Part-ORA is the regulation that defines how an Approved Training Organisation must operate under EASA. If you are the Head of Training (HoT) or accountable manager of an ATO, you answer for it when the auditor walks in. We built this checklist from working with ATO heads of training across Europe in 2025-2026.
It is a working operational checklist, meant to be used alongside ORA itself.
The five areas an inspector examines
- Management system (ORA.GEN.200)
- Personnel (ORA.GEN.210, plus the ATO-specific requirements)
- Training programmes (ORA.ATO.130)
- Facilities, equipment and records (ORA.GEN.215 and ORA.GEN.220)
- Internal monitoring and reporting
For each one, below are the records you need to be able to produce on demand.
1. Management system
- A safety policy signed by the accountable manager, dated, and reviewed every year.
- Safety management documentation (an SMS manual or equivalent). The inspector will ask for the latest issue and its revision history.
- A compliance monitoring programme scheduled at least 12 months ahead, with past audits, findings and closure evidence filed and indexed.
- Evidence of a reporting culture: anonymous safety reports submitted, reviewed and followed up. Three or four real entries in the last 12 months is the practical minimum.
The finding we saw most in 2025 was SMS documentation that existed and was reviewed once a year, with no evidence it was used in operational decisions. Have the minutes of your safety meetings ready.
2. Personnel and instructor records
For every instructor (FI, CRI, IRI, TRI, SFI and so on), you need:
- a verified copy of the licence and ratings, with current validity dates
- a current Class 1 medical
- a current ICAO language proficiency rating
- standardisation records for the last 12 months
- recurrent training covering at least the last 36 months
- a dated authorisation issued by the ATO
- records of every course delivered, the students taught and their outcomes
In 2025-2026, inspectors typically sampled 3-5 instructors and checked their full records. If one fails, expect them to look at every instructor.
An ATO managing more than 20 instructors on paper or in spreadsheets is one resignation away from a compliance gap. Whatever tool you use, it should track every renewal date and produce the instructor file the auditor asks for on demand.
3. Training programmes (ORA.ATO.130)
The auditor looks hardest at the training programme, because it ties everything else together. For each approved course (PPL, CPL, IR, ATP, type rating), keep:
- the approved version of the syllabus, with the CAA approval letter and revision history
- lesson plans for each module
- briefing and debriefing standards, documented and applied the same way by every instructor
- student progress records for every flight, ground lesson and exam attempt, signed by instructor and student
- examiner reports, filed and cross-referenced with student records
- a modification procedure that says when a syllabus is updated, who approves the change and who signs the CAA notification
Syllabus version control produced an unusually high number of findings in 2025-2026. Several ATOs were running 2-3 versions of the same syllabus across their instructors, because version control lived in someone's Drive folder.
4. Facilities, equipment and records
- Aircraft and simulator logbooks that are current, signed and cross-referenced with maintenance records.
- Defined access controls for student, instructor and restricted areas.
- A document retention policy. Part-ORA requires student records to be kept for at least 3 years after completion, and some national CAAs require longer.
- Backup and disaster recovery. The regulation does not prescribe cloud or paper, but the inspector will ask what happens if the office burns down.
5. Internal monitoring
- A designated compliance monitoring manager, separate from the Head of Training where practicable.
- An audit programme that covers each operational area at least once every 24 months.
- A findings register, open and closed, with closure evidence.
- A management review at least once a year, with documented minutes.
Auditors most often rate this area "satisfactory but vague". If you can produce a 12-month audit calendar, the reports from the past 6 audits and the minutes of your last management review, you are ahead of most ATOs.
The three most common findings in 2025-2026 inspections
- Instructor records that expire unnoticed. The auditor finds an expired CRI rating before the HoT does. Severity: Major.
- Student progress records signed after the fact, when instructors back-fill the logbook a week or a month later. Severity: Major, and it often involves several instructors at once.
- Syllabus version drift. Instructor A teaches from v3.2, instructor B from v3.0, and the CAA only approved v3.2. Severity: Major if it affects students.
All three are lapses in operational discipline, and tracking records continuously prevents all three.
The 30-day pre-audit sprint
If your audit is 30 days away, work through this list:
- [ ] Run the instructor expiry report and renew anything due within 90 days.
- [ ] Pull a random sample of 10 students and check their progress records are current, signed and consistent across instructors.
- [ ] Confirm the syllabus version on file matches the one every instructor is using.
- [ ] Confirm the minutes of the last management review are filed and signed.
- [ ] Confirm the compliance monitoring schedule shows the 24-month audit cycle on track.
- [ ] Walk the facility as an inspector would. Are restricted areas signed? Are extinguishers in date? Is the student noticeboard current?
- [ ] Brief your instructors. They will be interviewed, and nervous instructors create findings.
How Veejo helps
Veejo does not manage ATO records. Where it can help a Head of Training is hiring: when an instructor leaves mid-season or you need extra TRI or SFI capacity, Veejo can shortlist verified pilots from a network of 2,000+, with licence, medical and English rating already checked.