements with that aerodrome operator have been established;

(b)the ground handling organisation has declared its activity to the competent authority using the form set out in Appendix 1.

ED Decision 2025/007/R

PREPARATIVE STEPS

(a)The intention of point ORGH.GEN.115 is to set out the right order of these steps, to minimise the efforts required from the GH organisation to start operating at an aerodrome that restricts access in accordance with Council Directive 96/67/EC (the GH Directive).

(b)Examples of formal arrangements with the aerodrome operator may include, subject to the aerodrome’s operational context, any of the following topics:

(1)prerequisite compliance with any EU legislative acts regulating aerodrome market access, when they apply to the GH organisation;

(2)operational procedures of the GH organisation that may have an impact on the operation of the aerodrome;

(3)aspects of the access of the GH organisation’s employees and/or vehicles to the airside area;

(4)driving in the airside area;

(5)any training required for compliance with the aerodrome requirements or for use of aerodrome facilities.

(c)When a GH organisation intends to provide services at aerodromes where the GH Directive applies, it is recommended that the organisation start preparing for compliance with Commission Delegated Regulation (EU) 2025/20 and the applicable provisions referred to in the declaration even before the completion of formalities to receive the authorisation to operate at an aerodrome where the GH Directive applies.

Regulation (EU) 2025/20

(a)The ground handling organisation may use alternative means of compliance (AltMoC) to the acceptable means of compliance (AMC) adopted by the Agency to demonstrate compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts.

(b)If the ground handling organisation uses AltMoC, it shall provide the competent authority with the list of those AltMoC and shall make them available to the competent authority in due time for oversight purposes.

(c)If an organisation providing ground handling services in more than one Member State and having its principal place of business in a Member State applies an AltMoC only to aerodromes in one Member State, the organisation shall inform only the competent authority of that Member State. If such an organisation applies AltMoC to all its stations in the Member States, it shall inform the competent authority designated by the Member State where its principal place of business is located.

ED Decision 2025/007/R

DEMONSTRATION OF COMPLIANCE

(a)To demonstrate that the implementing rules are complied with, the GH organisation should complete and document a safety risk assessment for the AltMoC used. The result of this safety risk assessment should demonstrate that those AltMoC enable the achievement of a level of safety that is equivalent to that established by the AMC adopted by the Agency.

(b)The GH organisation should ensure that the competent authority receives the safety risk assessment for the AltMoC it uses in due time before an audit or inspection.

ED Decision 2025/007/R

INFORMATION AND COORDINATION

(a)The GH organisation should inform the aircraft operators or aerodrome operators concerned if its AltMoC have an impact on the procedures or instructions applicable to the provision of GH services under the current requirements.

(b)The GH organisation should also coordinate with the organisation affected by those AltMoC and agree with them on any necessary measures to ensure that those AltMoC have no unintended consequence on the activities of the other organisation.

(c)If an AltMoC is applicable only at certain stations, those stations should be mentioned in the relevant AltMoC.

ED Decision 2025/007/R

SUBMISSION OF INFORMATION TO THE COMPETENT AUTHORITY AND SAFETY RISK ASSESSMENT

(a)The GH organisation submits its list of AltMoC to the competent authority, as identified in point ORGH.GEN.105.

(b)It is recommended that the GH organisation conduct the safety risk assessment of the AltMoC used at the headoffice level, so that the assessment is valid and applicable to all stations. This is intended to avoid inconsistencies between the stations where the GH organisation provides services.

Regulation (EU) 2025/20

In order to discharge their responsibilities regarding the safe provision of ground handling services, the ground handling organisation may use its own operational procedures or industry standards or both.

ED Decision 2025/007/R

USE OF INDUSTRY STANDARDS AND GOOD PRACTICES

(a)For the purpose of the Commission Delegated Regulation (EU) 2025/20, industry standards and good practices are documented technical or operational instructions, procedures or specifications applied on a wide scale in the GH industry that establish norms, principles and criteria to standardise various aspects of GH operations, processes, products or equipment.

(b)The GH organisation may apply one or more industry standards and good practices on a voluntary basis to comply with the implementing rules. The industry standard may cover any of the following elements:

(1)management of a GH organisation, including its SMS, documentation system, compliance monitoring function, contracted services and emergency response plan (ERP);

(2)standard operational procedures for the provision of GH services and any physical or virtual tools, equipment, applications or programmes used;

(3)training for the GH functions;

(4)technical and/or safety specifications for products and equipment used to provide GH services.

(c)The organisation should ensure that the industry standards and good practices that it uses to comply with Commission Delegated Regulation (EU) 2025/20 meet the criteria for safety and quality of AMC2 ORGH.GEN.125.

(d)The GH organisation should document deviations from the applicable industry standards that affect safety of operation. Where deemed relevant, the organisation should conduct a safety risk assessment for those deviations.

Use of industry standards and good practices — internal compliance monitoring checks

(e)When the GH organisation uses industry standards and good practices to comply with Commission Delegated Regulation (EU) 2025/20, the internal compliance monitoring checks should include a random verification of the correct application of those industry standards and good practices.

Use of a thirdparty service provider to verify conformity with industry standards

(f)The GH organisation should comply with point ORGH.MGM.205 for contracted services when a thirdparty industry auditor verifies the organisation’s conformity with industry standards and good practices. The GH organisation should also ensure that there is no conflict of interest of the thirdparty auditors with the audited organisation.

(g)The GH organisation should remain aware that conformity with the industry standards and good practices demonstrated through thirdparty industry audits does not automatically presume compliance with the implementing rules.

ED Decision 2025/007/R

OBJECTIVE CRITERIA FOR INDUSTRY STANDARDS

(a)The industry standards used to demonstrate compliance with Commission Delegated Regulation (EU) 2025/20, including those that are subject to the evaluation referred to in point ARGH.OVS.310 of Commission Implementing Regulation (EU) 2025/23, should meet the following criteria as a minimum:

(1)they are developed, maintained and endorsed with the participation of experts from relevant industry stakeholders;

(2)they address the scope of Annex I and/or II to Commission Delegated Regulation (EU) 2025/20, as applicable, with sufficient details to enable implementation of the related implementing rules;

(3)they are based on experience in the field and have proven themselves through testing;

(4)they are supported by scientific and/or technical data and documentation, safety tests and safety impact assessments, as applicable;

(5)they include technical, operational and, if applicable, human factors specifications for their safe implementation;

(6)they clearly identify the responsibilities of the persons involved in their application;

(7)they contain procedures for continuing review and improvement, to include lessons learned from daily operations and consider relevant innovations in the field.

RELEVANT INDUSTRY STAKEHOLDERS

(b)The industry stakeholders represented in the development, maintenance and endorsement of an industry standard should include but not be limited to aircraft operators, GH organisations, aerodrome operators, product manufacturers, GSE manufacturers, aircraft manufacturers, and regional or global industry associations thereof, as applicable. The aim of their inclusion is to ensure that all stakeholders involved in the development and maintenance of industry standards are also involved in their endorsement.

ED Decision 2025/007/R

INDUSTRY STANDARDS AND GOOD PRACTICES IN THE SCOPE

(a)Industry standards and good practices refer to several documents developed by industry and used by organisations for the provision of GH services, which may be used to implement the requirements of Commission Delegated Regulation (EU) 2025/20.

(b)Examples of industry standards and good practices adopted by industry are as follows:

(1)IATA Ground Operations Manual (IGOM),

(2)IATA Airport Handling Manual (AHM),

(3)IATA Cargo Handling Manual (ICHM),

(4)IATA Dangerous Goods Regulations (DGR),

(5)IATA Live Animals Regulations (LAR),

(6)IATA Perishable Cargo Regulations (PCR),

(7)IATA ULD Regulations (ULDR),

(8)JIG standards related to fuelling,

(9)SAE standards related to aircraft ground deicing and antiicing,

(10)EN standards for GSE (EN 123121 to 1231220 and EN 19151 to 19154),

(11)IBAC International Standard for Business Aircraft Handlers regarding GH (ISBAH) for business aviation operations.

Regulation (EU) 2025/20

(a)The ground handling organisation shall develop, implement and maintain a process as part of its management system to manage changes to its established processes, procedures and services. If the changes directly affect its capability to safely provide ground handling services, it shall ensure the following:

(1)assess the safety risks of the expected changes, and implement mitigating measures to address those risks;

(2)determine whether and how the changes affect its interfaces with other organisations and, if necessary, involve those organisations in the safety risk assessment and risk mitigation and align those mitigating measures to avoid contradictions or deterioration of safety;

(3)communicate the changes and mitigating measures to the organisations affected by them;

(4)document the process.

(b)If the changes affect its declaration, the ground handling organisation shall update the declaration and submit it to the competent authority without undue delay.

(c)Notwithstanding points (a) and (b), the assessment of risks arising from any planned changes and the related documentation shall be proportionate to the size and complexity of the ground handling organisation.

(d)Notwithstanding points (a), (b) and (c), aircraft operators performing self-handling and aerodrome operators providing ground handling services may apply their already existing process for the management of changes to manage the changes related to the provision of ground handling services.

(e)The ground handling organisation shall provide the competent authority with the relevant documentation covering point (a) in due time for an audit or inspection.

ED Decision 2025/007/R

ASSESSMENT OF CHANGES

(a)Changes may affect the safety performance of a GH organisation and may result in the inadvertent introduction of new hazards that could expose the organisation to new or increased risks if they are not properly managed.

(b)Examples of major changes affecting operations, organisations and personnel:

(1)provision of new GH services;

(2)new types of equipment, including GSE, or equipment based on new technologies;

(3)new types of aircraft for which GH services will be provided;

(4)new stations or schedules;

(5)new training methods or training providers;

(6)new AltMoC;

(7)new or significantly amended regulations, industry standards, good practices or operational procedures, if these have not already undergone a safety risk assessment;

(8)changes in security arrangements;

(9)changes to organisational structure (change of ownership, mergers);

(10)significant changes in personnel affecting key personnel and/or large numbers of personnel (e.g. high volume of newly hired personnel, high staff turnover, insufficient personnel);

(11)transfer of GH services between service providers or between a GH organisation and an aerodrome operator (e.g. PRM handling, operation of PBBs);

(12)changes in the economic situation of an organisation (e.g. commercial or financial).

(c)Effective management of change starts by identifying the scope of the change (why it is necessary, its range, its objective), the magnitude of the change, its safety criticality and its potential impact on human performance. Then, the GH organisation follows the same steps as for a safety risk assessment (hazard identification, risk assessment, risk mitigation). The assessment should be supported by the following data and information obtained through:

(1)conduct of safety cases, safety risk assessments focused on aviation safety. A safety case is a structured argument, supported by evidence, intended to justify that a system is acceptably safe for a specific application in a specific operating environment;

(2)the involvement of key stakeholders in the change management process as appropriate;

(3)the review of previous safety risk assessments, existing hazards and mitigation measures applied; where present;

(4)transparent communication on the implementation plan and progress against the plan.

(d)The assessment of changes is normally initiated by the team that proposes and/or implements them. However, a change can only be successfully implemented if all the personnel affected by the change participate in the process.

(e)The management of change is effective if it is meaningful to the GH organisation and adjusted to its size and complexity.

(f)It is recommended that the process be reviewed upon closure, to identify gaps and lessons learned for future assessments.

ED Decision 2025/007/R

CHANGES NOT AFFECTING THE DECLARATION

(a)The intention of point ORGH.GEN.130(b) is to also cover changes that are not directly reflected in the declaration but could influence the discharge of the responsibility for the provision of GH services as declared. Such changes — for example, a change to the organisation’s financial structure or human resource procedures, may have an indirect effect on the organisation’s management system, but they do not have to be reported to the competent authority. That is why it is important that they are managed appropriately.

(b)GH organisations are not expected to inform the competent authority every time they change their documentation. For example, changes such as amendments to their GH manuals or procedures they follow, or updates to their training programmes, station representatives or GSE maintenance programmes, do not need to be reported to the competent authority.

(c)A GH organisation only needs to ensure that the competent authority has the latest version of its documentation, including the items mentioned above, in due time before an inspection or audit.

Regulation (EU) 2025/20

For the purpose of determining whether a ground handling organisation acts in accordance with its declaration, the ground handling organisation shall ensure, at any time, that the persons duly authorised by the competent authority responsible for the oversight of that organisation:

(a)are granted access to any facility, document, records, data, procedures or any other material relevant to the activity of the organisation;

(b)are allowed to perform or witness any action, inspection, test, assessment or exercise that the competent authority finds necessary.

Regulation (EU) 2025/20

The ground handling organisation shall submit the following documents in their latest version to the competent authority as identified in point ORGH.GEN.105, preferably in an electronic format, within a time frame commonly agreed with the competent authority and in due time before an oversight audit or inspection:

(a)if applicable, a list of the AltMoC used for the ground handling activities;

(b)the organisation’s ground handling manual;

(c)any other documents requested by the competent authority in preparation of an audit or inspection.

ED Decision 2025/007/R

SUBMITTING THE GH MANUAL FOR OVERSIGHT PURPOSES

If the organisation providing GH services is an aerodrome operator or a selfhandling aircraft operator that already has an aerodrome manual or an operations manual that contains GH elements, it is expected to submit only the parts of its manuals that show compliance with Commission Delegated Regulation (EU) 2025/20.

Regulation (EU) 2025/20

(a)When the competent authority raises a finding of non-compliance, the ground handling organisation shall take the following steps within the time period determined by the competent authority:

(1)identify the root cause(s) of the non-compliance(s) and the contributing factors of that or those non-compliances;

(2)develop a corrective action plan that addresses the root cause(s) and the factors contributing to the non- compliance(s);

(3)demonstrate the implementation of the corrective action(s) to the satisfaction of the competent authority, either at the management system level or at the station level, or both, as the case may be.

(b)In addition to point (a), in the case of an organisation providing ground handling services in more than one Member State that may or may not be part of a single business grouping, the findings raised on the operation or a component of the organisation’s management system at one station and the related corrective action plans and corrective actions shall be communicated by the responsible person at that station to the organisation’s head office at its principal place of business.

(c)When the non-compliance directly affects the safety risk within, or the responsibilities of, the aircraft operator or the aerodrome operator, the ground handling organisation shall inform, without undue delay, the aerodrome operator and the aircraft operators concerned of the actions listed in point (a) and, if appropriate, coordinate such actions with them within the time period referred to in point (a).

ED Decision 2025/007/R

GENERAL

(a)The corrective action plan defined by the organisation providing GH services should address the effects of the noncompliance, as well as its root cause(s) and contributing factors.

(b)When a finding is raised at an individual station of a GH organisation providing GH services in more than one Member State (which may or may not be part of a single GH organisation business grouping), the GH organisation may decide how to implement the corrective action — either at the station level, at Member State level or at the management system level, with the aim of addressing the issue at all stations where the same finding has been raised.

(c)In the case of level 2 findings, as referred to in point ARGH.OVS.325 of Commission Implementing Regulation (EU) 2025/23, the GH organisation should submit a root cause analysis and a corrective action plan to the competent authority within a specified period. This period should be shorter than the corrective action implementation period, in order to provide sufficient time for the competent authority to agree on the submitted corrective action plan and for the GH organisation to implement it before the end of the implementation period.

ED Decision 2025/007/R

ROOT CAUSE ANALYSIS

(a)It is important that the analysis does not primarily focus on establishing who or what caused the noncompliance, but on why it happened. Establishing the root cause(s) of noncompliance often requires an overarching view of the events and circumstances that led to it, to identify all possible systemic and contributing factors (regulatory, human, organisational, technical, operational, etc.) in addition to the direct factors.

(b)A narrow focus on single events or failures to identify the chain of events that led to the noncompliance may not properly reflect the complexity of the issue. Such an approach may not consider important factors that must be addressed to prevent recurrence. An inappropriate or partial causal analysis often leads to defining ‘quick fixes’ that only address the effects of the nonconformity. A peer review of the results of the causal analysis may increase its reliability and objectivity.

(c)It is expected that the root cause analysis consider organisational structures, processes and their interfaces, procedures, personnel, equipment, facilities and the environment in which the organisation operates to set up effective corrective actions to preventing recurrence. Root cause analysis methods — for example, fishbone diagrams, Pareto charts, the ‘5 whys’ and failure mode and effects analysis — may be used to identify the underlying causes of problems, failures and inefficiencies.

Regulation (EU) 2025/20

(a)The ground handling organisation shall implement, without undue delay, any safety measures or safety directives mandated by the competent authority as an immediate reaction to a safety problem.

(b)The ground handling organisation shall inform, without undue delay, the aircraft operator to which it provides services and the aerodrome operators concerned of the implementation of the measures or safety directives referred to in point (a).

Regulation (EU) 2025/20

(a)As part of its management system referred to in point ORGH.MGM.200 of this Annex, the ground handling organisation shall establish and maintain a reporting system for safety-related occurrences and events that meets the requirements of Regulation (EU) No 376/2014 and Regulation (EU) 2018/1139, as well as their delegated and implementing acts. This system shall include mandatory and voluntary reporting.

(b)The ground handling organisation shall report:

(1)to the competent authority of the Member State of occurrence, as well as to any other organisation required to be informed by the Member State of occurrence, any safetyrelated event or condition that endangers or, if not corrected or addressed, could endanger an aircraft, its occupants or any other person, and in particular any accident or serious incident;

(2)the dangerous goods events to the appropriate authority of the Member State of occurrence.

(c)The ground handling organisation shall also transmit the occurrence report referred to in point (b) to the aerodrome operator where the event occurred and the affected aircraft operator. If relevant, the report shall also be transmitted to the air traffic services provider and any other ground handling organisation concerned that operates at the aerodrome of the occurrence.

(d)The occurrence reports shall:

(1)be transmitted to the respective authorities referred to in point (b) and to the organisations referred to in point (c) as soon as practicable, but no later than 72 hours after the ground handling organisation became aware of the occurrence, unless exceptional circumstances prevent this; and

(2)contain all pertinent information about the condition known to the ground handling organisation at the time of reporting.

(e)For reports referred to in point (b), the ground handling organisation shall produce, when relevant, a follow-up report providing details of actions it intends to take to prevent similar occurrences in the future, as soon as these actions have been identified. The follow-up report shall be:

(1)sent to the entities referred to in points (b) and (c);

(2)made in a form and manner established by the competent authority referred to in point (b)(1) or, in the case of dangerous goods, by the appropriate authority referred to in point (b)(2).

ED Decision 2025/007/R

COMPETENT AUTHORITY FOR REPORTING IN ACCORDANCE WITH REGULATION (EU) NO 376/2014

The wording ‘any other organisation required to be informed by the Member State of occurrence’ refers to any organisation that is appointed by a Member State as responsible for the investigation of aviation occurrences in accordance with Regulation (EU) No 376/2014. This organisation can be different from the competent authority of the aerodrome where the occurrence took place.

ED Decision 2025/007/R

REPORTING DANGEROUS GOODS EVENTS

(a)The ‘appropriate authority of the Member State of occurrence’ means, for the purpose of dangerous goods reporting, the national competent authority or authorities designated or otherwise recognised by a state to perform specific functions related to the dangerous goods regulations.

(b)In this case, the appropriate authority is the national civil aviation authority of the state of occurrence.

(c)The dangerous goods events expected to be reported in accordance with the ICAO Technical Instructions include:

(1)any dangerous goods accident or incident;

(2)the discovery of undeclared or misdeclared dangerous goods in cargo or mail;

(3)the finding of dangerous goods carried by passengers or crew members, or in their baggage, when not in accordance with Part 8 of the Technical Instructions.

ED Decision 2025/007/R

FOLLOWUP OF OCCURRENCES

The GH organisation should ensure that the reporting process ends with clear followup actions. The reporting process should include, besides the follow-up actions, at least the following, documented in writing:

(a)the investigation of the occurrence and the conduct of an analysis to identify the root cause;

(b)the results of the investigation;

(c)the conclusions of an investigation into an occurrence;

(d)the actions taken to prevent similar occurrences in the future — when relevant, those actions should be included in the SMS, with a safety risk assessment, mitigation measures and safety performance indicators;

(e)the dissemination and promotion of the actions taken, such as, but not limited to, a change in a procedure or the GH manual, updates to the training programme, providing feedback to the reporter (when this is not anonymous), safety promotion actions and further actions with other stakeholders involved.

ED Decision 2025/007/R

REPORTABLE EVENTS AND FOLLOWUP REPORTS

(a)The list of reportable GH events can be found in Annex IV to Commission Implementing Regulation (EU) 2015/1018, ‘Occurrences related to aerodromes and ground services’, points 1 and 2.

(b)Not all occurrences recorded under a voluntary reporting system are reportable to the competent authority; only those that involve an actual or potential aviation safety risk (Article 5(5) and (6) of Regulation (EU) No 376/2014, covering voluntary reporting) are reportable to the competent authority.

(c)It is recommended that the GH organisation liaise with the competent authority to determine what types of occurrences are considered to involve an actual or potential aviation safety risk.

(d)The GH organisation may need to assess whether that reported occurrence is subject to mandatory or voluntary reporting and consequently apply the relevant notification obligations. Sometimes a report submitted under a voluntary reporting system may have to be reclassified by the GH organisation as a mandatory report and vice versa.

(e)The GH organisation is encouraged to include all available relevant information in the notification of the competent authority. If appropriate, the information should include the indication that no further analysis or followup actions will be conducted on that occurrence (‘closed on issue’) or the assessment of the safety risk of that occurrence and actions taken to mitigate it.

Regulation (EU) 2025/20

(a)The reporting system referred to in point ORGH.GEN.160 shall contain the necessary means and procedures to enable the ground handling organisation to improve and promote safe provision of ground handling services and a safety culture within the organisation. It shall:

(1)include an internal safety reporting scheme;

(2)be used for identifying the causes of, and contributing factors to, the errors, near misses and hazards reported, and address them as part of its safety risk management process in accordance with point ORGH.MGM.200(b)(2);

(3)be used for evaluating all known, relevant information relating to errors, near misses, hazards, and the failure to follow operational procedures;

(4)enable sharing of any other safety relevant information with the organisations with which it has interfaces;

(5)provide possibilities for voluntary reporting and for reporting anonymously as part of the internal safety reporting scheme;

(6)protect the identity of the reporter, ensure the reporter’s full confidentiality and that of any personal data or details.

(b)The ground handling organisation shall have procedures to:

(1)cover internal safety reporting — mandatory and voluntary, including when the ground handling organisation uses a separate scheme for voluntary reporting;

(2)record all reports submitted;

(3)determine which events qualify for reporting under point ORGH.GEN.160(b);

(4)conduct investigations of internal reports, as appropriate;

(5)in cooperation with the aircraft operator, or the aerodrome operator, or both, as appropriate, analyse and assess the reports or groups of occurrences having the same root cause, in order to address safety deficiencies and identify trends;

(6)participate in the investigation of reported events conducted by the aerodrome operator or the aircraft operator, as appropriate, where the ground handling organisation is directly affected by the event or the proposed mitigating measures;

(7)take the necessary actions to address the root cause of the event and prevent reoccurrences;

(8)provide feedback to the reporter, if this is known, and decide on the appropriate means to disseminate the results and the mitigating measures;

(9)refrain from attribution of blame in line with the ‘just culture’ principle.

(c)The ground handling organisation shall make arrangements to collect safety issues related to contracted activities referred to in point ORGH.MGM.205.

(d)The safety reporting system shall be proportionate to the size and complexity of the ground handling organisation.

ED Decision 2025/007/R

CONTENT, USAGE, CHARACTERISTICS OF THE SAFETY REPORTING SYSTEM

(a)The GH organisation’s reporting system should be adequate for the size of the organisation; it should be kept simple and include details on what, how, where and when to report.

(b)The reports should meet the requirements of point ORGH.GEN.160 on occurrence reporting in terms of time, format and information to be reported. The GH organisation should provide the means of and format for reporting when this is not established by the relevant authorities under point ORGH.GEN.160.

(c)The reporting system should:

(1)ensure confidentiality, and enable and encourage nonpunitive, free and frank reporting of any potentially safetyrelated occurrence or risk, including incidents such as errors or near misses, safety issues and identified hazards;

(2)provide acknowledgement to the reporter of the successful submission of the report — for small organisations, verbal acknowledgement may be sufficient.

(d)The reporting system, including internal safety reporting, should clearly express the purpose and objectives. The organisation should do the following.

(1)Contain procedures to implement a just culture.

(2)Identify those reports that require investigation and determine whether the event reported qualifies for reporting under points (b) and (c) of point ORGH.GEN.160. A small GH organisation should seek advice from its competent authority on this matter.

(3)Investigate the causal and contributing factors related to the occurrence, incident, error or near-miss event that was identified, including technical, organisational, managerial and human factors. The aim should be to understand what happened and how it happened and to prevent or reduce the probability and/or consequences of future recurrence. Complex organisations should analyse the collective data showing the trends and frequencies of the contributing factors.

(4)Take the necessary corrective actions based on the results of the investigation, to address the root cause of the event and to disseminate knowledge of relevant incidents and accidents and of actions taken to the employees concerned.

(5)Ensure, where relevant, cooperation with the aircraft operator and the aerodrome operator on occurrence investigations by exchanging relevant information to improve ground and flight safety.

(6)Participate in the investigation conducted by the aerodrome operator or the aircraft operator, as appropriate, where the organisation is directly affected by the event or the proposed mitigation measures.

(7)Ensure that the findings of investigations feed into the relevant recurrent training while maintaining the required confidentiality.

(e)Access to reports submitted should be restricted to personnel responsible for processing, storing and analysing them. A small GH organisation may apply a more flexible approach to this restriction, appropriate to its organisational structure.

ED Decision 2025/007/R

SAFETY REPORTING CULTURE — UNDERSTANDING THE RISKS OF NOT REPORTING

In a nonfunctioning or badly functioning safety environment, events go unreported due to fear of repercussions (possibly indicating poor or no just culture), lack of awareness, prioritisation of completing tasks over reporting safety issues, lack of training on occurrence reporting, etc.

In a wellfunctioning safety environment, a just culture within the organisation facilitates the accurate reporting of events by GH personnel when they occur to ensure that the appropriate assessments are carried out.

(a)Key risk areas:

(1)damage done to the aircraft may go unnoticed by the flight crew or not be reported to them, especially for aircraft with carbonfibre structures;

(2)events are not properly understood as an accurate root cause analysis is much harder to perform.

(b)Potential consequences:

(1)unnoticed aircraft damage may endanger the flight;

(2)effective corrective actions cannot be put in place;

(3)damagerelated costs increase.

(c)Mitigation measures:

(1)include the SMS in the training programme for personnel, explaining the value of having a safety culture and a healthy, nonpunitive safety reporting system;

(2)apply a just culture and encourage open communication at all levels, topdown and bottomup, about safety actions, events, occurrences and mitigation, to encourage proper reporting, thus enabling damage assessment and event analysis.

ED Decision 2025/007/R

SHARING OF SAFETYRELEVANT INFORMATION WITH INTERFACING ORGANISATIONS

(a)The relevant information to be shared with the aircraft operator or aerodrome operator, or both, to improve safety in GH and the operational procedures for addressing safety interfaces includes information, data, facts and analyses from various sources, such as:

(1)audits and inspections, their findings and associated corrective actions;

(2)safety reports;

(3)accident/incident investigations;

(4)safety studies and reviews from official and verified sources.

(b)Safetyrelevant information may also be communicated outside the regulatory framework of occurrence reporting as per point ORGH.GEN.160, which implements the essential requirements of Regulation (EU) 2018/1139 (Section 4.2.2 of Annex VII). For example, aerodrome safety committee meetings could be used to maintain regular communication on safety matters and share good practices, common procedures and safety information relevant to the interface procedures.

ED Decision 2025/007/R

SAFETY INVESTIGATION TEAM

It is recommended that the GH organisation ensure that the team involved in the analysis of the investigation includes:

(a)GH personnel that are competent in the area or subject of the occurrence;

(b)in the case of a complex GH organisation, a trained investigator or an individual that has received training in investigating occurrences.

Regulation (EU) 2025/20

(a)The ground handling organisation shall implement a procedure to ensure that its personnel:

(1)do not perform any duties under the influence of alcohol, any psychoactive substances or any medicine that may have an effect on their abilities to perform their tasks in a manner contrary to safety;

(2)do not consume any of those substances while on duty.

(b)The procedure shall be included in the ground handling organisation’s management system.

ED Decision 2025/007/R

ICAO GUIDANCE AND AERODROME OPERATOR PROCEDURE

(a)Further guidance on this issue may be found in ICAO’s Manual on Prevention of Problematic Use of Substances in the Aviation Workplace (Doc 9654).

(b)Alternatively, the GH organisation may adopt the aerodrome operator’s procedure in this area and refer directly to it in its own documentation.

SUBPART MGM — MANAGEMENT SYSTEM

Regulation (EU) 2025/20

(a)The ground handling organisation shall develop and implement a management system proportionate to the type and complexity of activities, the size of the organisation, and the operational context, to manage the safety risks; it shall aim for continuous improvement of this system and ensure fostering of a safety culture within its organisation. The management system shall cover all the systems and processes necessary for the ground handling organisation to discharge its responsibilities.

(b)The management system shall include the following:

(1)clearly defined lines of accountability and responsibility with regard to the overall activities of the organisation throughout the organisation, including a direct safety accountability of the accountable manager;

(2)a safety management system that includes the following elements:

(i)a description of the overall philosophy and principles of the organisation with regard to safety, referred to as ‘the safety policy’, signed by the accountable manager;

(ii)a process to identify safety hazards, and to assess and mitigate the safety risks in ground handling activities, including the human factors;

(iii)a process to manage and improve the organisation’s safety performance by establishing safety objectives, standards, and indicators, and to validate the proportionality and effectiveness of the mitigating measures in addressing the safety risks;

(iv)means to promote safety within the organisation, with the purpose of fostering a safety culture, in particular, means to communicate on safety topics, so that personnel are aware of their role in maintaining ground and flight safety and in contributing to the safety culture;

(v)identification of interfaces with other stakeholders, and the ground handling organisation’s own safety accountability, authority and responsibility within those interfaces;

(3)a process to manage changes in accordance with point ORGH.GEN.130;

(4)methods to ensure a minimum level of control to prevent fatigue to its personnel by complying with the existing applicable requirements, also considering the different ground handling functions and the associated safety risks of the assigned tasks;

(5)a training programme to ensure that personnel involved in the ground handling activities are competent to perform the safety-related duties and that they are familiarised with the rules and procedures relevant to their tasks;

(6)a process to monitor compliance of the ground handling organisation with the applicable requirements and regulations under the terms of its declaration, which shall include feedback on findings to the accountable manager to ensure effective implementation of corrective actions as necessary, and continuous improvement and updates of the management system components;

(7)a document management system.

(c)The ground handling organisation shall document the processes of the management system referred to in points (b)(1) to (7).

(d)Notwithstanding points (a), (b) and (c), if the ground handling organisation is part of a legal entity that holds one or more additional certificates, approvals, or authorisations or declares its activity in accordance with Regulation (EU) 2018/1139 and its delegated and implementing acts, the ground handling organisation may integrate its management system with the management system that it has already established under the provisions applicable to that certificate, approval, authorisation or declaration, as the case may be.

ED Decision 2025/007/R

SMALL GH ORGANISATIONS

(a)An organisation that has up to 25 fulltime equivalent (FTE) employees is considered a small GH organisation. It may perform any of the GH activities listed in Article 2 of Commission Delegated Regulation (EU) 2025/20. It should be understood that a small organisation is considered to be noncomplex, and also that the complexity refers to its organisational structure, not to the complexity of the operations it performs.

(b)The maximum number of FTEs should be regarded as an annual average, to accommodate any seasonal or occasional fluctuations.

(c)If the GH organisation uses more than 25 FTEs regularly or for periods longer than six consecutive months, it should no longer be considered small and should apply the AMC associated with Regulation (EU) 2025/20 or the parts thereof that are applicable to complex organisations.

ED Decision 2025/007/R

SCALABILITY AND SUITABILITY OF AN OPERATIONAL AND EFFECTIVE MANAGEMENT SYSTEM

(a)All organisations, regardless of their size, are exposed to risks, some of which are potentially significant. This means that:

(1)all elements of a management system should apply;

(2)the effectiveness of the management system will depend on how appropriately its elements are designed, implemented and operated.

(b)However, an operating management system does not need to be complicated and expensive to be effective. It could be made scalable if it keeps on delivering as expected and provides an effective way to manage all key operational risks.

(c)Scaling a management system (including the SMS) does not mean choosing to apply only some elements of the system and not others. Scalability is about adapting the system to the specific operational context of the organisation.

(d)The following aspects are vital for any organisation to understand the context in which its management system operates, the purpose of the management system and the key risks that it must manage effectively (the list is not exhaustive):

(1)regarding the size of the organisation:

(i)number of employees, number of stations where GH services are provided, facilities, pieces of GSE utilised, internal and external interfaces and organisational structure;

(ii)type and variety of services provided;

(iii)number of aircraft operator customers and volume of serviced flights or passengers (as relevant);

(2)regarding the complexity of the GH activities performed and, consequently, of the risks to be managed:

(i)the GH organisation’s hazards log, the safety risk assessment reflected in the safety risk severity and tolerability levels, safety performance indicators, the complexity of mitigation measures and controls put in place to minimise the risks of a particular GH activity;

(ii)the number of personnel compared to the number and complexity of tasks to complete for a particular GH activity or for all GH services provided by a GH organisation;

(iii)the training programme to be completed by the personnel assigned to a particular GH activity;

(iv)the interfaces of a particular GH activity with other GH operations or other actors contributing to its execution;

(v)the communication layers among the individuals and entities involved in the execution of that activity, and the hierarchical levels involved in the communication chain;

(vi)the use of any GSE for the execution of a particular GH activity;

(vii)risks associated with the operating environment (e.g. congested aerodrome, mountainous, climate, geographical location, stations near conflicts zones), safety consequences of low safety performance of services provided, potential downtime, etc.;

(viii)risks associated with the business model (e.g. takeovers, mergers, extent of contracted services, services based on a short turnaround or operations under commercial pressure; GH organisation as part of a single GH organisation business grouping, a standalone organisation, or part of an aircraft operator or aerodrome operator);

(ix)AltMoC granted by the competent authority;

(3)regarding other external and internal factors:

(i)societal and public expectations;

(ii)economic and commercial environment, competition, balance between the need to ensure stability of the business and the need for change;

(iii)experience in the business, adequacy and robustness of existing procedures;

(iv)safety culture, open reporting culture, prevention culture and just culture;

(v)state’s overall performance.

(e)This multidimensional complexity needs proper weighing. The topics below may be used for this evaluation. More details are provided in the Annexes to EASA’s Management System Assessment Tool.

(1)The safety policy may be a brief highlevel statement of the commitment of management, supported by safety objectives that address significant risks; it would be more detailed in a challenging environment. The regular updating of the safety objectives is necessary where the business/operations are continually evolving (due to changing operational activities, numerous deficiencies, crises, etc.).

(2)It is recommended that the communication of these safety objectives be commensurate with the resources of the organisation.

(3)The reporting policy, just culture policy and safety objectives could be combined with the safety policy for small organisations.

(4)The significance of the areas of greater risk (severity, likelihood), the robustness of the mitigation measures greatly affect the efficiency of the safety barriers;

(5)For organisations with a lower level of risk, the safety risk assessment model that they use may be very simple if the hazards identified are easy to mitigate. In addition, the organisation will strive to classify risks in a consistent manner; expert judgement may be sufficient to measure the efficiency of the safety barriers, especially when the volume of data or safety information does not support the precise evaluation of the likelihood and the severity of the consequences of the hazards.

(6)Focus on risks at interfaces will significantly depend on the criticality of the contracted services and the magnitude of the supply chain. The communication of changes and communication at the interfaces will certainly be more demanding in a large organisation or in an organisation contracting many activities.

(7)The management system documentation, hazard log and records (of safety risk assessments, decisions, actions, ownership and monitoring) should be clear and concise but sufficiently detailed to ensure the adequate management of risks. They should be consistent and complete. However, in a small GH organisation, they should not generate ‘red tape’.

(8)Human performance and human resources can be critical for organisations of all sizes, although the related issues may depend on organisations’ context and size: small organisations will be more affected by retirement, transfer of knowledge, sickness and a stressful environment, whereas large organisations experiencing major changes or significant growth will face major challenges.

(9)The degree of urgency of reaching a certain level of safety based on deficiencies, feedback from the compliance monitoring system, cultural factors or changes to rapidly manage any immediate/pressing safety issue, may affect the resources required for the timely achievement of the safety objectives.

(f)The implementation of industry standards and good practices directly relevant to a GH organisation’s activities will also be considered in the design and functioning of its management system.

(g)It is the responsibility of the GH organisation to determine the suitability and scalability of its management system and to demonstrate to its competent authority that its management system is appropriately designed and suitable to effectively deliver results as expected. An operating management system or SMS does not necessarily need to be complicated, timeconsuming and expensive to be effective and demonstrate that the significant risks are under control and that the organisation is safetydatarich and therefore able to take the right managerial decisions.

(h)The following levels of maturity of a GH organisation’s management system and experience in the implementation of an SMS are expected to be achieved and demonstrated gradually in several steps, from ‘present’ to ‘effective’.

(1)Present. This means that the GH organisation is able to provide evidence that the components of its management system are defined and documented within its management system documentation.

(2)Suitable. This means that the components of its management system are appropriate and meaningful for its GH activities, its size and the complexity of the services it provides based on the inherent risk of its activities.

(3)Operating. This means that the GH organisation is able to provide evidence that the components of its management system are in use and that an output is being produced.

(4)Effective. This means that the components of its management system achieve the desired outcome, have a positive effect on safety and strive to ensure continued improvement; the desired effect is achieved when the safety objectives are achieved.

Management systems’ levels of maturity may change over time, as they depend on the challenges and changes that a GH organisation faces. As the management system of a GH organisation matures to ‘operating’ and ‘effective’, the criteria measuring the management system’s ‘suitability’ level may need to be revised.

(i)Details on the implementation of management systems and their suitability and scalability can be found in EASA’s Management System Assessment Tool, Annexes 1 and 2.

ED Decision 2025/007/R

ACCOUNTABILITY, RESPONSIBILITY AND SENIOR MANAGEMENT

(a)Senior management is usually a group consisting of the persons whose functions are performed at the highest level of management in the organisation, immediately below the board of directors.

(b)Other terms used are ‘executive management’, ‘higher management’ and ‘management team’.

(c)For the purpose of Commission Delegated Regulation (EU) 2025/20, senior management includes the accountable manager.

(d)The GH organisation may have a reduced senior management structure, where several functions are fulfilled by a single person.

(e)In the English language, the notion of accountability is different from the notion of responsibility. ‘Accountability’ refers to an obligation that cannot be shared or delegated. ‘Responsibility’ refers to an obligation that can be delegated and shared; it means that a person is assigned specific duties or tasks to perform.

(f)Senior management is expected to:

(1)continually promote the safety policy to all personnel and demonstrate their commitment to it;

(2)provide the human and financial resources necessary for its implementation;

(3)establish safety objectives and performance standards;

(4)take overall accountability for the organisation’s outcomes and results.

ED Decision 2025/007/R

SAFETY MANAGEMENT SYSTEM

(a)The GH organisation should implement and maintain an SMS that is commensurate with the safety risks of its organisation and activities performed. The SMS should establish processes and procedures covering:

(1)safety policy and objectives:

(i)management commitment;

(ii)accountabilities and responsibilities, including for the accountable manager;

(iii)appointment of key safety roles and assigned personnel;

(iv)SMS documentation;

(2)safety risk management:

(i)hazard identification;

(ii)safety risk assessment and mitigation actions;

(3)safety assurance:

(i)monitoring and measurement of safety performance;

(ii)management of change;

(iii)continuing improvement of the SMS;

(4)safety promotion:

(i)training;

(ii)safety communication.

(b)The capability of a GH organisation to manage safety should be proportional to the safety risks to be managed, which can be at the service level or at the organisational level.

(c)The mitigation measures put in place should reduce the risks to an acceptable level. The effectiveness of mitigation measures should be monitored, as it may change over time.

(d)The GH organisation should establish and apply monitoring activities, measuring tools and indicators to evaluate the organisation’s safety performance. Where the various elements of the GH organisation’s management system are included in separate programmes, procedures or manuals, they should be crossreferenced.

ED Decision 2025/007/R

SMS FOR SMALL GH ORGANISATIONS

(a)Small GH organisations should develop and implement an SMS that is commensurate with the safety risks of their organisation and activities performed.

(1)The safety policy of these organisations should express a commitment to ensuring adherence to the safety standards required by Commission Delegated Regulation (EU) 2025/20, improving and maintaining the safety of its activities, complying with the applicable requirements, considering best practices and providing appropriate resources for the discharge of its responsibilities as declared.

(2)Safety risk management may be performed using hazard checklists or similar risk management tools or processes, which are integrated into the activities of the organisation.

(b)While the SMS framework remains the same as for complex GH organisations, the management system and resources should be scalable, and processes and procedures may be simplified and combined. For example, safety risk management may be performed using hazard checklists or similar risk management tools or processes, which are integrated into the activities of the organisation.

(c)The GH organisation should identify a person who fulfils the role of safety manager and is responsible for coordinating the processes and tasks related to safety management. This person may be the accountable manager or a person with an operational role within the organisation, on the condition that they are qualified to perform the safety manager role.

ED Decision 2025/007/R

SAFETY MANAGEMENT DOCUMENTATION

(a)A GH organisation should develop safety management documentation as the key instrument for communicating the approach to safety for the entire organisation. The safety management documentation should contain all aspects of safety management detailed in AMC1 ORGH.MGM.200(b)(2), as well as the safety reporting and investigation process and ERP.

(b)The safety management documentation may consist of a manual (safety management manual) or a set of procedures issued as standalone documents or included in various manuals. The safety management documents should contain adequate crossreferences to one another.

(c)The safety management documentation of small GH organisations should reflect the size of the organisations and the complexity of their activities.

(d)The documentation should be available to all personnel.