Management of change at a small operator

Two kinds of change

For an AOC holder, ORO.GEN.130 splits every change in two. Any change affecting "the scope of the certificate or the operations specifications" or "any of the elements of the operator's management system as required in ORO.GEN.200(a)(1) and (a)(2)" needs prior approval by the authority ORO.GEN.130(a). "All changes not requiring prior approval shall be managed and notified to the competent authority as defined in the procedure approved by the competent authority" ORO.GEN.130(c). An ATO has the same rule in ORA.GEN.130, with "terms of approval" in place of operations specifications.

So the procedure in your manual that says how you manage and notify the second kind matters: it is approved by the authority, and changing that procedure itself needs prior approval GM1 ORO.GEN.130(a), point (b).

Declared organisations have no approval step. A declared operator (commercial SPO, or non-commercial with complex aircraft) notifies any change to its declaration "without delay" with an amended declaration ORO.DEC.100(d). A DTO notifies "without undue delay" any change to the information in its declaration and to its training programmes DTO.GEN.116.

How far ahead

These are AMC: your approved procedure and your authority may set other lead times. Check yours.

Changes that need prior approval

GM1 ORO.GEN.130(a) lists typical changes that may affect the AOC, the operations specifications or the management system: the name of the operator; a change of legal entity; the principal place of business; the scope of activities; additional locations; the accountable manager; reporting lines between the accountable manager and the nominated persons; the operator's documentation, safety policy and procedures; and the facilities. For an ATO, GM1 ORA.GEN.130(a) has a similar list, which also names "any of the persons referred to in ORA.GEN.210(a) and (b)".

GM1 ORO.GEN.130(b) adds a longer, non-exhaustive checklist of items that need prior approval under other rules, among them alternative means of compliance, leasing agreements, specific approvals under Part-SPA, dangerous goods training programmes, flight crew and cabin crew training programmes, the MEL, and the method used to establish aerodrome operating minima.

For these changes the rule is strict:

• Apply "before any such change takes place", with the relevant documentation ORO.GEN.130(b).
• "The change shall only be implemented upon receipt of formal approval", and you operate under any conditions the authority sets in the meantime ORO.GEN.130(b).
• "Operators should conduct a safety risk assessment and provide it to the competent authority upon request" AMC1 ORO.GEN.130(b).

On the other side, GM1 ORA.GEN.130(c) gives ATO examples that do not need prior approval: medical equipment, FSTD technical staff, the schedule of preventive maintenance, and the list of instructors.

The safety risk of every change

Approval or not, every change goes through your safety risk management. For a non-complex operator the AMC says: "The operator should manage safety risks related to a change. The management of change should be a documented process to identify external and internal change that may have an adverse effect on safety. It should make use of the operator's existing hazard identification, risk assessment and mitigation processes" AMC1 ORO.GEN.200(a)(1);(2);(3);(5). ATOs have the same words in AMC1 ORA.GEN.200(a)(1);(2);(3);(5).

In practice, for a small organisation, that means the same few questions every time:

1. What exactly changes, and when? One sentence, one owner, one planned date.
2. Which kind is it? Prior approval, notification under your procedure, or internal only.
3. What could go wrong? Hazards the change brings or removes, found with your normal hazard identification (see risk assessment and a free hazard log). External changes count too: a new rule, a new airspace structure, a contractor that stops.
4. What do we do about it? Each mitigation with an owner and a date, done before the change goes live where it can be.
5. What has to be updated? Manuals, training, briefings, contracts with outsourced providers, and records.
6. Has the authority what it needs? Application or notification sent with the lead time, and for prior approval changes the formal approval in hand.
7. Did it work? A review after the change, and the changed area added to the compliance monitoring programme. See how to build the annual audit plan.

Common changes at a small operator

How each usually sorts, by the rule text and GM. Your approved procedure and your authority have the final word.

The one-page change checklist

One page per change, in four parts: classify the change, assess the safety risk, prepare (manuals, training, the application or notification), and close it after a review. Each item carries its rule reference. Free to use and adapt.

Why the inspector asks about change

Your authority audits you on a cycle of up to 24 months, and may stretch it to 36 months only if, among other things, you have "continuously demonstrated under ORO.GEN.130 that it has full control over all changes" ARO.GEN.305(c)(2). ATOs have the same condition under ORA.GEN.130 ARA.GEN.305(c)(2). The other conditions include no level 1 findings and every corrective action on time, covered in how to close a finding. A file of completed change checklists, each with its risk assessment and the date the authority was told, is the simplest way to show that control.

Sources: EASA Easy Access Rules for Air Operations (March 2026: ORO.GEN.130 with AMC1 and GM1, ORO.GEN.200, ORO.DEC.100, ARO.GEN.305), Easy Access Rules for Aircrew (October 2026: ORA.GEN.130 with AMC1 and GM1, ORA.GEN.200, ARA.GEN.305, DTO.GEN.116). Rule text checked 31 October 2026; where this guide and the Official Journal differ, the Official Journal text prevails.