CORRECTIVE ACTION PLANS · Aero Support Group FZCO · Updated 22 October 2026
What regulators and auditors expect
- EASA air operators (ORO.GEN.150) and Part-145 organisations (145.A.95) must identify the root cause of a finding, define a corrective action plan and demonstrate its implementation within the period agreed with the competent authority. Authorities classify findings as level 1 or level 2.
- IOSA and ISAGO findings must be closed with evidence that the audit organisation verifies before registration or accreditation is completed.
- ICAO USOAP findings are addressed by the State through corrective action plans submitted on the USOAP CMA online framework, which ICAO assesses and later validates.
- Internal findings from compliance monitoring are handled the same way under the organisation’s management system, with effectiveness checked before closure.
Root cause at system level
Many CAPs are rejected because they repeat the finding as its cause. “Training records were missing” is the finding. The cause might be that no one owns the process of transferring records from training providers, or that the records system cannot show expiry dates. Those causes point to different actions.
We look for causes in four places: governance (who is accountable and whether they have authority), resources (people, time and tools), process ownership (whether a named person runs the process end to end) and oversight effectiveness (whether compliance monitoring would have detected the problem). Techniques such as the five whys or a fishbone diagram help, but the test is whether the stated cause explains why the problem occurred and could recur elsewhere.
A root cause should be honest without damaging the organisation. Blaming one person rarely satisfies an auditor, and admitting a total system failure where none exists invites wider scrutiny. The right cause is specific, supported by evidence and fixable.
Writing actions that can be audited
Each action in an ASG CAP states:
- what will change, in terms specific enough to check (“Revise procedure 3.4 to require monthly reconciliation of training records against the roster”, not “improve training records management”);
- who owns it, by post title;
- the target date, set realistically against the closure period;
- the evidence that will prove implementation, such as a revised procedure, training attendance, completed records or a follow-up audit;
- how effectiveness will be checked, and when.
The final action taken statement is written in the past tense and points to that evidence, so the auditor can trace each action to a document or record.
Implementation and closure
CAPs fail most often at implementation, after they have been accepted. Actions are left with people who have no time to do them, dates slip without the authority being told, or the evidence submitted shows that a document was revised but not that anyone works to it.
ASG supports implementation with a tracking register that lists every action, its owner, its status and its evidence. We review evidence before it is submitted, so closure requests are complete the first time. Where a date cannot be met, we help the organisation inform the authority early, with interim measures and a revised plan.
How ASG supports CAP development
- Review of the audit report and clarification of what each finding requires.
- Root cause workshops with the people who run the process.
- Drafting of CAPs and FAT statements in the format required by the authority, IATA or ICAO.
- A tracking register for implementation, evidence and effectiveness checks.
- Pre-submission review of closure evidence.
- Follow-up audits to confirm that actions have worked before findings are closed.
Conclusion
A corrective action plan earns acceptance when its root cause is credible and its actions can be checked. It earns closure when the evidence shows the organisation now works differently. ASG helps organisations reach both, and keeps the record clear for the next audit.
Frequently asked questions
It explains why the problem occurred, not just what was found. It is supported by evidence, points to something the organisation can change, and would prevent recurrence if fixed.
A final action taken statement describes, in the past tense, what the organisation did to close a finding and where the evidence can be found. It is the basis on which the auditor or authority closes the finding.
Generally no. Closure requires evidence that the actions are complete. Where some actions take longer, the organisation should agree the timeline with the authority or audit organisation and keep the finding open until the evidence is available.
Tell the authority or audit organisation before the date passes, explain why, and propose interim measures and a revised date. Silence is treated more harshly than a realistic revised plan.
Someone independent of the area concerned, usually the compliance monitoring or internal audit function. ASG can carry out verification audits where independence or capacity is lacking.
Key takeaways
- Authorities and IATA expect a root cause, a corrective action and evidence of implementation
- Look for causes in governance, resources, process ownership and oversight
- Each action needs an owner, a date and the evidence that will prove it
- FAT statements are written in the past tense and linked to evidence
- Check effectiveness before asking for closure
Facing findings with a deadline?
Send us the audit report. ASG will review the findings and propose root causes and actions the authority can accept.