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CMM toolkit

The compliance monitoring manager toolkit

Free audit checklists, an annual audit plan and a findings log for small operators, ATOs and DTOs, in Excel and Word. Every item points to the public EASA rule it comes from. Plus a short guide to running the programme with a small team.

Download the templates

Free to use and adapt, no sign-in. Built from the EASA Easy Access Rules for Air Operations and Aircrew. Check each item against the current rule text and your own approved procedures.

ORO.GEN.200(a)(6)

Air operator compliance monitoring checklist

For a non-complex AOC, SPO or NCC operator. Uses the GM3 "Compliance Monitoring Checklist" layout, grouped by the AMC1 minimum scope.

ORA.GEN.200

ATO compliance monitoring checklist

For an ATO, including the yearly organisational review that LAPL, PPL, SPL and BPL-only ATOs may use instead ORA.GEN.200(c).

DTO.GEN.270

DTO annual internal review

The AMC1 review items and the annual activity report in one place. DTOs have no compliance monitoring function: this is what they do instead.

AMC1 ORO.GEN.200(a)(6)

Annual audit plan

A 12-month grid of audit areas with auditor, independence check, last audited, planned and done.

GM3 ORO.GEN.200(a)(6)

Findings log and NCR form

The GM3 Non-compliance Report fields, with a proposed level 2 due date (3 months), status and overdue flags in Excel, and a one-page NCR form in Word.

All in one

The whole pack

All five templates in Excel and Word, in one zip file.

A short guide for the compliance monitoring manager

What the rule asks for

ORO.GEN.200(a)(6) asks for "a function to monitor compliance", including "a feedback system of findings to the accountable manager". ORA.GEN.200 does the same for ATOs. AMC1 lists the documents you need: a schedule of the monitoring programme, audit procedures with an audit plan, reporting procedures, follow-up and corrective action procedures, and a recording system.

What it must cover

The AMC1 ORO.GEN.200(a)(6) minimum scope: the privileges of the operator; manuals, logs and records; training standards; management system procedures and manuals; the areas under your nominated persons; and any outsourced activities, against the contract ORO.GEN.205.

How often

Part-ORO and Part-ORA set no fixed audit interval. You set the schedule in your programme. The GM3 template for non-complex operators is headed "Year:", so most small operators plan on an annual cycle. Two exceptions do have a number: an ATO training only for LAPL, PPL, SPL or BPL may run an organisational review "at least once every calendar year" ORA.GEN.200(c), and Part-CAMO verifies all aspects every year, extendable by up to 100% with a risk assessment and authority agreement AMC2 CAMO.A.200(a)(6). Step by step, with a sample year: how to build the annual audit plan.

Who may audit

Audits are "carried out by personnel not responsible for the function, procedure or products being audited". In a non-complex operator the accountable manager may act as compliance monitoring manager if they have shown the competence, and one person may be both compliance monitoring manager and safety manager if both functions have enough resources. External auditors are fine "under the responsibility of the compliance monitoring manager" AMC1, GM1 ORO.GEN.200(a)(6).

Findings: the clock that matters most

  • For every finding: identify the root cause, define a corrective action plan, and demonstrate implementation within the period agreed with the authority ORO.GEN.150.
  • A level 2 authority finding gets a corrective action period that "initially shall not be more than three months", from the written communication of the finding, extendable with an agreed plan ARO.GEN.350, GM2. Missing it can escalate the finding to level 1.
  • The authority's oversight cycle is up to 24 months, and can be extended to 36 months when there were no level 1 findings and all corrective actions were on time ARO.GEN.305. Closing findings on time earns you a longer audit interval.

Root cause, evidence and the authority's answer format, with a worked example: how to close a finding.

What the inspector looks at

"Part of an audit should concentrate on the organisation's compliance monitoring reports ... to determine if the organisation is identifying and correcting its problems" AMC1 ARO.GEN.305(b)(1). EASA's Management System Assessment Tool rates each element as Present, Suitable, Operating and Effective. A finished checklist with dated evidence, and findings closed on time, is what moves you from "Present" to "Operating".

When something changes

A new accountable manager, base, aircraft type or nominated person goes through ORO.GEN.130 or ORA.GEN.130: prior approval or notification, with lead times. It is also a cue to add the changed area to your audit plan. Guide and free one-page checklist: management of change.

For DTOs

A DTO has a representative and a head of training, not a compliance monitoring manager DTO.GEN.210. Instead it runs an annual internal review and an annual activity report, sent to the authority by the date it sets DTO.GEN.270. Records are kept three years DTO.GEN.220. Use the DTO template above.

Running this in spreadsheets works. Where it usually breaks is the follow-up: due dates nobody is reminded of, evidence in someone's inbox, and an audit pack built by hand the week before the inspection. That is the part Folvan does for you.

Sources: EASA Easy Access Rules for Air Operations (March 2026), Easy Access Rules for Aircrew, Easy Access Rules for Continuing Airworthiness, EASA Management System Assessment Tool.

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