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ARA.GEN.220 Record-keeping

ANNEX VI (Part-ARA) · Regulation (EU) No 1178/2011 · EAR revision 25 Nov 2025

IRImplementing rule

ARA.GEN.220Record-keeping

(a)The competent authority shall establish a system of record-keeping providing for adequate storage, accessibility and reliable traceability of:

(1)the management system’s documented policies and procedures;

(2)training, qualification and authorisation of its personnel;

(3)the allocation of tasks, covering the elements required by ARA.GEN.205 as well as the details of tasks allocated;

(4)certification and declaration processes as well as oversight of certified and declared organisations;

(5)processes for issuing personnel licences, ratings, certificates and attestations and for the continuing oversight of the holders of those licences, ratings, certificates and attestations;

(6)processes for issuing FSTD qualification certificates and for the continuing oversight of the FSTD and of the organisation operating it;

(7)oversight of persons and organisations exercising activities within the territory of the Member State, but overseen or certified by the competent authority of another Member State or the Agency, as agreed between these authorities;

(8)the evaluation and notification to the Agency of alternative means of compliance proposed by organisations and the assessment of alternative means of compliance used by the competent authority itself;

(9)findings, corrective actions and date of action closure;

(10)enforcement measures taken;

(11)safety information and follow-up measures;

(12)the use of flexibility provisions in accordance with Article 71 of Regulation (EU) 2018/1139; and

(13)the evaluation and authorisation process of aircraft laid down in points ORA.ATO.135 (a) and DTO.GEN.240 (a).

(b)The competent authority shall establish and keep up to date a list of all organisation certificates, FSTD qualification certificates and personnel licences, certificates and attestations it issued, DTO declarations it received, and the DTO training programmes it verified or approved for compliance with Annex I (Part-FCL), Annex III (Part-BFCL) to Commission Regulation (EU) 2018/395, or Annex III (Part-SFCL) to Commission Implementing Regulation (EU) 2018/1976.

(c)All records shall be kept for the minimum period specified in this Regulation. In the absence of such indication, records shall be kept for a minimum period of 5 years subject to applicable data protection law.

IR · ARA.GEN.220 — Regulation (EU) No 1178/2011 · Regulation (EU) 2020/359 · Aircrew Easy Access Rules · EAR revision 25 Nov 2025

AMCAcceptable means of compliance

AMC1 ARA.GEN.220(a)Record-keeping

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GENERAL

(a)The record-keeping system should ensure that all records are accessible whenever needed within a reasonable time. These records should be organised in a way that ensures traceability and retrievability throughout the required retention period.

(b)Records should be kept in paper form or in electronic format or a combination of both media. Records stored on microfilm or optical disc form are also acceptable. The records should remain legible and accessible throughout the required retention period. The retention period starts when the record has been created.

(c)Paper systems should use robust material, which can withstand normal handling and filing. Computer systems should have at least one backup system, which should be updated within 24 hours of any new entry. Computer systems should include safeguards against unauthorised alteration of data.

(d)All computer hardware used to ensure data backup should be stored in a different location from that containing the working data and in an environment that ensures they remain in good condition. When hardware- or software-changes take place, special care should be taken that all necessary data continue to be accessible at least through the full period specified in the relevant Subpart or by default in ARA.GEN.220(c).

AMC · AMC1 ARA.GEN.220(a) — Regulation (EU) No 1178/2011 · ED Decision 2012/006/R · Aircrew Easy Access Rules · EAR revision 25 Nov 2025

AMCAcceptable means of compliance

AMC1 ARA.GEN.220(a)(1);(2);(3) Record-keeping

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COMPETENT AUTHORITY MANAGEMENT SYSTEM Records related to the competent authority’s management system should include, as a minimum and as applicable:

(a)the documented policies and procedures;

(b)the personnel files of competent authority personnel, with supporting documents related to training and qualifications;

(c)the results of the competent authority’s internal audit and safety risk management processes, including audit findings and corrective actions; and

(d)the contract(s) established with qualified entities performing certification or oversight tasks on behalf of the competent authority.

AMC · AMC1 ARA.GEN.220(a)(1) — Regulation (EU) No 1178/2011 · ED Decision 2012/006/R · Aircrew Easy Access Rules · EAR revision 25 Nov 2025

AMCAcceptable means of compliance

AMC1 ARA.GEN.220(a)(4)Record-keeping

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ORGANISATIONS Records related to an organisation certified by, or having declared its activity to, the competent authority should include, as appropriate to the type of organisation:

(a)the application for an organisation approval or the declaration received;

(b)the documentation based on which the approval has been granted and any amendments to that documentation or, in the case of declared training organisations, the documentation required to be submitted with the declaration and any amendments thereto;

(c)the organisation approval certificate or any approval, including any changes;

(d)a copy of the continuing oversight programme listing the dates when audits or inspections are due and when such audits or inspections were carried out;

(e)continuing oversight records including all audit and inspection records;

(f)copies of all relevant correspondence;

(g)details of any exemption and enforcement actions;

(h)any report from other competent authorities relating to the oversight of the organisation; and

(i)a copy of any other document approved by the competent authority.

AMC · AMC1 ARA.GEN.220(a)(4) — Regulation (EU) No 1178/2011 · ED Decision 2018/009/R · Aircrew Easy Access Rules · EAR revision 25 Nov 2025

GMGuidance material

GM1 ARA.GEN.220(a)(4)Record-keeping

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CERTIFIED ORGANISATIONS - DOCUMENTATION Documentation to be kept as records in support of the approval include the management system documentation, including any technical manuals, such as the operations manual, and training manual, that have been submitted with the initial application, and any amendments to these documents.

GM · GM1 ARA.GEN.220(a)(4) — Regulation (EU) No 1178/2011 · ED Decision 2018/009/R · Aircrew Easy Access Rules · EAR revision 25 Nov 2025

GMGuidance material

GM2 ARA.GEN.220(a)(4)Record-keeping

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DECLARED TRAINING ORGANISATIONS - DOCUMENTATION Documents to be kept as records in support of the declaration process include the declaration form and all required attachments to it (training programmes) as well as any amendments to these documents.

GM · GM2 ARA.GEN.220(a)(4) — Regulation (EU) No 1178/2011 · ED Decision 2018/009/R · Aircrew Easy Access Rules · EAR revision 25 Nov 2025

AMCAcceptable means of compliance

AMC1 ARA.GEN.220(a)(5)Record-keeping

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PERSONS Records related to personnel licences, certificates, ratings, authorisations or attestations issued by the competent authority should include, as a minimum:

(a)the application for a licence, certificate, rating, authorisation or attestation or change to a licence, certificate, rating, authorisation or attestation;

(b)documentation in support of the application for a licence, certificate, rating, authorisation or attestation or change to a licence, certificate, rating, authorisation or attestation, covering as applicable:

(1)the course Area 100 KSA assessment;

(2)theoretical examination(s);

(3)skill test(s);

(4)proficiency check(s); and

(5)certificates attesting required experience;

(c)a copy of the licence or certificate including any changes;

(d)all relevant correspondence or copies thereof;

(e)details of any exemption;

(f)details of any enforcement action(s); and

(g)any report from other competent authorities relating to personnel licences, certificates, ratings, authorisations or attestations issued by the competent authority.

AMC · AMC1 ARA.GEN.220(a)(5) — Regulation (EU) No 1178/2011 · ED Decision 2018/011/R · Aircrew Easy Access Rules · EAR revision 25 Nov 2025

AMCAcceptable means of compliance

AMC1 ARA.GEN.220(a)(7)Record-keeping

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ACTIVITIES PERFORMED IN THE TERRITORY OF A MEMBER STATE BY PERSONS OR ORGANISATIONS ESTABLISHED OR RESIDING IN ANOTHER MEMBER STATE

(a)Records related to the oversight of activities performed in the territory of a Member State by persons or organisations established or residing in another Member State should include, as a minimum:

(1)oversight records including all audit and inspection records and related correspondence;

(2)copies of all relevant correspondence to exchange information with other competent authorities relating to the oversight of such persons/organisations;

(3)details of any enforcement measures and penalties; and

(4)any report from other competent authorities relating to the oversight of these persons/organisations, including any notification of evidence showing non-compliance with the applicable requirements.

(b)Records should be kept by the competent authority having performed the audit or inspection and should be made available to other competent authorities at least in the following cases:

(1)serious incidents or accidents;

(2)findings through the oversight programme where organisations certified by, or having declared its activities to, another competent authority are involved to determine the root cause;

(3)an organisation being certified by, having approvals issued by, or having declared its activities to, competent authorities in several Member States.

(c)When records are requested by another competent authority, the reason for the request should be clearly stated.

(d)The records can be made available by sending a copy or by allowing access to them for consultation.

AMC · AMC1 ARA.GEN.220(a)(7) — Regulation (EU) No 1178/2011 · ED Decision 2018/009/R · Aircrew Easy Access Rules · EAR revision 25 Nov 2025

GMGuidance material

GM1 ARA.GEN.220Record-keeping

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GENERAL Records are required to document results achieved or to provide evidence of activities performed. Records become factual when recorded. Therefore, they are not subject to version control. Even when a new record is produced covering the same issue, the previous record remains valid.

GM · GM1 ARA.GEN.220 — Regulation (EU) No 1178/2011 · ED Decision 2012/006/R · Aircrew Easy Access Rules · EAR revision 25 Nov 2025

All rules in SUBPART GEN – GENERAL REQUIREMENTS

Consolidated from the EASA Easy Access Rules (revision 25 Nov 2025, extracted 17 Aug 2026) for convenience. Not the official publication — verify against the Official Journal of the European Union and the EASA publications before operational use.

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