PART-145 SMS · Aero Support Group FZCO · Updated 23 October 2026
What is SMS for a Part-145 maintenance organisation?
A safety management system in a Part-145 organisation is the part of the management system required by 145.A.200 that identifies hazards in maintenance activity, assesses the associated risks and checks that mitigations work. Regulation (EU) 2021/1963 brought the ICAO Annex 19 framework into Part-145 and aligned it with Part-CAMO and the operator rules.
The requirement applies to every Part-145 organisation, whatever its size. The depth of the system should match the size, nature and complexity of the organisation’s activities, as the AMC to 145.A.200 allows.
What 145.A.200 requires
- Clearly defined lines of responsibility and accountability, including the accountable manager’s direct safety accountability.
- A safety policy and related safety objectives.
- Identification of aviation safety hazards, with assessment and mitigation of the associated risks and verification of the effectiveness of mitigations.
- Training and competence of personnel to carry out their tasks.
- Documentation of all key management system processes, including a process to make staff aware of their responsibilities.
- A function to monitor compliance with the relevant requirements, with feedback of findings to the accountable manager.
- Any additional requirements in the applicable Part-145 points.
145.A.202 adds an internal safety reporting scheme, and 145.A.60 keeps occurrence reporting under Regulation (EU) No 376/2014.
Where Part-145 SMS implementations fall short
- A hazard log exists but is populated once at implementation and never updated from occurrence reports, audits or changes.
- Risk assessments are produced for paperwork and not used to decide manpower, shift patterns or tooling.
- Safety performance indicators count reports instead of measuring safety outcomes in maintenance.
- Internal reports are not analysed for trends, and reporters receive no feedback.
- Management of change is applied to new capability but not to staffing reductions, new contractors or facility moves.
- Human factors and maintenance error investigations stop at the individual instead of the system.
How ASG builds a Part-145 SMS
- Gap analysis against 145.A.200, 145.A.202 and 145.A.200A and their AMC/GM, mapped to what the competent authority will sample.
- Design of hazard identification, risk assessment and management of change processes that fit the organisation’s base and line stations.
- Documentation: MOE Part 2 and supporting procedures written around how the organisation actually works.
- Safety performance: SPIs and targets tied to maintenance outcomes, with a review cycle and a safety review board that takes decisions.
- Training for the accountable manager, safety manager, compliance monitoring staff and certifying personnel.
- Effectiveness check: a mock audit after three to six months of operation to show the system is producing decisions and evidence.
Conclusion
A Part-145 SMS is judged by whether it changes decisions in the hangar. The competent authority will look for hazards that were identified from real activity, risks that were assessed and acted on, and indicators that are reviewed and followed up. ASG helps organisations build that system and prove it works.
Frequently asked questions
Yes. Since Regulation (EU) 2021/1963 applied on 2 December 2022, 145.A.200 requires a management system that includes safety risk management for every Part-145 organisation.
The rule requires defined safety accountabilities and a management system; the AMC to 145.A.200 describes a safety manager role. Small organisations may combine roles where independence is not compromised.
Since 22 February 2026, 145.A.200A requires an information security management system that addresses risks to aviation safety, under Regulation (EU) 2023/203.
The SMS must be proportionate to the size, nature and complexity of the organisation. The requirement applies, but the depth of processes can be scaled.
Typically the hazard log and risk assessments, SPI data and review records, safety review minutes with follow-up, internal reports and investigations, and compliance monitoring findings with closure.
Key takeaways
- 145.A.200 requires a management system with safety risk management for all Part-145 organisations
- Applicable since 2 December 2022 (Regulation (EU) 2021/1963)
- 145.A.200A adds information security from 22 February 2026
- The SMS must be proportionate to size and complexity
- Authorities look for decisions and follow-up, not just documents
Building or fixing a Part-145 SMS?
Tell us about your organisation and stations. ASG will assess your system against 145.A.200 and set out a practical implementation plan.