Which cost can be expected to perform a DPO approval? (external cost, e.g. to be paid to EASA)
Answer
An estimate of workload connected with the approval procedure is provided by EASA as part of the quotation that may be requested in the application. As DPO is an entirely new domain for the Agency, these activities in accordance with the principles in the F&C regulation will be charged on an hourly rate basis. This is stated under Chapter IV, Article 21, Subparagraph 2 (page 10 of Regulation 2019/2153):
“The hourly rates set out in Part II of the Annex shall apply as of the entry into force of this Regulation to any tasks ongoing at the entry into force of this Regulation and for which fees or charges are calculated on an hourly basis.”
The level of effort depends on a number of specific factors linked to the organization itself and the type of equipment under consideration, so the assessment is done based on the documentation and exposition of activities accompanying the application. This is why EASA only provides detailed estimates in conjunction with a submitted application. The following provides additional detail:
- An applicant is entitled to request a financial quotation, and the Agency will provide the quotation before starting the investigation. This ensures that the DPO applicant has all the financial elements to make a business decision. An applicant can request a financial estimate (including working hours) via point 8 of the Application form. After submitting the application, EASA will reply with a quotation of estimated cost. Invoicing will be done based on the actual effort.
- The production of the estimate should not last more than a few working days, in parallel to the assessment of technical and administrative eligibility of the application, and the information is provided to the applicant. Procedurally, there is a maximum period of 90 days for the applicant to evaluate the quote and accept it.
- If the applicant would decide not to accept the quotation, there would be no fees/charges incurred. The investigation would start once the quotation is accepted.
- It is also important to be aware that an approved DPO organisation will incur additional costs under the EASA oversight activity. This oversight activity will also be invoiced for hours worked and travel costs.
If an organization has other questions linked to filling out the DPO application forms or about the logic applied to the initial investigation in order to better prepare the approach, it is possible to schedule a “pre-application” meeting with EASA to clarify specific points before an application is formally submitted.