As with most of our blogs, this one was prompted by a question from one of our longstanding customers who, to paraphrase, said to us “hey, they want us to do our own recurrent evaluation”. Of course what they were actually being invited to do was participate in the EASA Extended Evaluation (EEP) Programme.
The existence of the EEP has been in the EASA regulations for some time (see ORA.FSTD.225 Duration and continued validity) but, in our experience, has not been extensively used. That seems to be changing and in 2025 EASA issued ‘AMC and GM to Part-ORA — Issue 1, Amendment 8’. It added considerably to the details of the Acceptable Means of Compliance (AMC) and Guidance Material (GM) for operators. The next amendment, ‘AMC and GM to Part-ORA — Issue 1, Amendment 9’, which is the amendment that incorporates the much heralded task-to-tool philosophy, has changes that further clarify the EEP. So it seems a good time to take a look at the programme, what it is and how it works.
So what is the EEP?
This derives from the regulations (ARA.FSTD.120 Continuation of an FSTD qualification item c) that allows the competent authority to extend the recurrent evaluation period from 12 months to up to 36 months. Whilst the onsite evaluations by the competent authority are extended, as we will see, the requirement for annual evaluations very much remains. Note however that does not extend to the competent authorities’ need to audit operators management systems, that remains at 12 months and if anything becomes more important.
Great, what do we have to do?
Well, first of all, you need “a person or group of persons” assigned to the task. In practice this will in most cases mean having technical persons, equivalent to a competent authority Technical Inspector (TI) and an equivalent to a Flight Inspector (FI). Within the person or persons you need the ability to analyse the QTG re-runs and to be able to assess the performance, handling and features of the device(s). That said the QTG reviewer needs to do more than a pass/fail assessment. Take the case where a test is failing and the TDM provides a rationale; it’s not good enough to just accept the rationale, the reviewer needs fully understand it and agree to it (just as the competent authority would have done).
For the FI role, whilst the person fulfilling the role doesn’t need to hold a type rating for the device(s) being assessed to be an assigned person, if they don’t have one, you need to supply someone in addition who is type rated or is a qualified Type Rating Instructor (TRI)/Type Rating Examiner (TRE) as well. All to say, you have to have competent people to do objective and subjective assessments. A further requirement is that the person(s) should have been involved in a competent authority initial or recurrent evaluation within the prior 36 months, the capacity of the involvement is not specified, but common sense says a bit more than making the tea. The last requirement for the assigned persons, albeit only guidance material (GM1 ORA.FSTD.225(b)) relates to their independence. Specifically they can’t have been the persons doing the QTG reruns and quality flyouts during the last 12 months.
After you’ve got the person or persons in place, what now? Well once approved, it brings us back to the initial comment from our customer, namely “hey, they want us to do our own recurrent evaluation”, you do indeed need to carry out your own evaluations! Very unusually ORA.FSTD.225 points you to ARA.FSTD.120(c) and ARA.FSTD.120(b)(1). Part.ARA are the instructions for competent authorities, national aviation authorities, falling under the EASA umbrella. As an aside, we quite regularly find ourselves urging operators to read Part.ARA as it is often ignored by them, the benefit being this tells you exactly what the competent authority will be looking for from you. However in this case it directs you to the instructions on how to carry out your internal re-qualification exercise. ORA.FSTD.225 tells you when, ARA.FSTD.120 tells you how.
Last but not least comes the documentation requirements in (AMC2 ORA.FSTD.225(b)). This defines the documentation you need to provide the competent authority prior to being granted EEP authorisation and then the documents the assigned persons need to supply, and when, on an ongoing basis. Our thoughts are that the best way to approach this is to produce an appendix to your existing organisation manuals covering EEP.
Regarding the ongoing documentation one of the misconceptions we have heard is that with an authorised EEP there is no need to produce the information dossier prior to a recurrent, that is still in place. It’s just that the initial reviewers change to your assigned persons. The other part of the documentation is the reporting to your competent authority, in essence you will be producing the same reports you always did plus the ones the competent authority would have done if they had carried out the recurrent evaluation and providing those to the competent authority. You will also need the record and monitor discrepancies exactly as they would have done. Finally Amendment 9, again albeit as guidance material, provides a report template, essentially the same as in Part.ARA, for reporting back.
Summary
So all in all, yes, they want our customer to do their own recurrent evaluation. For us the granting of an EEP is a vote of confidence in the maturity of an organisation’s compliance system, but it does come with some fairly onerous obligations and certainly cannot be viewed as an excuse to do nothing for three years. That said, for many of the organisations we know with outstanding compliance systems it shouldn’t prove a high bar to cross, they have QTG reviewers who regard a QTG review as more than a paperwork exercise and instructors diligent on their fly-outs. Of course at least one of our SIM OPS partners will tell you, and it’s hard to argue against it, every training session should be a fly-out!
One of the biggest hurdles we see is the independence of the assigned person; organisations will be loath to add expensive people to their payroll and there needs to be people waiting in the wings in case the assigned person leaves.
How can SIM OPS help?
Two members of the SIM OPS team have in the past been approved as EEP TIs and we have developed a training course specifically for EEP covering the principles of EEP, and to the TI and FI for their specific responsibilities. We also have an advanced QTG evaluation course. Contact us at training@sim-ops.com or direct to one of us.
