EASA Part 145 Repair Stations Now Required to Implement SMS Under Rule Change

Repair shops with EASA Part 145 certificates must now implement and maintain safety management systems (SMS), according to a decision signed by the Bilateral Oversight Board in February, 2025.

NATA hosted a webinar to share insights and advice about how repair stations can prepare for the new FAA-EASA maintenance requirements.

Division Manager, AFS-900, FAA Safety Analysis and Promotion Division Kawehi Lum offered a basic definition of SMS, stating, “It's a systemic approach to managing safety, including organizational structures, accountabilities, policies and procedures…and it focuses on proactive hazard identification, risk management and continuous improvement.”

Lum added, “An aviation service provider can develop their SMS from scratch, or they can adopt a third-party existing SMS to fit their particular organization. But either method you choose to implement needs to yield the result of an SMS that meets the Part 5 requirements applicable to your organization.”

What is the Part 5 SMS requirement?

Division Manager, AFS-300, FAA Aircraft Maintenance Division Jackie Black explained the basics of the change, sharing, “The Bilateral Oversight Board signed Decision No. 0013 on February 10, 2025, making SMS a special condition under Annex 2 of the US-EU Bilateral Agreement. These changes impact the US-based FAA repair stations that hold an EASA certificate in the United States. In June 2025, EASA and FAA signed the Maintenance Annex Agreement, MAG Change 10, and the entry-into-force date is October 10, 2025.”

He continued, “Change 10 incorporates the SMS special conditions, which requires EASA Part 145 certificated repair stations in the United States to establish, implement and maintain a safety management system that meets the requirements of 14 CFR Part 5.”

Who’s impacted by the SMS compliance change?

Discussing which types of organizations will be impacted by this change, Senior Advisor at NATA Randy DeBerry noted, “February 10, 2025, if you're applying for a new EASA Part 145 certificate, or reinstating one after this date, you're going to need to be fully compliant and implemented before submitting your application.”

DeBerry clarified, “If you're just a regular FAA Part 145 and you're not doing EASA currently, currently, this does not apply to you. But I would say that industry is moving closer towards that type of system around the world.”

 “So, even if you're not affected today, it is definitely worth preparing for the future, and that's by having an effective audit program to make sure that you identify all your hazards and your risk and mitigate those and ensure that you don't create any resistance from that,” added DeBerry

How to comply with the new FAA Part 5 SMS requirement

“On October 10, 2025, for existing EOS and repair stations, this is your critical first checkpoint. You're going to have to revise your EASA supplement to include a statement confirming that your SMS is ready or has been implemented. Or, if it's still in progress, SMS policies and procedures will be developed and implemented, and the declaration will be submitted to the FAA no later than December 31, 2025,” said DeBerry

He continued, “That declaration is not just paperwork. It confirms your SMS meets 14 CFR Part 5 and aligns with AC 120-92 and that you're actively functioning within your organization.”

“Once you submit your declaration to the FAA stating that you're SMS compliant, the inspector workforce will go into the SAS database and set up a reconfiguration, which means that is going to change the way that you’re being overseen. When they come out to take a look at your operations, they’ll be targeting all their questions toward SMS related topics, issues and everything that goes in line with being SMS compliant,” concluded DeBerry.

Lum shared insight on how to comply with the new rule, stating, “Part Five is performance-based rule, so it's not prescriptive, and it's you tell us how best you want to identify your hazards and mitigate your risks.”

Jenny Ann Urban, VP of regulatory affairs at NATA and host of the webinar, asserted, “You need to use a conditions-based approach, really seeing what conditions you are facing as a repair station. It's just not a cut-and-paste model. Don't just try to submit your declaration of compliance. You really need to make sure that you make it work for you, instead of changing it to meet somebody else's ideas and then formalize what you're already doing.”

Urban shared an anecdote about a NATA member’s process for implementing an SMS. She said, “He always talks about how they started off with an Excel spreadsheet that was the system they utilized at the beginning to start their SMS and to start hazard reporting. To start those, you don't need an expensive, complex system to get started. That worked very well for the conditions that they were facing.”

Urban added, “Now, have they possibly changed it moving forward? Absolutely. But don't make it too complex. Yes, there will need to be resources put into this, but you can do it while keeping cost as a factor in that.”

When asked what first steps repair stations can take, DeBerry stressed that the implementation will look different for all stations, as it’s not intended as a one-size-fits-all requirement that standardizes the same system across all shops.

DeBerry advised, “Focus on making sure that it's right-sized, and then SMS can be scaled to your operation. I would highly recommend working with the FAA and industry trade associations such as NATA. And there's a lot more out there that offer these types of programs for you, and templates. I would focus on having a conversation with my CMT or the folks that oversee you.”

“If you're not ready, make sure you have open and effective communications with your FSDO…they can answer most, if not all, your questions,” added DeBerry

What if my shop already uses an SMS?

DeBerry shared, “If you already have a system in place, I highly recommend that you start with a gap analysis and compare what you do now to what is in Part 5 requirements. Consider using the FAA’s SMSVP as a guide. It's an accepted path, and it's the start of a solid foundation.”

Black noted, “Participation in the FAA SMS Voluntary Program, referred to as SMSVP, satisfies the requirement. That was something we negotiated with EASA specifically. So, the development of an SMS or adoption of a third-party SMS can be considered, provided that it’s fully integrated into the company's culture and procedures and it meets Part 5 requirements to participate in the FAA’s Voluntary Program.”

What resources can help prepare for 14 CFR Part 5 SMS compliance?

“The key documentation that kind of is the reference point for this is the FAA’s InFO for operators, inFO24007, which we revised on July 8 to provide some critical, detailed guidance on compliance deadlines and requirements for the SMS,” said Black.

He continued, “We strongly encourage that repair stations carefully review this info…it outlines the specific actions and timelines to comply with EASA Part 145 approval. Understanding that content is essential for ensuring that your organization's compliance is upheld and that it avoids potential disruptions to your operations.”

DeBerry offered more detail on helpful resources, sharing, “The key guidance is AC 120-92. It provides a comprehensive guide to implementing SMS, and InFO24007 covers your deadline, scope, timing. Also check out the FAA’s Aviation Safety Outreach and be sure to get access to DRS. It's the dynamic regulatory system for the SAS data collection tools and inspector resources.”

DeBerry added, “Once you get configured for SAS and SAS for SMS, ask the inspectors for the DCTs. That will help you set up your design, and then it'll also help you with the questions that they're going to ask you, so you can be better prepared to make sure that all your SMS meets the requirements.”

On the importance of being open to and compliant with the new rule, Black stated, “If we stand in the way of adopting SMS, we're not helping safety. So, we made it as simple as possible to adopt and get SMS implemented as quickly as you can, and then we will surveil against it. Hopefully, it will mature over time, as those audits and the correspondence goes back and forth.”