Sofema Aviation Services (SAS) considers key changes which have taken place in the EASA Part 147 & Part 66 Environment.
Introduction
Commission Implementing Regulation (EU) 2023/989 and the associated ED Decision 2023/019/R.
- Designed to integrate new training technologies
- Update basic knowledge requirements (including SMS), and
- Simplify licensing for General Aviation
Regulation (EU) 2023/989: Amending Regulation (EU) No 1321/2014.
- Adoption: May 2023 (Applicability: 12 June 2024)
ED Decision 2023/019/R: Amending AMC & GM to Part-147 and Part-66.
- Published: October 2023 (Applicability: 12 June 2024)
Changes to Part-66
The most visible changes for engineers and applicants involve the modernisation of the Basic Knowledge Syllabus (Appendix I) and the introduction of Safety Management System (SMS) concepts into the license itself.
Basic Knowledge Syllabus Updates (Appendix I)
Regulation (EU) 2023/989 introduced a revised syllabus to reflect modern aircraft technologies and safety standards.
- Module 9 (Human Factors) & Module 10 (Aviation Legislation):
>> SMS Integration: Significant new content added regarding Safety Management Systems (SMS) and occurrence reporting. This aligns the engineer’s knowledge with the Part-145 SMS requirements.
>> Exam Format Change: The Essay questions for Module 9 and Module 10 have been removed. Assessment is now purely a Multiple Choice Question (MCQ).
>> Question Increase: To compensate for the loss of the essay, the number of MCQs has increased (e.g., Module 10 increased from 40 to 44 questions).
- Technical Modules Updates:
>> Module 6 (Materials): Updated to include new composite materials and additive manufacturing (3D printing).
>> Module 7 (Maintenance Practices): New content on electrical wiring interconnection systems (EWIS) and critical design configuration control limitations (CDCCL).
>> Module 13 (Aircraft Aerodynamics/Structures/Systems): Updated with modern avionics and fly-by-wire system concepts.
On-the-Job Training (OJT) Flexibility (Appendix III)
The rigidity of OJT has been a long-standing complaint. The new regulation introduces a more “competence-based” approach.
- OJT List: The OJT list is no longer a fixed, rigid checklist. It can be adapted to the actual maintenance environment, provided it covers a representative cross-section of tasks relevant to the license category.
- Assessment: The focus has shifted slightly from “time spent” to “competence demonstrated.”
Type Rating Endorsements
- Group 3 Aircraft (Piston): Simplification of requirements for endorsing Type Ratings on Group 3 aircraft (small piston aeroplanes).
- Direct Approval of Training: EASA now allows for the recognition of type training conducted by organisations not holding a Part-147 approval, provided the training is directly approved by the Competent Authority (CA). This helps in niche cases where no Part-147 school offers a specific type rating.
Changes to Part-147 (The Training Organisation)
For Training Managers and Quality Managers, the changes focus on “New Training Methods” and digital transformation.
New Training Methods & Technologies
The regulation now formally recognises and regulates “Distance Learning” and “Virtual Classrooms,” moving them from temporary COVID-19 exemptions to permanent regulation.
- Virtually Controlled Environment (VCE): This term is now formally defined in AMC. It refers to synchronous distance learning (e.g., instructor-led Zoom/Teams training).
- Distance Learning (Async): Asynchronous learning (CBT/WBT) is permitted for basic and type training, but must be balanced with instructor interaction.
- Synthetic Training Devices (STD): greater credit and usage allowance for Virtual Reality (VR) and Augmented Reality (AR) tools in practical training, provided they are approved as part of the MTOE.
Management & Facility Requirements
- Personnel (147.A.105): A distinction is now made between “Large” and “Small” training organisations regarding management structure. Small organisations have more flexibility to combine roles (e.g., Training Manager and Quality Manager roles may be combined under specific conditions in minimal setups).
- Facilities (147.A.100): The requirement for facility size is now linked to “adequacy” for the instructional method. If you are teaching via VCE, you do not need physical classrooms for those students, but you must demonstrate robust IT infrastructure and “data integrity” (attendance tracking).
Examination Standards
- Question Bank Management: Stricter AMC regarding the security and integrity of the examination database to prevent fraud (a prelude to the forthcoming changes below).
- Examination Software: If exams are delivered digitally, the software must be validated to ensure it cannot be manipulated and that it accurately tracks timing and results.
Forthcoming Changes (2025 and beyond)
EASA has several active Rulemaking Tasks (RMTs) and Notices of Proposed Amendment (NPAs) that will impact the industry in the near future.
Review of Part-147 (NPA 2023-10) Status: Proposal phase (Opinion likely in 2025).
Focus: Anti-Fraud & Examination Integrity – Details:
- EASA is cracking down on “exam farming” (students memorising questions without learning).
- Expect new requirements for randomising exam questions.
- Proctoring: Stricter rules for remote invigilation of examinations.
- Language Proficiency: New requirements ensuring that instructors and students have a sufficient command of the language in which training/exams are delivered (usually English).
SMS for Part-147 Organisations Status: Ongoing debate (RMT.0255 / RMT.0544).
Clarification: While Part-145 organisations generally had to implement SMS by Dec 2024 (or Dec 2025 for US-based EASA 145s), Part-147 does not yet have a strict “Organisation SMS” mandate in the same legal sense.
The CAW Regulation does not currently require Part-147 organisations to implement a formal organisation-level SMS. The Syllabus inside Part-147 (what you teach) must now cover SMS (as per the Module 9/10 changes above).
EASA encourages voluntary SMS implementation and expects SMS elements to become a standard during oversight audits.
Electronic Licensing (e-Licence) Status: Roadmap phase.
Details: EASA is moving toward a standard for digital personnel licences to replace the paper Part-66 licence. This will likely roll out progressively across member states starting late 2025/2026.
Summary Table of Compliance Action Items
- Update MTOE to reflect “Virtually Controlled Environment” procedures if using remote training.
- Update Basic Training material (Modules 6, 7, 9, 10, 13, 14, 16). Remove Essays from Mod 9 & 10.
- Update Question Bank generation (new MCQ totals).
- Ensure Module 9 & 10 training includes specific SMS content (Safety Policy, Risk Management, Reporting).
- Review OJT procedures to utilise the new “flexible list” approach.
Next Steps
Sofema Aviation Services (SAS) and Sofema Online provide classroom, webinar and online training for EASA Part 147 and Part 66. Please see the websites or email [email protected].
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Sofemaonline, AviationTraining, SofemaAviationServices, AviationMaintenance, SafetyManagementSystems, AviationCompliance, EASARegulations, EASAPart66, EASAPart147, AircraftEngineering, MaintenanceTraining
