You Need a CMM. You Cannot Afford a Full-Time One. Here Is the Solution.
If you are running a small Part-145 Maintenance Organisation, a newly approved CAMO, or an AOC holder still building your team, you already know the challenge. EASA regulations require you to have a competent, independent Compliance Monitoring Manager (CMM). This is not optional. It is written into the regulation — 145.A.200, CAMO.A.200, and ORO.GEN.200 are all explicit on this point.
But here is where the reality bites: hiring a qualified, experienced CMM on a full-time basis typically costs between €60,000 and €95,000 per year in salary alone — before employer contributions, benefits, office overhead, and training costs. For a start-up MRO working towards initial Part-145 approval, or a small CAMO managing a fleet of five to ten aircraft, that expense is simply not justifiable.
Many small organisations respond to this pressure in one of two ways. Some combine the CMM role with another post holder — often the Quality Manager or a Nominated Person — creating a conflict of interest that the regulation explicitly warns against. Others appoint someone internally who lacks the depth of regulatory knowledge the role actually demands, leaving the organisation exposed during NAA audits.
There is a third option. And it is the one that makes the most commercial and regulatory sense.
What Is a Fractional Compliance Monitoring Manager?
The fractional or part-time CMM model is straightforward: instead of hiring a full-time compliance professional, your organisation retains an experienced, qualified CMM on a structured monthly basis. They perform all the functions the regulation requires — audit planning, audit execution, finding management, corrective action follow-up, and management review reporting — but as a dedicated external resource rather than a salaried employee.
This is not subcontracting your compliance programme. It is not outsourcing responsibility. The CMM role carries personal accountability under EASA regulations, and a competent fractional CMM accepts and fulfils that accountability in full. What changes is the employment model, not the regulatory standard.
The fractional CMM works to an agreed scope of service each month: a fixed number of audit days, defined deliverables, and a direct reporting line to your Accountable Manager — exactly as the regulation requires.
What Does EASA Actually Say About This?
This is where it gets important, and where many organisations get confused.
EASA does not require the CMM to be a full-time employee. The regulation requires the function to be:
- Independent — the CMM cannot hold a position involved in the activities being audited;
- Competent — the person must demonstrate relevant knowledge, background, and experience;
- Properly resourced — the audit programme must be implemented, maintained, and continually reviewed;
None of these requirements mandate a full-time salaried post. In fact, AMC guidance for both Part-145 and Part-CAMO explicitly acknowledges that for smaller, non-complex organisations, the compliance monitoring function can be structured proportionately to the size and nature of the operation.
For very small organisations, the regulation even permits the Accountable Manager to fulfil the CMM function — provided they can demonstrate competency and there is no conflict of interest. This flexibility is deliberate. EASA understands that a five-person MRO should not face the same structural overhead as a Tier 1 MRO with 500 employees.
A fractional CMM sits neatly within this regulatory flexibility. Correctly documented in your MOE or CAME, with a clear Terms of Reference and a formally agreed audit programme, the arrangement is fully compliant and auditable.
The Real Cost Comparison
Let us run the numbers honestly.
Full-time CMM (in-house hire):
- Annual salary: €65,000–€90,000
- Employer social contributions (Malta / EU average ~20%): €13,000–€18,000
- Recruitment fee (typically 15–20% of first-year salary): €10,000–€18,000
- Ongoing training and regulatory update costs: €3,000–€5,000 per year
- Total Year 1 cost: €91,000–€131,000
Fractional CMM on monthly retainer:
- Structured monthly retainer covering audit programme delivery, findings management, and management reporting
- No recruitment cost, no social contributions, no redundancy liability
- Regulatory knowledge maintained and updated by the provider at no extra cost to you
- Typical annual cost: a fraction of the full-time equivalent — with no long-term employment commitment
For a start-up organisation in the first two to three years of operation — when cash flow is tight and the audit workload has not yet reached full-cycle maturity — this difference is transformative.
Who Benefits Most From This Model?
New Part-145 Applicants
The period between initial application and receiving your approval certificate is one of the most compliance-intensive phases any maintenance organisation will face. You need an audit programme drafted and documented in your MOE. You need evidence that your compliance function exists and is operational. You need someone who can speak with authority when the NAA comes knocking.
A fractional CMM brings exactly the experience needed to navigate this phase efficiently — without the cost of a permanent hire before your first CRS has been issued.
Small Existing Part-145 and CAMO Holders
If your organisation holds an approval and is operating — but your CMM function is being fulfilled by someone wearing three other hats — you are carrying regulatory risk every day. The next oversight audit will test the independence, competency, and documented output of your compliance function. If those elements cannot withstand scrutiny, your approval is at risk.
A fractional CMM steps in as a clean, independent, documented solution. They bring fresh eyes to your audit programme, identify systemic issues that internal staff often miss, and ensure your finding closure rates are demonstrably in order.
AOC Holders Without a Dedicated CMM
Airlines and commercial operators under ORO.GEN.200 face the same structural challenge. The compliance monitoring function is mandatory. For smaller AOC holders — charter operators, regional carriers, air taxi operators — maintaining a full-time CMM alongside all the other operational post holders is a significant overhead. The fractional model gives you a fully compliant compliance function at a cost that scales with your actual operational size.
What a Monthly Retainer Engagement Looks Like in Practice
A well-structured fractional CMM retainer is not a vague arrangement. It is a defined scope of work, delivered monthly, with clear outputs. Here is what a typical engagement covers:
Audit Programme Management Development and maintenance of an annual audit plan covering all areas required by your approval: production, contracted maintenance, procurement, training, subcontractors, and supporting functions. The plan is risk-based, documented, and aligned to your regulatory obligations.
Audit Execution Scheduled internal audits conducted against your MOE/CAME procedures and applicable EASA requirements. Findings documented with severity classification, root cause narrative, and corrective action requirements — in a format your Accountable Manager can present directly to the competent authority.
Finding and Corrective Action Follow-Up The audit loop is only complete when corrective actions are verified as closed. Monthly tracking of all open findings, follow-up communications with responsible post holders, and formal closure verification — all maintained in an auditable record.
Management Review Reporting A monthly compliance status report delivered to your Accountable Manager. This is the documented evidence that the feedback mechanism required by the regulation is functioning. It also serves as your primary tool for trend analysis and proactive risk identification.
Regulatory Watch EASA regulations change. AMC and GM updates, new NPA consultations, ED Decisions — keeping pace with regulatory development is a full-time task in itself. As your fractional CMM, AviaThrust monitors regulatory developments and flags any changes that affect your approval, your procedures, or your audit programme.
Why Independence Actually Improves With an External CMM
There is a counterintuitive truth here that experienced auditors know well: an external fractional CMM is often more independent than an internal one.
An in-house CMM, however well-intentioned, operates within an organisational culture. They know which post holders to avoid challenging. They understand the unspoken pressures around audit findings that might reflect badly on a colleague or manager. They have career considerations that can subtly influence how findings are classified and reported.
An external fractional CMM has none of those constraints. Their professional reputation depends on calling findings accurately, reporting them clearly, and following through without compromise. That independence is not just regulatory — it is structural and cultural.
For your Accountable Manager, this means receiving compliance reporting that genuinely reflects operational reality, rather than a filtered version of it.
How Aviathrust Delivers This Service
Aviathrust is a Malta-based aviation training and consultancy business specialising in EASA regulatory compliance. Our principal holds active credentials as an Aircraft Maintenance Auditor and Compliance Monitoring Manager, with hands-on experience across Part-145, Part-CAMO, and Part-M regulatory environments.
We do not offer generic compliance support. Every fractional CMM engagement is built around your specific approval scope, your MOE or CAME structure, and the operational realities of your organisation. We work remotely via Microsoft Teams as our primary delivery platform — reducing travel overhead for your organisation while maintaining the documentation rigour of an on-site function.
Our monthly retainer engagements are structured around a fixed scope of deliverables agreed at the outset. You know exactly what you are receiving each month, and you have a direct line to a qualified compliance professional whenever a regulatory question arises between scheduled audit cycles.
For organisations in the initial approval process, we also provide pre-approval compliance support — reviewing your MOE/CAME for regulatory alignment, supporting post holder preparation for NAA interviews, and ensuring your compliance monitoring framework is documented to the standard the competent authority expects.
The Questions to Ask Before Your Next NAA Audit
Before your next oversight visit, consider the following honestly:
- Can your CMM demonstrate independence from the activities they are auditing?
- Is your annual audit programme documented, current, and being executed as planned?
- Are your finding closure rates demonstrably compliant, with evidence of root cause analysis?
- Is your Accountable Manager receiving formal compliance status reports, documented and dated?
- Does your CMM have current, demonstrable knowledge of the applicable EASA regulations and their most recent amendments?
If any of those answers give you pause, the cost of addressing them now — through a structured fractional CMM arrangement — is a fraction of the cost of an NAA finding at Level 1, or worse, a suspension of activities.
A Conversation Worth Having
The fractional CMM model is not a workaround. It is a mature, commercially rational response to a genuine regulatory requirement — designed specifically for the operational scale of small and growing aviation organisations.
If your organisation holds a Part-145, Part-CAMO, or AOC approval — or is working towards one — and you need a compliance monitoring function that is independent, competent, and properly resourced, AviaThrust can deliver that on a monthly retainer basis.
