Most flight schools don't fail audits because they break the rules on purpose. They fail because nobody could show, on the day, that the rules were being followed. A training record is missing a signature. An instructor's rating lapsed two weeks ago. A finding from last year's internal audit was never closed.
That is what compliance monitoring exists to prevent. This guide explains what EASA and the FAA actually require, how the two frameworks differ, and how to build a compliance monitoring program that keeps your school audit-ready every day, not just the week before an inspection.
This guide summarizes the requirements as of 2026. Always check the current regulation text and your competent authority's guidance before making changes to your procedures.
Compliance monitoring is the ongoing, structured process of checking that your training organization meets the regulations that apply to it and follows its own approved procedures, such as the training manual and operations manual. It includes planned audits and inspections, recording findings, fixing the root cause, and reporting the results to management.
It is different from a safety management system (SMS). An SMS asks "what could hurt us?" Compliance monitoring asks "are we doing what the rules and our manuals say we do?" Mature schools run both and feed them into each other.
Under Part-ORA, every ATO's management system must include a function to monitor compliance with the relevant requirements. EASA's acceptable means of compliance say the structure should reflect the size of the organization and the complexity of its activities. A small ATO training only for the PPL does not need the same setup as a multi-base airline academy, but it still needs a working system.
The accountable manager designates a compliance monitoring manager, who is responsible for making sure the compliance monitoring program is implemented, maintained, and continually reviewed and improved. The compliance monitoring manager can perform audits personally or appoint competent auditors, from inside or outside the organization. When external auditors are used, the audits still run under the compliance monitoring manager's responsibility.
Audits should be carried out by people who are not responsible for the function or procedure being audited. In a small school, that can mean the head of training audits the maintenance coordination process while an external auditor reviews the training itself.
ATOs must keep the following records for at least 3 years after the completion of the training:
The format of student training records must be specified in the training manual. For ATOs training only for the LAPL, PPL, SPL, or BPL, EASA's guidance allows training details and instructor progress reports to be kept on a student progress card. Your national authority may add requirements on top, so check its guidance as well. Read the full text in EASA Part-ORA.
A Part 141 school must keep a current, accurate record for each student, covering enrollment, the training received, test results, and the date the student graduated, terminated, or transferred. A few details trip schools up:
See the full text of 14 CFR 141.101.
Part 141 does not use EASA's term "compliance monitoring function." In practice, the chief instructor carries much of that responsibility, and FAA inspectors expect the school to show that its approved training course outline is being followed and that its records are complete. Running your own internal audits is the most reliable way to meet that expectation.
U.S. flight training providers, including independent Part 61 instructors, also answer to the TSA. Key obligations include:
See 49 CFR 1552.15 for the recordkeeping text.
| Requirement | EASA ATO (Part-ORA) | FAA Part 141 school |
|---|---|---|
| Formal compliance monitoring function | Required (ORA.GEN.200(a)(6)) | Not named in the rule; expected in practice |
| Designated person | Compliance monitoring manager | Chief instructor certifies records |
| Student training record retention | At least 3 years after training is completed | At least 1 year after graduation, termination, or transfer |
| Record format | Specified in the training manual | School record, separate from the student logbook |
| Security program | National requirements vary | TSA Part 1552 (also applies to Part 61) |
Build a compliance checklist that lists each applicable requirement, where your manuals address it, who owns it, and what evidence proves it. For an EASA ATO that means Part-ORA, Part-FCL, and your national authority's guidance. For a U.S. school it means Part 141 or Part 61, plus TSA Part 1552.
Name the compliance monitoring manager or, for Part 141, the person who owns internal audits. Decide who audits what so nobody audits their own work.
Create an audit plan that covers every area within a set period, typically including facilities, flight and ground training, instructor qualifications and standardization, training records, and the airworthiness status of training aircraft. Audit high-risk or previously weak areas more often.
Classify each finding by severity, assign an owner and deadline, and require a root-cause analysis for anything beyond a one-off slip. A finding is only closed when the fix is verified, not when someone promises it.
Share audit results, open findings, and trends with the accountable manager on a regular schedule. Repeated findings in the same area are a signal to change the process, not just retrain people.
The most common audit pain is reconstructing records after the fact. Record training, instructor sign-offs, and expiry dates as they happen, in one place, so any record can be produced in minutes.
At least once a year, check whether the program is catching problems before inspectors do. Feed compliance trends into your safety management system and vice versa.
For a step-by-step preparation checklist, see How to Prepare for a Flight School Audit in 2026.
FlightLogger, the Flight School Operating System, keeps training records, scheduling, maintenance, and safety in one connected platform, so the evidence your compliance monitoring depends on is created as part of daily operations. Training is recorded against the syllabus, instructor and student expiry dates are tracked automatically, and bookings can be blocked when a requirement is not met. A built-in safety management system sits alongside, and compliance frameworks including FAA and EASA are supported. In 2025, FlightLogger helped over 210 flight schools stay audit-ready. Book a demo to see how it works for your school.
EASA makes compliance monitoring an explicit function; the FAA builds the same expectation into its records and inspection requirements. Either way, the schools that pass audits with confidence are the ones that know the requirements, audit themselves honestly, close findings properly, and keep records complete as training happens.
It is the part of an ATO's management system, required by ORA.GEN.200(a)(6), that checks the organization complies with the applicable regulations and its own procedures. It includes planned audits and inspections, findings, corrective actions, and reporting to the accountable manager.
The compliance monitoring manager is designated by the accountable manager and is responsible for implementing, maintaining, and continually improving the compliance monitoring program. They can perform audits themselves or appoint competent internal or external auditors.
Under ORA.ATO.120, at least 3 years after the completion of the training. This covers training details, instructor progress reports and assessments, and information on the student's licences, ratings, and medical certificates. National authorities may set additional requirements.
Under 14 CFR 141.101, at least 1 year from the date the student graduates, terminates enrollment, or transfers to another school. The chief instructor must certify the record at that point.
Yes. Part 61 schools do not have Part 141's training record rule, but they are covered by the TSA Flight Training Security Program under 49 CFR Part 1552, which requires a security coordinator, security awareness training, and specific records.
Compliance monitoring checks that the school follows regulations and its own procedures. A safety management system identifies hazards and manages safety risks. Both are part of an EASA ATO's management system and work best when their findings inform each other.