If your ground handling operation already runs to IATA IGOM and AHM, and you hold ISAGO registration, it is tempting to assume you are ready for Europe’s first dedicated ground handling regulation. You are not — at least not automatically. Regulation (EU) 2025/20 and Regulation (EU) 2025/23 have, for the first time, turned ground handling into a regulated activity with a direct relationship between the provider and its competent authority. That relationship is built on a declaration, an auditable management system, mandatory occurrence reporting and a ground handling manual — none of which are ramp procedures, and none of which IGOM or AHM were ever designed to deliver.
At Aero Support Group we mapped IATA IGOM Edition 14 and AHM Edition 46 — treated as a single combined document — against the full EASA Easy Access Rules for Ground Handling: 63 requirements across Part-GH.OPS, Part-ORGH and Part-ARGH. The conclusion is consistent and decisive: IGOM and AHM give you the content; EASA demands the system. This article explains where you are already covered, where the real gaps sit, and how we help ground service providers (GHSPs) close them.
The new regulatory reality for ground handlers
Regulation (EU) 2025/20 introduces the organisation (Part-ORGH) and operational (Part-GH.OPS) requirements; Regulation (EU) 2025/23 sets the competent-authority requirements (Part-ARGH). Together they mean that operating at an EU aerodrome is now conditional on a formal compliance framework — not just good ramp practice. For most providers the day-to-day handling is already sound; the exposure lies in the regulatory architecture around it.
Where IGOM, AHM and ISAGO already deliver
The good news is that Part-GH.OPS is largely covered. EASA drafted its operational requirements broadly in line with existing industry practice — much of it traceable to IGOM and ISAGO — so your core procedures are already substantially compliant. Apron safety, GSE operation, refuelling, de-icing and anti-icing, loading and unloading, ULD handling, pushback and towing, and passenger, baggage and cargo handling all map cleanly. AHM’s 500-, 600- and 900-series remain the authoritative content source, and IGOM remains the procedural backbone.
The implication is reassuring: you do not need to re-write your ramp procedures — you need to map them, and build the regulatory framework around them.
Content versus compliance: the 63-requirement picture
| Layer | IGOM + AHM + ISAGO | What EASA adds |
|---|---|---|
| Operational (Part-GH.OPS) | Largely covered | Procedure-precedence hierarchy, SMS-compatible interfaces, language proficiency, formal turnaround coordination, SERA.14001 phraseology |
| Organisation (Part-ORGH) | Partial / gap | Declaration, management system with compliance monitoring, Part-IS, occurrence reporting, safety directives, Ground Handling Manual, training architecture |
| Authority (Part-ARGH) | Not applicable to GHSP | Oversight, findings and safety-directive mechanisms run by the competent authority |
Where the real gaps are: the seven Part-ORGH themes
These are precisely the areas IGOM and AHM were never written to address, because they belong to the regulatory relationship between the provider and its authority.
- Declaration to the competent authority (ORGH.DEC.100 / DEC.105). A per-aerodrome declaration, kept current through change. Start of operations is conditional on completing the declaration, manual and management system in the correct sequence (GEN.115).
- A management system with compliance monitoring (ORGH.MGM.200). The single biggest structural difference — accountable manager accountability, a signed safety policy, a functioning SMS, fatigue management and an independent compliance-monitoring function. The phrase “compliance monitoring” does not appear as a requirement in IGOM or AHM.
- Information security — Part-IS (ORGH.MGM.201). Aligned with Reg (EU) 2022/1645 and 2023/203, effective 27 March 2031, and entirely new to ground handling.
- Mandatory occurrence reporting (ORGH.GEN.160 / GEN.165). Reporting to the authority under Reg (EU) 376/2014 plus voluntary, just-culture reporting — including undeclared dangerous goods.
- Safety directives and the finding–CAP cycle (ORGH.GEN.150 / GEN.155). Binding authority instruments and a time-bound, auditable corrective action process — EASA-specific with no IATA counterpart.
- The Ground Handling Manual construct (ORGH.DOC.110). An approved, version-controlled, authority-accessible manual. IGOM and AHM are an excellent content source, but the manual construct itself must be built deliberately.
- Training and competence architecture (ORGH.TRG.100). Training needs analysis, a defined competence-assessment phase, recurrence no later than every 36 months, and DG training aligned to the ICAO Technical Instructions.
EASA and ISAGO: complementary, not competing
Many providers ask whether EASA compliance replaces ISAGO. It does neither. ISAGO remains the airline-facing audit standard your customers contract against; EASA is the regulator-facing legal requirement to operate at an EU aerodrome. ISAGO’s GHSP and station standards generate much of the evidence EASA’s GH.OPS and ORGH requirements demand. Run in isolation, the two cost you twice and audit you twice; integrated, they become one durable ground operations compliance system.
Why getting this wrong is expensive
An operation can execute every IGOM procedure flawlessly and still fall short of EASA compliance, because compliance now lives in the declaration, the management system, the compliance-monitoring function, the reporting obligations and the controlled manual. A competent-authority inspection will look for exactly these — and findings translate into corrective-action pressure, reputational risk with airline customers, and, ultimately, your ability to operate at the aerodrome.
Key dates: the declaration window and what applies when
The timeline matters because a declaration is a legal statement of compliance from the day it is submitted.
- 27 March 2025: Delegated Regulation (EU) 2025/20 entered into force.
- 27 March 2027: ground handling service providers can start submitting declarations to their competent authority. EASA has said no findings will be raised during the transition.
- 27 March 2028: Regulation (EU) 2025/20 applies. From this date a provider needs a valid declaration to operate.
- 27 March 2031: information security requirements (ORGH.MGM.201 and Part-IS, through Delegated Regulation (EU) 2025/22) apply to ground handlers.
A provider based in an EASA Member State declares to its home authority. A provider based outside declares to each State where it operates. Recurrent training must take place at least every 36 months, dangerous goods recurrent training at least every 24 months, and occurrences must be reported within 72 hours. For an organisation starting now, the realistic plan is a gap analysis in the first quarter of 2027 and a declaration-ready management system before the window opens.
More on the declaration process and our support: EU ground handling regulation consulting.
How Aero Support Group closes the gap
We do not hand you a binder that sits on a shelf between audits. We build the declaration, the management system, the compliance-monitoring function, the reporting process and the controlled manual as a working system your team can sustain. Our EASA ground handling support includes:
- Gap analysis — IGOM + AHM + ISAGO vs Reg 2025/20 & 2025/23. A requirement-by-requirement assessment across all 63 requirements, each classified as covered, partial or gap, with a prioritised remediation roadmap.
- Management system and compliance-monitoring build. We stand up the ORGH.MGM.200 system and integrate it with any existing Part-145, Part-CAMO or aerodrome management system — rather than duplicating it.
- Ground Handling Manual development. We design the approved, version-controlled manual required by ORGH.DOC.110 and map your validated IGOM and AHM content into it.
- Declaration, occurrence reporting and authority liaison. We prepare the per-aerodrome declaration, establish the Reg 376/2014 reporting system, and support engagement with your competent authority through a structured corrective action plan cycle.
- Part-IS roadmap and training architecture. We plan your Part-IS information security system ahead of 27 March 2031 and rebuild your training framework to the ORGH.TRG standard.
Why choose ASG
Our consultants combine deep regulatory expertise with hands-on ground operations experience across airlines, ground service providers and aerodromes in 100+ countries, with 1,000+ projects delivered. We were among the first to publish a full requirement-by-requirement mapping of Reg (EU) 2025/20 and 2025/23 against IGOM 14 and AHM 46 — the analysis behind this article. Our philosophy is simple: compliance is not a documentation exercise, it is an operational capability.
Ready to become EASA ground handling ready?
Whether you are preparing your first declaration, integrating EASA requirements with an existing ISAGO programme, or building your management system and Ground Handling Manual from the ground up, we can help. Explore our dedicated EASA Ground Handling Regulation Consulting service, or contact our team to discuss your operation — the underlying 63-requirement gap matrix is available on request.