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Aviation Compliance — 14 CFR Part 145 + US-EU Bilateral

How a US Repair Station Gets EASA Part 145 Approval

The how-to-get-approved process for a US 14 CFR Part 145 shop: obtaining EASA approval under the US-EU Bilateral Aviation Safety Agreement (BASA) and its Maintenance Annex Guidance (MAG) — the EASA Supplement, the special conditions, the SMS expectation, and how the FAA handles the review under the bilateral.

Chad Griffith, Founder & CEOReviewed: June 15, 202614 min read

Compliance document perspective, not airworthiness, A&P/IA, or legal advice. This article explains the documentation side of obtaining EASA approval under the US-EU bilateral — it is not a substitute for the judgment of your accountable manager, quality manager, DOM, certificated personnel, an EASA-approval consultant, or an aviation attorney on any specific approval scenario. EASA, MAG, and BASA specifics are described as bilateral-agreement and FAA/EASA guidance, not as Federal Aviation Regulations.

HomeBlogAviation ComplianceGetting EASA Approval

The Short Answer

A US repair station does not pass a separate full EASA audit to become EU-certificated. Instead, under the US-EU Bilateral Aviation Safety Agreement (BASA) and its Maintenance Annex Guidance (MAG), the FAA grants EASA approval to an existing 14 CFR Part 145 repair station. The shop adds an EASA Supplement to its repair station manual documenting the EASA-specific procedures and special conditions the MAG requires; the FAA reviews it on EASA's behalf through the bilateral; and the EASA approval is issued on top of the FAA certificate.

The MAG is the governing guidance for this process — a bilateral-agreement and FAA/EASA guidance document, not a section of the Federal Aviation Regulations. The biggest recent change: EASA added an SMS expectation that, through the MAG, became a special condition for US shops holding EASA approval (EASA Supplement update due Oct 10, 2025; SMS declaration of compliance due Dec 31, 2025 — both now past). A domestic-only US shop is not federally required to run an SMS; a US shop holding EASA approval is, under the bilateral.

BASA + MAG
The bilateral agreement and guidance behind EASA approval
US-EU bilateral (not CFR)
EASA Supplement
The section you add to your repair station manual
Manual itself: §145.207
SMS Expected
EASA special condition for approval holders
EASA/MAG, not 14 CFR Part 5

US MRO shops chasing EU work hit the same wall: the customer wants EASA-acceptable paperwork, and the shop assumes that means flying EASA in for a full audit. It usually does not. Because the US and EU maintain a bilateral, a US Part 145 station can hold EASA approval through a documentation path the FAA administers — but only if it understands which obligations come from the FARs and which come from the bilateral.

This article is the how-to-get-approved half of the subject. For what happens after you hold EASA approval — dual release, FAA Form 8130-3 versus EASA Form 1, the §145.219 retention floor versus the longer EASA-side expectation, and the records each authority cross-checks — see the companion guide, EASA-approved US repair stations: the bilateral, dual release & supplement records. Get approved here; keep the records audit-ready there.

The bilateral is guidance and agreement — not the FARs

Do not cite a 14 CFR section for the MAG, the EASA Supplement, the EASA special conditions, or the EASA SMS expectation. Those are governed by the US-EU bilateral and FAA/EASA guidance. The only things in this topic that come from the Federal Aviation Regulations are your underlying Part 145 obligations — application (§145.51), issue of certificate (§145.53), ratings (§145.59, §145.61), housing and facilities (§145.103), the manual (§145.207, §145.209), and the quality control system (§145.211). This article verifies those against the CFR and treats the rest as bilateral practice. EASA approval is a foreign-authority credential; confirm current MAG requirements with your FAA Flight Standards office and the bilateral guidance before relying on any summary.

What "EASA Approval" Actually Means for a US Shop

The phrase "EASA Part 145" gets thrown around loosely in the US, and it causes real confusion when shops scope an approval project. Three things are worth nailing down before you start.

You stay a 14 CFR Part 145 station

There is no FAA rule called "EASA Part 145." A US shop is certificated under 14 CFR Part 145 — that is the only repair-station rule set in the FARs. EASA Part 145 is the European Union maintenance-organization regulation; a US shop does not become EU-certificated under it. Holding "EASA approval" means the FAA, through the bilateral, has recognized your Part 145 shop as approved to release work into the EASA system. You never stop being a Part 145 station.

The bilateral does the heavy lifting

The United States and the European Union maintain a Bilateral Aviation Safety Agreement (BASA). For maintenance, the operative document is the Maintenance Annex Guidance (MAG) — the agreed guidance that lets the FAA grant a US Part 145 shop EASA approval, and lets EASA-approved shops release into the US system, without each authority re-certificating the other's facilities from scratch. (The current MAG revision, MAG Change 10, entered into force in late 2025, superseding Change 9 — confirm the live revision with the FAA before relying on specifics.) The MAG is guidance under the bilateral, not a Federal Aviation Regulation.

The EASA Supplement is where it lives

The mechanism is the EASA Supplement — a controlled section you add to your repair station manual that documents the EASA-specific procedures the MAG requires. The manual itself is required by §145.207 and its contents by §145.209; the EASA Supplement layered onto it is a bilateral/MAG construct, not a CFR section. Getting approved is, in large part, the work of building that supplement correctly and proving you follow it.

The CFR hook that makes the bilateral work

§145.53(b) provides that for applicants located in a country with which the US has a bilateral aviation safety agreement, the FAA may accept that country's civil-aviation-authority certification under signed implementation procedures. That is the same machinery running in reverse — it is why the FAA can administer the EASA-related review of US shops under the bilateral rather than EASA re-auditing every US facility itself.

Thinking about an EASA approval project? Start by scoring how audit-ready your underlying Part 145 records already are — it is the foundation the EASA Supplement attaches to.

Check Your Readiness Score

The 6-Step Path to EASA Approval

Each step separates the FAA obligation (verifiable CFR, linked to Cornell's Legal Information Institute) from the bilateral layer (MAG/EASA practice), and names the document the step produces.

1

Hold (or earn) the FAA Part 145 certificate first

14 CFR §145.51, §145.53

EASA approval at a US shop is layered onto an FAA Part 145 certificate — it is not a standalone credential. §145.53(a) provides that a person who meets subparts A through E of Part 145 is entitled to a repair station certificate with appropriate ratings and operations specifications. If you are not yet certificated, you complete the FAA process first (application, manuals, facility, ratings) and only then add EASA. If you already hold the certificate, you start from a much shorter runway.

Document produced

FAA Part 145 air agency certificate + operations specifications

2

Confirm the ratings and capability your EASA scope will sit on

14 CFR §145.59, §145.61

Your EASA approval scope cannot exceed your FAA ratings. §145.59 sets the airframe, powerplant, propeller, radio, instrument, and accessory ratings (each in defined classes); §145.61 covers limited ratings for a particular make/model or specialized work. Get your ratings and your capability list accurate and current — the EASA scope the bilateral recognizes maps back to them, and a mismatch here surfaces as a finding later.

Document produced

Ratings list, capability list, operations specifications

3

Build the repair station manual and quality control manual that underpin it

14 CFR §145.207, §145.209, §145.211

The EASA Supplement attaches to your repair station manual, so that manual has to be solid first. §145.207 requires you to prepare, follow, and keep current a repair station manual acceptable to the FAA; §145.209 sets its contents; §145.211 requires a quality control system and QC manual acceptable to the FAA. §145.51 lists both manuals among the application contents. A weak base manual or QC system makes a clean EASA Supplement impossible.

Document produced

Repair station manual (RSM) + quality control manual (QCM)

4

Write the EASA Supplement to your repair station manual

Bilateral / MAG (manual itself: §145.207)

This is the heart of the EASA-approval process and the document that does not come from the CFR. The EASA Supplement documents the EASA-specific procedures the MAG requires — dual-release handling, EASA work-order control, the EASA special conditions, and the designation of who may sign the EASA side. It is a bilateral/MAG construct grafted onto a CFR-required manual, so it carries no 14 CFR citation. You must follow it, keep it current, and control its revisions the same way §145.207 disciplines the rest of the manual.

Document produced

EASA Supplement (a controlled section of the RSM)

5

Implement the SMS the EASA special condition now expects

EASA / MAG special condition (NOT 14 CFR Part 5 for Part 145)

EASA added an SMS expectation for repair stations, and through the MAG it became a special condition for US shops holding EASA approval: the EASA Supplement was to be updated by October 10, 2025 and an SMS declaration of compliance submitted by December 31, 2025 (both now past). This is EASA-driven — 14 CFR Part 5 does not mandate SMS for Part 145, and Part 145 is not in the FAA general SMS mandate. If you hold EASA approval, your SMS and its documentation should already exist; a generic, uncustomized SMS template is itself a compliance risk.

Document produced

SMS manual + SMS declaration of compliance (EASA-side)

6

Submit through the FAA under the bilateral and hold the approval

14 CFR §145.53(b) + bilateral/MAG process

Under the BASA, the FAA reviews your EASA Supplement and special conditions on EASA’s behalf rather than EASA re-auditing your facility from scratch — §145.53(b) is the CFR hook that lets bilateral certification flow under signed implementation procedures. Once issued, the EASA approval is held alongside your FAA certificate, renewed/maintained on its own cycle, and audited against your EASA Supplement. Your FAA surveillance continues in parallel; the EASA layer is additive.

Document produced

EASA approval certificate (held with the FAA certificate)

See where your FAA records stand before you bolt EASA on top

Every step above rests on a clean Part 145 foundation. FileFlo's FAA readiness score reviews your record documentation across the §145.207 manual, §145.211 quality control, ratings/capability, and recordkeeping areas an FSDO inspector checks — the same base your EASA Supplement is layered onto. Takes under 10 minutes.

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The SMS Special Condition: The Change That Caught Shops Off Guard

If one part of the EASA-approval picture has surprised US shops recently, it is the safety management system (SMS) expectation. Here is the precise, cautious version — because the FAA and EASA pictures are different.

FAA side (14 CFR)

Is SMS required for Part 145? No. 14 CFR Part 5 (the SMS rule) does not mandate an SMS for repair stations, and Part 145 is not in the FAA's general SMS final-rule mandate.

Who is in that mandate? The general SMS framework reaches operators such as Part 121, certain Part 135 and §91.147 operations, and certain Part 21 certificate holders — with a single compliance date in 2027 on the §91.147/135 side.

Bottom line: A domestic-only US repair station has no federal SMS requirement from this rulemaking.

For the operator-side SMS picture, see the Part 135 SMS guides linked below — that mandate is a separate subject from repair-station EASA approval.

EASA side (bilateral / MAG)

Is SMS expected? Yes — EASA introduced an SMS expectation for repair stations, and through the MAG it became a special condition for US shops holding EASA approval.

The dates (now past): EASA Supplement to be updated by Oct 10, 2025; SMS declaration of compliance submitted to the FAA by Dec 31, 2025.

Who it applies to: Only US Part 145 stations that hold EASA approval — not every Part 145 shop.

Source character: this is an EASA-driven, bilateral requirement described in FAA/EASA guidance — not a 14 CFR provision. Confirm current MAG status with your FAA office.

A generic SMS template is itself a risk

Industry guidance is consistent that standing up a credible SMS typically takes six to twelve months, and that adopting an off-the-shelf SMS template without tailoring it to your actual operation is a compliance exposure, not a shortcut. If you hold EASA approval and the dates above have passed, your SMS — and the EASA Supplement that documents it — should already be implemented and current; if there is a gap, treat it as a live finding to close, and the documentation behind it as something an EASA-side audit will examine.

Holding EASA approval and unsure where your SMS and supplement documentation stands? Score how audit-ready your records are before an EASA-side audit asks.

Check Your Readiness Score

Don't confuse two different SMS conversations

The operator SMS mandate (Part 135 charter operators, single 2027 compliance date) and the EASA-approval SMS special condition for repair stations are unrelated rulemakings that happen to share an acronym. A Part 135 operator's 2027 deadline says nothing about your repair-station EASA approval, and your EASA SMS special condition says nothing about Part 135. Keep them in separate boxes. For the operator side, start with the Part 135 SMS 2027 deadline and Part 135 SMS requirements; if you need to find your own gaps, the Part 135 SMS gap analysis walks the SMS pillars (and the same gap discipline applies to a repair-station EASA SMS).

Where Shops Trip Up on the Approval

The EASA-approval process rarely fails on capability — these shops can do the work. It fails on documentation discipline. Four recurring traps.

Trap 1: A weak base manual under a polished EASA Supplement

The EASA Supplement attaches to your repair station manual, so a supplement is only as credible as the §145.207/§145.209 manual and the §145.211 quality control system beneath it. Shops sometimes invest in a slick supplement while the base RSM and QCM are out of date or out of step with how the floor actually works. Fix the foundation first — an auditor pulls the thread from the supplement straight down into the base manual.

Trap 2: EASA scope that exceeds the FAA ratings

Your EASA approval scope sits on your FAA ratings (§145.59) and limited ratings (§145.61) and your capability list — it cannot exceed them. A capability list that is stale, or an EASA scope written more broadly than the underlying FAA ratings support, is a self-inflicted finding. Reconcile the two before you submit, and keep them reconciled as ratings change.

Trap 3: Treating the SMS special condition as optional

Because 14 CFR Part 5 does not require SMS for Part 145, some shops assumed the EASA SMS expectation did not reach them. It does, if they hold EASA approval. The Oct 10, 2025 / Dec 31, 2025 dates have passed; a holder without an implemented, documented SMS and an updated EASA Supplement has an open bilateral gap, not a deferred to-do. And a generic, uncustomized SMS is treated as a gap of its own.

Trap 4: Attaching CFR cites to bilateral documents

The EASA Supplement, EASA Form 1, the MAG special conditions, and the EASA SMS expectation are not CFR provisions. Shops (and some templates) mislabel them with invented 14 CFR section numbers, which signals to an auditor that the shop does not understand the line between the FARs and the bilateral. State your Part 145 obligations from the CFR; describe everything EASA/MAG as bilateral guidance. Be cautious of any source that does otherwise.

How this connects to the rest of your Part 145 records

Getting approved is the front half; keeping the resulting records audit-ready is the back half. The documentation discipline behind the approval is the same discipline that carries your day-to-day Part 145 compliance:

See the companion EASA / FAA-MAG bilateral records guide for dual release and 8130-3 vs EASA Form 1; the repair station quality control manual (RSQCM) and how to write the RSM and QCM for the base manuals your supplement attaches to; and Part 145 recordkeeping requirements (§145.219) plus the Part 145 audit binder inspectors ask for for what a records review actually pulls.

Where a Document Intelligence Platform Fits in EASA Approval

FileFlo is a compliance document intelligence platform — a read-only proof layer that sits alongside the maintenance stack and makes the documents you already have audit-ready. It does not get you EASA approval, write your repair station manual, quality control manual, EASA Supplement, or SMS manual, run your quality or safety program, or give legal advice. Those come from your accountable manager, your certificated personnel, the consultants you choose, and the FAA/EASA bilateral process. FileFlo handles the documentation layer those efforts leave exposed.

For a shop pursuing or holding EASA approval, that means: classifying and version-controlling your RSM, QCM, EASA Supplement, and SMS manual revisions so the controlled current version is never in doubt; tracking the approval-cycle, SMS, and document-revision dates you configure with a 90/60/30-day expiration queue; indexing the personnel and training records that back the ratings your EASA scope sits on; and assembling an audit-ready binder organized the way a records review proceeds — for an FSDO inspector or an EASA-side audit. The judgment stays with your people; the proof stays organized.

Version-control your manual & supplement revisions

Upload your RSM, QCM, EASA Supplement, and SMS manual — FileFlo classifies each, keeps the controlled current version unambiguous, and retains superseded revisions per your policy.

Track approval, SMS & revision dates

Configure the EASA approval cycle, SMS milestones, and document-review dates; records and dates nearing their deadline surface in the 90/60/30-day queue before they become findings.

Index the records behind your ratings

Personnel, training, and capability records that support the FAA ratings your EASA scope is built on are classified and indexed so the link from scope to evidence is one search, not a binder hunt.

Audit binder for either authority

Generates a records packet organized the way a Part 145 review proceeds — manual control, quality control, personnel/training, recordkeeping — usable for an FSDO inspector or an EASA-side audit.

FileFlo does not grant EASA approval, write your manuals or SMS, perform maintenance, or run your quality or safety program. It keeps the documents that prove those systems exist and are maintained — audit-ready, the moment an FAA or EASA-side auditor asks. It does not replace your accountable manager, quality manager, certificated personnel, an EASA-approval consultant, or the bilateral process. FileFlo does not claim SOC 2 certification.

Pricing: Starter $89/month, Professional $299/month. 5-day free trial, no credit card required. Learn more at FileFlo for Part 145 Repair Stations.

Frequently Asked Questions

How does a US repair station get EASA Part 145 approval?

A US repair station does not pass a separate, full EASA audit and become an EU-certificated organization. Instead, under the US-EU Bilateral Aviation Safety Agreement (BASA) and its Maintenance Annex Guidance (MAG), the FAA can grant EASA approval to an existing 14 CFR Part 145 repair station. The shop stays a Part 145 station; it adds an EASA Supplement to its repair station manual documenting the EASA-specific procedures and special conditions the MAG requires, the FAA reviews the application and the supplement on EASA’s behalf through the bilateral, and the EASA approval is issued on top of the FAA certificate. The MAG is the governing guidance for that process — it is a bilateral-agreement and FAA/EASA guidance document, not a section of the Federal Aviation Regulations.

Do I need a separate EASA audit, or does the FAA handle it under the bilateral?

The whole point of the bilateral is that you generally do not face a separate, standalone full EASA audit of your facility. Under the US-EU BASA and the MAG, the FAA acts as the agent for EASA-related oversight of US-based repair stations: the FAA reviews your EASA Supplement and the additional EASA special conditions and, where everything is satisfied, the EASA approval is issued through that bilateral process rather than by EASA re-inspecting your shop from scratch. 14 CFR §145.53(b) reflects this in reverse — for applicants in countries the US has a bilateral with, the FAA may accept the foreign authority’s certification under signed implementation procedures. Your FAA surveillance does not go away; the EASA layer is added to it, not substituted for it.

What is the EASA Supplement and why do I need one?

The EASA Supplement is a section a US Part 145 repair station adds to its repair station manual to obtain and hold EASA approval under the bilateral. It documents the additional EASA-specific procedures the MAG requires — items such as how the shop handles dual release, how it controls EASA work orders, how it meets the EASA special conditions, and who is authorized to sign the EASA side. The underlying repair station manual itself is required by 14 CFR §145.207, and its contents by §145.209; the EASA Supplement is layered onto that manual because of the BASA and MAG, not because of any CFR section. You need it because it is the document the FAA reviews to grant EASA approval and the document an EASA-side audit checks your work against afterward.

How long does EASA Part 145 approval take for a US repair station?

There is no published fixed timeline, and as of 2026 it depends heavily on whether you are already an FAA Part 145 certificate holder. If you hold a current Part 145 certificate in good standing, adding EASA approval through the bilateral is largely a documentation exercise — building the EASA Supplement, meeting the special conditions, and getting it reviewed — and operators commonly plan on a span of a few months from a complete application. If you are not yet a Part 145 station, you must first get the FAA certificate (a separate, typically multi-month effort that hinges on how fast you complete your manuals and facility), and only then layer EASA on top. Treat any single number with caution: the gating factor is usually how complete and accurate your manual, QC manual, and EASA Supplement are when you submit, not a queue.

Does my EASA approval require an SMS now?

Yes, if you hold EASA approval — and this is the change that caught many US shops off guard. EASA introduced a safety management system (SMS) expectation for repair stations under its own rules, and through the MAG it became a special condition for US repair stations holding EASA approval: the EASA Supplement had to be updated by October 10, 2025, and an SMS declaration of compliance submitted by December 31, 2025 (both dates now past). Important nuance: this is an EASA-driven, bilateral requirement, not a US one. 14 CFR Part 5 does not mandate an SMS for Part 145 repair stations, and Part 145 is not in the FAA’s general SMS final-rule mandate. So a domestic-only US repair station is not federally required to run an SMS, while a US shop holding EASA approval is expected to under the bilateral. If your approval is current, your SMS and the EASA Supplement that documents it should already be in place.

What FAA ratings carry over to my EASA approval scope?

Your EASA approval scope is built on, and constrained by, your FAA Part 145 ratings — you cannot hold EASA scope for work you are not FAA-rated to do. The FAA issues ratings under 14 CFR §145.59 (airframe, powerplant, propeller, radio, instrument, and accessory ratings, each in defined classes) and limited ratings under §145.61 for a particular make/model or specialized work. The EASA approval and the capability the MAG recognizes are aligned to those ratings and your capability list. In practice, the scope of your EASA approval is described in EASA terms but maps back to your FAA ratings and operations specifications, so keeping your ratings and capability list accurate is the foundation of an accurate EASA scope.

What is the difference between this and the EASA records / dual-release topic?

They are two halves of the same subject. This article is the how-to-get-approved process slice — the path a US Part 145 shop takes to obtain and hold EASA approval through the bilateral: the EASA Supplement, the special conditions, the SMS expectation, and how the FAA handles it under the MAG. The companion article on the FAA-EASA bilateral records covers what happens after you are approved — dual release, FAA Form 8130-3 versus EASA Form 1, the §145.219 retention floor versus the longer EASA-side expectation, and the records each authority cross-checks. Get approved here; keep the resulting records audit-ready there.

Does FileFlo get me EASA approval or write my EASA Supplement?

No. FileFlo is a compliance document intelligence platform — a read-only proof layer. It does not perform maintenance, hold your repair station certificate, grant EASA approval, write your repair station manual, quality control manual, EASA Supplement, or SMS manual, run your quality or safety program, or give legal advice. Those come from your accountable manager, your certificated personnel, the consultants you choose, and the FAA/EASA bilateral process. What FileFlo does is organize and prove the documents around your approval: it classifies and version-controls your manual and EASA Supplement revisions, tracks the expirations and the SMS and approval-cycle dates you configure, indexes the personnel and training records that back your ratings, and assembles an audit-ready binder for an FSDO inspector or an EASA-side audit. It is the documentation layer, not the approval authority.

CG

Chad Griffith

Founder, FileFlo — compliance document intelligence

FileFlo helps aviation operators and repair stations keep their compliance documents classified, indexed, and audit-ready. This article is a compliance-document perspective on obtaining EASA approval under the US-EU bilateral — it is not legal, airworthiness, or A&P/IA certification advice, and it is not a substitute for your accountable manager, quality manager, certificated personnel, an EASA-approval consultant, or an aviation attorney on any specific scenario. FAA requirements are stated from 14 CFR; EASA, MAG, and BASA items are described as bilateral-agreement and FAA/EASA guidance, and EASA approval is a foreign-authority credential to confirm with your FAA Flight Standards office and the current MAG.

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