If you manage quality for an EASA Part 147 maintenance training organisation, audits are a fact of life. Your national aviation authority (NAA) will conduct regular surveillance audits — typically annually — and your organisation must demonstrate ongoing compliance across every area of your approval.
This article provides a structured checklist of what NAA inspectors typically examine, based on the requirements of EASA Part 147 and associated Acceptable Means of Compliance (AMC). Use it as a preparation tool before your next audit — and as a benchmark for your internal quality system.
1. Maintenance Training Organisation Exposition (MTOE)
The MTOE is the foundation document of your Part 147 approval. Inspectors will verify that it is current and accurately reflects your operations.
- Current revision status — does the MTOE reflect the latest approved amendments?
- Organisational structure — does the documented structure match reality? Are all key personnel (Accountable Manager, Quality Manager, Head of Training) correctly identified?
- Scope of approval — does the MTOE accurately describe the courses you deliver (basic, type, continuation)?
- Training procedures — are the documented procedures for enrolment, examination, attendance, and certification consistent with what actually happens?
- Amendment control — is there a clear process for MTOE amendments, including NAA notification where required?
2. Training Records and Student Files
This is where most findings occur. Inspectors will typically sample several student files and cross-check them for completeness and consistency.
- Entry qualifications — is there evidence that each student met the prerequisites for their training programme?
- Enrolment documentation — are enrolment dates, assigned courses, and track information recorded?
- Training progress — can you demonstrate each student's progress through the syllabus?
- Examination results — are all exam scores recorded per module, with dates and pass/fail status?
- Attendance records — do attendance logs match the training schedule? Are minimum attendance thresholds documented and enforced?
- Practical assessment records — are workshop skill assessments (P1–P9) signed off by qualified assessors?
- Record retention — are records retained for the regulatory minimum period (typically 10 years)?
Key risk: The most common audit finding is inconsistency between different record sources — for example, an attendance spreadsheet showing different dates than the training schedule, or exam results in one file contradicting a certificate in another.
3. Examination System and Question Banks
Your examination system must demonstrate fairness, security, and compliance with the Part 66 syllabus.
- Question bank coverage — does the question bank cover all required Part 66 modules at the appropriate knowledge levels?
- Question review cycle — is there evidence that questions are periodically reviewed, updated, and retired?
- Exam assembly rules — are exams assembled according to documented rules that ensure balanced syllabus coverage?
- Security — how are question banks secured? Who has access? Is there a process for managing compromised questions?
- Re-sit procedures — are re-examination procedures documented and followed consistently?
- Pass mark criteria — is the pass mark clearly defined and consistently applied?
4. Instructor and Examiner Qualifications
Every instructor and examiner must be qualified and current. Inspectors will check personnel records.
- Instructor qualifications — does each instructor hold the required licence, experience, and pedagogical training?
- Examiner authorisation — are examiners formally authorised, and is their authorisation current?
- Continuation training — have instructors completed required continuation training within the defined intervals?
- Records of competency assessments — is there evidence that instructor competency is periodically assessed?
5. Facilities and Equipment
- Classroom adequacy — do classrooms meet the documented specifications in the MTOE?
- Workshop facilities — are practical training facilities equipped as described in the approval?
- Training aids — are aircraft components, tooling, and training aids maintained and current?
- IT systems — if online examinations or digital training delivery is used, is the system documented in the MTOE?
6. Certificate of Recognition (CoR) and EASA Form 148
- CoR issuance process — is there a documented checklist or validation step before a CoR is issued?
- Form 148 compliance — do issued certificates match the EASA Form 148 format requirements?
- Certificate registry — is every issued certificate logged with a unique reference number?
- Prerequisite verification — can you demonstrate that all prerequisites (exams, attendance, practicals) were met before each certificate was issued?
7. Quality System and Internal Audits
Your internal quality system is your first line of defence. Inspectors will review it closely.
- Audit schedule — is there a documented internal audit programme covering all areas of the MTOE?
- Audit reports — are internal audit findings documented with severity classification?
- Corrective actions — have findings been addressed with documented corrective actions and follow-up verification?
- Management review — is there evidence that quality findings are reviewed at management level?
- Occurrence reporting — is there a process for reporting and investigating training-related occurrences?
How Software Eliminates the Most Common Findings
The pattern in most Part 147 audit findings is the same: information is scattered across multiple systems — spreadsheets for attendance, email for exam distribution, paper forms for practical assessments, and manual certificate generation. When an inspector cross-checks these sources, inconsistencies appear.
Purpose-built Part 147 software like AMTOS addresses this by maintaining a single source of truth for every training record. When attendance is recorded, it feeds the same database as the exam results and the CoR prerequisites. There is no opportunity for records to diverge, because there is only one record.
| Common Finding | Root Cause | How AMTOS Prevents It |
|---|---|---|
| Inconsistent attendance records | Multiple spreadsheets, manual entry | Single digital attendance system with automatic threshold enforcement |
| Missing exam documentation | Paper exams, manual grading | Online exams with automatic grading and record creation |
| Invalid CoR issued | Manual prerequisite checking | Automated prerequisite validation before CoR generation |
| Outdated question bank | No review tracking | Question bank with module tagging, review dates, and version control |
| Incomplete student files | Data in multiple locations | Centralised student profile with all records in one place |