By Ferhan Bugay, Executive Director, Aero Support Group · Updated 10 November 2026
ICAO Annex 19 Amendment 2 was adopted on 23 June 2025 and applies from 26 November 2026. It was published as the 3rd Edition of Annex 19. For service providers it brings eleven changes to the SMS framework, adds RPAS operators, their maintenance organisations and certified heliports to the SMS list, and gives States new duties to assess your SMS periodically.
Key dates
| Milestone | Date |
|---|---|
| Adopted by the ICAO Council | 23 June 2025 |
| Effective | 4 November 2025 |
| Applicable | 26 November 2026 |
| Published as | Annex 19, 3rd Edition (November 2025) |
Who must have an SMS under Amendment 2
Annex 19, 3.3.2.1 lists the service providers that States must require to implement an SMS. Three entries are new.
| Service provider | Annex 19 reference | Status |
|---|---|---|
| Approved training organisations (Annex 1) exposed to safety risks related to aircraft operations | 3.3.2.1 a) | Already required |
| International commercial air transport operators, aeroplanes and helicopters | 3.3.2.1 b) | Already required |
| RPAS operators authorised to conduct international operations | 3.3.2.1 c) | New |
| Approved maintenance organisations serving international CAT operators | 3.3.2.1 d) | Already required |
| Approved maintenance organisations serving international RPAS operators | 3.3.2.1 e) | New |
| Type design and production organisations (aircraft, engines, propellers) | 3.3.2.1 f) | Already required |
| Air traffic services providers | 3.3.2.1 g) | Already required |
| Operators of certified aerodromes and certified heliports | 3.3.2.1 h) | Heliports new |
| International general aviation, large or turbojet aeroplanes | 3.3.2.2 | State of Registry sets SMS criteria |
Organisations outside this list, such as ground handlers, fuel suppliers and de-icing providers, are not named in Annex 19. A new Recommendation, 3.3.5.3, asks States to review periodically whether SMS should be extended to other aviation sectors as a safety risk control. In the EU, Commission Delegated Regulation (EU) 2025/20 brings ground handling organisations under EASA rules with a management system requirement once it applies, and IATA ISAGO already expects an SMS.
The 11 changes for service providers
These are the changes between the 2nd and 3rd Editions that affect a service provider’s SMS. The first eight change the SMS framework itself. The last three are obligations on States that change what your authority will expect from you.
| # | Change and provision | What to check |
|---|---|---|
| 1 | The first SMS component is now “Safety policy, objectives and resources” App. 2, 1; 1.5.1 a) · Standard |
Your SMS manual describes the people, budget and tools committed to the SMS |
| 2 | System description, scope and interfaces 4.1.1 b)–c) · Standard |
A written system description defines the SMS scope and lists organisational interfaces with owners |
| 3 | Hazards from internal and external interfaces App. 2, 2.1.1 · Standard |
Your hazard log covers interfaces between departments and with contractors and partners |
| 4 | Safety performance measurement restructured App. 2, 3.1 a)–c) · Standard |
You can show performance monitoring, progress against each safety objective and validation of risk controls; targets are used where appropriate |
| 5 | Safety objectives consider State objectives App. 2, 1.1.3 · Recommendation |
Your objectives take account of your State’s SSP objectives where they exist |
| 6 | Human performance in the SMS 4.1.3 · Recommendation |
Risk assessment, investigation and change templates prompt for workload, fatigue, interface design and procedure usability |
| 7 | Effects from security, facilitation, economics and environment App. 2, 2.2, Notes 1–2 · Guidance |
Risk assessments consider how decisions in other domains affect safety, and the reverse |
| 8 | “Size and complexity” moved from the Standard to guidance 4.1.1, Note 1 · Guidance |
The way your SMS is tailored to your size and complexity is documented and justified |
| 9 | States must periodically assess your SMS and monitor your safety performance 3.4.1.3 · Standard (to States) |
Records, SPI trends, SRB minutes and closed actions ready for an assessor |
| 10 | States must set a surveillance policy on events you may resolve internally 3.4.1.4 · Standard (to States), previously a Recommendation |
Your occurrence procedure follows your authority’s policy |
| 11 | Your SPIs should consider State-level measurement 3.4.2.2 · Recommendation (to States) |
Your SPIs line up with the indicators your State uses, where that makes sense |
What changes for States, and why operators will see it
Amendment 2 changes the State Safety Programme in four ways that reach service providers.
SMS assessment becomes a State duty. Under 3.4.1.3, States must have mechanisms to assess the SMS of the service providers listed in 3.3.2.1 periodically and to monitor their safety performance. Guidance is in the Safety Management Manual (Doc 9859). Expect your authority to ask whether the SMS is operating and effective, with evidence from records, and to look past the manual.
Internal resolution needs a written policy. 3.4.1.4 turns a former Recommendation into a Standard. Your authority must state when you may deal with and resolve certain safety events within your SMS. If your occurrence procedure assumes this already, check it against the policy once it is published.
ALoSP is replaced. The 2nd Edition required States to establish an acceptable level of safety performance (2nd Ed., 3.4.2.1). The 3rd Edition replaces it with safety performance indicators, supported by qualitative means, and targets where appropriate (3rd Ed., 3.4.2.1). Recommendation 3.4.2.2 asks States to make sure service providers’ measurement considers the State level.
Chapter 5 becomes “Development of safety intelligence”. In the 2nd Edition, Chapter 5 dealt with safety data and safety information. The 3rd Edition renames it and strengthens it. States should have a strategy for developing safety intelligence (5.1.1), must run a safety data collection and processing system with a standard reporting taxonomy (5.2), and must analyse the data to support SPIs, State-level hazard identification and safety intelligence (5.3.1). These provisions are addressed to States. Service providers are named in Recommendation 5.5.3, which asks States to promote the sharing of safety information and safety intelligence among service providers. In practice you will feel it through reporting taxonomy, data requests from your authority and invitations to safety information sharing groups. Guidance is in the Safety Intelligence Manual (Doc 10159); see our guide to Doc 9859 and Doc 10159.
What to do before 26 November 2026
- Check your applicability. Confirm which entry of 3.3.2.1 covers you and whether your State has extended SMS further under national rules.
- Run the 11-item check. For each change, record the status, the manual reference and the evidence.
- Rewrite the resources section. The first component now includes resources. Name the safety team, the budget line and the tools, and show who approves them.
- Review safety performance measurement. Show progress against each safety objective and at least one validated risk control. Keep targets only where they help decisions.
- Prepare for the State assessment. Pull twelve months of hazard log entries, SPI trends, SRB minutes and action closure records. If an assessor asked tomorrow, could you show that the SMS changed a decision?
- Ask your authority. Find out how it will run the periodic SMS assessment under 3.4.1.3 and when its surveillance policy under 3.4.1.4 will be published.
Sector guides
Each guide covers the applicability, the changes that matter most and typical evidence for that sector.
- Annex 19 3rd Edition for airlines
- Annex 19 3rd Edition for maintenance organisations and CAMOs (coming 11 November)
- Annex 19 3rd Edition for aerodromes and heliports (coming 12 November)
- Annex 19 and airport service providers: ground handling, fuel and de-icing (coming 13 November)
- Annex 19 3rd Edition for civil aviation authorities (coming 16 November)
How Amendment 2 relates to IOSA, ISAGO and EASA
IOSA and ISAGO standards are written by IATA and follow their own revision cycles. Their SMS sections draw on Annex 19, so check each new ISM and GOSM edition for the changes above. Airlines preparing for IOSA under ISM Edition 19 should read its ORG section alongside this list.
EU rules (Part-ORO, Part-145, Part-CAMO, Part-ADR) already require a management system. EASA usually addresses ICAO amendments through rulemaking tasks listed in the European Plan for Aviation Safety, so check the current EPAS for the status of Annex 19 Amendment 2. Third country operators under EASA TCO or UK CAA TCO are assessed against ICAO standards, so the State of the Operator’s implementation of Amendment 2 will matter at your next review.
How ASG can help
ASG’s SMS specialists include active IATA auditors. We run Annex 19 gap assessments with an evidence check for each element, facilitate multi-assessor calibration workshops, and support SMS implementation through ASG RADAR. Write to info@aerosupport360.com.
Related services: SMS development consulting · IOSA audit preparation · ISAGO audit preparation · EASA Part-145 consulting · EASA TCO authorisation · ICAO USOAP and SSP support · SMS training
References
- ICAO Annex 19, Safety Management, 3rd Edition, November 2025 (Amendment 2), Chapters 3, 4 and 5 and Appendix 2
- ICAO Annex 19, Safety Management, 2nd Edition, July 2016
- ICAO Doc 9859, Safety Management Manual
- ICAO Doc 10159, Safety Intelligence Manual
- ICAO Safety Management: icao.int/safety-management
- Commission Delegated Regulation (EU) 2025/20 (ground handling)
- EASA European Plan for Aviation Safety: easa.europa.eu
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
Amendment 2 to Annex 19 was adopted by the ICAO Council on 23 June 2025, became effective on 4 November 2025 and applies from 26 November 2026. It was published as the 3rd Edition of Annex 19 in November 2025.
Operators holding an RPAS operator certificate and authorised to conduct international operations (3.3.2.1 c), approved maintenance organisations serving them (3.3.2.1 e), and operators of certified heliports (3.3.2.1 h).
Annex 19 does not list ground handling service providers. Recommendation 3.3.5.3 asks States to review whether SMS should be extended to more sectors, IATA ISAGO already expects an SMS from ground handlers, and in the EU, Delegated Regulation (EU) 2025/20 adds a management system requirement once it applies.
The first component now includes resources, the SMS must rest on a system description with defined interfaces, hazard identification must cover interface hazards, and safety performance measurement now covers monitoring, progress against objectives and validation of risk controls.
Chapter 5, “Development of safety intelligence”, is addressed to States. Service providers are mentioned in Recommendation 5.5.3 on sharing safety information and safety intelligence. You will feel it through reporting taxonomy and data exchange with your authority.
The Safety Intelligence Manual. Annex 19, 3rd Edition, refers to it for safety data collection, analysis, governance, protection and information sharing.
The 3rd Edition replaces it with safety performance indicators, qualitative means and targets where appropriate (3.4.2.1).
