Introduction

The Aviation Safety (Amendment) Regulation 2023, introduced by Statutory Instrument (SI) 2023 No. 588, amends UK Regulation (EU) No 1321/2014, specifically Annex II (Part 145)

This amendment introduces a formal and enforceable requirement for all UK Part 145-approved organisations to implement a Safety Management System (SMS) by 1 July 2026.

This regulatory step brings the UK Civil Aviation Authority (CAA) into alignment with global standards established by ICAO Annex 19, and moves it closer to the EASA model, which already mandates SMS as part of maintenance organisation approvals.

Scope and Applicability

This new requirement applies to all organisations currently holding a UK Part 145 approval. The requirement is a binding obligation.

• All approval holders must demonstrate by 1 July 2026 that they have implemented a compliant, functioning SMS that meets the regulatory expectations.

Regulatory Background and Transition from Guidance to Regulation

CAP 795 reflects the structure of ICAO Annex 19 and provides a detailed framework for implementing SMS across aviation domains, including maintenance.

With the enactment of SI 2023 No. 588, SMS is no longer a matter of best practice it is a regulatory obligation.

• The regulation mandates that all maintenance organisations develop and maintain a system that proactively identifies hazards, assesses risk, and assures safety performance.

• SMS must now be embedded into the organisation's management and operational structure, fully integrated into day-to-day activities, and overseen at the highest level of the company.

Key Requirements for SMS Implementation

Organisations are expected to establish and maintain an SMS that includes the following elements:

• Safety Policy and Objectives, led and endorsed by the accountable manager.

• Safety Risk Management, including processes for hazard identification, risk analysis, and mitigation.

• Safety Assurance, encompassing internal safety reporting, audits, monitoring of SPIs (safety performance indicators), and continuous improvement.

• Safety Promotion, including communication strategies, training programs, and reinforcement of a just culture.

These components should be tailored to the size, nature, and complexity of the organisation and the risks associated with its maintenance activities.

The SMS must also consider contracted or subcontracted work, and ensure that safety responsibilities are clearly defined, delegated, and monitored.

Implementation Planning and Gap Analysis

UK CAA recommends that all affected organisations begin the implementation process immediately.

• The first step is to conduct a comprehensive SMS gap analysis.

• This process involves assessing the current state of the organisation’s safety practices and comparing them against the requirements of the amended regulation.

Organisations should use the CAA's Phase 1 SMS Evaluation Tool, available through the CAA SMS portal, to benchmark their systems. Based on this analysis, organisations must prepare an SMS Implementation Plan detailing:

• The scope and objectives of implementation.

• Identified gaps and actions required.

• Assignment of roles and responsibilities.

• A step-by-step timeline leading up to 1 July 2026.

Documentation and Oversight Process

As part of compliance, organisations must document their SMS within their Maintenance Organisation Exposition (MOE). The SMS section of the MOE must describe the structure, policies, procedures, safety accountabilities, safety reporting systems, and performance monitoring methods. The MOE will be subject to review and approval by the UK CAA.

The CAA will conduct targeted oversight of SMS implementation as part of routine and scheduled audits. In the period leading up to 2026, CAA inspectors will engage with approval holders to evaluate progress and provide feedback. From 1 July 2026 onward, SMS will be a core element of Part 145 compliance verification.

Organisational Responsibilities and Cultural Expectations

The successful implementation of an SMS requires visible leadership and active engagement from senior management, particularly the Accountable Manager, who retains overall responsibility for safety within the organisation.

While the Safety Manager plays a key role in the day-to-day coordination of SMS activities, the effectiveness of the system depends on the engagement of all staff. This includes fostering a strong safety culture, underpinned by clear communication, trust, transparency, and a well-defined Just Culture policy.

A mature SMS is not just an administrative burden—it is an enabler of business resilience, operational efficiency, and improved risk visibility.

Strategic Considerations for Dual-Approved and Global Organisations

UK organisations that also hold EASA approvals or work with international clients will benefit from early alignment with EASA SMS standards, which have been mandatory since December 2022.

Aligning with both UK and EASA expectations ensures:

• Harmonised documentation.

• Interoperable systems.

• Reduced regulatory fragmentation and duplicated oversight.

These organisations are advised to harmonize their SMS implementation across both domains to ensure consistent performance and audit readiness.

Conclusion and Recommended Actions

The introduction of mandatory SMS requirements for UK Part 145 organisations represents a pivotal shift from reactive compliance toward a risk-based, proactive safety framework.

This change aligns the UK with international safety principles and reinforces the importance of safety as a core business function.