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01

What does Regulation (EU) No 376/2014 require of an operator?

An organisation must run a system through which its staff report occurrences, must pass each mandatory occurrence to its competent authority within 72 hours of becoming aware of it in an ECCAIRS-compatible format, must analyse what it collects and act on it, and must protect the people who report.

  • Article 4 sets mandatory reporting: the occurrence types are listed in Implementing Regulation (EU) 2015/1018, as amended by Implementing Regulation (EU) 2026/1821, and the organisation reports them to the authority as soon as possible and within 72 hours of becoming aware of them.
  • Article 5 sets voluntary reporting for everything else that a reporter considers a hazard.
  • Article 7 requires reports to carry the data fields the authority needs, in a format compatible with ECCAIRS and the ADREP taxonomy, so they can be loaded into the European Central Repository.
  • Article 13 requires the organisation to analyse each occurrence, decide the safety action, report the preliminary results and the action to the authority within 30 days, and the final results within three months.
  • Article 16 protects the reporter: identity is recorded only where necessary, and no prejudice may follow a report except in cases of wilful misconduct or gross negligence. Each organisation adopts internal rules that implement Just Culture.

02

What are the 30-day and three-month deadlines in Article 13?

Article 13(4) of Regulation (EU) No 376/2014 says that where the analysis of a reported occurrence identifies an actual or potential safety risk, the organisation sends its competent authority the preliminary results of the analysis and the action to be taken within 30 days of the reporter notifying it, and the final results in principle within three months. They are deadlines for the analysis, not a period during which the report at the portal is somehow open — a report already filed can be updated whenever the analysis moves on.

  • Article 13(1) and (2) put the analysis itself on the organisation: collect, analyse, identify the safety hazards, and determine any action needed to improve safety.
  • Article 13(4) sets the timing: 30 days for the preliminary results and the action to be taken, and in principle three months for the final results. The trigger is the risk the analysis identifies; where it identifies none, there is nothing to send.
  • The follow-up is filed against the report already in ECCAIRS 2, as a new version of it rather than a new occurrence.

03

What does ORO.GEN.200 require an AOC holder's management system to contain?

Six things, each of which has to exist and be documented: clear lines of responsibility and accountability including the accountable manager's direct accountability for safety; a safety policy; hazard identification with evaluation and management of the associated risks, including verifying that mitigations work; personnel kept trained and competent; documentation of all key management-system processes; and a compliance monitoring function. The whole thing must be proportionate to the operator's size and the complexity of its activities.

What does ORO.GEN.200 require an AOC holder's management system to contain?
ORO.GEN.200(a)RequirementModule
(1)Lines of responsibility and accountability; the accountable manager's direct accountability for safetySettings: organisation profile, Accountable Manager history
(2)A safety policySafety documentation: the signed policy statement
(3)Hazard identification, risk evaluation and management, verification of mitigationsRisk register and risk assessments, occurrence reporting, the action tracker (verification is a status of its own), management of change, dashboard SPIs
(4)Personnel trained and competent for their tasksSafety promotion: training records with expiry, attested by the trainee and confirmed by the Head of Training
(5)Documentation of key management-system processesSafety documentation: the register of Operations Manual parts, manuals and expositions, with revisions
(6)A compliance monitoring functionAudits and findings: checklists, findings, deadlines

04

Does an approved training organisation need a safety management system?

Yes. ORA.GEN.200 in Regulation (EU) No 1178/2011 requires an approved training organisation to run a management system with the same six components as an operator's under ORO.GEN.200, proportionate to its size and the complexity of its training. Declared training organisations under Part-DTO are a different regime and are not subject to ORA.GEN.200.

05

What does ICAO Annex 19 add to the EU rules?

The framework the EU rules are built on. Annex 19 defines a safety management system as four components with twelve elements: safety policy and objectives; safety risk management; safety assurance; and safety promotion. ICAO Doc 9859, the Safety Management Manual, supplies the working methods — including the likelihood-against-severity risk matrix that most operators use.

What does ICAO Annex 19 add to the EU rules?
Annex 19 componentElementsModule
Safety policy and objectivesManagement commitment; accountabilities; key safety personnel; emergency response planning; SMS documentationSettings, safety documentation
Safety risk managementHazard identification; safety risk assessment and mitigationOccurrence reporting, risk register
Safety assuranceSafety performance monitoring and measurement; management of change; continuous improvementDashboard SPIs, trends, management of change, audits and findings
Safety promotionTraining and education; safety communicationSafety promotion

06

What is ERCS, the European Risk Classification Scheme?

ERCS, established by Delegated Regulation (EU) 2020/2034 under Article 7 of Regulation (EU) No 376/2014, gives an occurrence a risk score from two judgements: the severity of the most likely accident it could have led to — a key risk area and the potential loss of life give a severity from A (no likelihood of an accident) through E, I, M and S to X — and how much of the defence remained, weighted barrier by barrier into a score from 0 to 9. The result reads like S4, falls in a red, yellow or green zone and carries a numerical equivalent for aggregation. Competent authorities use it to classify every report they receive; an organisation that classifies its own occurrences the same way speaks the authority's language.

07

How does a 5×5 risk matrix work?

A hazard is scored on two five-point scales — likelihood, from extremely improbable to frequent, and severity, from negligible to catastrophic — and the two are multiplied. The score falls into one of three regions: acceptable, tolerable with mitigation, or intolerable. Doc 9859 gives the shape; the organisation sets the thresholds. AviSMS defaults to 8 and 15, so a score of 15 or more is intolerable and escalated to the Accountable Manager.

08

What does an operator have to do before it changes something?

Assess the change for safety before it happens, and check afterwards that the assessment held. ICAO Annex 19 makes the management of change an element of safety assurance, and AMC1 ORO.GEN.200(a)(3) expects the operator's hazard identification and risk management process to cover changes — a new aircraft type, a new route or destination, a revised procedure, a change of nominated person, a new system, or work moved to a contractor. Changes to the certificate itself, including a change of accountable manager or another nominated person, are also notified to the competent authority under ORO.GEN.130.

  • The assessment looks at what the change affects: the operations it touches, the documents that have to be revised, the training people need, and the hazards it introduces — which are assessed on the organisation's own risk matrix like any other.
  • The change is approved by someone with the authority to accept the residual risk, which in practice is the accountable manager.
  • After implementation the organisation reviews whether the change did what it was meant to and whether the assessment was right.

09

What are Level 1 and Level 2 findings?

The authority's classification, in ARO.GEN.350, for what it finds during oversight: a Level 1 finding is a significant non-compliance that lowers safety or seriously hazards flight safety and demands immediate action; a Level 2 finding is any other non-compliance, for which the authority sets a corrective-action period of up to three months. Internal compliance monitoring borrows the same language. AviSMS defaults to 30 days for Level 1, 90 for Level 2 and 180 for observations; each is configurable.

10

What are ECCAIRS 2 and E5X?

ECCAIRS 2 is the European reporting platform, operated by EASA and the national authorities, through which organisations and authorities file and exchange occurrence reports, and which feeds the European Central Repository. E5X is its exchange format: a zip package holding one XML document per occurrence in the ADREP taxonomy, together with any attachments, so that a report produced in one system can be loaded into another without retyping. An organisation reaches ECCAIRS 2 through the portal's form, by uploading an E5X package, or through the machine-to-machine E2 API — each of which needs an organisational account created by its competent authority. ECCAIRS 5, the previous generation, has been out of support since 2021.

11

What is the Accountable Manager responsible for?

Under ORO.GEN.210(a) the operator appoints an accountable manager with the corporate authority to ensure that all activities can be financed and carried out to the applicable requirements, and who is responsible for establishing and maintaining an effective management system. ORO.GEN.200(a)(1) adds direct accountability for safety. A change of accountable manager is a change to the certificate that the authority must be told about.

General information as of September 2026, not legal advice. The consolidated regulations on EUR-Lex and EASA's Easy Access Rules are the texts that count; verify with your competent authority.

Run it the way the regulation reads.

The defaults in AviSMS are the ones above. Change any of them in Settings when your authority or your manual says otherwise.