Regulation (EU) No 1178/2011 AIRCREW : Pilot Licences
DTO.GEN.210 Personnel requirements - Regulation (EU) 2020/359
- A DTO shall designate:
- a representative, who shall be responsible and duly authorised to do at least the
- ensure compliance of the DTO and its activities with the applicable
requirements and with its declaration;
- develop and establish a safety policy which ensures that the DTO's
activities are carried out safely, ensure that the DTO adheres to that
safety policy and take the necessary measures in order to achieve the
objectives of that safety policy;
- promote safety within the DTO;
- ensure the availability of sufficient resources within the DTO so that the
activities referred to in points (i), (ii) and (iii) can be carried out in
an effective manner.
- a head of training, who shall be responsible and qualified to ensure at least the
- that the training provided complies with the requirements of Annex I
(Part-FCL), Annex III (Part-BFCL) to Commission Regulation (EU) 2018/395 and
Annex III (Part-SFCL) to Commission Regulation (EU) 2018/1976 and with the
DTO’s training programme;
- the satisfactory integration of flight training in an aircraft or a flight
simulation training device (FSTD) and theoretical knowledge instruction;
- the supervision of the progress of students;
- in the case referred to in point DTO.GEN.250(b), the supervision of the
deputy head or heads of training.
- A DTO may designate a single person as its representative and its head of training.
- A DTO shall not designate a person as its representative or its head of training if there
are objective indications that he or she cannot be trusted to carry out the tasks listed in
point (a) in a manner which safeguards and furthers aviation safety. The fact that a person
has been subject to an enforcement measure taken in accordance with point ARA.GEN.355 in the
past three years shall be deemed to constitute such an objective indication, unless that
person can demonstrate that the finding leading to that measure, by reason of its nature,
scale or impact on aviation safety, is not such as to indicate that he or she cannot be
trusted to carry out those tasks in that manner.
- A DTO shall ensure that its theoretical knowledge instructors have either of the following
- practical background in aviation in the areas relevant for the training provided and
have undergone a course of training instructional techniques;
- previous experience in giving theoretical knowledge instruction and an appropriate
theoretical background in the subject on which they will provide theoretical
- Flight instructors and flight simulation training instructors shall hold the qualifications
required by Annex I (Part-FCL), Annex III (Part-BFCL) to Commission Regulation (EU) 2018/395
and Annex III (Part-SFCL) to Commission Implementing Regulation (EU) 2018/1976 for the type
of training they provide.
GM1 DTO.GEN.210(a)(1)(i) Personnel requirements - ED
OCCURRENCE-REPORTING SYSTEM COMPLIANT WITH REGULATION (EU) No 376/2014
The following list provides an overview of the main elements of the occurrence-reporting
system that is compliant with Regulation (EU) No 376/2014 and provides references to the
relevant articles of that Regulation.
- Occurrence-reporting system that caters for both mandatory and voluntary reporting (cf.
Articles 4 and 5).
Note 1: The mandatory reporting system established under Regulation (EU) No 376/2014
is also intended for the reporting of those additional items that qualify for mandatory
reporting and are defined in the EASA implementing rules.
Note 2: The voluntary reporting system is intended to facilitate the collection of
details of occurrences that may not be captured by the mandatory system and of other
safety-related information which is perceived by the reporting organisation as an actual
or potential hazard to aviation safety.
- Designation of one or more persons to independently handle the collection, evaluation,
processing, analysis and storage of details of occurrences with regard to data
collection and hazard identification (cf. Article 6(1)).
Note 1: In agreement with their competent authority, small-sized organisations may
make use of simplified mechanisms to ensure the collection, evaluation, processing,
analysis and storage of details of occurrences, possibly by sharing those tasks with
other similar organisations.
Note 2: An existing internal safety-reporting scheme, which collects safety-relevant
data, proposals and information, including data, proposals and information on potential
safety issues that have not resulted in any occurrence, may serve as a basis for the
mandatory and voluntary occurrence-reporting system. From this pool of safety relevant
information and data collected internally, the organisation will determine whether a
mandatory report is required or whether a voluntary report may be adequate.
- Reporting details of occurrences collected under the mandatory scheme as soon as
possible and in any event no later than 72 hours after becoming aware of the occurrence
(cf. Article 4(8) & (9)).
Note 1: The reference to ‘becoming aware of’ an occurrence implies that a person in
the organisation identifies the occurrence as falling into the category of a mandatory
occurrence report — usually through being involved in the occurrence or witnessing it,
but also on review or investigation of information reported to the organisation’s safety
reporting scheme. In the case of design or production organisations, the 72-hour period
starts at the point when the unsafe condition is identified.
In the case of automated data collection systems, the 72-hour period starts when the
person that is responsible for the analysis of the data detected the reportable
Note 2: The 72-hour period does not apply to the reporting of details of occurrences
which may involve an actual or potential aviation safety risk and safety-related
information collected under the voluntary scheme. These are to be reported in a timely
manner (cf. Article 5(5) & (6)).
- Establishment of data quality checking processes to ensure that the information
initially collected and the data stored in the database(s) are consistent (cf. Article
Note: It is understood that data quality checking processes should address four main
- errors in data entry;
- completeness of data, specially referring to mandatory data;
- proper use of the ADREP1 taxonomy;
- improve data consistency, notably between the information collected initially
and the report stored in the database (cf. Article 7(3)).
- Storage of occurrence reports that qualify for mandatory and voluntary reporting in one
or more databases (cf. Article 6(5)) using standardised formats to facilitate
information exchange and which are compatible with the ECCAIRS2 software and
ADREP taxonomy (cf. Article 7(4)).
Note: Organisations that are able to report through an ECCAIRS software compatible
reporting system provided by their competent authority are deemed to be automatically
compliant with the reporting system requirements in Article 7(4) and do not need to have
their own ECCAIRS software compatible reporting system.
- Application of the safety policy (cf. AMC1 DTO.GEN.210(a)(1)(ii)) to occurrences:
- identification of the safety hazards that are associated with identified
occurrences or groups of occurrences reported to the competent authority (cf.
- analysis of the related risks in terms of probability and severity of the
outcome, as well as assessment of the risks in terms of tolerability;
- based on the result of the risk assessment: determination of the need for
mitigation action, as required for improving aviation safety (cf. Article
- monitoring the timely implementation and effectiveness of any mitigation action
required (cf. Article 13(2)).
- In addition to the actions required under paragraph (f) above, where the organisation
identifies an actual or potential aviation safety risk as a result of the analysis of
occurrences or group of occurrences:
- transmission of the following information to the competent authority within 30
days from the date of notification of the occurrence to the authority (cf.
- the preliminary results of the risk assessment performed; and
- any preliminary mitigation action to be taken.
- where required, transmission of the final results of the risk analysis to the
competent authority as soon as they are available and, in principle, no later
than 3 months from the date of notification of the occurrence to the authority
(cf. Article 13(4)).
Note: The legal obligation to provide the initial results of the analysis of
the occurrence, follow-up reports and final results lies with the other
organisation that issued the initial report. Where an organisation receives a
copy of a report from another organisation that initially reported the
occurrence to the competent authority, depending on its contribution to the
actual or potential aviation safety risk underlying the occurrence, it may
however be required to perform its own analysis of the issue reported and to
provide a follow-up report to the competent authority.
- Safety policy and just culture: Consultation of staff representatives to ensure
mutual agreement on and adoption of the rules describing how ‘just culture’
principles are guaranteed and implemented within the organisation.
Note 1: The purpose of those rules is to ensure that employees and
contracted personnel that report or are mentioned in occurrence reports, both
mandatory or voluntary, are not subject to any prejudice by their employer or
any other organisation for which the services are provided on the basis of the
information supplied by the reporter (cf. Article 16(9)), unless an exception
applies (cf. Article 16(10)).
Note 2: Staff representatives may be nominated either by the trade union(s)
or by the staff themselves.
- Ensuring that employees and contracted personnel are regularly provided with
information concerning the analysis of, and follow-up on, occurrences for which
mitigation action is taken (cf. Article 13(3), while ensuring that only
disidentified information is disseminated.
- Ensuring that personal details are made available to staff of their
organisation, other than the persons designated in accordance with paragraph
(2), only where absolutely necessary to investigate occurrences with a view to
enhancing aviation safety.
- Ensuring that reports addressed to the competent authority contain at least the
information listed in Annex I to Regulation (EU) No 376/2014.
1 The ICAO Accident/Incident Data Reporting (ADREP) system.
2 European Coordination Centre for Accident and Incident Reporting
AMC1 DTO.GEN.210(a)(1)(ii) Personnel requirements - ED
- The safety policy should define, in relation to the DTO training programme, at least the
means and methods used for:
- hazard identification;
- risk assessment; and
- effectiveness of the mitigation measures (implementation and follow-up).
- The safety policy should additionally include the procedures required for occurrence
reporting pursuant to Regulation (EU) No 376/2014 (cf. GM1 DTO.GEN.210(a)).
AMC1 DTO.GEN.210(a)(2) Personnel requirements - ED
QUALIFICATION AND EXPERIENCE OF THE HEAD OF TRAINING (HT)
- The HT should, with regard to the size and the training scope of the DTO, possess
sufficient managerial capabilities in order to discharge their responsibilities, and
- in the case of a DTO that provides training in aircraft or FSTDs, hold an
unrestricted instructor certificate in accordance with Part-FCL with
instructional privileges that are relevant to the training provided by the DTO,
including sufficient experience as necessary;
- in the case of a DTO that provides theoretical knowledge training only, have
appropriate experience in aviation and knowledge relevant to the training
- At a DTO that provides training courses for different aircraft categories, the HT should
be assisted by one or more nominated deputy HTs qualified in accordance with paragraph
(a) and with regard to the other category or categories of aircraft.
GM1 DTO.GEN.210(a)(2) Personnel requirements - ED Decision
SUFFICIENT EXPERIENCE OF THE HEAD OF TRAINING (HT)
‘Sufficient experience’, as per AMC2 DTO.GEN.210(a)(1) paragraph (a)(1), means that the HT
should have gained the required experience as an instructor in order to have the capacity to
administer the particular training activity of the DTO in question. The following factors
should be taken into consideration for determining the experience required:
- training scope of the DTO, including specific training courses (e.g. aerobatic rating,
sailplane cloud flying rating, examiner courses for sailplanes and balloons);
- location of the DTO training area (e.g. mountains, sea, congested airspace);
- size of the DTO (volume of activity, number of training aerodromes and operating
- use of FSTDs;
- training aircraft models used by the DTO.
GM1 DTO.GEN.210(c) Personnel requirements - ED Decision
CIRCUMSTANCES UNDER WHICH A PERSON CANNOT BE TRUSTED TO CARRY OUT THE TASKS OF A
REPRESENTATIVE OR A HEAD OF TRAINING (HT) IN A MANNER WHICH SAFEGUARDS AND FURTHERS
Examples of objective indications that a person cannot be trusted to carry out the tasks of a
representative or an HT in a manner which safeguards and furthers aviation safety.
If that person, within the last 5 years preceding their nomination as representative or HT,
in a declaration in accordance with Part-DTO:
- holds or has held a pilot licence and that licence and/or any associated ratings,
certificates or authorisations have been subject to limitation, suspension or
- has knowingly and deliberately been responsible for committing any non-compliance with
the Basic Regulation and its implementing rules.
AMC1 DTO.GEN.210(d);(e) Personnel requirements - ED
In order to ensure and monitor that instructors maintain their required qualification, DTOs
should permanently keep a list of all instructors, including information on their
instructional privileges as well as on the validity periods of their licences, ratings and
certificates, including their medical certificates.
GM1 DTO.GEN.210(d);(e) Personnel requirements - ED
- The ratio of all students to flight instructors should allow maintaining the quality and
safety of the training provided.
- Class numbers in ground subjects involving a high degree of supervision or practical
work should not exceed 28 students.