Part-ORA (Organisation Requirements for Aircrew)

Part-ORA is Annex VII to the Aircrew Regulation, Commission Regulation (EU) No 1178/2011. It answers a different question from the licensing annex beside it: **Part-FCL** says what a pilot must do to hold a licence or rating; **Part-ORA** says what an organisation must be in order to train them towards one.

Its structure runs from general to specific.

**Subpart GEN** applies to every organisation in scope. It covers the application and the terms of approval, the **management system**, the **compliance monitoring** function, personnel requirements including the accountable manager and nominated persons, record-keeping, facility requirements, changes requiring prior approval, and continued validity of the approval.

**Subpart ATO** carries the requirements specific to Approved Training Organisations: the training programme, the training manual and operations manual, the requirements for a **Head of Training** and for the instructors and examiners, aircraft and flight simulation training device requirements, and the aerodrome or operating-site conditions.

**Subpart FSTD** covers the qualification of flight simulation training devices, and **Subpart AeMC** the aero-medical centres. Declared Training Organisations sit outside this annex, under **Part-DTO**, with a declaration rather than an approval and a correspondingly lighter organisational burden.

Two structural ideas do the most work.

The first is the **management system**: a single framework combining safety management, compliance monitoring and the documentation that describes both, with an accountable manager who carries final responsibility and nominated persons for defined areas. It is a standing obligation rather than a one-off approval exercise.

The second is **compliance monitoring** — an internal audit function, independent of the activity it audits, that checks the organisation is doing what its manuals say and that those manuals still satisfy the regulation. Findings are raised, classified and closed against a corrective action plan, and this is the machinery an authority inspects first.

The practical consequence for a school is that an approval is not a certificate you obtain and file. The manuals bind, changes to defined areas need prior approval, and the gap between documented and actual practice is the most common category of finding.

There is no FAA equivalent annex. The comparable obligations are distributed differently: 14 CFR Part 141 sets out certification, curricula and facility requirements for pilot schools, while Part 61 governs training and certification outside that structure.

For a school deciding between structures, Part-ORA is most of the cost difference between an ATO and a DTO. An ATO carries the management system, the compliance monitoring function, named postholders and an approved training manual; a DTO declares against a narrower scope. The right choice follows from which courses the school wants to run, not from which sounds more impressive.

The recurring failure is drift between manuals and practice. Procedures evolve, the manual does not, and an audit compares the two. This is not usually a safety failure — it is a documentation failure that reads as a governance failure, which is worse at inspection.

The second is treating compliance monitoring as an annual exercise. It is a continuous function with an independence requirement, and an audit programme that exists only in the weeks before an authority visit will look exactly like what it is.

Aviatize carries the compliance module a Part-ORA management system needs behind it: internal audits are performed and recorded in the system, and audit findings are tracked through to follow-up rather than living in a spreadsheet nobody owns. Safety occurrences are captured in a built-in, lightweight safety management system alongside them.

Document management is compatible with both EASA and FAA structures, with separate document libraries, staff approval of uploaded documents, and expiry tracking — which is what makes personnel qualification and student documentation evidenceable rather than reconstructed. Training records, syllabus progression and instructor grading sit on the same record as scheduling and billing, so the training evidence an inspector asks for reflects what was actually flown. The approval itself, the manuals and the nominated-person appointments remain the organisation's own.