Changes to EASA Part 145 Requirements Related to Contracting – Subcontracting and the Maintenance of Associated Records

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Sofema online (SOL) considers changes which are taking place within the EASA Part 145 Environment.


Regulation 2021/1963 amends Continuing Airworthiness Regulation (EU) No 1321/2014 as regards safety management systems in maintenance organisations and correcting that Regulation.

By way of derogation from points (1) and (2) of point 145.B.350(d) of Annex II (Part-145), a maintenance organisation that holds a valid approval certificate issued in accordance with Annex II (Part-145) may correct, until 2 December 2024, any findings of non-compliance related to the Annex II requirements introduced by Commission Regulation (EU) 2021/1963.

Where after 2 December 2024 the organisation has not closed such findings, the approval certificate shall be revoked, limited, or suspended in whole or in part.

Specific Requirements Related to Contracting and Subcontracting

Introduction to EASA Part 145.A.205 Contracting and subcontracting

The organisation shall ensure that when contracting or subcontracting any part of its maintenance activities:

» The maintenance conforms to the applicable requirements;
» Any aviation safety hazard associated with such contracting or subcontracting is considered as part of the organization’s management system.

If the organisation subcontracts any part of its maintenance activities to another organisation, the subcontracted organisation shall work under the scope of approval of the subcontracting organisation.

Management system, contracting, and subcontracting records

The organisation shall ensure that the following records are retained for a minimum period of 5 years:

» Records of management system key processes referred to in point 145.A.200;
» Contracts, both for contracting and subcontracting, are referred to in point 145.A.205.

Personnel records

» The organisation shall ensure that the following records are retained:

o Records of the qualifications, training, and experience of the personnel involved in maintenance, compliance monitoring, and safety management;
o Records of the qualifications, training and experience of all airworthiness review staff.

Note - The records of all airworthiness review staff shall include:

» Details of any appropriate qualifications held, together with;
» A summary of their relevant continuing airworthiness experience and training, and;
» A copy of the airworthiness review authorisation issued to that staff by the organization.

The records of all the certifying staff and support staff shall include the following:

» The details of any aircraft maintenance license held under Annex III (Part-66) or equivalent;
» The scope of the certification authorisations that were issued to that staff, where relevant;
» The particulars of the staff that held limited or one-off certification authorisations are referred to in point 145.A.30(j).

Note - Personnel records shall be kept for as long as a person works for the organisation additionally:

» shall be retained for at least 3 years after the person has left the organisation,
» or after an authorisation issued to that person has been withdrawn.
» Staff may access personal records and receive a copy of their personal records when leaving the organisation.

Record Keeping

The organisation shall establish a record-keeping system that allows adequate storage and reliable traceability of all its activities.

» The format of the records shall be specified in the organisation’s procedures.
» The records shall be stored in a manner that ensures that they are protected from damage, alteration, and theft.

Next Steps

Sofema Aviation Services & Sofema Online provide Classroom, Webinar & Online Regulatory Training & Consulting Related to EASA Part 145. For additional details, please see our websites or email

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