MOE DEVELOPMENT & REVIEW · Aero Support Group FZCO · Updated 22 October 2026
What the MOE has to cover
Point 145.A.70(a) lists the content of the exposition. It includes a statement signed by the accountable manager confirming that the MOE and associated manuals define the organisation’s compliance with Part-145, the safety policy, the titles and names of nominated persons and their duties, an organisational chart, the list of certifying and support staff, the facilities at each location, the scope of work, the change notification procedure and the list of alternative means of compliance used.
Since 2 December 2022, when Implementing Regulation (EU) 2021/1963 introduced the management system requirement (145.A.200), the MOE must also describe safety risk management, compliance monitoring and the internal safety reporting scheme (145.A.202). Since 22 February 2026 it must address the information security management system under 145.A.200A, directly or by reference to a separate manual.
The structure authorities expect
AMC1 145.A.70(a) sets out a standard structure, and EASA’s MOE User Guide (UG.CAO.00024) applies it to foreign Part-145 organisations:
- Part 0: general organisation and document control;
- Part 1: management: accountable manager’s statement, safety policy, nominated persons, staff resources, facilities, scope of work and the procedure for changes;
- Part 2: maintenance procedures, from supplier evaluation and tooling control to work orders, defect handling, certification and records;
- Part L2: additional line maintenance procedures;
- Part 3: management system procedures, including hazard identification and risk management, compliance monitoring, human factors training and staff qualification;
- Part 4: contracted operators and customers;
- Part 5: supporting documents and lists, such as subcontractors, line stations and contracted organisations.
Organisations add sections for information security and, if they hold an FAA certificate under the EU–US arrangements, an FAA supplement. Following the standard numbering makes the authority’s review faster, because inspectors know where to find each item.
Why MOEs fail at audit
- The MOE is adapted from another organisation and describes facilities, tooling or line stations that do not exist.
- Procedures are written as policy statements, with no owner, no steps and no record that proves they were followed.
- Part 3 copies SMS text from a guidance document, but the hazard log, risk assessments and management reviews it describes are not in use.
- The scope of work lists aircraft types or component ratings that the maintenance data, tooling and certifying staff cannot support.
- Forms and records referred to in the procedures are not controlled or cannot be traced to a form number.
- After the old 145.A.65 quality system was replaced, the MOE still describes the pre-2022 quality system instead of compliance monitoring within the management system.
How ASG develops and reviews MOEs
1. Assessment. We review the existing MOE and procedures against Part-145, the current AMC and GM and, for foreign organisations, UG.CAO.00024, and compare them with what we see in the hangar and the records.
2. Structure. We map each requirement to an MOE section using the standard numbering, so the authority can find each item quickly.
3. Drafting. We write procedures with the people who do the work. Each procedure names its owner, its steps, the form or record it produces and the Part-145 point it addresses.
4. Review and approval. The accountable manager and nominated persons review the draft. We prepare the submission and support the organisation through the authority’s questions.
5. Implementation. We brief staff on the new procedures and check that records are being produced before the authority’s audit.
Related manuals
The MOE often sits alongside other controlled documents. ASG also works on:
- the continuing airworthiness management exposition (CAME) for CAMOs under Part-CAMO;
- the FAA supplement for organisations holding an FAA certificate under the EU–US MAG, and the repair station and quality control manuals for FAA Part 145;
- the information security management manual (ISMM) under Part-IS;
- capability lists, forms registers and procedures manuals referred to by the MOE.
Conclusion
An MOE that matches the organisation is the fastest route through an authority review and the best protection at every oversight visit. ASG writes and reviews expositions around the organisation’s real facilities, scope and procedures, using the structure inspectors expect.
Frequently asked questions
The MOE is required by 145.A.70 for Part-145 maintenance organisations. The CAME is the exposition required for continuing airworthiness management organisations under Part-CAMO. An organisation holding both approvals keeps both documents, and they must be consistent.
The structure in AMC1 145.A.70(a), as applied in EASA’s MOE User Guide UG.CAO.00024. Following it makes EASA’s review faster.
Yes. Since 2 December 2022 the management system under 145.A.200, including safety risk management and compliance monitoring, must be described in the MOE, usually in Part 3.
Changes affecting the approval certificate, the accountable manager, nominated persons, facilities or the scope of work need prior approval under 145.A.85. Other changes can follow an approved procedure for changes not requiring prior approval.
Yes. A pre-submission review checks the MOE against Part-145, the AMC and GM and, where relevant, UG.CAO.00024, and identifies gaps the authority is likely to raise.
Key takeaways
- The MOE content is set by 145.A.70 and its structure by AMC1 145.A.70(a)
- Foreign Part-145 organisations follow EASA's MOE User Guide UG.CAO.00024
- The MOE must describe the management system, SMS and, since 2026, information security
- Changes listed in 145.A.85 need prior approval
- Each procedure should name an owner and the record it produces
Need an MOE written or reviewed?
Send us your current MOE or describe your scope of work. ASG will review it against Part-145 and propose the work needed for approval.