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145.A.200, introduced by Regulation (EU) 2021/1963, requires the organisation to establish, implement, and maintain a management system with clearly defined accountabilities, a safety policy, hazard identification and safety risk management, compliance monitoring, and safety promotion — integrating safety management and the former quality system into a single framework.
What it means in practice
145.A.200 is the backbone clause of the modern Part 145 organisation. Under 145.A.200(a), the organisation must establish, implement, and maintain a management system that includes: clearly defined lines of responsibility and accountability throughout the organisation, including the direct safety accountability of the accountable manager; a safety policy and related safety objectives established and promoted by the accountable manager under 145.A.30(a); the identification of aviation safety hazards entailed by the organisation's activities, their evaluation, and the management of the associated risks, including actions to mitigate risk and verify their effectiveness; personnel trained and competent for their tasks; documentation of all management-system key processes; a compliance monitoring function to verify that the organisation complies with Part 145 requirements, with feedback of findings to the accountable manager; and any additional requirements prescribed in the regulation.
The management system must correspond 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. Where the organisation holds other organisation certificates within the scope of Regulation (EU) 2018/1139, the management system may be integrated with the systems required by those other certificates.
Internal safety reporting and contracting
145.A.202 requires the organisation to establish an internal safety reporting scheme as part of the management system: it must enable the collection and evaluation of occurrences, errors, and hazards reported internally, ensure analysis and follow-up, protect reporters consistent with just culture principles, and feed the resulting information into the safety risk management process. The scheme works alongside the external occurrence-reporting obligations of 145.A.60 and Regulation (EU) No 376/2014.
145.A.205 requires that maintenance and specialised services that are contracted or subcontracted are covered by the organisation's management system. Subcontracted work performed under the organisation's approval must remain under its full control — and a base maintenance check of an aircraft, or a complete engine or engine-module overhaul, may not be subcontracted to an organisation that is not itself appropriately approved.
Transition and integration
Regulation (EU) 2021/1963 moved the safety policy and quality system requirements from the former 145.A.65 into 145.A.200–145.A.205, aligning Part 145 with the management-system structure already used in Part-CAMO (CAMO.A.200) and Part-ORO (ORO.GEN.200), and with ICAO Annex 19. Organisations were required to complete the transition to the integrated management system within the transition period set by that regulation.
From 22 February 2026, organisations approved under Part 145 also fall within the scope of the Part-IS information security requirements of Regulation (EU) 2023/203: information security risks with a potential impact on aviation safety must be identified and managed through an information security management system (ISMS) that interfaces with the 145.A.200 management system.
Common compliance gaps
Typical findings include hazard registers that exist but do not drive decisions, compliance monitoring that lost independence in the merger of quality and safety functions, safety objectives that are not measured, and internal reporting schemes that staff do not trust or use. A just culture policy that is contradicted by actual disciplinary practice remains one of the fastest ways to render the whole management system ineffective in the eyes of both staff and the competent authority.
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