EASA Shifts Focus to SMS Performance for US Part 145 Repair Stations

With the December 31, 2025, deadline for implementing a Safety Management System (SMS) now passed, U.S.-based Part 145 repair stations holding approval from the European Union Aviation Safety Agency (EASA) are entering a new phase of regulatory oversight. The focus for both EASA and the Federal Aviation Administration (FAA) is shifting from confirming the existence of an SMS plan to evaluating its demonstrated effectiveness and performance in daily operations. This development in aviation safety management marks a critical transition towards a proactive and data-driven safety culture within the aircraft maintenance sector.

The requirement for an Aviation Safety Management System affects all FAA-certificated Part 145 repair stations that also perform maintenance on E.U.-registered aircraft under their EASA approval. This mandate stems from a revised special condition within the Bilateral Aviation Safety Agreement (BASA) between the United States and the European Union. The agreement's Maintenance Annex Guidance (MAG) details the procedures for mutual acceptance of maintenance organization approvals, streamlining regulatory burdens for facilities operating under both jurisdictions.

The Regulatory Framework and Deadlines

The path to this new phase of oversight was established through a series of key deadlines. According to regulatory guidance, including FAA Information for Operators (InFO) 24007, affected repair stations were first required to update their EASA Supplement by October 10, 2025, to declare their intent to implement an SMS. Following this, a formal declaration of compliance, confirming the SMS was fully in place, was due by the end of 2025. Now that these milestones have been met, regulators expect these systems to be mature and functional.

The underlying regulations, 14 CFR Part 145 in the U.S. and EASA Part 145 in Europe, provide the foundational standards for maintenance organizations. The SMS requirement, enforced through the BASA, aligns U.S. maintenance providers more closely with standards set by the International Civil Aviation Organization (ICAO) and EASA, which have long championed the SMS approach. This harmonization is a key trend in international aviation, aimed at creating a more consistent and high-level safety standard worldwide.

From Implementation to Performance

The current regulatory posture emphasizes that having a documented SMS is no longer sufficient. Aviation authorities are now focused on performance-based oversight. During audits and routine surveillance, inspectors will seek tangible evidence that the SMS is an integrated part of the organization's culture and decision-making processes. This includes verifying hazard identification, risk assessment, and safety assurance processes.

Amanda Ferraro, CEO of Aviation Safety Solutions and a member of the NBAA Safety Committee, advises organizations to be prepared for this heightened scrutiny. “Be ready to demonstrate clear, organized and current evidence of SMS implementation – not just intent,” Ferraro stated. “Organizations should be prepared to show how SMS is being implemented in practice, consistent with the documented processes and procedures. In other words, all SMS components should be review-ready for oversight by FAA or EASA authorities.”

This means maintenance facilities must maintain records demonstrating:

• Regular safety meetings and communications.
• A functional safety reporting system that encourages employee participation.
• Analysis of safety data to identify trends and emerging risks.
• Documentation of how identified risks are mitigated.
• Management review of safety performance and commitment to continuous improvement.

What Comes Next

For the foreseeable future, Part 145 repair stations with EASA approval can expect regulatory audits to include in-depth evaluations of their SMS performance. The official EASA guidance for U.S.-based organizations serves as a primary resource for compliance. Failure to demonstrate a functioning and effective SMS could jeopardize a repair station's EASA approval, restricting its ability to service aircraft registered in E.U. member states.

This performance-based approach represents a significant evolution in safety oversight. Instead of a simple compliance check, it requires a cultural shift within organizations, where safety is managed proactively rather than reactively. The success of this initiative will depend on the commitment of maintenance organizations to not only adopt the structure of an SMS but also to fully embrace its principles of continuous safety improvement.

Why This Matters

This regulatory shift solidifies the move toward a globally harmonized, proactive safety culture in aircraft maintenance. For U.S. repair stations, demonstrating a robust and effective SMS is now a critical component of maintaining access to the European market. The focus on performance over paperwork signals a maturation of safety management principles, ultimately enhancing continuing airworthiness and safety standards across the international aviation network.

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