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147.A.85 requires the organisation to notify the competent authority of any planned changes that affect the terms of its approval, and to obtain prior approval for changes before they are implemented.
What it means in practice
Any change that could affect the organisation's compliance with Part 147 must be notified to the competent authority. Changes that directly affect the terms of approval, such as changes to the accountable manager, training locations, approved course scope, or key personnel, require prior approval from the competent authority before implementation. Other changes must be notified so the competent authority can assess whether they affect compliance.
The organisation must have an internal process for identifying, assessing, and managing changes. This should include evaluating the regulatory impact of each change and determining whether prior approval or notification is required.
Key requirements
Changes requiring prior approval must not be implemented until the competent authority has granted approval. The MTOE must be updated to reflect all changes. The organisation must submit proposed amendments to the competent authority in a timely manner and maintain records of all changes and their regulatory notifications.
Common compliance gaps
A frequent finding is organisations implementing changes before obtaining competent authority approval, particularly changes to key personnel or training locations. Another common gap is failing to update the MTOE after changes are approved, leaving the exposition out of alignment with current operations.
Part 147 Training
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Sofema's Part 147 course covers regulatory requirements for training organisations — from approval terms and syllabus standards to examination and record-keeping.
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