SMS - EASA Rules

In all aviation domains, except airworthiness, the rules are structured as follows:

  • Authority Requirements (A/R) take due account of the critical elements of a safety oversight system defined by ICAO Annex 19:
    • They include elements that are essential for establishing a comprehensive aviation safety management system at EU level.
    • These common authority requirements are directly relevant to the implementation of the European Aviation Safety Programme (EASP).
  • Organisation Requirements (O/R) include consolidated general requirements for management systems
  • They are designed to embed the ICAO Annex 19 in a way as to ensure SMS compatibility with existing management systems and to encourage an integrated management system.
  • It should fit various organisations, whatever their size, nature or complexity of activities and whatever business model they follow, thus catering for proportionate application.

Information on each respective domain is available below:

For further information, please navigate through the regulation structure by area of implementation on our website page 'Regulations'.

Note 1: The A/R(s) do not yet cover the need for the Member States to have an SSP as required by ICAO Annex 19, awaiting the amendment of Regulation (EU) 2018/1139.
Note 2: For the different technical areas, the general O/R(s) and A/R(s) may be complemented with more specific requirements (e.g. flight data monitoring requirements for air operators).

Initial and Continuing Airworthiness

The same concept as applied in other aviation domains will be developed through Rulemaking Task RMT.0251 ‘Embodiment of safety management system requirements into Commission Regulations (EU) Nos 1321/2014 and 748/2012’ Phase II. This task will introduce SMS into the requirements of:

  • Part 21 Design (Subpart J) and Production (Subpart G) organisations, and
  • Part-145 Maintenance organisations. 

Refer to the Terms of Reference for this Rulemaking Task. A legislative proposal is planned to be provided to the European Commission in the course of 2020, for adoption.

Meanwhile, the following steps towards transposition of ICAO Annex 19 have been accomplished:

  • A risk-based approach to the determination of the Level of Involvement (LOI) of the competent authority in compliance verification in product certification has been introduced (Regulation (EU) 2019/897; related AMC/GM have been issued by EDD 2019/018/R).
  • For Continuing Airworthiness Management Organisations (CAMOs), the SMS alignment is already introduced by the new ‘Part-CAMO’ (Annex Vc), through Regulation (EU) 2019/1383 of 8 July 2019 amending and correcting Regulation (EU) No 1321/2014.

Note 1: SMS requirements are not introduced in the new Part-CAO (Annex Vd to Regulation (EU) No 1321/2014), which regulates ‘Combined Airworthiness Organisations’ (continuing airworthiness management and/or maintenance privileges) for non-complex motor-powered aircraft not used by licenced air carrier. 
Note 2: SMS requirements will not be introduced in EASA Part-147 Maintenance Training Organisations; however SMS elements will be introduced in the Part-66 basic knowledge training syllabus (refer to RMT.0255).


  • ICAO compliant for pilot training organisations providing training for commercial licenses (ATPL-MPL-CPL and Type Ratings). The Regulation also considers Safety management System (SMS) for aero-medical centres and Flight Simulation Training Devices (FSTD) qualification certificate holders. Refer to Commission Regulation (EU) No 1178/2011 as amended by Commission Regulation (EU) No 290/2012.
  • ATOs providing training only for the Light Aircraft Pilot License (LAPL), Private Pilot License (PPL), Sailplane Pilot License (SPL) and Balloon Pilot License (BPL) however benefit from some alleviations with regard to the details of how to establish the SMS (AMC1 ORA.GEN.200 (a) (1); (2); (3); (5)).
  • Training organisations for PPL having been ‘registered facilities’ in accordance with JAR-FCL before 8 April 2015 benefit from Article 10a (3) of Regulation (EU) No 1178/2011 which exempts these organisations from the obligation to comply with Part-ARA and Part-ORA until 08 April 2018, although they are already entitled to provide training for a Part-FCL LAPL or PPL. This means that until 08 April 2018 these organisations still exist in accordance with JAR-FCL organisational requirements, meaning no SMS. This period of time is expected to be extended until 08.04.2019 in order to provide a transitional period after entry-into-force of the new Annex VIII (Part-DTO) to Regulation (EU) No 1178/2011) (envisaged for 08.04.2018).
  • In the area of SPL and BPL, for both licenses and training organisations opt-outs are still running until 08 April 2018. This means that until that date training organisations for SPL and BPL are allowed to provide training for national licenses and following national organisational requirements = no SMS, if not foreseen under national rules. This opt-out is expected to be extended until 08.04.2020 in the context of Rulemaking Tasks (RMT) RMT.0654 and RMT.0701 (new FCL requirements for sailplanes and balloons). 
  • After 08 April 2018 training organisations for PPL, LAPL, BPL and SPL may make use of the future EASA rules creating a declaration regime (no SMS, but requirements for a safety policy and for safety promotion).

Air Operations

Commission Regulation (EU) No 965/2012, as subsequently amended, contains the ‘Technical requirements and administrative procedures related to air operations’. It covers commercial air transport (CAT) with aeroplanes and helicopters, non-commercial operations with complex motor-powered aircraft (NCC), non-commercial operations with other-than-complex aircraft (NCO), specialised operations (SPO).

Operators engaged in commercial air transport (CAT)1 , commercial specialised operations (SPO)2, as well as operators conducting non-commercial air operations with complex motor-powered aircraft (NCC) need to implement a management system. Specific alleviations are foreseen for less complex organisations.

For commercial operations of balloons, separate Commission Regulation (EU) No 2018/395 has been adopted, which is applicable from 8 April 2019 and calls for a simplified management system for commercial operations. The national rules apply unless a MS has decided to apply Commission Regulation No 965/2012 for which a management system is applicable.

Related AMC/GM to Commission Regulation (EU) No 2018/395 are provided by ED Decision 2018/004/R.

For commercial operations of sailplanes, the national rules apply unless a MS has decided to apply Commission Regulation 965/2012 for which a management system is applicable. It is envisaged that a separate regulation for sailplanes will be applicable from 8 April 2020. Please refer to Opinion 07/2017.

1 Including CAT operations starting and ending at the same aerodrome/operating site with Performance class B aeroplanes or non-complex helicopters (so called A-to-A operations).
2 “Specialised operation” means any operation other than commercial air transport where the aircraft is used for specialised activities such as agriculture, construction, photography, surveying, observation and patrol, aerial advertisement.


ATM/ANS (Air Traffic Management/Air Navigation Services)

Currently Commission Regulation (EU) No 1035/2011 contains requirements for SMS for providers of ATS and CNS services.

However, Commission Regulation (EU) 2017/373 will introduce the necessary authority and organisation requirements, like in the other domains. It shall apply to the Member States and the service providers (except for Data services (DAT) providers) as from 2nd January 2020:

  • a comprehensive management system framework is proposed for all service providers (e.g. ANS (incl. ATS, MET, AIS, CNS), DAT, Air Traffic Flow Management (ATFM) and airspace management (ASM) providers), limiting the safe provision of the services to those service providers with direct operational implications, i.e. the ATS providers and regulating the management of operational safety risks through the ATS provider’s SMS.
  • This management system framework is a more quality and performance oriented management system aiming at management of the performance of the services provided to the user, but it allows a full integration with the SMS of the ATS provider when the same organisation provides a combination of these services.

Until 2nd January 2020, Commission Regulation (EU) No 1035/2011 continues to apply.

Air Traffic Controllers (ATCOs)

Commission Regulation (EU) No 2015/340 lay down technical requirements and administrative procedures relating to air traffic controllers’ licenses and certificates contains the requirements for ATCO training organisations to establish and maintain a management system, which are built on ICAO Annex 19 provisions.


The EU rules on "Authority, Organisation and Operations Requirements for Aerodromes" have been published with Commission Regulation (EC) No 139/2014. The relevant provisions (Part ADR.OR) of this Regulation foresee that aerodrome operators shall implement and maintain a management system that integrates a safety management system. These requirements are closely related to the organisation requirements developed in other domains (e.g. aircrew, air operations, ATM/ANS) and are built on ICAO Annex 19 provisions.