What Annex 19, 3rd Edition, changes in an airline SMS from 26 November 2026: applicability, interfaces, resources, safety performance and the new State SMS assessment.
Annex 19 Amendment 2 applies from 26 November 2026. The 11 SMS changes for service providers, who now needs an SMS, and what States will check.
EASA Part-IS compliance is now mandatory. Learn what airlines, MROs, CAMOs, and ATOs must demonstrate after the February 2026 deadline.
IOSA audit preparation has fundamentally changed with risk-based auditing and ISM Edition 18. Learn the 7 steps airlines must take now for IOSA renewal compliance in 2026.
IOSA AUDIT READINESS · By Ferhan Bugay, Executive Director, Aero Support Group FZCO · Updated 21 October 2026
Risk-based IOSA (RBI) is the audit model IATA moved to in 2024. The audit no longer gives every ISARP the same weight. IATA describes it as a scope “tailored for each airline”, combining a baseline of industry-wide standards with operator-specific elements.
The operator-specific part is driven by the airline’s operational profile (routes, fleet, complexity), its recent safety events and occurrence data, its IOSA history including repeat findings, and its regulatory environment. Two airlines audited in the same month can therefore face very different scopes. An airline with past findings in ground handling oversight should expect deeper sampling there; an operator flying into demanding aerodromes should expect more attention on FLT and DSP.
The practical consequence is that you need to know your own risk profile before the audit organisation does. Preparing every section to the same depth wastes effort and leaves the high-risk areas thin.
IATA states that maturity assessment criteria are now fully integrated into Edition 18 Rev 1. The other changes IATA lists, section by section, are:
The ORG upgrades are the ones most airlines feel first. What used to be advisory on compliance monitoring and SMS integration is now auditable, and a finding there tends to cascade into other disciplines.
Under the conventional model the auditor’s question was binary: conformity or finding. Under RBI the auditor also forms a view on how mature each safety-critical system is. An airline can conform to a standard and still receive a weak maturity rating, for example an SMS with documented processes but little evidence that hazard reports change anything, or a compliance monitoring programme that runs audits but does not close findings on time.
Preparation therefore has to reach operational evidence. Typical items auditors ask for are SPI trends with targets and the decisions taken on them, hazard register activity, SRB minutes with tracked follow-up, corrective action closure and effectiveness checks, competency assessment results, and examples of risk-based decisions in operational control.
IATA reports that the first 100-plus risk-based audits found on average twice as many non-conformities as conventional audits, while auditing fewer standards. Deeper sampling in the high-risk areas finds what the old broad-but-shallow audit missed.
Airlines that use their last IOSA result as a guide to readiness are likely to underestimate their exposure. The safety case for doing this well is clear in IATA’s 2025 Safety Report: IOSA-registered carriers had an accident rate of 0.98 per million sectors against 2.55 for non-IOSA carriers.
IATA has released ISM Edition 19. Under the IOSA Program Manual it applies to all audits conducted on or after 1 January 2027. The IAH Edition 19 tables already show the main operator changes: the DSP 4.2.3 parallel conformity option ends, the projected full conformance dates for ADT and ROAAS move to 31 December 2027 and 31 December 2028, CVR and DLR leave the active implementation list, and several security references move into new GRH 3.7 ISARPs. We cover these in IOSA ISM Edition 19: what airlines should do before 1 January 2027.
IOSA preparation in 2026 is about operational evidence. The risk-based model sends auditors to your weakest areas, the maturity assessment asks whether your systems work, and the ORG upgrades in Edition 18 Rev 1 make compliance monitoring and SMS integration auditable Standards. Airlines that start from their own risk profile and build their evidence around it go into the audit knowing where they stand. With Edition 19 effective on 1 January 2027, the time to plan the next delta review is now.
It is the work an airline does to test and strengthen its conformity with the IOSA Standards Manual before the audit. Under the risk-based model it covers the airline’s own risk profile, the maturity of its safety-critical systems and the evidence that those systems work.
ISM Edition 18 Rev 1 applies in 2026. Edition 19 applies to audits conducted on or after 1 January 2027, in line with the IOSA Program Manual.
Maturity assessment criteria are fully integrated. ORG 2.4.2 and ORG 3.4.1 became Standards, DSP 3.2.8C added a safety risk assessment at the flight planning stage, and there are changes in FLT, MNT, CAB, GRH, CGO and SEC. IATA notes that its published list is not exhaustive.
It is the auditor’s evaluation of how well an airline’s safety-critical systems function, beyond conformity with each ISARP. It looks at SMS performance, compliance monitoring, training effectiveness and operational control.
The scope combines baseline standards with operator-specific elements: operational profile, safety events and occurrence data, IOSA audit history and regulatory context.
EASA and the UK CAA look at an operator’s safety performance and oversight evidence when they assess a TCO application. IOSA registration and a strong audit record are useful supporting evidence, though they do not replace the TCO requirements.
Aero Support Group supports airlines from gap analysis and risk profile review to evidence development, mock audits and audit-day support. Our IOSA RADAR service keeps your conformance continuously current between audits.
Aero Support Group (ASG) is an aviation safety, quality and compliance consultancy with offices in Dubai and Istanbul and a branch office in London. It prepares airlines, MROs, ground handlers, airports and civil aviation authorities for IOSA and ISAGO audits, EASA and UK CAA Third Country Operator (TCO) authorisation, EASA and FAA Part-145 approval, and ICAO USOAP audits.
Its work also covers Part-CAMO, Part-M and Part-147, Part-IS information security, SMS, QMS and SeMS development, gap analyses, mock audits and corrective action plans, operations manuals and MOEs, emergency response and business continuity planning, DAQCP, IFQP, JIG and IDQP inspection preparation, ACC3, RA3 and KC3 cargo security validation, CEIV Pharma, and SAF and CORSIA compliance.
ASG has completed 1,000+ projects at 500+ airports in 100+ countries. Its consultants have also served as subject matter experts, auditors and advisors for ICAO, IATA Consulting, IATA audit pools (IOSA, ISAGO, IDQP, IFQP), PRISM, ARGUS International and RSM.
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