AMC1 ORO.GEN.200(a)(6) Management system

• ED Decision 2019/019/R found in: Air Operations (965/2012) Part-ARO Part-ORO Part-CAT Part-SPA Part-NCC Part-NCO Part-SPO (Feb 2025)
• ED Decision 2025/020/R found in: Air Operations Revision 24 Part-ARO Part-ORO Part-CAT Part-SPA Part-NCC Part-NCO Part-SPO (Mar 2026)

AMC1 ORO.GEN.200(a)(6) Management system ED Decision 2019/019/R COMPLIANCE MONITORING — GENERAL (a) Compliance monitoring The implementation and use of a compliance monitoring function should enable the operator to monitor compliance with the relevant requirements of this Annex and other applicable Annexes. (1) The operator should specify the basic structure of the compliance monitoring function applicable to the activities conducted. (2) The compliance monitoring function should be structured according to the size of the operator and the complexity of the activities to be monitored. (b) Organisations should monitor compliance with the procedures they have designed to ensure safe activities. In doing so, they should as a minimum, and where appropriate, monitor compliance with the following: (1) privileges of the operator; (2) manuals, logs, and records; (3) training standards; (4) management system procedures and manuals; (5) activities of the organisation carried out under the supervision of the nominated persons in accordance with [ORO.GEN.210(b)](#_DxCrossRefBm927677538); and (6) any outsourced activities in accordance with [ORO.GEN.205](#_DxCrossRefBm927677803), for compliance with the contract. (c) Organisational set up (1) To ensure that the operator continues to meet the requirements of this Part and other applicable Parts, the accountable manager should designate a compliance monitoring manager. The role of the compliance monitoring manager is to ensure that the activities of the operator are monitored for compliance with the applicable regulatory requirements, and any additional requirements as established by the operator, and that these activities are carried out properly under the supervision of the relevant head of functional area. (2) The compliance monitoring manager should be responsible for ensuring that the compliance monitoring programme is properly implemented, maintained and continually reviewed and improved. (3) The compliance monitoring manager should: (i) have direct access to the accountable manager; (ii) not be one of the other persons referred to in [ORO.GEN.210(b)](#_DxCrossRefBm927677538); (iii) be able to demonstrate relevant knowledge, background and appropriate experience related to the activities of the operator, including knowledge and experience in compliance monitoring; and (iv) have access to all parts of the operator, and as necessary, any contracted operator. (4) In the case of a non-complex operator, this task may be exercised by the accountable manager provided he/she has demonstrated having the related competence as defined in (c)(3)(iii). (5) In the case the same person acts as compliance monitoring manager and as safety manager, the accountable manager, with regards to his/her direct accountability for safety, should ensure that sufficient resources are allocated to both functions, taking into account the size of the operator and the nature and complexity of its activities. (6) The independence of the compliance monitoring function should be established by ensuring that audits and inspections are carried out by personnel not responsible for the function, procedure or products being audited. (7) If more than one person is designated for the compliance monitoring function, the accountable manager should identify the person who acts as the unique focal point (i.e. the 'compliance monitoring manager'). (d) Compliance monitoring documentation (1) Relevant documentation should include the relevant part(s) of the operator’s management system documentation. (2) In addition, relevant documentation should also include the following: (i) terminology; (ii) specified activity standards; (iii) a description of the operator; (iv) the allocation of duties and responsibilities; (v) procedures to ensure regulatory compliance; (vi) the compliance monitoring programme, reflecting: (A) schedule of the monitoring programme; (B) audit procedures including an audit plan that is implemented, maintained, and continually reviewed and improved; (C) reporting procedures; (D) follow-up and corrective action procedures; and (E) recording system. (vii) the training syllabus referred to in (e)(2); (viii) document control. (e) Training (1) Correct and thorough training is essential to optimise compliance in every operator. In order to achieve significant outcome of such training, the operator should ensure that all personnel understand the objectives as laid down in the operator’s management system documentation. (2) Those responsible for managing the compliance monitoring function should receive training on this task. Such training should cover the requirements of compliance monitoring, manuals and procedures related to the task, audit techniques, reporting and recording. (3) Time should be provided to train all personnel involved in compliance management and for briefing the remainder of the personnel. (4) The allocation of time and resources should be governed by the volume and complexity of the activities concerned. AMC1 ORO.GEN.200(a)(6) Management system ED Decision 2019/019/R COMPLIANCE MONITORING — GENERAL (a) Compliance monitoring The implementation and use of a compliance monitoring function should enable the operator to monitor compliance with the relevant requirements of this Annex and other applicable Annexes. (1) The operator should specify the basic structure of the compliance monitoring function applicable to the activities conducted. (2) The compliance monitoring function should be structured according to the size of the operator and the complexity of the activities to be monitored. (b) Organisations should monitor compliance with the procedures they have designed to ensure safe activities. In doing so, they should as a minimum, and where appropriate, monitor compliance with the following: (1) privileges of the operator; (2) manuals, logs, and records; (3) training standards; (4) management system procedures and manuals; (5) activities of the organisation carried out under the supervision of the nominated persons in accordance with [ORO.GEN.210(b)](#_DxCrossRefBm318085174); and (6) any outsourced activities in accordance with [ORO.GEN.205](#_DxCrossRefBm318085433), for compliance with the contract. (c) Organisational set up (1) To ensure that the operator continues to meet the requirements of this Part and other applicable Parts, the accountable manager should designate a compliance monitoring manager. The role of the compliance monitoring manager is to ensure that the activities of the operator are monitored for compliance with the applicable regulatory requirements, and any additional requirements as established by the operator, and that these activities are carried out properly under the supervision of the relevant head of functional area. (2) The compliance monitoring manager should be responsible for ensuring that the compliance monitoring programme is properly implemented, maintained and continually reviewed and improved. (3) The compliance monitoring manager should: (i) have direct access to the accountable manager; (ii) not be one of the other persons referred to in [ORO.GEN.210(b)](#_DxCrossRefBm318085174); (iii) be able to demonstrate relevant knowledge, background and appropriate experience related to the activities of the operator, including knowledge and experience in compliance monitoring; and (iv) have access to all parts of the operator, and as necessary, any contracted operator. (4) In the case of a non-complex operator, this task may be exercised by the accountable manager provided he/she has demonstrated having the related competence as defined in (c)(3)(iii). (5) In the case the same person acts as compliance monitoring manager and as safety manager, the accountable manager, with regards to his/her direct accountability for safety, should ensure that sufficient resources are allocated to both functions, taking into account the size of the operator and the nature and complexity of its activities. (6) The independence of the compliance monitoring function should be established by ensuring that audits and inspections are carried out by personnel not responsible for the function, procedure or products being audited. (7) If more than one person is designated for the compliance monitoring function, the accountable manager should identify the person who acts as the unique focal point (i.e. the 'compliance monitoring manager'). (d) Compliance monitoring documentation (1) Relevant documentation should include the relevant part(s) of the operator’s management system documentation. (2) In addition, relevant documentation should also include the following: (i) terminology; (ii) specified activity standards; (iii) a description of the operator; (iv) the allocation of duties and responsibilities; (v) procedures to ensure regulatory compliance; (vi) the compliance monitoring programme, reflecting: (A) schedule of the monitoring programme; (B) audit procedures including an audit plan that is implemented, maintained, and continually reviewed and improved; (C) reporting procedures; (D) follow-up and corrective action procedures; and (E) recording system. (vii) the training syllabus referred to in (e)(2); (viii) document control. (e) Training (1) Correct and thorough training is essential to optimise compliance in every operator. In order to achieve significant outcome of such training, the operator should ensure that all personnel understand the objectives as laid down in the operator’s management system documentation. (2) Those responsible for managing the compliance monitoring function should receive training on this task. Such training should cover the requirements of compliance monitoring, manuals and procedures related to the task, audit techniques, reporting and recording. (3) Time should be provided to train all personnel involved in compliance management and for briefing the remainder of the personnel. (4) The allocation of time and resources should be governed by the volume and complexity of the activities concerned. ##### AMC1 ORO.GEN.200(a)(6) Management system *ED Decision 2025/020/R* **COMPLIANCE MONITORING — GENERAL** (a) Compliance monitoring The implementation and use of a compliance monitoring function should enable the operator to monitor compliance with the relevant requirements of this Annex and other applicable Annexes. (1) The operator should specify the basic structure of the compliance monitoring function applicable to the activities conducted. (2) The compliance monitoring function should be structured according to the size of the operator and the complexity of the activities to be monitored. (b) Organisations should monitor compliance with the procedures they have designed to ensure safe activities. In doing so, they should as a minimum, and where appropriate, monitor compliance with the following: (1) privileges of the operator; (2) manuals, logs, and records; (3) training standards; (4) management system procedures and manuals; *[applicable until 31 December 2027 — ED Decision 2019/019/R]* (4) management system procedures and manuals, including procedures applicable to the flight data monitoring programme, when such a programme is required; *[applicable from 1 January 2028 — ED Decision 2025/020/R]* (5) activities of the organisation carried out under the supervision of the nominated persons in accordance with [ORO.GEN.210(b)](#_DxCrossRefBm523087047); and (6) any outsourced activities in accordance with [ORO.GEN.205](#_DxCrossRefBm523087322), for compliance with the contract. (c) Organisational set up (1) To ensure that the operator continues to meet the requirements of this Part and other applicable Parts, the accountable manager should designate a compliance monitoring manager. The role of the compliance monitoring manager is to ensure that the activities of the operator are monitored for compliance with the applicable regulatory requirements, and any additional requirements as established by the operator, and that these activities are carried out properly under the supervision of the relevant head of functional area. (2) The compliance monitoring manager should be responsible for ensuring that the compliance monitoring programme is properly implemented, maintained and continually reviewed and improved. (3) The compliance monitoring manager should: (i) have direct access to the accountable manager; (ii) not be one of the other persons referred to in [ORO.GEN.210(b)](#_DxCrossRefBm523087047); (iii) be able to demonstrate relevant knowledge, background and appropriate experience related to the activities of the operator, including knowledge and experience in compliance monitoring; and (iv) have access to all parts of the operator, and as necessary, any contracted operator. (4) In the case of a non-complex operator, this task may be exercised by the accountable manager provided he/she has demonstrated having the related competence as defined in (c)(3)(iii). (5) In the case the same person acts as compliance monitoring manager and as safety manager, the accountable manager, with regards to his/her direct accountability for safety, should ensure that sufficient resources are allocated to both functions, taking into account the size of the operator and the nature and complexity of its activities. (6) The independence of the compliance monitoring function should be established by ensuring that audits and inspections are carried out by personnel not responsible for the function, procedure or products being audited. (7) If more than one person is designated for the compliance monitoring function, the accountable manager should identify the person who acts as the unique focal point (i.e. the 'compliance monitoring manager'). (d) Compliance monitoring documentation (1) Relevant documentation should include the relevant part(s) of the operator’s management system documentation. (2) In addition, relevant documentation should also include the following: (i) terminology; (ii) specified activity standards; (iii) a description of the operator; (iv) the allocation of duties and responsibilities; (v) procedures to ensure regulatory compliance; (vi) the compliance monitoring programme, reflecting: (A) schedule of the monitoring programme; (B) audit procedures including an audit plan that is implemented, maintained, and continually reviewed and improved; (C) reporting procedures; (D) follow-up and corrective action procedures; and (E) recording system. (vii) the training syllabus referred to in (e)(2); (viii) document control. (e) Training (1) Correct and thorough training is essential to optimise compliance in every operator. In order to achieve significant outcome of such training, the operator should ensure that all personnel understand the objectives as laid down in the operator’s management system documentation. (2) Those responsible for managing the compliance monitoring function should receive training on this task. Such training should cover the requirements of compliance monitoring, manuals and procedures related to the task, audit techniques, reporting and recording. (3) Time should be provided to train all personnel involved in compliance management and for briefing the remainder of the personnel. (4) The allocation of time and resources should be governed by the volume and complexity of the activities concerned.