By Ferhan Bugay, Executive Director, Aero Support Group · 13 November 2026
Ground handlers, into-plane fuel suppliers and de-icing providers are not on the Annex 19 list of service providers that must have an SMS. Annex 19, 3rd Edition (Amendment 2), which is applicable from 26 November 2026, still reaches them in two ways. It asks States to review whether to extend SMS requirements to other organisations, and it requires airlines and aerodromes to manage hazards at their interfaces, so they will ask their suppliers for safety data. In the EU, Regulation (EU) 2025/20 adds an SMS requirement for ground handling organisations.
Who Annex 19 lists, and who it does not
| Organisation | Annex 19 basis | Position |
|---|---|---|
| Approved training organisations exposed to safety risks in aircraft operations | 3.3.2.1 a); 4.2.1 | Listed |
| Organisations responsible for type design or manufacture | 3.3.2.1 f); 4.2.6–4.2.7 | Listed |
| Air traffic services providers | 3.3.2.1 g); 4.2.8 | Listed |
| Ground handlers, into-plane fuel suppliers, de-icing providers | 3.3.5.3 | Not listed; the State should review whether to extend SMS requirements to them |
How the 3rd Edition reaches unlisted organisations
State review (3.3.5.3). States are asked to review whether SMS requirements should apply to other organisations whose activities affect aviation safety. Some States already require an SMS from ground handlers through national rules or the aerodrome certificate. Check what your own State has decided, and where it has not decided yet, expect the question.
Interface hazards at your customers (App. 2, 2.1.1). Airlines and aerodrome operators must identify hazards at their interfaces with other organisations and describe those interfaces in their system description (4.1.1 c)). Turnaround, loading, fuelling and de-icing are among their busiest interfaces. Expect customers to ask for your occurrence data, your hazard and risk assessments for shared operations and your participation in their safety meetings.
Emergency planning (App. 2, 1.4). Aerodrome and airline emergency plans must be coordinated with the plans of the organisations they interface with. Your own emergency procedures will be part of that coordination.
EU ground handling: Regulation (EU) 2025/20
Regulation (EU) 2025/20 sets organisation requirements for ground handling. ORGH.MGM.200 requires a management system that includes safety risk management and covers interfaces with other organisations, and ORGH.GEN.130 requires change management. The definitions in Article 3 bring into-plane fuelling and de-icing within ground handling services, so EU fuel and de-icing providers fall under the same rules once they apply. If you work in the EU, plan your SMS against this regulation and Annex 19 at the same time.
Industry programmes
ISAGO audits ground service providers against standards that include safety management. Fuel quality and de-icing programmes such as IFQP, JIG and DAQCP audit fuel and de-icing operations for their airline members. An SMS built to Annex 19 will make these audits easier, because the same hazard log, occurrence data and training records serve all of them.
What to prepare
| Area | Evidence a customer or authority will ask for |
|---|---|
| Safety policy and accountabilities | Signed policy, named safety manager, accountabilities per station |
| Interfaces | List of customers, aerodromes and subcontractors with an owner for each interface |
| Hazards and risks | Hazard log for turnaround, loading, fuelling and de-icing tasks, with risk owners |
| Occurrence data | Twelve months of occurrence and damage reports, with trends shared with customers |
| Safety performance | SPIs such as aircraft damage events, load errors, fuelling incidents and de-icing quality findings |
| Change management | Risk assessments for new customers, new equipment and new stations |
| Emergency planning | Station emergency procedures with records of coordination with the aerodrome and airlines |
Where to start
- Find out what your State has decided under 3.3.5.3 and, in the EU, plan against Regulation (EU) 2025/20.
- List every interface with customers, aerodromes and subcontractors and give each one an owner.
- Build a hazard log for your core tasks and share relevant entries with your customers.
- Agree a small set of SPIs and report them to customers on a fixed cycle.
- Align the SMS with your ISAGO, IFQP, JIG or DAQCP audit evidence so one set of records serves all of them.
How ASG can help
ASG prepares ground handlers for ISAGO and for EASA ground handling regulation, supports de-icing and fuel quality programmes, and runs Annex 19 gap assessments with an evidence check for each element. Write to info@aerosupport360.com.
Related: ICAO Annex 19 Amendment 2: the 11 changes · Annex 19, 3rd Edition, for airlines · Annex 19, 3rd Edition, for aerodromes and heliports
References
- ICAO Annex 19, Safety Management, 3rd Edition, November 2025 (Amendment 2): 3.3.2, 3.3.5.3, Chapter 4 and Appendix 2
- Regulation (EU) 2025/20 on ground handling: Article 3, ORGH.GEN.130, ORGH.MGM.200
- IATA ISAGO Standards Manual
Free download: Annex 19 SMS Assessment
The Amendment 2 differences checklist, a 28-feature SMS maturity assessment against the Appendix 2 framework, a dashboard and an action plan, in Excel. Versions for airlines and MROs, aerodromes and heliports, and other aviation organisations such as ground handlers, fuel suppliers and ATS providers. Fill in the form and the download links arrive by email.
Civil aviation authorities: this tool is built for service providers. For support with your State’s side of Amendment 2, tailored to the size of your State and the scope of your oversight, write to info@aerosupport360.com.
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Frequently asked questions
Annex 19 does not list ground handlers among the service providers that must have an SMS. It asks States to review whether to extend SMS requirements to other organisations (3.3.5.3), and some States already require one. In the EU, Regulation (EU) 2025/20 requires a management system with safety risk management for ground handling organisations.
Article 3 of Regulation (EU) 2025/20 defines into-plane fuelling and de-icing as ground handling services, so EU providers of those services fall under the same organisation requirements once they apply.
Airlines and aerodromes must identify hazards at their interfaces with other organisations (App. 2, 2.1.1). Ground handling, fuelling and de-icing are among those interfaces, so customers need your occurrence data and risk assessments to meet their own SMS requirements.
ISAGO standards include safety management, and the same records support both. Annex 19 obligations come through your State and your customers, so check national rules as well.
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