Training Organisations - Continuing Airworthiness


In light of the implementation of Regulation (EU) No 2019/1383, amending Continuing Airworthiness Regulation (EU) No 1321/2014, clarification of whether training organizations under the oversight of ICETRA are to be considered commercial or non-commercial is needed. In accordance with the amending regulation, Commercial ATOs and DTOs are required to be approved as a CAMO or as a CAO for the management of the continuing airworthiness of its aircraft in accordance with Part-CAMO or Part-CAO, or contract such an organisation, and ensure that all maintenance is performed by maintenance organisations with Part-M, Part-145 or Part-CAO approval.

For the evaluation ICETRA will apply a criteria of the amount of students attending LAPL/PPL/CPL courses at the training organisation and the organisation’s marketing operation.

Training organisations that these conditions apply to (one or both) are to be considered commercial:

  • Each calendar year the training organisation has 11 students or more attending LAPL/PPL/CPL courses.
  • The training organisation is involved in promotion of its courses, e.g. through social media or other forms.

Commercial Approved Training Organisations that currently do not fulfil the airworthiness requirements that apply to them have until the end of the year 2021 to amend the management of their aircraft. The same requirements will apply to DTOs with the implementation of the amending regulation, they are therefore encouraged to take action immediately.

The regulation requirement in question is ML.A.201(e). Please see the Regulation as it has been implemented in EU member states here.