The UK CAA Part-145 SMS deadline is 1 July 2026. Organisations not compliant face approval revocation. Here is exactly what AMOs must do before the deadline.
EASA Part-IS compliance is now mandatory. Learn what airlines, MROs, CAMOs, and ATOs must demonstrate after the February 2026 deadline.
EASA Part-IS | Information Security in Aviation Safety
The 22 February 2026 compliance deadline for EASA Part-IS has now passed. For air operators, Part-145 maintenance organisations, CAMOs, and Approved Training Organisations operating under EASA oversight, information security is now a legally mandated aviation safety requirement. National Aviation Authorities are initiating their first specialised cyber-audit cycles. Organisations that cannot demonstrate an operational Information Security Management System (ISMS) face significant regulatory exposure.
On 22 February 2026, the applicability date under Commission Implementing Regulation (EU) 2023/203 took effect. For the vast majority of EASA-regulated organisations — air operators, Part-145 maintenance organisations, Continuing Airworthiness Management Organisations (CAMOs), Approved Training Organisations (ATOs), aeromedical centres, and Flight Simulation Training Device (FSTD) operators — this date marked a legal obligation, not a recommended practice. EASA Part-IS compliance is now mandatory.
This is not a gradual transition. The regulatory framework under Part-IS — composed of Delegated Regulation (EU) 2022/1645 and Implementing Regulation (EU) 2023/203 — represents a structural shift in how the European Union treats cybersecurity in aviation. Information security risks that could impact aviation safety are now formally subject to the same management rigour as operational safety risks. They must be identified, assessed, mitigated, monitored, and reported — through a documented system that regulators can inspect and audit.
This aligns with the core principle underpinning our work at Aero Support Group’s Safety Management System consulting: cybersecurity is not an IT department problem. It is a safety governance issue that sits squarely within the remit of Accountable Managers, Safety Managers, and Quality Assurance teams. And now, it is a regulatory compliance issue with audit consequences.
EASA Part-IS is built on two regulatory pillars. Delegated Regulation (EU) 2022/1645 established the overarching framework for managing information security risks with potential safety impact. Implementing Regulation (EU) 2023/203 translates this into detailed, operational requirements applicable to the wider aviation population.
At its core, Part-IS requires organisations to establish, implement, and maintain an Information Security Management System (ISMS) that is proportionate to their size, complexity, and risk profile. While the standard is broadly aligned with ISO/IEC 27001, EASA has introduced aviation-specific provisions that go beyond conventional IT security frameworks — particularly around the interface between information security and flight safety.
EASA’s Easy Access Rules for Information Security (December 2025 revision) consolidate EU 2022/1645 and EU 2023/203 along with AMC & GM. Three ED Decisions in 2025 — 2025/013/R, 2025/014/R, and 2025/015/R — updated the AMC & GM for Part-IS, providing detailed acceptable means of compliance. These documents define what “compliant” looks like in practice and are essential reading for every organisation preparing for a cyber-audit.
EASA structured Part-IS implementation in two waves. The first applicability date of 16 October 2025 targeted design and production organisations (Part-21 DOA/POA), aerodrome operators, and apron management service providers. The second — and most widely impactful — wave took effect on 22 February 2026.
The following organisations became subject to Part-IS on 22 February 2026:
EASA recognises that full ISMS maturity is a progressive journey. To manage this, the regulator introduced the PSOE model — a four-stage maturity framework:
By 22 February 2026, organisations were required to achieve at least the Present and Suitable levels. An additional 18-month transition period — running through approximately August 2027 — provides time to achieve Operational and Effective maturity. However, this is not a licence for inaction: National Aviation Authorities are already initiating their first cyber-audit cycles.
The post-deadline period is not a quiet one. National Aviation Authorities across Europe are now incorporating information security assessments into their standard oversight programmes. For Part-145 organisations and CAMOs in particular, the next scheduled surveillance audit may include specific cyber-resilience checks. Auditors will typically seek evidence in the following areas:
One of the most common gaps we anticipate in the coming audit cycle is the failure to integrate the ISMS with existing SMS and QMS structures. Part-IS explicitly envisions that information security management should be embedded within — not parallel to — the organisation’s existing Safety Management System and Quality Management System. Running three separate silos is not just operationally inefficient; it is a compliance gap.
Airlines must treat Part-IS as an extension of their SMS framework. Operational systems such as Electronic Flight Bags (EFBs), crew management platforms, aircraft health monitoring feeds, and ACARS data links all represent potential information security risk vectors with direct safety impact. The ISMS must map these assets and demonstrate proportionate controls. For airlines undergoing IOSA audit preparation, integrating Part-IS compliance into your IOSA SMS chapter is now a logical necessity.
For MROs, the critical information asset landscape includes maintenance management software (AMOS, Envision, TRAX), component traceability databases, digital task card systems, and supplier/customer data interfaces. Any breach, manipulation, or loss of availability in these systems carries a potential flight safety consequence — which is precisely why EASA has brought them within the regulatory compliance perimeter. EASA Part-145 organisations must ensure their ISMS is integrated with their MOE and Maintenance Organisation quality framework.
CAMOs manage the airworthiness of fleets through continuous data — MEL tracking, AMP data, component life monitoring, and AD compliance records. Cybersecurity failures in CAMO environments can lead to inaccurate airworthiness decisions, which have direct safety implications. Part-IS requires CAMOs to assess these risks formally and document their mitigations within their ISMS.
ATOs must consider the security of training record management systems, simulator data integrity, and the safety impact of data manipulation on licence and rating management. While the risk profile may differ from an MRO, the regulatory obligation under Part-IS is identical.
Part-IS does not exist in a regulatory vacuum. Organisations holding or pursuing IATA Operational Safety Audit (IOSA) registration will note that the IOSA Standards Manual increasingly incorporates information security considerations within its safety management chapter. A robust ISMS contributes directly to IOSA compliance maturity, and an IOSA-registered airline that cannot demonstrate Part-IS compliance faces an inconsistency that auditors will note.
ICAO Annex 19, 3rd Edition — the international standard for Safety Management Systems — now explicitly acknowledges information security as a component of the broader safety risk environment. Organisations building or enhancing their SMS under Annex 19 should ensure that their hazard identification and risk assessment processes extend to information security threats and vulnerabilities. This is a key area of focus within the ICAO USOAP framework, where State-level SMS effectiveness increasingly encompasses cybersecurity governance.
For Third Country Operators seeking or holding EASA TCO authorisation, Part-IS compliance adds a new dimension to the compliance matrix. While TCO authorisation is primarily assessed against safety oversight standards, the increasing integration of Part-IS into EASA’s oversight framework means that TCO holders and their national oversight authorities will face growing scrutiny of cybersecurity governance.
UK-based operators and approved organisations should note that the UK CAA has published its own regulatory framework aligned with the principles of EU Part-IS. UK organisations are not exempt from equivalent information security obligations and should verify their current compliance position with their National Aviation Authority. For ground handling providers, ISAGO-registered organisations should also review how Part-IS principles intersect with their ground operations safety and quality management frameworks.
EASA Part-IS is not a temporary regulatory exercise. It is a permanent expansion of the aviation safety framework — one that reflects the operational reality that the safety of modern aviation is increasingly dependent on the integrity, availability, and confidentiality of information systems.
The February 2026 deadline has passed. The question is no longer “Do we need to comply?” It is “How well can we demonstrate our compliance when the auditor arrives?” Organisations that treat Part-IS as a documentation exercise will fail that test. Organisations that embed information security governance into their operational safety culture will not only pass — they will be better positioned to manage the cyber risks that increasingly threaten aviation integrity.
At Aero Support Group, we work with airlines, MROs, CAMOs, and training organisations to build compliance systems that are operational, auditable, and sustainable. Part-IS compliance is not a standalone project — it is part of a broader safety and quality governance architecture that we help organisations design, implement, and defend.
Aero Support Group provides specialist Part-IS gap assessments, ISMM development, ISMS integration with SMS/QMS, and implementation support for aviation organisations across all regulatory frameworks.
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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