European ground handling organizations face an important deadline. On March 27, 2028, most provisions of Commission Delegated Regulation (EU) 2025/20 will become applicable, bringing ground handling activities within the European Union Aviation Safety Agency's (EASA) aviation safety regulatory framework.

With approximately 18 months remaining, organizations have an opportunity to assess their existing procedures, identify compliance gaps and prepare for a new level of regulatory oversight. That preparation should begin well before the deadline.

The regulation establishes two sets of requirements particularly relevant to ramp services. Annex I, Part-ORGH, addresses the organizational responsibilities of ground handling providers, while Annex II, Part-GH.OPS, establishes operational requirements governing how ground handling services are delivered.

Together, these requirements will affect how organizations document, manage and perform ramp operations.

The ground handling manual

One of the central requirements of Part-ORGH is the ground handling manual. Under ORGH.DOC.110, every ground handling organization must establish a manual documenting its activities and procedures.

Most organizations already maintain such manuals, often developed around established industry standards. The difference is that the manual is now a regulatory obligation, with its content and structure addressed by EASA's accompanying acceptable means of compliance (AMC) and guidance material (GM).

AMC1 ORGH.DOC.110(a) identifies the principal topics the manual should address, beginning with its own administration and control. Additional topics include the organization's management system; personnel training, assessment and qualification; standard operational procedures; ground support equipment (GSE); dangerous goods procedures; and security procedures.

Organizations have flexibility in how they arrange this information. The manual may consist of a single document or several cross-referenced documents, and additional topics may be included where necessary.

The objective is not simply to produce a comprehensive manual, but to establish a coherent set of instructions that reflects how the organization actually operates.

Documenting ramp procedures

For ramp service providers, standard operational procedures represent a particularly important component of the ground handling manual.

EASA's acceptable means of compliance identifies several operational areas that should be covered, as applicable to the services an organization provides. These include passenger handling, baggage handling, aircraft servicing, turnaround activities, load control, ground supervision and cargo operations.

Much of what the industry considers ramp services falls within these categories.

Organizations providing these services must therefore ensure that their documented procedures address the applicable regulatory requirements. Existing manuals may provide a strong foundation, but they should be reviewed to determine whether they contain the necessary information.

Building on industry standards

The new regulations do not require ground handling organizations to abandon established industry practices.

ORGH.GEN.125 permits organizations to use their own operational procedures, industry standards or a combination of both. EASA's guidance recognizes established industry references, including the IATA Ground Operations Manual (IGOM) and Airport Handling Manual (AHM).

However, adopting an industry standard does not automatically establish regulatory compliance.

Organizations must ensure that the standards they use meet EASA's applicable criteria. Safety-relevant deviations must be documented, and compliance monitoring must verify that procedures are correctly implemented.

This distinction is important. An organization may already follow widely accepted industry practices while still having gaps between those practices and the new regulatory requirements.

A thorough gap analysis is therefore an essential part of preparing for compliance.

Translating requirements into ramp operations

Annex II, Part-GH.OPS, establishes the operational requirements that organizations must incorporate into their procedures.

Its five principal subparts address passenger handling, baggage handling, aircraft servicing, aircraft turnaround, and cargo and mail handling.

Aircraft servicing requirements encompass several activities directly affecting ramp safety, including apron operations, GSE operation, aircraft refueling and defueling, potable water servicing, aircraft toilet servicing, exterior cleaning, and deicing and anti-icing.

Aircraft turnaround requirements address the coordination of turnaround activities, aircraft arrival, securing aircraft on the ground, loading and unloading, loading supervision, unit load devices, departure activities, towing and pushback, and communication and phraseology.

These requirements illustrate the breadth of the regulation's impact on everyday ramp operations.

For ground handling organizations, the practical challenge is to translate the applicable requirements into documented procedures that personnel can consistently follow.

In many cases, existing industry standards and operational practices will already address substantial portions of these requirements. Where a gap analysis identifies missing elements, however, organizations will need to revise their procedures and implement the necessary changes before the regulation becomes applicable.

Managing operational interfaces

Another important consideration is the relationship between ground handling organizations, aerodrome operators and aircraft operators.

AMC1 ORGH.DOC.110(a) specifies that interfaces with aerodrome and aircraft operators should be highlighted in each relevant section of the ground handling manual.

These interfaces are fundamental to ramp operations.

Every aircraft turnaround involves the coordination of ground handling activities with airline requirements, airport procedures and available infrastructure. Responsibilities may overlap, making clear communication and well-defined procedures essential to safe operations.

A manual that describes individual activities without adequately identifying these interfaces may fail to meet the intent of the new regulatory framework.

Organizations should therefore examine not only their internal procedures, but also how those procedures interact with the requirements of their airline customers and the airports where they operate.

Making manuals usable

Regulatory compliance involves more than documenting the correct procedures. Those procedures must also be understandable and accessible to the personnel responsible for carrying them out.

GM1 ORGH.DOC.110(e) addresses the usability of ground handling manuals through human factors principles.

Manuals should be legible, clearly laid out and logically organized. Text, photographs, diagrams and charts should communicate instructions unambiguously, while language should remain concise, coherent and easy to understand.

Abbreviations, acronyms, symbols and color codes should be explained. Translated material should also remain current and free of operational errors that could compromise safety.

These considerations are particularly relevant to ramp operations, where personnel work in dynamic environments and must frequently make decisions under time pressure.

A technically complete manual offers limited practical value if personnel cannot readily understand or apply its instructions.

Beyond regulatory compliance

Ground handling manuals and documented operational procedures have been established industry practices for many years. What changes under the new EASA framework is their regulatory status and the corresponding level of oversight.

Organizations must prepare for greater scrutiny of their procedures, management systems and operational practices by competent authorities.

The preparation period offers an opportunity to examine existing processes, strengthen coordination with aircraft and aerodrome operators, and address weaknesses that may have persisted under previous arrangements.

Rather than treating the new requirements solely as an administrative burden, ground handling organizations should approach them as an opportunity to strengthen operational performance.

Clearer procedures, better-defined responsibilities and more effective documentation can contribute to safer ramp operations, greater operational consistency and improved service delivery.

The March 2028 deadline provides a clear target. The work required to meet it should also deliver benefits that extend well beyond regulatory compliance.