Aero Support Group

ICAO Annex 19, 3rd Edition, for MROs and CAMOs: What Changes in Your SMS

By Ferhan Bugay, Executive Director, Aero Support Group · 13 November 2026

From 26 November 2026, Annex 19, 3rd Edition (Amendment 2), is applicable to approved maintenance organisations that serve international commercial air transport, and for the first time to those that maintain aircraft for international RPAS operators. For an MRO it means a system description with interfaces, interface hazards in the hazard log, resources named in the SMS manual, safety performance measured against objectives, and periodic SMS assessment by the authority. CAMOs are not listed separately in Annex 19, but most of them sit inside an operator’s SMS or run their own management system under national rules.

Does it apply to your organisation?

Your organisation Annex 19 or EASA basis What it means
AMO maintaining aeroplanes or helicopters for international commercial air transport 3.3.2.1 d); 4.2.4 SMS acceptable to the State(s) responsible for your approval
AMO maintaining aircraft for international RPAS operators 3.3.2.1 e); 4.2.5 New in the 3rd Edition
Maintenance done under the operator’s own system, not by an AMO 3.3.2.1 b), Note; 4.2.2, Note That maintenance is inside the operator’s SMS
CAMO Not listed separately in 3.3.2.1 In the EU, CAMO.A.200 requires a management system with hazard identification and risk management; for air carriers it is part of the operator’s management system (CAMO.A.200(d))
EASA Part-145 organisation 145.A.200 A management system with safety policy, hazard identification and risk management is already required

What changes in an MRO SMS

The table takes the framework changes from the 3rd Edition and shows what each usually means for a maintenance organisation.

Change and provision What it means for an MRO
Resources join the first component
App. 2, 1; 1.5.1 a)
The SMS manual names the safety manager, the time set aside for safety work in hangars and shops, and the budget for reporting and analysis tools
System description, scope and interfaces
4.1.1 b)–c)
A system description that covers approval ratings, base and line stations, shops and subcontractors, with an owner for each interface
Interface hazards
App. 2, 2.1.1
The hazard log covers work packages from different customers and CAMOs, parts and tooling suppliers, subcontracted specialist tasks such as NDT, shift handovers and line maintenance at outstations
Safety performance measurement
App. 2, 3.1
SPIs such as repeat defects, maintenance-related occurrences, tool control findings and task card errors, with progress shown against each safety objective and evidence that key controls such as independent inspections work
Objectives consider State objectives
App. 2, 1.1.3
Safety objectives cross-checked against your State’s SSP objectives
Human performance
4.1.3
Investigation, risk assessment and change templates prompt for fatigue on night shifts, time pressure from turnaround commitments and task card design
Effects from other domains
App. 2, 2.2, Notes 1–2
Commercial decisions, such as a new customer type, a shorter turnaround commitment or a new subcontractor, go through a safety risk assessment
Size and complexity
4.1.1, Note 1
The way the SMS is scaled to your ratings, stations and headcount is written down and justified

What your authority will check

Periodic SMS assessment (3.4.1.3). Your State must assess your SMS periodically and monitor your safety performance. An assessor will want to see that the SMS runs: hazard log entries raised from the hangar floor, SPI trends with action taken, safety review minutes with decisions followed through, and investigations that changed a procedure or a task card.

Internal resolution policy (3.4.1.4). Your State must publish a policy on which safety events you may resolve inside your SMS. Check your occurrence handling procedure against it, in particular for internal reports that never reach the authority.

State-level SPIs (3.4.2.2). Where your State publishes safety performance indicators, it should ask service providers to consider them. Expect questions on how your SPIs relate to the national ones.

Evidence an assessor will ask for

Area Evidence
Resources Safety manager appointment, time allocation, tool licences
System description Current document with ratings, stations, subcontractors, interfaces and owners
Interface hazards Hazard log entries for customers, suppliers and subcontractors, with risk owners
Safety performance Twelve months of SPI trends, objectives with progress, one or more validated controls
Management review Safety review board minutes and an action log with closure dates
Human performance Investigation reports that looked at fatigue, time pressure or task card design
Change management Risk assessments for new customers, new ratings or new subcontractors

EASA Part-145 and Part-CAMO

EU organisations already work under 145.A.200 and CAMO.A.200, which require a management system with a safety policy, hazard identification, risk management and compliance monitoring. For them the 3rd Edition changes are mostly about evidence: a system description with interfaces, interface hazards in the log and safety performance that is measured and acted on. Foreign Part-145 organisations answer to their own State for Annex 19 and to EASA for the Part-145 approval, so the same SMS should satisfy both.

Where to start

  1. Write or update the system description and list every interface with an owner.
  2. Add interface hazards to the hazard log, starting with customer work packages, subcontracted tasks and shift handovers.
  3. Rewrite the resources section of the SMS manual.
  4. Review your SPIs and objectives and pick one control, such as independent inspection, to validate this quarter.
  5. Prepare a one-page evidence pack for the State SMS assessment.

How ASG can help

ASG runs Annex 19 gap assessments for maintenance organisations with an evidence check for each element, prepares organisations for EASA Part-145 approval and supports SMS implementation through ASG RADAR. Write to info@aerosupport360.com.

Related: ICAO Annex 19 Amendment 2: the 11 changes · Annex 19, 3rd Edition, for airlines · EASA Part-145 approval · SMS development consulting

References

  • ICAO Annex 19, Safety Management, 3rd Edition, November 2025 (Amendment 2): 3.3.2, 3.4.1.3, 3.4.1.4, 3.4.2.2, Chapter 4 and Appendix 2
  • ICAO Doc 9859, Safety Management Manual
  • Regulation (EU) No 1321/2014, Annex II (Part-145), 145.A.200, and Annex Vc (Part-CAMO), CAMO.A.200

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

If you are an approved maintenance organisation serving international commercial air transport, you were already covered. The new scope is AMOs serving international RPAS operators (3.3.2.1 e)). For everyone else the 3rd Edition changes what the SMS must contain and how your State will assess it.

Annex 19 does not list CAMOs separately. Maintenance done under the operator’s own system falls inside the operator’s SMS (3.3.2.1 b), Note). In the EU, CAMO.A.200 requires a management system with hazard identification and risk management, and for air carriers it is part of the operator’s management system.

Customer work packages from different operators and CAMOs, parts and tooling suppliers, subcontracted specialist tasks and shift handovers. Each needs an owner in the system description (4.1.1 c)) and hazards in the log (App. 2, 2.1.1).

145.A.200 already requires a management system with safety risk management. The gap is usually evidence: a system description with interfaces, interface hazards and safety performance measured against objectives. Your own State will assess the SMS against Annex 19 as well.

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