1. Regulatory Foundation – Reg. (EU) 2018/1139 (Basic Regulation)
As Accountable Manager, you hold ultimate responsibility for ensuring your organisation’s Management System (MS) meets the essential requirements of the Basic Regulation and is effective.
- Annex II: Essential requirements for airworthiness (product integrity, design, materials, systems, continued airworthiness, etc.). The aircraft must remain in a condition for safe operation throughout its life.
- Annex V: Essential requirements for air operations (AOC holders) – safe operations, crew, equipment, and organisational capabilities.
These high-level requirements are implemented through:
- Part-CAMO (Continuing Airworthiness Management Organisation) under Reg. (EU) 1321/2014 as amended. The golden book is the CAME;
- Part-145 (Maintenance Organisation or AMO) under Reg. (EU) 1321/2014 as amended. The golden book here is the MOE;
- If applicable AOC (Air Operator Certificate) under Regulation (EU) No 965/2012 as amended; Part-SPO or Part-NCC under Regulation (EU) No 965/2012 as amended.
2. Concept of Continuing Airworthiness
According with Icao Doc. 9760 Airworthiness Manual:
- ”Airworthy”is the status of an aircraft, engine, propeller or part when it conforms to its approved design and is in a condition for safe operation.
- ”Continuing Airworthiness”is the set of processes by which an aircraft, engine, propeller or part complies with the applicable airworthiness requirements and remains in a condition for safe operation throughout its operating life.
- ”Maintenance” is the performance of tasks on an aircraft, engine, propeller or associated part required to ensure the continuing airworthiness of an aircraft, engine, propeller or associated part including any one or combination of overhaul, inspection, replacement, defect rectification, and the embodiment of a modification or a repair.
Key Elements Shown in the Flowchart:
- CAMO manages the planning, tracking, and oversight of all continuing airworthiness tasks. This includes: Part-21, TCDS, Aircraft Maintenance Programme (AMP), Approved Technical Log (ATL), airworthiness reviews (ARC), defect rectification, modifications, repairs, MEL management, and record-keeping.
- Part-145 (Maintenance Organisation) executes the physical maintenance and required tasks via approved Work Orders (W/O).
- Records, AMP Effectiveness & Performance Data (“Sensors”) feed back into the system. This includes maintenance findings, reliability data, defect trends, flight hours/cycles, component performance, and occurrence reports.
- Continuous Closed-Loop Process: Data → Analysis → “Is the risk level still acceptable?” → Adjustments (resources, procedures, training, contracts, etc.) to maintain safety, compliance, and airworthiness.
Full CAMO Critical Processes in the Closed-Loop System
- Planning & Control (CAMO core)
- Execution Oversight
- Monitoring & Feedback (“Sensors”)
- Risk & Decision Layer (at every step)
- Continuous Improvement & Management of Change
Your role:
Ensure to implement and maintain a management system to ensure compliance with the essential requirements set out in Annex II of Reg. (EU) 2018/1139, manage safety risks and aim for continuous improvement of that system. This is providing sufficient resources (people, tools, facilities, financing) so that the Continuing Airworthiness Process (left side of the flowchart) delivers safe, compliant aircraft.
3. Management System Requirements (Integrated SMS + Compliance Monitoring + ISMS)
EASA requires a single, integrated Management System that combines Safety Management, Compliance Monitoring Function, and now Information Security Management.
Key features:
- The Management System can (and should) integrate the Information Security Management System (ISMS) required by Regulation (EU) 2023/203 (Part-IS). This ensures information security risks with potential impact on aviation safety are systematically identified, assessed, and mitigated within the same framework.
- Safety Management System (SMS): Hazard identification, risk assessment and mitigation, safety performance monitoring, continuous improvement, and just culture.
- Compliance Monitoring Function (formerly Quality System): Independent audits to verify conformity with regulatory and internal procedures. Findings must be reported directly to the Accountable Manager.
- Information Security Management System (ISMS): Management of cybersecurity and information security risks affecting aviation safety (fully integrable with SMS and Compliance Monitoring).
- Occurrence reporting (internal and external as per Reg. (EU) 376/2014 and 996/2010 as required)
Key elements shown in the flowchart:
- CAMO manages planning, tracking, and oversight of continuing airworthiness tasks (Part-21, TCDS, AMP/ATL, etc.).
- Part-145 executes the physical maintenance via Work Orders (W/O).
- Records / AMP Effectiveness / tasks completion (Sensors) feed back performance data.
- Continuous loop: Data → Analysis → “Is the risk level still acceptable?” → Adjustments to maintain safety & compliance.
Two independent functions you must ensure are effective:
- Safety Management System (SMS): Safety Policy and Objectives – Safety Positive Leadership that fosters a positive safety ‘’just culture’’, Hazard identification, risk assessment & mitigation, safety performance monitoring, continuous improvement, management of change (the mother of all risks and Safety Promotion and Training.
- Compliance Monitoring (CMM): Independent audits to verify the organisation meets regulatory and internal procedures. Findings are reported directly to you. It can be integrated with Part-IS (optimizing allocation of resources).
4. Accountable Manager’s Key Responsibilities
- Nominate competent persons (Nominated Persons / Post Holders) for key functions, including Safety Manager and Compliance Monitoring Manager (if proper qualified could also act as Part-IS CMM).
- Ensure they have direct access to you and sufficient authority/resources.
- Oversee the entire Management System effectiveness – you are ultimately accountable for safety and compliance monitoring, Part-IS.
- Review safety performance (Safety Objectives as well as SPIs and SPTs) and audit findings; ensure effective corrective actions.
- Demonstrate basic understanding of the applicable regulations (Part-CAMO, Part-145, etc.).
- Sign the OMM (organization’s management manual, including the ISMS) safety policy, the compliance statement, the CAME (Continuing Airworthiness Management Exposition) and Maintenance Organisation Exposition, committing the organisation to compliance.
5. Practical Takeaway from the Flowchart
The system is a closed-loop process:
- Continuing Airworthiness Process starts with safety & compliance inputs.
- CAMO plans and controls.
- Part-145 performs maintenance.
- Records & effectiveness data (sensors) flow back.
- At every step: “Is the risk level still acceptable?”
- Part-IS: confidentiality, integrity and availability.
If not → act (resources, procedures, training, contracts). Your job is to keep this loop healthy.
Bottom line:
As Accountable Manager, you do not perform the day-to-day tasks, but you own the system. A robust Management System (SMS + Compliance Monitoring) protects your AOC/CAMO/Part-145 approvals, your people, your passengers, and your organisation’s reputation.
This integrated approach ensures safe operations while maintaining full regulatory compliance under the EASA framework.
Use the flowchart as a visual aid during team briefings to reinforce closed-loop safety leadership and build a strong, positive culture of safety, information security, and compliance.
ROI: By eliminating waste and improving efficiency, Accountable Managers routinely deliver 3% to 5% annual operational cost savings.
Questions: sms@mycs.swiss
Thanks for your kind attention and enjoy safe, legal, effective, efficient and sustainable operations!