EASA Level 1 and Level 2 Findings: What Each Level Means, the 3-Month Clock and Observations

The short answer

The authority's letter to ExampleMRO lists two items. F-01, level 2: sampled tools are missing from the tool control register. O-01, an observation: tools due for calibration are piling up. Only F-01 comes with a clock.

Under the EASA authority rules (145.B.350 for Part-145, in near-identical words for Part-CAMO, Air Ops and Aircrew), a level 1 finding is a significant non-compliance that lowers safety or seriously endangers flight safety. The authority acts immediately to prohibit or limit the activity until it is corrected. In Part-145 a level 2 finding is any other non-compliance. Its corrective action period is initially no more than three months from the written communication, extendable only on an agreed corrective action plan. Miss it and the finding is raised to level 1. An observation is not a finding, and only some Parts have it. None of these texts has a level 3.

Key facts

• A level 1 finding is a "significant non-compliance" which "lowers safety or seriously endangers flight safety" (145.B.350(b)). Four cases are level 1 by definition, among them "the lack of an accountable manager".
• For level 1 the authority takes "immediate and appropriate action to prohibit or limit the activities of the organisation involved" (145.B.350(d)(1)). Part-21 design organisations first get a period that "shall not be more than 21 working days" (21.B.433(d)1.(i)).
• For level 2 the corrective action period "shall initially not be more than 3 months", counted "from the date of the written communication of the finding" (145.B.350(d)(2)(i)).
• An extension comes only at the end of that period, "provided that a corrective action plan has been agreed with the competent authority".
• No acceptable plan, or the work not done in time, and "the finding shall be raised to level 1" (145.B.350(d)(3)).
• Observations appear in 145.B.350(f), 21.B.225(e), 21.B.433(e) and ADR.AR.C.055(e). CAMO.B.350, ARO.GEN.350 and ARA.GEN.350 have no observation clause.

Level 1 and level 2 in the Part-145 text

Part-145 has the fullest version of the scheme, so start there.

Three things make a level 1: the non-compliance is significant, it has the safety effect named at the end of (b), and it breaches the regulation, your own procedures and manuals, or your certificate. Level 2 is defined by exclusion: every other non-compliance.

The four listed cases are level 1 without any safety argument.

Both levels are issued by the competent authority after its own analysis under (a). The organisation does not choose the grade. Read 145.B.350 in full.

What happens after the finding letter

A level 1 finding has no grace period in Part-145. The restriction comes first and lasts until the corrective action is successful.

A level 2 finding runs on a clock:

• It starts on the date of the written communication, which is not necessarily the day of the audit.
• Three months is a ceiling, not an allowance. The period must be "appropriate to the nature of the finding", so the letter can set less.
• An extension is decided at the end of the period, and only with an agreed corrective action plan. Do not plan on one.

The authority assesses both your corrective action plan and your implementation plan. Point (d)(3) gives two routes from level 2 to level 1: no acceptable plan, or the work not done within the accepted or extended period.

Here is F-01's clock. The dates are an illustration.

What goes into the plan (root cause, contributing factors, the actions and the evidence) is worked through in Root cause analysis and CAPs for EASA audit findings.

The day the letter arrives:

1. Record the letter's date, the date you received it, and each finding's level and cited requirement exactly as written.
2. For a level 1, record what activity is stopped or limited, and by whom.
3. For a level 2, diary the end of the period and an internal review well before it.
4. For each observation, decide what you will do and record the decision.

Observations, and why there is no level 3

EASA's guidance, GM1 145.B.350(f), draws the line with a tool-control example.

An observation has no clock, but it is not free. 145.A.95 turns it into a recorded decision on the organisation's side:

We looked at it and decided not to act, because… is a decision. Silence is not, and the GM above says an overlooked observations process can itself lead to a level 2.

Observations are not universal. Among the authority rules in this guide, 145.B.350(f), 21.B.225(e) and 21.B.433(e) open with the same words, "The competent authority may issue observations for any of the following cases not requiring level 1 or level 2 findings", and ADR.AR.C.055(e) has its own version, quoted below. CAMO.B.350, ARO.GEN.350 and ARA.GEN.350 have no observation clause.

None of these rules has a level 3. For Part-21 production, EASA documented where the label went. Its non-binding transition guide for the 2022 amendments (attached to EASA FAQ 137623) notes against 21.A.158 that "Level III findings are replaced by observations", adding that "the concept is the same as ‘Level 3’ findings". Against 21.B.225 it records "Level 3 findings converted to Observations".

Ramp inspections add to the confusion, because their scale runs the other way. Under ARO.RAMP.130, "a category 3 finding is any detected significant non-compliance with the applicable requirements or the terms of a certificate that has a major influence on safety". See SAFA ramp inspection findings.

Side by side: Part-145, CAMO, Air Ops, Aircrew, Part-21 and aerodromes

Phrases in quotation marks are verbatim from the rule in that row.

The escalation is the same everywhere. CAMO.B.350, ARO.GEN.350, ARA.GEN.350 and ADR.AR.C.055 say "the finding shall be raised to a level 1 finding"; 145.B.350, 21.B.225 and 21.B.433 say "the finding shall be raised to level 1".

The start of the level 2 period differs. 145.B.350, CAMO.B.350, 21.B.225 and 21.B.433 count it "from the date of the written communication of the finding". ARO.GEN.350 leaves the start to guidance, quoted below. ARA.GEN.350 and ADR.AR.C.055 do not state it.

Part-CAMO weighs your track record before extending. Its level 2 test is also worded differently: a non-compliance "which may lower safety or endanger flight safety", where Part-145 says "which is not classified as a level 1 finding".

Air Ops says "could lower safety or hazard flight safety" for level 2, and puts the start date in guidance.

Aircrew uses the same safety wording as Air Ops. For declared training organisations, GM1 ARA.GEN.350(e) notes that "Part-ARA requirements do not require competent authorities to categorise findings issued to a DTO."

Part-21 design organisations get a level 1 correction window. Production organisations under 21.B.225 do not; their level 1 follows the Part-145 pattern.

Aerodromes set no number.

Worked examples: which words decide the level

These are illustrations. The competent authority issues the finding and decides its level; the examples only show which quoted words the decision turns on.

Internal findings are not authority findings

The level rules quoted above are authority text: how the competent authority classifies and follows up its own findings.

Your own compliance monitoring raises findings too. Many organisations grade them with the same words, so that everyone from the auditor to the accountable manager reads an internal grade the same way. That is a practice, not a requirement of the rules quoted here. How internal findings are graded and how long they may stay open is set by your own procedures; the programme side is in the compliance monitoring audit programme guide.

Keep the two lists apart: an authority finding carries the authority's level and period, an internal one carries yours. When both describe the same problem, link them rather than merge them.

Keeping findings in Avioverse

Findings from your own audits live in Audits. When you Raise finding during an audit, you choose Level 1 — Significant non-compliance, Level 2 — Non-compliance or Observation — Improvement recommended, and record a Regulatory reference and a Target close-out date. Each finding card carries the line "Internal finding grade: follow your organisation’s procedure. Authority-issued deadlines are separate." A level 1 finding asks for an Immediate containment decision. Share with auditee creates a link, protected by a passphrase by default, where the auditee sends a plan and then the actions taken, with no account needed. Creating the link needs a paid plan. A finding cannot be marked closed until its handling and a risk decision are complete; the steps are in the root cause guide.

Findings an authority raises against you fit Trackers. Choose New tracker, then the External audit findings template. Each finding gets a reference with the prefix F, a Severity of Level 1, Level 2 or Observation, and a Requirement / reference column. The status path is fixed: Open, Response submitted, Response accepted, Closed. Give an item an owner and the authority's due date: while the item is Open or Response submitted, the owner gets an in-app notice shortly before it is due and once it is overdue. A manager can use Invite guest to bring in someone from outside by email; they sign in to Avioverse. A guest can move a finding to Response submitted. Only a manager can accept the response, close the finding or reopen it.

What stays with you: the level is the one the authority wrote; nothing calculates it. The tracker is your working list, not a channel to the authority, and root cause and corrective actions go in each item's comments and actions rather than separate fields.

Next in this series: root cause analysis and CAPs for EASA audit findings.