The EASA ATO approval process
An organisation must be an ‘Approved Training Organisation’ (ATO) in order to provide training for the issue or renewal of European professional pilot’s licences (e.g. CPL, MPL, ATPL) and the associated ratings (e.g. IR and type ratings). For organisations that have their ‘principle place of business’ outside of the member states of the European Union the approval must be issued by EASA. EASA publishes a guide to applicants describing the process, but here is an overview of what you can expect if you make an ATO application to EASA:
The application starts by sending a completed application form to EASA together with evidence of the applicant’s legal status. Although EASA suggest that the operations and training manuals can also be sent at this stage it’s not a requirement. The application will be checked for eligibility, this does not include any ‘technical evaluation’, so would include things like confirming that EASA is the correct competent authority for the application.
Fees and charges
EASA will charge fees for processing an application and then for conducting continued oversight if the application is approved. The charges are established by European Regulation (Regulation 319/2014). The charges will be based on an hourly rate for the time spent on the project by EASA staff. The current hourly rate is €233 (April 2019). You can ask for an estimate of the likely cost at the time of application, but the actual cost may be different depending on how long it takes to deal with the application.
Fees will need to be paid in advance, so you will be asked to maintain a credit balance with EASA throughout the process. Any travelling time by the inspection team will be charged at the same rate (on top of the business-class air fare) and, of course, EASA will decide how many visits are necessary. For a medium sized ATO offering 20 different type-rating courses EASA might estimate 150 man-hours (meaning an application fee of €35,000), but the final fee charged may be very different if more time is required.
The best way to minimise the cost of the application process is to manage the project effectively and ensure that all submissions are fully compliant first time.
The ‘technical investigation’ is the process EASA uses to verify that your organisation complies with all the applicable requirements. This will either be conducted by EASA inspectors or may be subcontracted to a ‘service provider’, typically one of the European national aviation authorities. Before the start of the technical investigation you’ll need to submit a complete suite of manuals as well as a ‘compliance checklist’ showing how the organisation complies with every relevant aspect of the aircrew regulation (it’s a big checklist).
The technical investigation will involve a document review during which the inspectors will examine your organisation, operations and training manuals. They’ll also need to see the resumes of key management personnel and check that your instructors are suitably qualified. Once any non-conformities have been addressed there’ll be an on-site inspection.
Once the document review is complete EASA, or the ‘service provider’, will schedule an on-site inspection. During this inspection one or more inspectors will interview staff and managers, observe training, check records and examine processes to make sure that they are compliant with the regulation and with the submitted manuals. You should expect the inspectors to put particular emphasis on the management system including compliance monitoring and safety risk management. If training is to take place at more than one location the inspectors may need to visit the different training locations. An initial on-site inspection would typically take about one week.
Once the inspection is complete EASA will advise you of any non-compliances. These non-compliances will need to be corrected before the application can proceed, and there might need to be another on-site inspection to verify that the non-compliances have been corrected.
Issue of ATO certificate
When any non-compliances from the investigation have been corrected EASA will be in a position to issue a certificate. There will be some internal quality checks before this takes place, especially if the investigation was conducted by a ‘service provider’ rather than EASA itself.
At the same time as the approval certificate is issued EASA will send you an advance invoice for the fees for continued oversight. This will be based on the number of man-hours planned for audits and inspections in the coming year. EASA have the right to conduct unannounced as well as scheduled inspections, but since they always have to be paid in advance you shouldn’t expect any surprise visits!
EASA publications suggest that an ATO application could be completed in 7 months, but this excludes the time taken for initial ‘application management’ by EASA so 9 months should be considered an absolute minimum. Experience suggests that most applications take much longer than this.
The aircrew regulation requires each organisation to develop a management system “corresponding to the size of the organisation and the nature and complexity of its activities, taking into account the hazards and associated risks inherent in those activities”. The management system must be tailored to the organisation and there is no ‘one-size fits all’. Because of this there is very little value in buying a ‘generic operations manual’. At best the manual will provide a template for the section headings, but this is already available in AMC.
Many organisations applying for ATO approval using ‘generic’ manuals have found that the application process has taken much longer than they expected because of the number of rewrites required during the application process. If a manual doesn’t describe your organisation and your procedures then it’s useless. We recommend adapting your existing manuals and procedures rather than starting from scratch. Your personnel will have a lot of changes to assimilate without having to deal with completely new manuals as well.
If a consultant tries to sell you a manual that is ‘fully compliant with the regulation’ or ‘already approved by EASA’ then find a different consultant. It would be like me trying to sell you my shoes because they’re a great fit!
How to manage an ATO application
Applying for approval as a training organisation is a unique activity with a specific deliverable aimed at meeting a specific need. In management speak it is therefore a ‘project’ and should be managed as such, with a professional project manager, a robust change management methodology, a sensible timescale and a realistic budget.
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