Part-ORA is the regulation that defines how an Approved Training Organisation must operate under EASA. If you're a Head of Training (HoT) or accountable manager at an ATO, the buck stops with you when the auditor walks in. This is the checklist we've assembled from working with ATO heads of training across Europe in 2025-2026.
It is not a substitute for reading ORA itself — it is a working operational checklist.
The five pillars
Part-ORA breaks into five operational areas the inspector will examine:
- Management system (ORA.GEN.200)
- Personnel (ORA.GEN.210 + ATO-specific)
- Training programmes (ORA.ATO.130)
- Facilities, equipment, records (ORA.GEN.220)
- Internal monitoring and reporting
We'll walk each one and flag the records you need to produce on demand.
1. Management system
- Safety policy signed by the accountable manager, dated, and reviewed annually.
- Safety management documentation (SMS manual or equivalent) — the inspector will ask for the latest issue and revision history.
- Compliance monitoring programme with a schedule covering at least 12 months ahead. Past audits, findings, and closure evidence must be filed and indexed.
- Reporting culture evidence — anonymous safety reports submitted, reviewed, and outcomes communicated. Three or four real entries in the last 12 months is the practical minimum.
The single most common 2025 finding: SMS documentation is present but reviewed only annually, with no evidence of *active* use in operational decisions. Have minutes from safety meetings ready.
2. Personnel and instructor records
For every instructor (FI, CRI, IRI, TRI, SFI, etc.):
- Licence and ratings — verified copy, current validity dates
- Class 1 medical — current
- ICAO Language Proficiency rating — current
- Standardisation records (last 12 months)
- Instructor recurrent training (last 36 months at minimum)
- Authorisation issued by the ATO, dated
- Records of all courses delivered + students taught + outcomes
Inspector practice in 2025-2026: random sample of 3-5 instructors, full record check. If one fails, expect a deep dive on all instructors.
Practical tooling note: any ATO managing more than 20 instructors on paper or in spreadsheets is one resignation away from a compliance gap. The Veejo platform tracks every renewal date and produces the auditor-ready PDF on request.
3. Training programmes (ORA.ATO.130)
The training programme is the document the auditor scrutinises hardest because it ties everything else together.
For each approved course (PPL, CPL, IR, ATP, type rating):
- Approved version of the syllabus on file — including the approval letter from the CAA and revision history
- Lesson plans for each module
- Briefing and debriefing standards documented and consistent across instructors
- Student progress records — every flight, every ground lesson, every exam attempt, signed by instructor and student
- Examiner reports filed and cross-referenced with student records
- Modifications procedure — when do you update a syllabus? Who approves? Who signs the CAA notification?
The 2025-2026 finding rate on syllabus version control was unusually high. Multiple ATOs were running 2-3 different versions of the same syllabus across instructors because version control lived in someone's Drive folder.
4. Facilities, equipment, records
- Aircraft and simulator logbooks — current, signed, cross-referenced with maintenance records
- Facility access controls — student / instructor / restricted areas defined
- Document retention policy — Part-ORA requires student records held for at least 3 years post-completion (some national CAAs require longer)
- Backup and disaster recovery — the regulation does not specify cloud vs paper but the inspector will ask what happens if the office burns down
5. Internal monitoring
- Compliance monitoring manager designated, distinct from the Head of Training where practicable
- Audit programme covering each operational area at least once every 24 months
- Findings register — open, closed, with closure evidence
- Management review — at least once a year, documented minutes
This is the area auditors most often find "satisfactory but vague." If you can produce a 12-month audit calendar, the past 6 audits' reports, and minutes from the last management review meeting, you're above 80% of ATOs in our network.
The three most common findings in 2025-2026 inspections
From the audit summaries shared in the Veejo Flight Schools community:
- Instructor record expiry caught at audit, not by the ATO. The auditor finds an expired CRI rating before the HoT does. Severity: Major.
- Student progress records signed retroactively. Instructors back-fill the logbook a week or a month later. Severity: Major. Often catches multiple instructors at once.
- Syllabus version drift. Instructor A uses syllabus v3.2, instructor B uses v3.0. CAA only approved v3.2. Severity: Major if the impact reaches students.
All three are operational discipline failures, not training quality failures. They are also all addressable by a single change: continuous tracking instead of periodic catch-up.
The pre-audit 30-day sprint
If your audit window is 30 days out, work this list:
- [ ] Run instructor expiry report. Renew anything within the next 90 days.
- [ ] Pull random sample of 10 students. Verify progress records are current, signed, and consistent across instructors.
- [ ] Confirm the syllabus version on file matches the version every instructor is using.
- [ ] Confirm last management review minutes are filed and signed.
- [ ] Confirm the compliance monitoring schedule shows the 24-month audit cycle is on track.
- [ ] Walk the facility with an inspector's eye. Are restricted areas signed? Are extinguishers in date? Is the student noticeboard current?
- [ ] Brief instructors. They will be interviewed; nervous instructors create findings.
How Veejo helps
The Veejo ATO platform was built with former civil-aviation auditors. The three audit-killer features:
- Instructor compliance radar — every renewal date tracked, alerts at 90 / 30 / 14 days
- Student progress timeline — flight + ground records visible to instructor, student, and HoT
- Regulation watch — when an EASA regulation changes, the affected sections of your manuals are flagged automatically
Heads of Training tell us pre-audit prep is the single biggest time sink in the role — typically measured in weeks. Keeping records audit-ready continuously, instead of reconstructing them before each visit, is where most of that time comes back.