Mandatory Occurrence Report (MOR)

Regulation (EU) 376/2014 of the European Parliament and of the Council, which entered into force on 15 November 2015 and replaced the earlier Directive 2003/42/EC, establishes the mandatory occurrence reporting framework for EU Member States and for organizations in those States holding approvals issued under EASA's regulatory framework. Article 4(1) requires that "relevant persons" — defined in Article 2(7) to include pilots, engineers, maintenance technicians, air traffic controllers, airport operators, and persons engaged in the design, manufacture, or maintenance of aircraft — report occurrences that fall within the categories defined in Annex I (air operations), Annex II (ATM/ANS), Annex III (aerodromes), Annex IV (design and manufacture), and Annex V (maintenance). The list of specific reportable occurrence types within each Annex is further specified in Implementing Regulation (EU) 2015/1018, which replaced Commission Regulation (EU) No 1321/2007. For flight schools and ATOs, the most operationally relevant categories are in Annex I (aircraft operations), which includes events such as controlled flight toward terrain, runway incursions, ACAS/TCAS resolution advisories, bird strikes causing structural damage, smoke or fire on board, fuel emergencies, and any event that required emergency procedures.

The reporting timeline is specified in Article 4(5) of Regulation (EU) 376/2014: reports must be submitted "as soon as possible and in any case within 72 hours of becoming aware of the occurrence." This is the key statutory deadline. If an initial report is filed within 72 hours and subsequent investigation reveals additional facts, a supplementary report must follow within 30 days. Under Article 4(6), organizations (as opposed to individuals) that receive an internal occurrence report that meets the Annex criteria must also submit to the competent authority — organizations therefore have a dual obligation: collect internal reports and transmit qualifying ones externally. Under Article 6, Member States must make the national reporting system available electronically, and all national reports feed into the European Central Repository (ECR), which is operationally maintained by EASA through the ECCAIRS 2 (European Co-ordination Center for Accident and Incident Reporting Systems) database. ECCAIRS 2 uses the ADREP taxonomy (Aircraft Accident and Incident Data Reporting, aligned with ICAO Doc 9156) for occurrence classification.

The analysis obligation is equally important and equally enforceable. Article 13 of Regulation (EU) 376/2014 requires that organizations that collect occurrence reports must analyze them to identify safety hazards, assess risks, and determine necessary corrective or preventive actions. This analysis obligation is not satisfied by filing the MOR and closing the record — the regulator expects evidence that the filed occurrence was analyzed, that a hazard was either identified or ruled out, and that any identified hazard was entered into the SMS safety risk management process. EASA AMC1 ORO.GEN.200(a)(3) specifically links occurrence reporting to the hazard identification and risk assessment cycle, making the MOR the entry point for the Safety Risk Management (SRM) loop rather than a standalone administrative act.

In parallel, EASA also operates a voluntary occurrence reporting framework alongside the mandatory system. Article 5 of Regulation (EU) 376/2014 requires Member States to establish voluntary reporting systems that capture safety information not covered by the mandatory categories. Voluntary reports receive the same just-culture protections under Article 16 as mandatory reports — the key practical difference is that voluntary reports are not subject to the 72-hour deadline and cover a broader range of safety observations that do not meet the Annex I–V mandatory threshold but are nonetheless safety-relevant (e.g., observed non-compliance, equipment condition concerns, fatigue observations).

In the United States, the structure is bifurcated across multiple regulatory bodies and rule sets. The NTSB requires notification — not a full written report — of aircraft accidents and serious incidents under 49 CFR Part 830. Part 830.5 specifies the events requiring immediate notification (accidents, flight control failures, in-flight fire, mid-air collisions, damage to property exceeding $25,000, and a specific list of serious injuries), and Part 830.15 requires a written report within 10 days for accidents and for certain serious incidents involving turbine-powered aircraft. Part 830 does not cover the full range of occurrences covered by EU 376/2014 Annexes I–V — its scope is narrower, focused primarily on accidents and a subset of serious incidents. FAA Service Difficulty Reports (SDRs) under 14 CFR §21.3 (design approval holders), §145.221 (repair stations), and §43.9(d) capture maintenance-related findings; the FAA Malfunction or Defect Report (MDR/SDR) system receives approximately 30,000–40,000 reports annually. For Part 141 flight schools specifically, there is no dedicated MOR equivalent in US federal regulations — the primary reporting obligation is the NTSB Part 830 accident/incident notification, supplemented by any voluntary reporting through the Aviation Safety Hotline or ASAP programs where applicable.

The most consequential failure mode in MOR compliance for flight schools and ATOs is systematic under-reporting driven by a combination of poor just-culture implementation and inadequate occurrence recognition training. Instructors and students frequently do not know which events qualify as reportable under Annex I of Regulation (EU) 376/2014 — for instance, many do not recognize that a TCAS/ACAS Resolution Advisory (RA), even if no evasive action was required, is categorically mandatory to report under Annex I item 1.6. A missed RA report that is later identified during a competent authority audit creates both a compliance finding and a retroactive analysis burden. EASA's Safety Information Bulletins and NPA 2022-01 (on occurrence reporting quality) have repeatedly noted that under-reporting — particularly of Annex I flight-phase events — remains materially prevalent at smaller operators and training organizations.

A second critical failure is the late-filing pattern: organizations that receive an internal report, conduct an informal investigation, and only then file the MOR — by which point the 72-hour window has often passed. The 72-hour clock runs from when any responsible person in the organization "becomes aware" of the occurrence (Article 4(5)), not from when the internal safety investigation is complete. Many organizations incorrectly interpret this as permission to delay filing until they have something substantive to say in the report, rather than filing an initial report within 72 hours and supplementing it within 30 days. EASA and competent authorities treat late filing as a standalone compliance finding even if the eventual report is complete and accurate. For combined ATO/AOC operators, scope ambiguity adds a third failure mode: an event occurring during a training flight on an AOC-operated aircraft may be unclear as to whether it is an ATO obligation, an AOC obligation, or both — and in the absence of a documented procedure, neither entity files.

Aviatize's safety management module implements MOR obligation tracking as a structured workflow rather than a policy reminder. When any occurrence report is submitted through the platform — whether by a pilot, instructor, student, or maintenance technician — the system immediately timestamps the submission and begins the 72-hour MOR assessment clock. The safety manager is presented with an Annex I–V category cross-reference tool that maps the reported event description against the EASA 2015/1018 Implementing Regulation category list; the system flags events that match one or more mandatory categories and generates a draft MOR notification with the required data fields (occurrence date/time, location, aircraft registration, occurrence category, brief description, reporter identity) pre-populated from the occurrence report. The safety manager confirms or overrides the category assessment, and the platform records the classification decision with timestamp and rationale — preserving the audit trail that the competent authority will examine. If the 72-hour window is approaching without a filing decision, the platform escalates an alert to both the safety manager and the accountable manager.

The compliance and auditing module maintains a live MOR registry showing: all occurrences assessed for MOR obligation, the assessment outcome (reportable/not reportable), the filing date versus the 72-hour deadline, and whether the mandatory 30-day supplementary report has been completed. This registry is the primary evidence artifact for SMS audits — auditors can compare the MOR registry against the occurrence report log to verify that no reportable events have been missed or filed late. For combined ATO/AOC operations, the platform enforces scope tagging on every occurrence report, resolving the ambiguity about which certificate holder bears the filing obligation. Voluntary occurrence reports that do not meet the mandatory threshold are tracked in the same interface under a separate classification, feeding the hazard identification pipeline without triggering the 72-hour MOR workflow.