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145.A.65, as replaced by Regulation (EU) 2021/1963, requires the organisation to establish maintenance procedures that ensure good maintenance practices and take human factors principles into account, covering all aspects of the maintenance activity including subcontracted specialised services. The safety policy and management-system requirements that older guidance associated with this clause now sit in 145.A.200.
What it means in practice
Under the current rule, 145.A.65 is about how maintenance is actually performed on the floor. The organisation must establish procedures, agreed by the competent authority through the MOE, that guarantee good maintenance practices and compliance with the applicable requirements of 145.A.25 to 145.A.95, so that aircraft and components can be released to service in a controlled, repeatable way.
These procedures must take human factors and human performance limitations into account: task design, shift and fatigue considerations, legible documentation, error-capturing steps, and clear handover practices are all part of compliant maintenance procedures, not optional refinements. The procedures must cover the full span of the maintenance activity, including the control of any subcontracted specialised services performed under the organisation's approval.
Where the safety policy and quality system went
Before Regulation (EU) 2021/1963, 145.A.65 carried the organisation's safety and quality policy and the independent quality system. Those requirements were not deleted — they were upgraded and relocated. The safety policy, hazard identification, safety risk management, compliance monitoring, and safety assurance requirements now live in 145.A.200 (Management system), supported by 145.A.202 (Internal safety reporting scheme) and 145.A.205 (Contracting and subcontracting).
Knowledge-base readers reviewing older MOEs should check that chapter references to '145.A.65 quality system' have been migrated: the compliance monitoring function and the integrated safety management system are now assessed against 145.A.200, while 145.A.65 is assessed against the adequacy of the maintenance procedures themselves.
Key requirements
The organisation must hold maintenance procedures covering all maintenance performed under the approval, keep them current through MOE control, and ensure they reflect human factors principles and good maintenance practice. Procedures must extend to subcontracted activity so that work performed by others under the organisation's approval meets the same standard as work performed in-house.
Common compliance gaps
The most common gap since the 2021 amendment is documentary: expositions and training material that still describe 145.A.65 as the safety policy and quality system clause. Auditors increasingly treat this as evidence that the organisation has not completed its transition to the integrated management system under 145.A.200. On the technical side, procedures that have not been reviewed against actual floor practice, or that ignore human factors in task and shift design, remain frequent findings.
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