Paper examinations are slow to prepare, slow to mark and hard to secure. Printed papers get photographed, question sets drift into circulation, and every result has to be typed into a record by hand. It is no surprise that more and more Part-147 maintenance training organisations (MTOs) want to run their Part-66 basic examinations on a computer.
The good news: computer-based testing (CBT) is explicitly allowed. EASA's Acceptable Means of Compliance to 147.A.135 states that examinations may be computer- or hard-copy-based or a combination of both. The part that catches organisations out is that moving to CBT changes how you prepare, conduct, mark and record examinations, and those are procedures your competent authority has approved in your Maintenance Training Organisation Exposition (MTOE). So the question is not "is CBT allowed?" but "how do we get our authority to accept our new procedures?"
This guide walks through what the regulation requires, where CBT fits in the MTOE, a practical acceptance route, and what inspectors look for when they watch a computer-based sitting.
This is general guidance, not legal advice. Your National Aviation Authority (NAA) decides what it accepts, and interpretations differ between authorities. Talk to your inspector early.
What the regulation actually requires
Beyond confirming that computer-based examinations are acceptable, there is no CBT-specific rule. Computer-based examinations have to meet exactly the same requirements as paper ones. The relevant points are:
- 147.A.135 Examinations. Your examination staff must ensure the security of all questions. On a computer this means who can see the question bank, who can build a paper, and whether a candidate can copy, print or photograph what is on screen. The AMC adds that the questions for a particular examination are determined by the examiners.
- 147.A.140 Maintenance training organisation exposition. Your examination procedures must be described in the MTOE, and changes to them must be accepted by the authority.
- Part-66 Appendix II, the basic examination standard. Multiple-choice questions, a 75% pass mark, and the rules on retakes: a failed module may not be retaken for at least 90 days, or 30 days if a Part-147 organisation runs retraining tailored to the failed subjects, and after three consecutive failed attempts a 12-month waiting period applies. Your system has to enforce these, not just record them.
- Authority oversight. EASA confirms that the authority does not have to supply or approve your questions, but as part of its oversight it must sample check and review your question bank and your examination process. With CBT, expect that review to include the software.
It is also worth knowing where the rules are heading. EASA's review of Part-147 (rulemaking task RMT.0544, NPA 2023-10) was proposed specifically to eliminate or reduce fraud in maintenance licence examinations. Commentary on the proposal points to question randomisation and stricter control of remote invigilation. Check the current status with your authority, but plan as if these expectations are coming, because a CBT system that already meets them will not need a second approval round.
Where computer-based testing lands in your MTOE
In the standard MTOE layout (Appendix I to AMC 147.A.140), examinations are covered by a group of sections in Part 2. There is no separate "CBT" chapter: each existing section has to describe how the computer-based process works.
| MTOE section | What to describe for CBT |
|---|---|
| 2.9 Organisation of examinations | Who schedules sittings, who builds papers, who may invigilate, and how the system enforces those roles. |
| 2.10 Security and preparation of examination material | Access to the question bank, question approval before use, how papers are assembled to cover the syllabus, and how exposure of questions is limited across sittings and resits. |
| 2.11 Preparation of examination rooms | Terminal set-up and control, seating, what candidates may bring, and how the room is checked before a sitting. |
| 2.12 Conduct of examinations | Identity checks, the invigilator's start authorisation, what happens if a candidate leaves the exam window, and the procedure for a crash, power cut or network failure. |
| 2.14 Marking and record of examinations | Automatic marking, any manual review, how results are released, and how a result is protected from later alteration. |
| 2.15 Storage of examination records | Where records and papers are held, for how long, backup, and how an inspector can retrieve a candidate's complete sitting. |
| 2.16 Examinations at locations not listed in 1.6 | Only if you will examine elsewhere: how the same controls are applied off site. |
Section numbering can differ slightly in your own exposition. What matters is that every one of these topics is covered.
A practical route to acceptance
1. Talk to your inspector before you buy or build
Explain what you intend to do and ask what your authority expects to see. Some NAAs have their own guidance or checklists for electronic examinations. Finding that out first saves a second amendment.
2. Amend the MTOE
Rewrite the Part 2 examination sections above so that they describe the computer-based process as it will actually run. Be specific. "Exams are conducted on computer" will not be accepted; "the invigilator verifies each candidate's identity against photo ID and authorises the start in the system; the candidate cannot open the paper before this" will.
3. Prepare a supporting dossier
Give the authority the evidence behind the words. A useful dossier covers:
- a description of the system and where the data is held;
- user roles and who can do what, especially who can see or edit questions;
- how papers are generated to cover the Part-66 syllabus, and how repeated exposure of questions is limited;
- identity verification and invigilation;
- what the system does to stop candidates reaching other material during the sitting;
- failure and contingency procedures, and how interruptions are logged;
- how marking works and how results and records are protected and retained;
- evidence that the system was tested: that it cannot be manipulated and that it records timing and results accurately.
4. Run a demonstration sitting
Invite the inspector to watch a realistic sitting on test data: check-in, start authorisation, an interruption and resume, submission, marking, and retrieving the record afterwards. Seeing the whole chain is far more convincing than reading about it.
5. Go live in a controlled way
Start with one module or one cohort, review the first sittings with your quality manager, and keep the evidence. Your first internal audit after go-live should include the CBT process.
What inspectors look for in a computer-based sitting
The CBT sitting checklist
Common mistakes
- Using a general learning platform's quiz tool as an exam system. Quizzes are built for learning. They rarely enforce invigilator start, retake rules or tamper-proof records.
- Reusing the same paper for resits. This is exactly the "question farming" the Part-147 review is aimed at.
- No written contingency procedure. Sooner or later a terminal fails mid-sitting. If the MTOE does not say what happens next, the sitting is in doubt.
- The instructor invigilating their own module without the authority having accepted that arrangement.
- No evidence the software was tested. "The vendor says it works" is not a validation.
How AMTOS supports this
AMTOS was designed around the Part-147 examination chain. Papers are assembled from exam blueprints against an approved Part-66 question bank, and repeat attempts draw on separate question sets. Candidates check in by webcam against their profile photo, and the invigilator can be required to approve every start. Leaving the exam window is detected and logged, answers are saved continuously so a failed terminal can resume, and every resume, time extension and override is recorded with who made it and when. Before a sitting can begin, AMTOS checks attendance minimums and the Part-66 retake rules: the 90-day interval, the 30-day interval after tailored retraining, and the 12-month waiting period after three consecutive failed attempts.
AMTOS customers also receive a CBT compliance guide and MTOE annex material to support their submission. We are happy to walk you through it in a meeting.
Quick answers
Does EASA Part-147 allow computer-based examinations?
Yes. AMC 147.A.135 states that examinations may be computer- or hard-copy-based or a combination of both. What matters is that your examination procedures are described in the MTOE, accepted by your competent authority, and still meet 147.A.135 and the Part-66 Appendix II examination standard.
Do I need NAA acceptance before running exams on a computer?
Yes. Changing how examinations are prepared, conducted, marked or recorded changes procedures in your MTOE, so the amended exposition must be accepted by your competent authority before credit-granting examinations are run on the new system.
Which MTOE sections change when you move to computer-based testing?
In the standard MTOE layout the examination sections are 2.9 Organisation of examinations, 2.10 Security and preparation of examination material, 2.11 Preparation of examination rooms, 2.12 Conduct of examinations, 2.14 Marking and record of examinations, 2.15 Storage of examination records and 2.16 Examinations at locations not listed in 1.6. Each needs to describe the computer-based process.
How long must a student wait after failing a Part-66 module?
At least 90 days, or 30 days if a Part-147 organisation runs retraining tailored to the failed subjects. After three consecutive failed attempts, a 12-month waiting period applies.
Sources
- EASA, AMC and GM to Part-147 (ED Decision 2015/029/R: AMC 147.A.135, MTOE layout)
- EASA, Part-147 FAQs (question bank oversight)
- EASA, NPA 2023-10: Review of Part-147 (RMT.0544)
- Regulation (EU) No 1321/2014, AMC 147.A.140 Appendix I, Maintenance training organisation exposition (as published in the UK CAA regulatory library)
- Regulation (EU) No 1321/2014, Annex III (Part-66) Appendix II, Basic examination standard