Contracted Services Across Aviation Sectors

Comparing ORGH.MGM.205, Part-145.A.205, and CAMO.A.205

EU Regulations 2025/20, 1321/2014 (2021/1963)

Three Regulations, One Common Principle

Whether you're managing ground handling, maintenance, or continuing airworthiness,
the fundamental requirement is the same: Manage the risks of contracted activities

ORGH.MGM.205

Ground Handling

EU Regulation 2025/20

  • Applies to ground handling organizations
  • Distinguishes: certified vs non-certified providers
  • GH org responsible for non-certified provider safety
  • Must risk-assess ALL contracted services in own SMS
  • Authority must have access to providers
145.A.205

Maintenance

EU Reg 1321/2014 (2021/1963)

  • Applies to approved maintenance organizations
  • Distinguishes: contracting vs subcontracting
  • Subcontractors work under Part-145 org approval
  • Part-145 org responsible for all subcontracted work
  • Must manage hazards and monitor compliance
CAMO.A.205

Continuing Airworthiness

EU Regulation 1321/2014

  • Applies to CAMO organizations
  • Can contract maintenance OR subcontract CAM tasks
  • Subcontractors work under CAMO approval
  • CAMO remains accountable for subcontracted tasks
  • Authority must have access to subcontractors

🔑 Key Commonalities:

  • ✓ All activities must conform to applicable requirements
  • ✓ Aviation safety hazards must be managed in the organization's management system
  • ✓ The primary organization retains responsibility/accountability
  • ✓ Competent authority access to contracted/subcontracted organizations required
  • ✓ Hazard identification, risk management, and compliance monitoring are mandatory

Side-by-Side Regulation Comparison

Aspect ORGH.MGM.205
Ground Handling		 145.A.205
Maintenance		 CAMO.A.205
Airworthiness
Regulation Source EU 2025/20 EU 1321/2014
(amended 2021/1963)		 EU 1321/2014
Key Distinction Certified vs Non-Certified Providers Contracting vs Subcontracting Contracting Maintenance vs Subcontracting CAM Tasks
Conformity Requirement ✓ Services/products must comply with applicable requirements ✓ Maintenance must conform to applicable requirements ✓ Activities must conform to applicable requirements
Hazard Management ✓ Safety hazards risk-assessed in own management system ✓ Safety hazards considered as part of management system ✓ Safety hazards considered as part of management system
Who Works Under Whose Approval? Non-certified: N/A (GH org manages)
Certified: Under own approval		 Subcontracting: Under Part-145 org approval
Contracting: Under own approval		 Subcontracting CAM: Under CAMO approval
Contracting Maintenance: Under Part-145 approval
Primary Responsibility Non-certified: GH org
Certified: Provider (but GH org still assesses)		 Subcontracting: Part-145 org
Contracting: Contracted Part-145 org		 Subcontracting: CAMO
Contracting: Contracted Part-145 org
Authority Access ✓ Competent authority must be enabled access to provider ✓ Implied through compliance monitoring requirements ✓ Competent authority must be given access to subcontracted org
Documentation ✓ Contract must be documented ✓ Implied (good practice) ✓ Implied (good practice)
SMS Integration ✓ Risk assessment in own SMS (all cases) ✓ Hazard ID and risk mgmt (145.A.200(a)(3)) ✓ Hazard ID and risk mgmt (CAMO.A.200(a)(3))
Compliance Monitoring ✓ Required (best practice - AMC1) ✓ Required (145.A.200(a)(6)) ✓ Required (CAMO.A.200(a)(6))
Occurrence Reporting ✓ Reporting system required (ORGH.GEN.160) ✓ Interfaces and communication channels required ✓ Interfaces and communication channels required

🎯 Critical Insight

All three regulations share the same core philosophy: The primary organization cannot outsource accountability. Whether you call it "contracting," "subcontracting," or working with "certified/non-certified" providers, you must always manage the safety risks within your own management system and ensure compliance.

ORGH.MGM.205 - Ground Handling (EU 2025/20)

Core Question: Is the Provider Certified?

Ground handling organizations must determine if service providers are certified, approved, authorised, or have declared under EU 2018/1139. This determines responsibility.

Point (a) - Non-Certified Providers

Services/products NOT certified, approved, authorised, or declared under EU 2018/1139:

  • GH org SHALL apply safety management process to manage risk BEFORE contracting
  • YOU are responsible for safety
  • Examples: IT, cleaning, catering, office equipment, facility maintenance

Point (b) - Certified Providers

Services/products that ARE certified, approved, authorised, or declared:

  • Provider SHALL be responsible for safety
  • Must comply with EU aviation regulations applicable to them
  • Must meet Annex I or II requirements
  • Examples: Other GH orgs, certified maintenance orgs, approved training orgs

Point (c) - Common Requirements (BOTH Types)

GH org SHALL ensure:

  1. Contracted services/products comply with applicable requirements
  2. Aviation safety hazards risk-assessed in OWN management system
  3. Competent authority enabled access to third-party provider
  4. Contract is documented

145.A.205 - Part-145 Maintenance (EU 1321/2014)

Core Distinction: Contracting vs Subcontracting

Subcontracting: Third party works under YOUR approval and management system. YOU remain responsible.
Contracting: Another approved Part-145 org releases under THEIR approval. Responsibility transfers for those tasks.

145.A.205(a) - General Requirements

When contracting or subcontracting any part of maintenance activities:

  1. Maintenance SHALL conform to applicable requirements
  2. Aviation safety hazards SHALL be considered in org's management system

145.A.205(b) - Subcontracting Rule

If subcontracting any part of maintenance:

  • Subcontracted org SHALL work under scope of approval of subcontracting org
  • Whether subcontractor has own approval is irrelevant
  • They work under YOUR management system and approval

GM1 145.A.205 - Your Responsibilities

Regardless of subcontractor's approval status:

  • All subcontracted activities subject to hazard ID and risk management
  • Include in compliance monitoring (145.A.200(a)(6))
  • Identify hazards from complex arrangements (multiple orgs/levels)
  • Check contracted org's approval covers activities and is valid
  • Establish interfaces for occurrence reporting
  • Establish channels for internal safety reporting (145.A.202)

GM2 145.A.205 - Terminology Clarification

SUBCONTRACTING

Third party under YOUR management system. YOU remain responsible. Tasks within YOUR scope. Released under YOUR approval. Whether third party is approved doesn't matter.

CONTRACTING

Another approved Part-145 org under THEIR approval. Responsibility transfers for those tasks. Must be allowed by owner/operator/CAMO.

CAMO.A.205 & CAMO.A.125(d)(3) - CAMO (EU 1321/2014)

Two Activities: Contracting Maintenance + Subcontracting CAM Tasks

CAMOs contract maintenance to Part-145 organizations AND can subcontract limited continuing airworthiness management tasks to qualified organizations working under the CAMO's management system.

CAMO.A.205(a) - General Requirements

When contracting maintenance OR subcontracting CAM activities:

  1. Activities SHALL conform to applicable requirements
  2. Aviation safety hazards SHALL be considered in org's management system

CAMO.A.205(b) - Subcontracting CAM Tasks

When subcontracting continuing airworthiness management activities:

  • Subcontracted org SHALL work under the approval of the organization
  • CAMO SHALL ensure competent authority given access to subcontracted org
  • For determining continued compliance with requirements

CAMO.A.125(d)(3) - Subcontracting Privileges

Approved CAMO may:

  • Arrange limited continuing airworthiness tasks with subcontracted organizations
  • Subcontractor works under CAMO's management system
  • Must be listed on the certificate

GM1 CAMO.A.205 - CAMO Responsibilities

Regardless of subcontractor's approval status:

  • All subcontracted activities subject to hazard ID and risk management
  • Include in compliance monitoring (CAMO.A.200(a)(6))
  • Identify hazards from complex arrangements
  • Check contracted maintenance org's approval covers activities and is valid
  • Establish interfaces for occurrence reporting
  • Establish channels for internal safety reporting (CAMO.A.202)

AMC1 CAMO.A.125(d)(3) - Subcontractable CAM Tasks

CAMO can subcontract limited tasks including:

  • Airworthiness directive analysis and planning
  • Service bulletin analysis
  • Planning of maintenance
  • Reliability monitoring, engine health monitoring
  • Maintenance programme development and amendments
  • Other activities agreed by competent authority (that don't limit CAMO responsibilities)

⚠️ Important: CAMO remains accountable. Management system extends to subcontracted orgs. Contracts must be acceptable to competent authority and subcontractors listed on EASA Form 14.

Decision Flowcharts

ORGH.MGM.205 - Ground Handling Decision Flow

GH Organization Needs Service/Product Is Provider CERTIFIED, APPROVED, AUTHORISED or DECLARED under EU 2018/1139? NO NON-CERTIFIED PROVIDER (Point a) GH Org SHALL Apply SMS Manage Risk BEFORE Contract YOU ARE RESPONSIBLE YES CERTIFIED PROVIDER (Point b) Provider is Responsible Must comply with EU regs and Annex I or II Common Requirements (Point c) GH Org SHALL Ensure All 4: 1. Services/Products comply with requirements 2. Safety hazards risk-assessed in OWN SMS 3. Authority enabled access to provider 4. Contract documented ✓ Best Practices (AMC1): Written Agreement, SMS Integration, Verification, Communication

145.A.205 - Part-145 Maintenance Decision Flow

Part-145 Org Needs External Maintenance Will third party release under their own approval or under YOUR approval? YOUR APPROVAL SUBCONTRACTING (Point b) Third party works under YOUR scope of approval YOU REMAIN RESPONSIBLE THEIR APPROVAL CONTRACTING (Not in Point b) Another approved Part-145 releases under THEIR approval Responsibility transfers for tasks Point (a) - Both Cases Maintenance conforms to requirements + Hazards in management system GM1 - Part-145 Org Responsibilities: • Hazard ID & risk mgmt (145.A.200(a)(3)) • Compliance monitoring (145.A.200(a)(6)) • Check approval covers activities & valid • Interfaces for occurrence reporting • Internal safety reporting channels (145.A.202)

CAMO.A.205 - CAMO Decision Flow

CAMO Needs External Support What type of activity? Maintenance or CAM tasks? CAM TASKS SUBCONTRACTING CAM Tasks (Points b & CAMO.A.125(d)(3)) Subcontractor works under CAMO APPROVAL CAMO REMAINS ACCOUNTABLE MAINTENANCE CONTRACTING Maintenance (Point a) Part-145 org releases under THEIR OWN APPROVAL Part-145 responsible for maintenance Point (a) - Both Cases Activities conform to requirements + Hazards in management system CAMO Responsibilities (GM1): • Hazard ID & risk mgmt (CAMO.A.200(a)(3)) • Compliance monitoring (CAMO.A.200(a)(6)) • Check approval covers activities & valid • Authority access to subcontracted org • Interfaces for occurrence reporting (CAMO.A.202)