Sept. 8, 2025
All U.S.-based Part 145 repair stations with European Union Aviation Safety Agency (EASA) approval are required to develop and implement a safety management system (SMS), due to a recently revised special condition in an aviation bilateral safety agreement between the FAA and EASA.
The special condition, described in Maintenance Annex Guidance (MAG) Change 10, requires these repair stations to update their EASA Supplement by Oct. 10, 2025, with full SMS integration by Dec. 31, 2025. Updated FAA InFO SMS Requirement for Repair Stations Located in the U.S. Seeking or Holding EASA Part 145 Certification under the E.U.-U.S. BASA 24007 provides additional details.
Amanda Ferraro, CEO of Aviation Safety Solutions, explained the two deadlines, saying if a repair station does not have an SMS fully implemented by Oct. 10, it should update its EASA supplement by that date to include a statement of intent to implement an SMS by Dec. 31. Then by Dec. 31, the repair station must submit a declaration of compliance, indicating the SMS is in place.
Ferraro is concerned many repair stations are not ready for compliance.
“Simply rebranding another company’s SMS manual or chapter is a mistake. The FAA relies on the manual to conduct oversight, and the policies and procedures written in it. Operators will be held accountable to the FAA for what they document,” she said.
Kent Stauffer, chief safety officer at Flexjet, also has concerns about whether affected repair stations will be prepared.
“If you’re just now starting, you’re behind,” said Stauffer. “Off-the-shelf solutions are a good start, but I fear that people will try to use them as is, not recognizing that they must be developed to be specific for your operation.”
In addition to consultants who specialize in SMS implementation, Stauffer said there are industry safety professionals who are willing to help and suggests repair stations who need assistance look for and reach out to those people.
Stauffer noted there are differences in EASA and FAA SMS regulations, starting with the fact 14 CFR Part 5 doesn’t include an SMS requirement for repair stations.
“If you have a voluntary SMS through the FAA, technically you should be okay,” said Stauffer.
He added that the statement of intent and declaration of compliance are only the first two stages. It is still unclear how EASA will verify compliance and oversee repair stations’ SMS program going forward.
Ferraro added a few more words of caution: “The declaration of compliance statement is a legal document submitted to the FAA, certifying that the operator’s FAA Part 5 SMS is fully in place.
“If repair stations have not started implementation, it’s critical that they begin now. It usually takes six to 12 months to implement,” she said.
International Business Aviation Council Ltd.