AMC & GM to Part ATCO.OR — Issue 2

Acceptable Means of Compliance and Guidance Material to Part ATCO.OR

Issue 2

8 June 2026

ANNEX III – PART ATCO.OR – REQUIREMENTS FOR AIR TRAFFIC CONTROLLER TRAINING ORGANISATIONS AND AERO-MEDICAL CENTRES

SUBPART B – REQUIREMENTS FOR AIR TRAFFIC CONTROLLER TRAINING ORGANISATIONS

GM1 ATCO.OR.B.001(c)(2) Application for a training organisation certificate

The requirement to add the list of ATC units is not relevant in the case of training organisations which provide initial training only.

AMC1 ATCO.OR.B.005 Means of compliance

In order to demonstrate that the Implementing Rules are complied with, a safety (risk) assessment should be completed and documented. The result of this safety (risk) assessment should demonstrate that an equivalent level of safety to that established by the Acceptable Means of Compliance (AMC) adopted by the Agency is reached.

AMC1 ATCO.OR.B.010(a) Terms of approval and privileges of a training organisation certificate

The management system documentation should contain the privileges and detailed scope of activities including the contracted ones for which the training organisation is certified, as relevant to this Regulation.

GM1 ATCO.OR.B.010(b) Terms of approval and privileges of a training organisation certificate

The specific agreement should detail the issues of liability and insurance for the provision of air traffic control service during on-the-job training and consider the relevant provisions of ATCO.OR.C.005 in order to ensure conformity of the contracted or purchased activity or part of activity to the applicable requirements as well as those of ATCO.OR.B.040 on occurrence reporting and ATCO.OR.C.025 on funding and insurances.

AMC1 ATCO.OR.B.015 Changes to the training organisation

(a) Training organisations should inform the competent authority of any changes to personnel specified in Annex III (Part ATCO.OR) that may affect the certificate or the training approval attached to it. (b) Training organisations should send to the competent authority each management system documentation amendment. Where the amendment requires the competent authority’s approval, the training organisation should receive it in writing.

GM1 ATCO.OR.B.015 Changes to the training organisation

(a) Examples of changes that may affect the certificate or the terms of approval of the training organisation or the training organisation’s management system are listed below: (1) the name of the training organisation; (2) change of legal entity; (3) the training organisation’s principal place of operation; (4) the training organisation’s type(s) of training; (5) additional locations of the training organisation; (6) the accountable manager; (7) any of the persons referred to in Part ATCO.OR; (8) the training organisation’s documentation as required by Subpart ATCO.OR.C on safety policy and procedures; (9) the facilities. (b) Prior approval by the competent authority is required for any changes to the training organisation’s procedure describing how changes not requiring prior approval will be managed and notified to the competent authority.

GM2 ATCO.OR.B.015 Changes to the training organisation

A change of name requires the training organisation to submit a new application as a matter of urgency. Where this is the only change to report, the new application can be accompanied by a copy of the documentation previously submitted to the competent authority under the previous name, as a means of demonstrating how the training organisation complies with the applicable requirements.

AMC1 ATCO.OR.B.030(b) Findings and corrective actions

The corrective action plan defined by the training organisation should address the effects of any noncompliance and its root cause.

GM1 ATCO.OR.B.030(a);(b) Findings

(a) Corrective action is the action to eliminate the root cause of a non-compliance in order to prevent its recurrence. (b) Determination of the root cause is crucial for defining effective corrective actions.

GM2 ATCO.OR.B.030(c) Findings

When reference is made to the competent authority, this means either the competent authority that has issued the certificate or the competent authority ensuring oversight of activities, if they are different, based on the agreement concluded between the authorities.

AMC1 ATCO.OR.B.040 Occurrence reporting

Training organisations should report all occurrences that may involve an actual or potential aviation safety risk. Commission Implementing Regulation (EU) 2015/1018 of 29 June 2015 laying down a list classifying occurrences in civil aviation to be mandatorily reported according to Regulation (EU) No 376/20141 and point ATCO.OR.B.040(c) of Annex III (Part ATCO.OR) to Commission Regulation (EU) 2015/340 provide examples of what is required to be reported. Reporting should not be limited to those items listed in Commission Implementing Regulation (EU) 2015/1018 and in point ATCO.OR.B.040(c) of Annex III (Part ATCO.OR) to Commission Regulation (EU) 2015/340.

GM1 ATCO.OR.B.040 Occurrence reporting

The training organisation’s report should focus on occurrences taking place during on-the-job training with regard to the training aspects involved. Without prejudice to Regulation (EU) No 376/2014 and its delegated and implementing acts, the report may be submitted together with, or as an integral part of, the report prepared by the air traffic services provider.

AMC1 ATCO.OR.B.040(a) Occurrence reporting

(a) Where the training organisation holds one or more additional organisation certificates within the scope of Regulation (EU) 2018/1139 and its delegated and implementing acts: (1) it may establish an integrated occurrence-reporting system covering all certificate(s) held; and (2) single reports for occurrences should only be provided if the following conditions are met: (i) the report includes all relevant information from the perspective of the different organisation certificates held; (ii) the report addresses all relevant specific mandatory data fields and clearly identifies all certificate holders for which the report is made; and (iii) the competent authority for all certificates is the same and such single reporting was agreed with that competent authority. (b) The training organisation should assign responsibility to one or more suitably qualified persons with clearly defined authority for coordinating actions on occurrences and for initiating any necessary further investigation and follow-up activities. (c) If more than one person is assigned such responsibility, the training organisation should identify a single person to act as the main focal point for ensuring a single reporting channel is established to the accountable manager. This should in particular apply to training organisations that hold one or more additional organisation certificates within the scope of Regulation (EU) 2018/1139 and its delegated and implementing acts where the occurrence-reporting system is fully integrated with that required under the additional certificate(s) held.

SUBPART C – MANAGEMENT OF AIR TRAFFIC CONTROLLER TRAINING ORGANISATIONS

GM1 ATCO.OR.C.001 Management system of training organisations

The requirements for the management system of training organisations may be satisfied if the air traffic services provider’s management system/safety management system (SMS) specifically covers the requirements of this Regulation.

AMC1 ATCO.OR.C.001(b) Management system of training organisations

SAFETY POLICY

The safety policy should: (a) be signed by the accountable manager;

(b) reflect the organisation’s commitment regarding safety, and its proactive and systematic management; (c) be communicated, with visible endorsement, throughout the organisation; (d) include safety-reporting principles and procedures, if applicable; (e) include the organisations’s commitment to: (1) improve towards the highest safety standards; (2) comply with all applicable legal requirements, meet all applicable standards and consider best practices; (3) provide appropriate resources; (4) enforce safety as the primary responsibility of all managers and staff; and (5) apply just culture principles in accordance with Regulation (EU) No 376/2014 and, in particular, not to make available or use the information on occurrences: (i) to attribute blame or liability to someone for reporting something that would not have been otherwise detected; or (ii) for any purpose other than the maintenance or improvement of aviation safety; (f) clearly indicate which types of operational behaviour are unacceptable, and include the conditions under which disciplinary action would not apply, if applicable; (g) enhance and embed safety culture and safety awareness; and (h) be periodically reviewed to ensure it remains relevant and appropriate to the training organisation.

GM1 ATCO.OR.C.001(b) Management system of training organisations

(a) The safety policy is the means whereby a training organisation states its intention to maintain and, where practicable, improve safety levels in all its activities and to minimise its contribution to the risk of an aircraft accident or serious incident as far as is reasonably practicable. It reflects the management’s commitment to safety, and should reflect the organisation’s philosophy as regards safety management, as well as become the foundation on which the organisation’s management system is built. It serves as a reminder of ‘how we do business here’. The establishment of a positive safety culture begins with the issuance of a clear, unequivocal direction. (b) The commitment to apply just culture principles forms the basis for the organisation’s internal rules describing how just culture principles are guaranteed and implemented, after consulting its staff representatives, as required by Article 16(11) of Regulation (EU) No 376/2014. (c) The safety policy should state that the purpose of safety reporting is to improve safety, not to apportion blame to individuals.

AMC1 ATCO.OR.C.001(c) Management system of training organisations

For training organisations not providing on-the-job training, the hazard identification process may be limited to a demonstration that there are no hazards directly identified. However, the training should be designed so as to ensure future safe operations.

AMC1 ATCO.OR.C.001(d) Management system of training organisations

PERSONNEL

A training organisation should demonstrate that: (a) a list of activities with relevant needed competence has been established; (b) their personnel have the relevant competence needed to fulfil the activities they are required to perform; (c) their personnel maintain a level of competence through training as appropriate; (d) their theoretical and practical instructors are qualified in accordance with Part ATCO, Subpart C of this Regulation; (e) their practical instructors either hold an OJTI endorsement or an STDI endorsement; (f) their assessors hold an assessor endorsement; and (g) knowledge of the current operational practices is ensured for their synthetic training device instructors and assessors if they are not holders of an ATCO licence with a valid unit endorsement.

AMC1 ATCO.OR.C.001(e) Management system of training organisations

Training organisations should demonstrate that the management system: (a) policies, processes and procedures are monitored to ensure they are current and subject to periodic review and amendment, when necessary, to maintain their continued accuracy and suitability; (b) allows for the impromptu recognition and initiation of improvements to policies, processes and procedures between periodic reviews; (c) controls, records and tracks changes to all of the management system policy, process and procedure documents; (d) includes a master record index that lists all the policies, processes and procedures; and (e) includes as a minimum the following:

(1) master record index; (2) training provider certificate; (3) management structure; (4) staff role profiles including accountabilities and responsibilities; (5) training manuals, plans and courses; (6) evidence of regulatory compliance; (7) change control process; (8) safety management manual; (9) course design documents; (10) instructor/assessor qualification and competence records.

AMC1 ATCO.OR.C.001(f) Management system of training organisations

(a) The implementation and use of a compliance monitoring function should enable the training organisation to monitor compliance with the relevant requirements of this Regulation. (b) Training organisations should specify the basic structure of the compliance monitoring function applicable to the activities conducted. (c) The compliance monitoring function should be structured according to the activities of the training organisation to be monitored.

GM1 ATCO.OR.C.001(f) Management system of training organisations

(a) Training organisations may monitor compliance with the procedures they have designed to ensure safe activities. In doing so, they may, as a minimum, and, where appropriate, monitor: (1) the organisational structure; (2) the plans and objectives; (3) the privileges of the organisation; (4) the manuals, logs and records; (5) the training standards; (6) the management system. (b) Organisational set-up (1) To ensure that the training organisation continues to meet the requirements of this Regulation, the accountable manager may designate a person responsible for the compliance monitoring function whose role is to verify, by monitoring the activities of

the organisation, that the standards required by this Regulation and any additional requirements as established by the organisation are met under the supervision of the relevant head of the functional area. For small training organisations, these identified functions can be fulfilled by the same person. (2) The person designated for the compliance monitoring function should be responsible for ensuring that the compliance monitoring programme is properly implemented, maintained and continually reviewed and improved. (3) The designated person responsible for the compliance monitoring function should: (i) have direct access to the accountable manager; and (ii) have access to all parts of the training organisation and, as necessary, to any contracted organisation. (c) Compliance monitoring documentation (1) Relevant documentation could include the relevant part(s) of the training organisation management system documentation. (2) In addition, relevant documentation could also include the following: (i) terminology; (ii) specified activity standards; (iii) description of the organisation; (iv) allocation of duties and responsibilities; (v) procedures to ensure regulatory compliance; (vi) compliance monitoring programme, reflecting: (A) schedule of the monitoring programme; (B) audit procedures; (C) reporting procedures; (D) follow-up and corrective action procedures; and (E) recording system; (vii) training elements referred to in paragraph 4(b) (viii) document control. (d) Training (1) Correct and thorough training is essential to optimise compliance in every training organisation. In order to achieve significant outcomes of such training, the training organisation needs to ensure that all personnel understand the objectives laid down in the organisation’s manual. (2) Those responsible for managing the compliance monitoring function should receive training in this task. Such training could cover the requirements of compliance monitoring, manuals and procedures related to the task, audit techniques, reporting and recording. (3) Time needs to be provided to train all personnel involved in compliance management and for briefing the rest of the personnel.

(4) The allocation of time and resources needs to be governed by the activities covered by the training organisation.

AMC2 ATCO.OR.C.001(f) Management system of training organisations

The person designated for the compliance monitoring function should be responsible for the review and continuous improvement of the established management system’s policies, processes and procedures. The following tools are essential to the ongoing continuous improvement process: (a) organisational risk profile; (b) risk management plan; (c) coherence matrix; (d) corrective and preventive action reports; and (e) inspection and audit reports.

GM2 ATCO.OR.C.001(f) Management system of training organisations

(a) These tools and processes related to the compliance monitoring function are interrelated and help define the continuous improvement efforts of the organisation. For example, any corrective or preventive action report could identify a deficiency or an opportunity for improvement. The person responsible for the compliance monitoring function would then be required to ensure the identified issue was addressed and the corrective or preventive action effectively implemented. The same would be true if the discovery of an issue was identified during an inspection or audit. (b) The effective implementation of change and the subsequent validation that the change did result in the desired outcome is critical to the continuous improvement process. Simply introducing a well-meaning suggestion for improvement into the organisation without carefully managing that change could have undesirable consequences. It is, therefore, the responsibility of the person in charge of the compliance monitoring function to introduce, monitor and validate improvement efforts. (c) A simple but effective process to use in managing continuous improvement is known as the plan-do-check-act, or PDCA, approach: (1) plan — map out the implementation of the recommended change, identifying at least: (i) those people who will be affected by the change; (ii) the required measures necessary to mitigate risk; and (iii) the desired outcome and its intended consequences. (2) do — execute the implementation plan once all affected groups have accepted the proposal and understand their role in ensuring its success;

(3) check — apply sufficient quality control ‘stage’ checks throughout the implementation phase to ensure any unintended deviations in the execution are identified and addressed without delay; and (4) act — analyse the results and take appropriate action as necessary.

AMC1 ATCO.OR.C.001(g) Management system of training organisations

(a) A training organisation should be considered complex when it has a workforce of more than 20 full-time equivalents (FTEs) involved in activities subject to Regulation (EC) 2018/11391 and its delegated and implementing acts. (b) A training organisation with up to 20 FTEs involved in the activities subject to Regulation (EU 2018/1139 and its delegated and implementing acts may also be considered complex based on an assessment of the following factors: (1) the extent and scope of contracted activities subject to the certificate, in terms of complexity; and (2) the different types of training provided, in terms of risk criteria.

AMC1 ATCO.OR.C.005 Contracted activities

(a) Training organisations may decide to contract certain parts of their activities to external organisations. (b) A written agreement should exist between the training organisation and the contracted organisation clearly defining the contracted activities and the applicable requirements. (c) The contracted safety-related activities relevant to the agreement should be included in the training organisation’s compliance monitoring programme. (d) Training organisations should ensure that the contracted organisation has the necessary authorisation or approval when required, and commands the resources and competence to undertake the task.

GM1 ATCO.OR.C.005 Contracted activities

(a) Regardless of the approval status of the contracted organisation, the contracting organisation is responsible to ensure that all contracted activities are subject to hazard identification and risk management as required by ATCO.OR.C.001(c) and to compliance monitoring as required by ATCO.OR.C.001(f).

(b) When the contracted organisation is itself certified to carry out the contracted activities, the organisation’s compliance monitoring should at least check that the approval effectively covers the contracted activities and that it is still valid.

GM1 ATCO.OR.C.010(b);(c) Personnel requirements

(a) Training organisations may nominate the person responsible for training and a person or persons subordinate to him or her as chief training instructor(s)/unit responsible training officer(s). (b) Usually, training organisations nominate only one person responsible for training. (c) Prerequisites, typical function and responsibilities of the person responsible for training may be: (1) to have extensive experience in instructing for all types of ATC training and possess sound managerial capability; (2) to have overall responsibility for ensuring satisfactory integration of all training provided and for supervising the progress of the persons undertaking training; (3) to be responsible for coordinating and delegating the contact to the competent authority in training-related issues; and (4) to be ultimately responsible to the accountable manager. (d) Prerequisites, typical functions and responsibilities of the chief training instructor(s)/unit responsible training officer(s) may be: (1) to have extensive experience in instructing for all types of ATC training and possess sound managerial capability; (2) to have responsibility for ensuring satisfactory training is provided and for supervising the progress of the persons undertaking training in the areas that have been delegated by the person responsible for training; and (3) to report to the person responsible for training.

AMC1 ATCO.OR.C.015(a) Facilities and equipment

FACILITIES

A training organisation should have access to facilities appropriate to the size and scope of the intended operations and the delivery of training, and provide an environment conducive to learning.

GM1 ATCO.OR.C.015(a) Facilities and equipment

GENERAL AREAS

These facilities should include general areas, which provide for sufficient: (a) office space for managerial, administrative and training staff; (b) space for study and testing, as well as briefing and debriefing; (c) (digital) library amenities; Annex IV to ED Decision 2026/004/R Page 14 of 18

(d) storage areas, including secure (digital) areas for training and personnel records; and (e) suitably equipped space for practical training.

AMC1 ATCO.OR.C.015(b) Facilities and equipment

(a) Synthetic training device classifications Synthetic training devices used for training should be classified according to one of the following classifications: (1) high-fidelity simulator (HI FI SIM) A replica of controller working positions (CWPs) including all equipment (hardware, software and connectivity) enabling the full functioning/interaction of the CWPs and their environment. In the case of aerodrome training (ADC), it includes an out-of-the-tower view. (2) simulator (SIM) A device that simulates important features of the real situation and operational conditions, enabling the student to practise tasks in real time. (3) part-task trainer (PTT) A training device which allows the student to practise operational functions independently from other functions. The table below indicates the best use of synthetic training devices. Initial Unit Continuation training: Practical instructor training training refresher training and assessor training (e.g. standard practices and procedures, abnormal and emergency situations (ABES) and Human Factors / TRM) and conversion training HI FI SIM x x SIM x x x x PTT x x

(b) Synthetic training device (STD) criteria If an STD is used for training, it should be approved by the competent authority according to its intended use. Training organisations should demonstrate how the STD will provide adequate support for the intended training, in particular how the STD will meet the stated objectives of the practical training exercises and enable the competencies to be assessed to the level determined in the training programme. This demonstration and the related documentation should include the following relevant criteria:

(1) the general environment, which should provide an environment in which STD exercises may be run without undue interference from unrelated activities; (2) the STD layout; (3) the equipment provided; (4) the display presentation, functionality, and updating of operational information; (5) data displays, including strip displays, where appropriate; (6) coordination facilities; (7) aircraft performance characteristics, including the availability of manoeuvres, e.g. holding or instrumental landing system (ILS) operation, required for a particular simulation; (8) the availability of real-time changes during an exercise; (9) the processes by which the training organisation can be assured that staff associated with the training conducted with the use of an STD are competent; (10) the degree of realism of any voice recognition system associated with the STD; and (11) where a simulator is an integral part of an operational ATC system, the processes by which the training organisation is assured that interference between the simulated and operational environments is prevented. The extent to which the STD achieves the above criteria will be used to determine the adequacy of the STD for the proposed use. As a general principle, the greater the degree of replication of the operational position being represented, the greater the use will be possible for any particular training. (c) STD used for on-the-job training When an STD is used for on-the-job training and the training time is counted as part of the operational training, the STD classification should be a high-fidelity simulator (HI FI SIM).

AMC1 ATCO.OR.C.020(a);(b) Record keeping

Training organisations should maintain the following records: (a) Records of persons undertaking training: (1) personal information; (2) details of training received including the starting date of the training, as well as the results of the examinations and assessments; (3) detailed and regular progress report forms; (4) certificate of completion of training courses. (b) Records of instructors and assessors: (1) personal information; (2) qualification records; (3) records of refresher training for instructors and assessors; (4) assessment reports;

(5) records of time spent instructing, evaluating and/or assessing. Training organisations should submit training records and reports to the competent authority as required.

AMC1 ATCO.OR.C.025 Funding and insurances

To demonstrate compliance with the requirement on the availability of sufficient funding, training organisations may be required to present an economic study identifying the minimum amount necessary to ensure that the training is conducted in accordance with the applicable requirements.

AMC2 ATCO.OR.C.025 Funding and insurances

To demonstrate compliance with the requirement on sufficient insurance cover, training organisations may be required to provide a deposit of an insurance certificate or other evidence of valid insurance. The insurance cover should be established by taking into account the nature of the training provided, the frequency and the fees applicable to the training courses.

SUBPART D – REQUIREMENTS FOR TRAINING COURSES AND TRAINING PLANS

AMC1 ATCO.OR.D.001 Requirements for training courses and training plans

CONTENT FOR TRAINING COURSES AND TRAINING PLANS

When developing training courses and training plans, training organisations should ensure that the training delivery methods are appropriate to the training objectives. The following points (nonexhaustive list) should be taken into consideration. (a) The planned way of conducting a course, or elements of it, meets the taxonomy/performance /competence requirements of the training objectives. (b) Training aids (hardware, software and connectivity) are specified and available whenever required for the chosen type of conduct. (c) When STDs are used for distance learning, it should be ensured that the training objectives are met without on-site personal guidance. (d) The training material and referenced bibliography should be made available to all students. (e) Data protection, protection of intellectual property as well as information security requirements are met.

(f) Appropriate procedures are established to ensure the integrity of the evaluations.

GM1 ATCO.OR.D.001 Requirements for training courses and training plans

A training organisation that intends to provide remote learning should: (a) ensure that the hardware, software and connectivity are suitable for the training; (b) continuously monitor the attendance and progress of students; (c) adapt the duration of lessons according to the students’ learning capacity during synchronous remote learning; (d) provide the competent authority with access to the virtual/remote environment; (e) ensure that staff are trained on remote training techniques; (f) familiarise students with virtual/remote learning; (g) develop detailed methods for virtual/remote evaluation, where applicable, ensuring the integrity of the process; (h) ensure the security of processing and the protection of personal data.