Part 147 Manual of Standards (MOS)

The MOS organises obligations around the concept of an MTO and the approval to conduct maintenance training and assessment. Key concepts in the MOS include:

• MTO: defined by the MOS through the use of that abbreviation and by the substantive obligations placed on entities holding a Part 147 approval (throughout, e.g. s 147.A.05-A.140). The exposition is the organisational instrument by which the MTO demonstrates compliance (s 147.A.140).

• Training categories: the MOS distinguishes between category training (licence category training under Part 66) and aircraft type training. Category training is subject to higher administrative prerequisites: an MTO seeking approval to conduct category training must be a registered training organisation (RTO) (s 147.A.10; s 147.A.200). Aircraft type‑only training may be provided by entities that are not RTOs (s 147.A.10).

• Exposition: the exposition is central and functions as the MTO’s internal rulebook describing responsibilities, procedures, personnel, facilities, lists of courses, and amendment procedures (s 147.A.140). Many operational decisions are delegated to what the exposition must contain and the procedures it must set out (for example student-to-instructor ratios, RPL procedures, and quality management arrangements).

• Quality management system and independent audit: the MOS mandates a quality management system set out in the exposition, with control procedures, independent periodic audits, remedial/corrective/preventative plans and feedback mechanisms to accountable/responsible managers (s 147.A.130). The MOS specifies that audits must be performed by a person independent of the person responsible for the MTO’s quality system (s 147.A.130(c)).

• Assessments and academic integrity: the MOS requires assessment security, defines cheating and sets procedural consequences (void declaration, 12-month assessment ban for the student, and reporting obligations to CASA) (s 147.A.135). There are also rules on assessor conduct and consequences for staff who assist cheating (s 147.A.135(c)).

• Recognition of prior learning (RPL): RPL is defined and permitted where equivalent; RPL may be used to satisfy unit/qualification prerequisites, but RPL assessors must meet exposition‑set standards and be appointed in writing (s 147.A.07; s 147.A.106(d)). If no RPL standards are set in the exposition for a particular rating, RPL may not be used for that rating (s 147.A.106(e)).

• Records, retention and reporting: the MOS prescribes recordkeeping for students and staff, retention periods (minimum 5 years), provision of summaries to students on request, and CASA inspection requirements (s 147.A.110; s 147.A.125; s 147.A.139). Reporting of issued certificates to CASA is mandatory within 4 weeks (s 147.A.139(a)).

• Competency frameworks and external standards: assessor competencies are tied to the Australian Qualifications Framework and National Skills Standards Council requirements, unless CASA approves alternatives in writing (s 147.A.106(a) & (a)3). Category and aircraft type training assessments must meet standards specified in the Part 66 MOS (s 147.A.205; s 147.A.300; s 147.A.305), thereby linking Part 147 compliance to Part 66 standards.

• Facilities, equipment and student limits: the MOS sets objective facility standards for theory (fully enclosed, separate from practical facilities, secure from mutual sight during assessments), practical workshops, heating and cooling, and a maximum of 28 students for knowledge training per course (s 147.A.100(b),(ba),(c),(d),(e)). For practical training, ratios are determined by the exposition (s 147.A.100(f)).

These concepts form the backbone of the regulatory regime the MOS defines: organisational governance via exposition and accountable managers, prescribed minimum operational standards, audit and quality control, assessment integrity, and explicit reporting and recordkeeping duties. The instrument repeatedly channels decision-making into exposition procedures and CASA oversight, making the exposition both the compliance blueprint and the control point for CASA’s approval and inspection functions (s 147.A.140; s 147.A.130; s 147.A.125(d)).

Primary regulated parties

• Maintenance training organisations (MTOs) holding or seeking approval under Part 147 of CASR 1998 are the direct and primary subjects of the MOS. Every obligation in the MOS is framed as “An MTO must…” (for example s 147.A.100, s 147.A.105, s 147.A.120), therefore the MTO is the entity legally obliged to comply.

• For MTOs providing category training, there is an additional statutory threshold: they must be registered training organisations (RTOs) (s 147.A.10; s 147.A.200). That requirement pulls entities into the national vocational education regulatory architecture where they were not before, with the attendant obligations of RTO status (the MOS itself references the Australian Qualifications Framework for assessor competencies, s 147.A.106).

Individuals within MTOs

• Accountable manager: the MTO must appoint an accountable manager who has corporate authority for finances and compliance and responsibility to ensure resources are available (s 147.A.105(a)). This is a named, accountable position in the organisation’s governance.

• Responsible manager(s): the exposition must name the responsible manager(s) who oversee compliance with this MOS and who may report to the accountable manager (s 147.A.105(b)). These roles are potential points of direct engagement with CASA (s 147.A.140(a)(2)-(3)).

• Teaching staff: instructors and assessors must meet selection criteria and qualification standards set out by the MTO and by this MOS, including assessors’ competencies and ongoing professional development requirements (s 147.A.105(c),(f),(h); s 147.A.106). Teaching staff are subject to disqualification from assessment duties if they assist cheating (s 147.A.135(c)).

• Students and prospective students: the MOS affects how students are taught, assessed and certified. It imposes student protections (for example access to course materials, library access s 147.A.100(i); receipt of course records s 147.A.125(c)) and sets student-facing rules about assessment outcomes, cheating sanctions, and pass marks (s 147.A.135; s 147.A.138).

Contracted third parties

• Organisations contracted to provide practical training, workshops or aircraft-type facilities are affected indirectly. The MOS allows MTOs to arrange such services, but requires written agreements specifying conditions of access and expressly requires the contracted organisation to permit CASA access (s 147.A.100(d),(e); s 147.A.140(a)(9),(10)). These contractual relationships thus carry regulatory expectations even if the contracted party is not itself the approved MTO.

Regulator

• The Civil Aviation Safety Authority (CASA) is the enforcement and oversight body. The MOS repeatedly establishes obligations to report to CASA (e.g. s 147.A.135(b)(3); s 147.A.139(a)), to give CASA access to facilities (s 147.A.100(d),(e)), and to make records available on request (s 147.A.125(d)). CASA’s approval, inspection and potential enforcement actions are the institutional mechanisms by which the MOS exerts regulatory control.

Other legal frameworks

• Entities that are not RTOs but that perform aircraft type training still fall within the MOS’s scope when they seek or hold Part 147 approval for type training (s 147.A.10; s 147.A.300). The MOS also incorporates the Australian Qualifications Framework and the Part 66 MOS for standards of training and assessment (s 147.A.106; s 147.A.200; s 147.A.300), so organisations and individuals operating at the intersection of vocational training and aviation maintenance must manage compliance across multiple regulatory regimes.

Who bears the costs and decision rights

• The MTO bears compliance costs: facilities, equipment, instructor qualifications and professional development, recordkeeping, quality systems and independent audits, and contractual arrangements with third parties (s 147.A.100; s 147.A.115; s 147.A.130; s 147.A.140). The accountable manager and responsible managers carry decision rights and internal accountability for compliance (s 147.A.105; s 147.A.140).

In short, the MOS governs MTOs and their personnel, shapes contractual relations with external providers, structures the relationship between MTOs and CASA, and imports external vocational and Part 66 standards that broaden the affected population to RTOs, assessors, students and contracted facility providers.

The MOS sets out specific duties an MTO must discharge and a set of procedural rights and reporting obligations that structure its relationship with CASA. Key duties and the limited rights implied by the MOS are as follows.

Duties of organisational governance

• Accountable manager appointment and duties: An MTO must appoint an accountable manager who has corporate authority to finance training commitments, ensure compliance with the exposition and MOS, and ensure adequate resources (s 147.A.105(a)). The exposition must contain a signed statement by the accountable manager confirming compliance with the MOS (s 147.A.140(a)(1)).

• Responsible manager(s): the MTO must name in the exposition the person or group responsible for ensuring MOS compliance; if not the same person, the responsible manager must report to the accountable manager (s 147.A.105(b)).

Exposition duties

• Produce and maintain an exposition describing the organisation and procedures with specified content, including lists of instructors/assessors, facility descriptions, course lists, procedures for using third‑party facilities, and amendment procedures (s 147.A.140(a)(5)-(13)). The exposition is the document through which many operational rules are defined and audited.

Facility and equipment duties

• Provide protected, fully enclosed theory facilities separate from practical facilities, ensure privacy during assessments, and ensure adequate environmental conditions (s 147.A.100(a)-(c), (b)2-3). Maximum theory class size is 28 students (s 147.A.100(ba)). Practical workshop and aircraft access requirements, including written agreements when facilities or aircraft are provided by another organisation, are duties (s 147.A.100(d),(e)).

Personnel and assessor duties

• Recruit and keep selection criteria and duty statements, appoint a sufficient number of qualified teaching staff, keep records of instructors/assessors for at least five years after employment ends (s 147.A.105(c),(f); s 147.A.110). Assessors for category training must hold specified AQF competencies or CASA‑approved equivalents; MTOs may appoint two persons to jointly assess where one has assessment competencies and the other has vocational knowledge (s 147.A.106(a),(b)). RPL assessors must meet exposition-set standards and be appointed in writing (s 147.A.106(d)-(e)).

Training, course plan and materials duties

• Have a course plan for each maintenance training course, containing course content, prerequisites, teaching staff qualifications, practical student numbers, type training compliance steps, duration, material outlines, synthetic device usage and assessment details including RPL handling (s 147.A.122). Provide course-aligned materials and library access (s 147.A.120; s 147.A.100(i)).

Assessment duties and pass marks

• Ensure security of assessment questions, conduct assessments only where approved for the corresponding training (s 147.A.135(a); s 147.A.137(a)). A student completes a course only on achieving a pass mark of 75% or more for each unit of competency in category training or for each element of aircraft type training (s 147.A.138(a)). Assessments must comply with the Part 66 MOS standards (s 147.A.205; s 147.A.305).

Academic integrity duties

• If a student is found to have cheated, the MTO must declare the assessment void, bar the student from taking any assessment for at least 12 months from the declaration, notify CASA of the cheating within 28 days and provide further information on request (s 147.A.135(b)). If staff assist cheating, the MTO must disqualify the staff member from assessment duties, declare the assessment void, and notify CASA including naming the staff member (s 147.A.135(c)).

Quality management and audit duties

• Establish control procedures and a quality management system in the exposition that provide for independent audits (annually or as described in the exposition), remedial action plans, a feedback system of audit findings to accountable and responsible managers, and regular review of the quality system (s 147.A.130(b)). Audits must be performed by a suitably qualified person independent of the person responsible for the MTO’s quality system (s 147.A.130(c)).

Records, retention and reporting duties

• Keep student course and assessment records, and staff records, for at least five years after last entry or after employment ceases (s 147.A.125(a)-(b); s 147.A.110(b)). Provide students, on request, with a document summarising course records and qualifications (s 147.A.125(c)). Provide CASA with details of certificates issued within 4 weeks, and include RPL matching statements when foreign or Defence qualifications are assessed (s 147.A.139(a),(e)). Make records available to CASA on request (s 147.A.125(d)).

Rights and procedural positions implied by the MOS

• Right to use RPL where the exposition provides a control procedure and standards; however if no exposition standards exist for RPL evaluations for a particular rating, RPL may not be used for that rating (s 147.A.07; s 147.A.106(d)-(e); s 147.A.122(9),(10)).

• Right to contract third parties for practical training but subject to written agreements and CASA access conditions (s 147.A.100(d),(e); s 147.A.140(a)(9-10)).

• Procedural right to define operational details in the exposition, subject to CASA oversight: many obligations are framed as “the MTO must have in its exposition” particular procedures or standards (s 147.A.120(c); s 147.A.130(b); s 147.A.140).

Limits and delegations

• The MOS permits some delegation of assessment roles, e.g. appointment of two assessors to jointly perform category assessment when their combined competencies meet the requirements (s 147.A.106(b)). It also allows synthetic training devices in lieu of real aircraft where they ensure adequate training (s 147.A.115(e)).

Collectively, the MOS prescribes a detailed package of duties that structure how an MTO must operate, what must be documented in the exposition, and how the MTO must interact with CASA. The rights are primarily procedural: the MOS grants MTOs the ability to set procedures in their exposition, to contract third parties, and to use RPL where the exposition provides for it, but those rights are constrained by express CASA notification, access and approval requirements.

The MOS itself, as reproduced here, primarily sets standards and procedural obligations. It does not include express penalty schedules or criminal sanction clauses in the text provided. Enforcement in practice follows from the MOS being a standards instrument tied to Part 147 approval under CASR 1998. The MOS prescribes obligations that, if not met, can be investigated and used by CASA as the basis to take regulatory or administrative action under CASR and related regulatory instruments. The MOS, however, does set out specific immediate administrative actions and reporting triggers that bind MTO behaviour and feed into CASA oversight:

• Reporting triggers and timelines: the MOS imposes mandatory reporting obligations to CASA. For example, MTOs must notify CASA in writing of cheating incidents within 28 days of declaring an assessment void (s 147.A.135(b)(3)) and provide further information on request (s 147.A.135(b)(4)); for staff-assisted cheating the MTO must give CASA the staff member’s name and further information (s 147.A.135(c)(3)-(4)). MTOs must also report details of each certificate issued to CASA within 4 weeks (s 147.A.139(a)). These reporting obligations create administrative evidence trails that CASA can use in enforcement or approval decisions.

• Access and inspection rights: the MOS requires written agreements with third-party facilities to include provision for CASA access (s 147.A.100(d),(e)). The MOS also requires MTOs to make records available to CASA on request within the time frame required (s 147.A.125(d)). These are operational enforcement mechanisms that enable CASA to verify compliance.

• Disqualification and internal disciplinary measures: the MOS requires that if a staff member assists cheating, the MTO must disqualify the person from being an assessor (s 147.A.135(c)(1)), effectively removing that individual’s ability to perform assessment functions pending further determination.

• Conditions of approval and compliance: the MOS repeatedly requires that assessments only be conducted where the MTO is approved to conduct the corresponding training (s 147.A.137(a)(1)). Failure to comply with MOS standards may therefore put an MTO’s Part 147 approval at risk, and CASA’s administrative toolkit under CASR 1998 includes actions such as suspending or revoking approvals, issuing directions and compliance notices, though those powers are in the CASR and enforcement regimes outside the MOS text itself.

What the MOS does not do in the text supplied

• The MOS does not set out monetary fines, criminal offences or administrative penalties in the instrument text provided. The compilation does not include the CASR enforcement provisions, so anyone relying on a penalties analysis must consult CASR 1998 and relevant enforcement instruments and policies for the specific sanctions CASA may apply for breaches of Part 147 approvals or of the MOS-prescribed requirements.

• The MOS does not include an express dispute or appeal mechanism against CASA decisions; these processes will exist under the CASR and administrative law frameworks, not in the MOS as reproduced.

Enforcement practice risks and mechanisms

• The MOS links many obligations to the exposition: CASA’s review of an MTO’s exposition and audits will be a central enforcement gateway (s 147.A.140; s 147.A.130). This creates concentrated discretion: CASA interprets MOS standards in the context of the exposition and can withhold or amend approvals if the exposition is deficient.

• The MOS creates procedural obligations that generate evidence (records, audit outcomes, reports) which CASA may use administratively. The MOS’s retention and reporting provisions (s 147.A.110; s 147.A.125; s 147.A.139) mean that non-compliance is likely to be discovered through certificate reporting mismatches, audit findings, or CASA inspections.

• Internal sanctioning duties (voiding assessments, disqualifying assessors) are required actions the MTO must take; failure to take those steps will itself be a compliance breach subject to CASA action (s 147.A.135).

In summary, enforcement is effected through CASA’s approval, reporting and inspection regime and by making compliance with MOS standards conditions of Part 147 approval. The MOS supplies specific procedural requirements and duties that both limit MTO discretion and provide CASA with inspection access and report-based triggers for enforcement, but it does not itself specify statutory penalties in the text provided.

The MOS is expressly an instrument made under CASR 1998 and is tightly integrated with other parts of the aviation regulatory framework and with the national vocational education framework. The MOS references, incorporates and depends upon multiple external legal or normative instruments. Those interactions determine the scope of obligations and the standards by which compliance will be assessed.

Integration with the Civil Aviation Safety Regulations 1998 and Part 66

• Legal source: The MOS is the manual of standards for Part 147 of CASR 1998 (s 147.A.05(a)). It is therefore subordinate to the CASR and functions to specify detailed standards for Part 147 approvals.

• Cross-reference to Part 66 MOS: For category training, the MOS requires compliance with the standard specified in section 66.A.25 of the Part 66 MOS and for aircraft type training with the standards in section 66.A.45 (s 147.A.200; s 147.A.300). Assessments must comply with standards set out in Part 66 MOS (s 147.A.205; s 147.A.305). Thus, to determine the full content of training standards and assessment rules, an MTO must consult both Part 147 MOS and the Part 66 MOS.

• Regulatory enforcement and approvals: the MOS sits within CASA’s broader regulatory enforcement regime under CASR 1998. While the MOS sets standards, the powers to approve, suspend and revoke approvals, and to impose penalties, will be exercised under regulations and statutory powers outside the MOS text. The MOS supplies the standard terms to be enforced under that statutory framework.

Interaction with national vocational education and training (VET) frameworks

• Australian Qualifications Framework and National Skills Standards Council: Assessor competencies for category training are required to meet “the current requirements for training and assessment under the Australian Qualifications Framework determined by the National Skills Standards Council, or its successors” (s 147.A.106(a)1). This imports VET competency standards into aviation assessor requirements.

• RTO status: the MOS requires MTOs conducting category training to be RTOs (s 147.A.10; s 147.A.200). RTOs are regulated under the national VET regulatory framework (e.g. the National Vocational Education and Training Regulator Act 2011 and the VET Quality Framework), so an MTO offering category training will have obligations under both CASA’s Part 147 MOS and the VET regulatory regime.

Administrative law and record disclosure

• The MOS imposes recordkeeping and disclosure duties in the context of CASA oversight (s 147.A.125(d)). These coexist with freedom of information or privacy regimes applicable to government-held records and to data about individuals; the MOS’s reporting obligations to CASA may involve personal data. Compliance with both MOS reporting duties and data protection laws will require MTOs to manage privacy-consistent information flows.

Contract law and commercial relationships

• The MOS permits MTOs to contract with third parties for practical training and access to aircraft (s 147.A.100(d),(e)). Contractual agreements must include CASA access. These clauses affect commercial relationships: contracted providers must accept CASA access as a condition of being used by an MTO. The MOS therefore influences contract terms and risk allocation in practical training arrangements.

Industrial and employment law

• Personnel records retention obligations (s 147.A.110) and disciplinary duties (for example disqualification of assessors who assist cheating, s 147.A.135(c)) interact with employment law. MTOs must ensure that internal discipline and recordkeeping policies comply with employment law and procedural fairness obligations while meeting MOS duties.

Transnational/foreign licence recognition

• The MOS requires an MTO assessing foreign licences or Defence Force authorisations for RPL to include in the report to CASA a statement about how the foreign or military qualifications match the Part 66 requirements for the category or type (s 147.A.139(e)). This provision interacts with immigration, defence and mutual recognition frameworks insofar as equivalence assessments may depend on foreign regulatory standards.

Statutory interpretation and subordinate instrument hierarchy

• The MOS is a manual of standards made under a regulation; therefore, if any provision conflicts with a regulation or primary legislation, the higher instrument prevails. The MOS imports standards from Part 66 MOS and from the AQF, meaning full compliance requires cross-reference to those instruments.

In practical terms, an MTO must manage compliance across multiple regulatory systems: CASA’s aviation-specific rules (CASR, Part 66 MOS), the national VET competency and RTO regulations, workplace and privacy laws affecting personnel records and discipline, and contract law for third‑party training facilities. The MOS does not operate in a vacuum and routinely delegates substantive standards (e.g. assessment content and assessor competencies) to other regulatory frameworks.

The compilation header and the Notes section at the end of the instrument set out the amendment history and the dates the instrument and its amendments commenced. The MOS as compiled was prepared on 22 December 2023 and takes into account amendments up to the Part 66 and Part 147 Amendment Instrument 2023 (No. 1), with the MOS in force on 5 December 2023 (compilation header). The Notes provide a specific table of the MOS and its amendment instruments:

• MOS 147 original (registered 18 February 2011; commenced 27 June 2011).
• MOS 147 2011 Amendment No. 1 (registered 22 June 2011; commenced 27 June 2011).
• MOS 147 2011 Amendment No. 2 (registered 21 November 2011; commenced 22 November 2011).
• MOS 147 2012 Amendment No. 1 (registered 4 June 2012; commenced 5 June 2012).
• MOS 147 2013 Amendment No. 1 (registered 17 July 2013; commenced 18 July 2013).
• Part 66 and Part 147 MOS Amendment Instrument 2023 (No. 1) (registered 4 December 2023; commenced 5 December 2023).

The detailed Table of Amendments (rendered in the compilation as an HTML table) lists which sections were affected by which amendment instruments. Examples from that table show that many of the core provisions were amended across different listings, for instance:

• s 147.A.05 was amended by MOS 147 2011 No. 1;
• s 147.A.100 was amended by MOS 147 2013 No. 1;
• s 147.A.106 saw amendments in MOS 147 2011 No. 2 and MOS 147 2012 No. 1;
• s 147.A.205 has amendments recorded up to the 2023 instrument (F2023L01613).

The Notes also show renumbering and replacement activity (for example s. 1, s. 2 renumbering to 147.A.01, and various repeals and substitutions as noted). The compilation’s Table of Amendments provides a mapping between the instrument provisions and the amendment instruments that affected them.

Practical implications of the amendment history

• The instrument as presented is a consolidated version reflecting successive refinements since 2011. The existence of a 2023 amendment linking Part 66 and Part 147 MOS indicates ongoing alignment between category/type training standards and the Part 147 organisational requirements. For compliance purposes, practitioners must ensure they consult the latest consolidated MOS (as in this compilation) and the underlying Part 66 MOS provisions referenced.

• Because the MOS incorporates standards from external bodies (for example AQF competency standards) and cross‑references Part 66 MOS standards, amendments in those external instruments (or in CASA’s interpretation of them) can affect the practical compliance duties of MTOs even when no change is made to the Part 147 MOS itself.

How to use the amendment history

• When advising clients, verify which amendment instruments affected specific MOS sections by consulting the Table of Amendments and the register numbers shown (e.g. F2023L01613). For regulatory decision-making, consult both the consolidated MOS and the underlying amendment instruments and external standards referenced (Part 66 MOS, AQF guidance) to assemble the full current compliance requirements.

In short, the MOS has a stable core established in 2011 with iterative amendments through to 2023; practitioners should rely on the consolidated instrument and cross‑check any sectoral or AQF changes that may alter assessor competency expectations or course content obligations.

The compilation provided contains no litigation history, no citations to cases, and no judicial or administrative determinations referenced. The MOS itself does not list any court decisions or appeals about its interpretation or application. The Notes and Table of Amendments record legislative and instrument amendments only.

What this means in practice

• There are no cases named in the instrument to rely upon for interpretation within the text provided. Any jurisprudence construing the MOS, Part 147 approvals, or CASA’s exercise of powers under CASR 1998 would need to be located through case law databases and not in this MOS compilation.

• Where disputes arise about CASA’s enforcement of MOS requirements, or about an MTO’s compliance and the consequences for its approval, the relevant litigation or administrative review would engage CASR 1998, the administrative law framework (including merits review appeals where applicable), and possibly contract or employment litigation in separate fora. Those processes are outside the MOS text and are not recorded in this compilation.

Practical advice pending litigation references

• Practitioners should not assume settled judicial interpretation from the MOS alone. Where legal advice or litigation strategy is required, search for decisions involving Part 147 approvals, CASA enforcement actions under CASR 1998, or judicial review of CASA decisions. The MOS will be prima facie evidence of the standards CASA expects, but judicial treatment of MOS provisions is not recorded here.

• For compliance disputes (for example, an MTO contesting CASA’s finding arising from audit reports or records), investigate whether CASA’s enforcement actions cite MOS provisions, and assemble administrative records, exposition documents and audit reports that will be pivotal to any review. The lack of in-instrument litigation history means the primary source for interpretation will be the MOS text, the exposition and CASA’s administrative records unless and until case law exists.

In sum, no litigation history appears in the copied MOS. For any legal dispute involving application of the MOS, practitioners must locate relevant case law and administrative decisions outside this instrument.

The MOS contains a number of provisions that are operationally consequential but may be overlooked. These “gotchas” are concrete compliance traps or operational constraints that practitioners and MTOs should note and manage.

1. RTO requirement is category‑specific (s 147.A.10; s 147.A.200). An organisation that provides only aircraft type training does not need to be an RTO (s 147.A.10). Practitioners must not assume RTO status is optional for category training; seeking category approvals without RTO registration will fail the MOS requirement.

2. Exposition as the control point (s 147.A.140). Many controls are delegated to the exposition. If an MTO’s exposition lacks sufficiently detailed control procedures (for RPL, student-to-instructor ratios, use of temporary facilities, audit plans, etc.), the MTO will breach multiple MOS provisions even if operational practice is adequate. CASA evaluates the exposition; absence of written procedures is itself non-compliance.

3. Student limits and ratios (s 147.A.100(ba); s 147.A.100(f)). Theory class maximum is 28 students. Practical student-to‑staff ratios are not specified numerically in the MOS but must be set in the exposition and followed; failing to document or adhere to appropriate ratios is a compliance risk.

4. Pass mark is categorical and high‑stakes (s 147.A.138(a)). Completion requires 75% or more for each unit of competency or type element. Partial passes or aggregate scoring that masks unit failures are not permitted by the MOS. MTO assessment design must ensure unit-level thresholds are enforced.

5. RPL conditionality and limits (s 147.A.07; s 147.A.106(d)-(e); s 147.A.122(10)). RPL can satisfy prerequisites and be used in assessments only where the exposition defines RPL assessment procedures and RPL assessors meet exposition standards. If the exposition fails to include RPL standards for a particular rating, the MTO may not use RPL for that rating.

6. Security and severe automatic consequences for cheating (s 147.A.135). Cheating leads to automatic administrative consequences: assessment void, 12‑month ban on assessments for the student and mandatory reporting to CASA. Staff-assisted cheating triggers disqualification and mandatory reporting including the staff member’s name. MTOs must have robust security and established control procedures for declaring assessments void (s 147.A.135(e)).

7. Records retention and CASA access obligations (s 147.A.110; s 147.A.125(d)). Records must be kept for at least 5 years after last entry or after employment ceases. CASA may demand records within a required time frame. Inadequate recordkeeping or inability to produce records on demand will create immediate compliance issues.

8. Independent audit requirement and potential resource costs (s 147.A.130(b)-(c)). The MOS mandates independent audits of training standards, assessment integrity and adequacy of procedures. The audits must be carried out by persons independent of the quality manager. Small MTOs must budget for independent audits and remedial plans.

9. Third‑party facility agreements must allow CASA access (s 147.A.100(d),(e); s 147.A.140(a)(9)). If an MTO relies on a contracted provider that refuses CASA access, the MTO will be non‑compliant. MTOs must ensure contracts include an express obligation to permit CASA inspections.

10. Assessors’ qualifications link to AQF and CASA discretion (s 147.A.106(a)1 & (a)3). Assessors for category training must meet AQF training-and-assessment competencies or have alternative equivalent competencies approved in writing by CASA. This creates an approval gate: assessors without AQF qualifications must obtain CASA’s-written approval of equivalence.

11. Reporting timelines for issued certificates (s 147.A.139(a)). MTOs must report details of every issued certificate to CASA within 4 weeks. Failures to report within that period may be treated as non-compliance, and it is a recurring administrative obligation that requires processes tied to certificate issuance.

12. Ambiguity about sanctions in the MOS (see “Penalties and enforcement” section). The MOS does not set monetary penalties; enforcement depends on CASA’s statutory powers in CASR. MTOs should not rely on the MOS alone to understand possible sanctions and must consult CASR enforcement provisions.

13. Student privacy and data handling tensions. The MOS requires reporting student qualifications and can include statements about English proficiency and airworthiness understanding (s 147.A.139(b)-(c)). MTOs must reconcile these reporting duties with privacy and data-protection requirements when sharing personal information with CASA.

14. Two-assessor joint assessment option (s 147.A.106(b)). While permitting flexibility, this arrangement can complicate accountability and recordkeeping: one assessor must have assessment competencies, the other vocational knowledge. MTOs must document the arrangement and ensure both are listed and records kept.

15. Use of synthetic training devices is permitted but limited (s 147.A.115(e); s 147.A.115(d)). Synthetic devices may substitute for aircraft types if they “ensure adequate training.” Determining adequacy is an evidentiary standard; MTOs should document equivalence evidence in their exposition.

These are concrete operational pitfalls. The recurrent theme is that many MOS obligations are procedural and document-driven: absent written exposition procedures and robust record systems, an MTO will fail multiple MOS requirements even if practical delivery is satisfactory. The MOS ties discretionary allowances (RPL, synthetic devices, joint assessors, contracting) to written exposition controls and CASA approvals, meaning informal practice without documented procedure is a systemic compliance risk.

Compliance with the MOS requires an MTO to design governance, documentation, operational controls and reporting systems aligned to the instrument’s specific requirements. Below is a practical compliance checklist mapped to the relevant MOS provisions. This is a practical implementation guide, not legal advice.

Governance and accountability

• Appoint an accountable manager with documented corporate authority for financing training commitments and ensuring MOS compliance. Record the appointment, duties and confirmation statement as required in the exposition (s 147.A.105(a); s 147.A.140(a)(1)).

• Name responsible manager(s) in the exposition and document reporting lines between responsible manager(s) and the accountable manager (s 147.A.105(b); s 147.A.140(a)(2)-(4)).

Create and maintain the exposition

• Draft an exposition that contains all the elements listed in s 147.A.140(a)(1)-(14). Ensure it includes:

  • lists of instructors and assessors (s 147.A.140(a)(5));
  • general description of training facilities (s 147.A.140(a)(6));
  • list of courses forming the extent of approval (s 147.A.140(a)(7));
  • procedures for amendment (s 147.A.140(a)(8));
  • detailed agreements and procedures for using other organisations’ facilities (s 147.A.140(a)(9-10));
  • detailed compliance procedures for all MOS requirements (s 147.A.140(a)(13));
  • any chosen criteria to confirm to CASA (age, English proficiency, experience) and the procedures to support those (s 147.A.140(a)(14)).

• Retain copies of documents treated as forming part of the exposition where the MOS allows them to be kept separately (s 147.A.140(b)-(c)).

RTO status and external standards

• If providing category training, register as an RTO and ensure the MTO’s internal processes meet VET regulatory obligations (s 147.A.10; s 147.A.200). Coordinate Part 66 MOS requirements with RTO requirements.

Facilities, equipment and classroom controls

• Establish fully enclosed theory classrooms separate from practical training areas, ensure seating and screen visibility arrangements prevent sighting others’ work during assessments, and maintain climate/noise controls (s 147.A.100(b),(c)). Ensure maximum theory class sizes do not exceed 28 students (s 147.A.100(ba)).

• For practical workshops and aircraft type training, either provide appropriate facilities or contract with third parties under written agreements specifying conditions of access and CASA’s right of entry (s 147.A.100(d),(e); s 147.A.140(a)(9-10)).

• Furnish classrooms with suitable presentation equipment and provide tools, aircraft examples, engines, parts and avionics as required for practical training (s 147.A.115(b),(c); s 147.A.115(d)-(e)). Where synthetic training devices are used, document justification for adequacy.

Personnel and assessor competence

• Prepare selection criteria and duty statements for teaching staff and only appoint staff meeting the selection criteria (s 147.A.105(f)). List assessors in the exposition (s 147.A.105(g)).

• Ensure assessors meet the AQF-based competencies for training and assessment or obtain CASA’s written approval for alternate equivalence (s 147.A.106(a)1 & (a)3). For type training assessors, set assessor qualification and experience standards in the exposition (s 147.A.106(c)1-2).

• Appoint RPL assessors in writing and set exposition standards for RPL evaluations; if no RPL standards are in the exposition for a rating, do not use RPL for that rating (s 147.A.106(d)-(e); s 147.A.122(10)).

• Implement a professional development programme for teaching staff at least once every two years covering current technology, practical skills, human factors and training techniques (s 147.A.105(h)). Keep records of PD.

Training, course planning and materials

• Create course plans for every course as required, including content, prerequisites, teaching staff qualifications, student numbers for practical courses, duration and timetable, course materials, synthetic device usage and assessment details including RPL handling (s 147.A.122(1)-(10)).

• Ensure course materials align with the relevant Part 66 knowledge syllabuses and type course content and establish a control procedure for production, updating and distribution of materials in the exposition (s 147.A.120(a)-(c)).

Assessment design, security and pass criteria

• Design assessments to comply with Part 66 MOS standards where applicable (s 147.A.205; s 147.A.305). Do not conduct assessments unless approved for the corresponding training (s 147.A.137(a)(1)).

• Implement secure assessment controls: storage, distribution, invigilation and post‑assessment security. Prohibit access to unauthorised materials during assessments and produce a written control procedure for declaring an assessment void (s 147.A.135(a); s 147.A.135(e)).

• Apply the pass mark of 75% for each unit of competency (for category training) or each element of type training, and provide certificates and course summaries consistent with s 147.A.138(a)-(b).

Procedures for academic misconduct

• Document procedures for detecting cheating, for declaring assessments void, for imposing the 12 month assessment ban on students found to have cheated, and for disqualifying assessors who assist cheating together with the timing and content of the required notifications to CASA (s 147.A.135(b)-(c)).

Recordkeeping, data handling and reporting

• Maintain student training and assessment records and instructor/assessor records for at least 5 years (s 147.A.125(a)-(b); s 147.A.110(b)). Provide students, on request, with summaries of their records (s 147.A.125(c)).

• Report each certificate issued under paragraph 147.040(d) of CASR 1998 to CASA within 4 weeks (s 147.A.139(a)). If assessing foreign or Defence qualifications for RPL, include statements about equivalence in reports to CASA (s 147.A.139(e)).

Quality management and auditing

• Establish a quality management system in the exposition with control procedures for compliance, procedures covering use of third-party resources and temporary facilities, independent annual (or exposition‑defined) audits assessing training standards, assessment integrity and procedural adequacy, a remedial/corrective/preventative plan and a feedback system to accountable and responsible managers (s 147.A.130(b)(1)-(4)).

• Contract or appoint independent auditors who are suitably qualified and clearly independent of the person responsible for the MTO’s quality system, and ensure audit findings trigger remedial actions and feed back to accountable management (s 147.A.130(c); s 147.A.130(b)(3)(i-ii)).

Contracting and third-party arrangements

• When contracting facilities or practical training to another organisation, ensure written agreements specify conditions of access, including CASA’s access, and document control procedures for outsourced assessments (s 147.A.100(d),(e); s 147.A.140(a)(9)-(10); s 147.A.105(d)).

Operational documentation and review

• Keep the exposition up-to-date and implement an exposition amendment procedure as required (s 147.A.140(a)(8)). Ensure all procedures referenced in the MOS are embedded in the exposition rather than existing only in practice.

Practical implementation tips

• Develop a compliance calendar mapping key recurring obligations: student records retention deadlines, certificate reporting within 4 weeks, audit schedule (annual or per exposition), staff PD every two years, and scheduled independent quality reviews.

• Use checklists for assessments to ensure that unit-level pass thresholds are applied, exam security is maintained, and invigilation records document any irregularities to allow mandated notifications to CASA.

• Document equivalence evidence where synthetic devices or RPL are used; be prepared to present that evidence to CASA when requested.

• Where assessors lack AQF training-and-assessment competencies, prepare and obtain CASA written approvals for any alternative competencies before deploying assessors in category assessments (s 147.A.106(a)3).

By mapping each MOS requirement to a specific operational control, the MTO demonstrates through its exposition and records that it has implemented the MOS obligations. CASA’s inspections and audit requests will look first to the exposition, then to records showing the exposition was followed. The exposition is the compliance blueprint and should be drafted to be operationally accurate and auditable.