European Union Aviation Safety Agency

Notice of Proposed Amendment 2026-102

issued in accordance with Article 6 of MB Decision 01-2022

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Regular update of Regulation (EU) 2023/2117

Repository of civil-aviation-related information

RMT.0749 (SUBTASK 3)

WHAT THIS NPA IS ABOUT

This NPA proposes to amend Regulation (EU) 2023/2117 which lays down the necessary rules and detailed requirements for the functioning and management of a repository of civil-aviation-related information.

This NPA proposes to amend:

— Annex I, by removing a number of information objects;

— Article 3, Article 4 and Article 8 in relation to the use access interface, reference to data analysis and dissemination of information respectively.

The proposed regulatory material is intended to improve the exchange of civil-aviation-related information between national competent authorities, the Agency and the European Commission and allow for a more effective and realistic application of the Regulation.

REGULATION INTENDED TO BE AMENDED Regulation (EU) 2023/2117

ED DECISION(S) INTENDED TO BE AMENDED/ISSUED n/a

AFFECTED STAKEHOLDERS Member States, European Commission, accident/incident investigation authorities, EASA

WORKING METHODS

Development Impact assessment(s) Consultation

By EASA Light

NPA - Focused

RELATED DOCUMENTS/INFORMATION

ToR RMT.0749, issued on 20.6.2024

PLANNING MILESTONES: Refer to Volume II of the latest EPAS edition.

European Union Aviation Safety Agency NPA 2026-102

Contents

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Contents

1. About this NPA ........................................................................................................ 4

1.1. How this regulatory material was developed .................................................................... 4

1.2. How to comment on this NPA ............................................................................................ 4

1.3. The next steps .................................................................................................................... 4

2. In summary — why and what .................................................................................. 6

2.1. Why we need to act............................................................................................................ 6

2.1.1. Description of the issue............................................................................................ 6

2.1.2. Who is affected by the issue .................................................................................... 7

2.1.3. Conclusion on the need for rulemaking ................................................................... 7

2.2. What we want to achieve — objectives ............................................................................. 8

2.3. How we want to achieve it — overview of the proposed amendments ........................... 8

2.4. Stakeholders’ views ............................................................................................................ 9

2.5. Other relevant information .............................................................................................. 10

3. Expected benefits and drawbacks of the proposed regulatory material .................. 11

4. Proposed regulatory material ................................................................................ 12

5. Monitoring and evaluation .................................................................................... 15

6. Actions to support implementation ....................................................................... 16

7. References............................................................................................................. 17

Appendix 1 — Impact assessment ................................................................................... 18

1. Introduction ...................................................................................................................... 18

2. What are the possible options ......................................................................................... 18

3. Methodology and data (optional) .................................................................................... 18

(a) Methodology applied ............................................................................................. 18

(b) Data collection ....................................................................................................... 18

4. What are the impacts ....................................................................................................... 20

(a) Safety impact.......................................................................................................... 20

(b) Environmental impact ............................................................................................ 20

(c) Social impact .......................................................................................................... 20

(d) Economic impact .................................................................................................... 20

(e) General Aviation and proportionality issues .......................................................... 23

5. Conclusion ........................................................................................................................ 24

(a) Comparison of the options..................................................................................... 24

(b) Question to stakeholders ....................................................................................... 24

Appendix 2 — Quality of the NPA ................................................................................... 25

1. The regulatory proposal is of technically good/high quality ............................................ 25

2. The text is clear, readable and understandable ............................................................... 25

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Contents

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3. The regulatory proposal is well substantiated ................................................................. 25

4. The regulatory proposal is fit for purpose (achieving the objectives set) ........................ 25

5. The regulatory proposal is proportionate to the size of the issue ................................... 25

6. The regulatory proposal applies the ‘better regulation’ principles ................................. 25

7. Any other comments on the quality of this document (please specify) .......................... 25

European Union Aviation Safety Agency NPA 2026-102

1. About this NPA

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1. About this NPA

1.1. How this regulatory material was developed

The European Union Aviation Safety Agency (EASA) identified an issue (as described in Chapter 2), and

after having assessed the impact of the possible intervention actions and having consulted those with

the EASA Advisory Bodies, identified rulemaking as the necessary intervention action.

This rulemaking activity is included in the 2026 edition of Volume II of the European Plan for Aviation

Safety (EPAS)1 under Rulemaking Task (RMT).0749, Subtask 3.

EASA developed the regulatory material in question in line with Regulation (EU) 2018/11392 (the Basic

Regulation) and the Rulemaking Procedure3, as well as in accordance with the objectives and working

methods described in the Terms of Reference (ToR) for this RMT4.

When developing the regulatory material, EASA received the input and support from the Member

States’ Advisory Body (MAB) in its capacity as the ‘Repository Steering Committee (RSC)’.

1.2. How to comment on this NPA

The draft regulatory material is hereby submitted for consultation with the MAB in accordance with

the ToR for this RMT.

Please submit your comments via email to [email protected].

The deadline for the submission of comments is 15 May 2026.

1.3. The next steps

Following the consultation of the draft regulatory material, EASA will review all the comments

received and will duly consider them in the subsequent phases of this rulemaking activity.

Considering the above, EASA may issue an opinion proposing amendments to Regulation (EU)

2023/21175. The opinion will be submitted to the European Commission which shall consider its

content and decide whether to issue amendments to that Regulation.

1 European Plan for Aviation Safety (EPAS) 2026 - 15th edition | EASA 2 Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common rules in the field

of civil aviation and establishing a European Union Aviation Safety Agency, and amending Regulations (EC) No 2111/2005, (EC) No 1008/2008, (EU) No 996/2010, (EU) No 376/2014 and Directives 2014/30/EU and 2014/53/EU of the European Parliament and of the Council, and repealing Regulations (EC) No 552/2004 and (EC) No 216/2008 of the European Parliament and of the Council and Council Regulation (EEC) No 3922/91 (OJ L 212, 22.8.2018, p. 1, http://data.europa.eu/eli/reg/2018/1139/oj).

3 EASA is bound to follow a structured rulemaking process as required by Article 115(1) of Regulation (EU) 2018/1139. Such a process has been adopted by the EASA Management Board (MB) and is referred to as the ‘Rulemaking Procedure’. See MB Decision No 01-2022 of 2 May 2022 on the procedure to be applied by EASA for the issuing of opinions, certification specifications and other detailed specifications, acceptable means of compliance and guidance material ('Rulemaking Procedure'), and repealing Management Board Decision No 18-2015 (EASA MB Decision No 01-2022 on the Rulemaking Procedure, repealing MB Decision 18-2015 (by written procedure) | EASA (europa.eu)).

4 ToR RMT.0749 - Regular update of Regulation (EU) 2023/2117 (Repository of civil-aviation-related information) | EASA 5 Commission Implementing Regulation (EU) 2023/2117 of 12 October 2023 laying down the necessary rules and

detailed requirements for the functioning and management of a repository of information pursuant to Regulation (EU) 2018/1139 of the European Parliament and of the Council (OJ L, 2023/2117, 13.10.2023, http://data.europa.eu/eli/reg_impl/2023/2117/oj).

European Union Aviation Safety Agency NPA 2026-102

1. About this NPA

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When issuing the opinion, EASA will also provide feedback to the commentators and information to

the public on who engaged in the process and/or provided comments during the consultation of the

draft regulatory material, which comments were received, how such engagement and/or consultation

was used in rulemaking, and how the comments were considered.

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2. In summary — why and what

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2. In summary — why and what

2.1. Why we need to act

Since the adoption of Regulation (EU) 2023/2117, the Agency, together with the RSC and the European

Commission, identified issues requiring an amendment to the Regulation regarding the list of

information objects in Annex I. These issues, if they are not solved today, would require

disproportionate investments by Member States and the Agency to enable the exchange of

information with no added benefit for safety. The Agency also identified a few issues in various articles

of the Regulation, which should be corrected.

2.1.1. Description of the issue

The need to act is driven by priority considerations to enable the most effective manner to upload the

necessary information objects to the repository.

Annex I – list of information objects

Various information objects have been identified as not being relevant for exchange through the

repository because either the information they bear is considered to bring no added value or they are

already exchanged through other means. Some would be very difficult to implement while certain

certificates or approvals do not exist. Maintaining these information objects in the repository will

require significant investments by the national competent authorities (NCAs) and the Agency which

are, because of the lack of added value, considered disproportionate.

In particular, the information objects related to medical data were discussed within the Medical Expert

Group that identified that such data exchange is problematic for the following reasons:

— The ‘Application form for pilot medical certificate’ and the ‘Pilot medical examination forms and

supporting medical certificates’ are information objects containing sensitive personal (health)

data. This would require an increase in information security measures for the entire repository.

— In several Member States, the storage of health data in the reporitory is not allowed by

legislation.

— Potentially, a medical broker would be required even if only one Member State is not allowed

to store health data in the repository. This further increases the information security risks and

will require significant investments. Moreover, the lack of a central storage of data does not

allow for the analysis of that data.

— The Medical Expert Group should be given more time to find solutions addressing the storage

issue, eliminating the need for a medical broker.

Therefore, the two objects related to medical data should be removed, to avoid the costly and

ineffective implementation pending the development of a better solution.

Article 3, paragraph 4 of Regulation (EU) 2023/2117

The repository is designed to store the data sent by the NCAs. However, it cannot be excluded that in

the future, certain data will be exchanged without being stored. This would be the case whenever a

medical broker solution (as referred to above) would be required. However, the current wording in

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2. In summary — why and what

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Article 3(4) seems to exclude that information — which is exchanged through a broker without being

stored — is presented in the user interface.

Article 4 of Regulation (EU) 2023/2117

In accordance with Article 74(1) of the Basic Regulation, the Agency shall establish and manage the

repository to ‘ensure effective cooperation between the Agency and the national competent

authorities concerning the exercise of their tasks relating to certification, oversight and enforcement

under this Regulation.’ In order to ensure an effective cooperation, it is considered that the analysis

of data in the repository is important for various processes like safety data analysis, standardisation

activities, rulemaking, etc. However, the Regulation currently does not include any explicit mandate

for the analysis of data.

Article 8 of Regulation (EU) 2023/2117

The current wording of Article 8 is such that interested parties may request the Agency to disseminate

information contained in the repository. However, the vast majority of the information objects are

copies of certificates issued by the NCAs of the Member States; hence, it is expected that also the

majority of dissemination requests are related to certificates which are not issued by the Agency. In

accordance with Article 4(4) of Regulation (EC) No 1049/20016, the Agency would need to consult the

Member States (unless it is clear that the document shall or shall not be disclosed).

The second subparagraph of Article 74(6) of the Basic Regulation stipulates that the Commission and

the Agency may disseminate the repository’s information ‘where relevant’. That requirement should

be understood to mean that it is relevant for the Agency to disseminate information objects

originating from it, namely those issued by the Agency. Conversely, it should not be considered

relevant for the Agency to disseminate information objects stored in the repository that were issued

by an NCA. In such cases, the NCA is better placed to assess requests for dissemination, since it is not

only in possession of the original document, whereas the Agency holds only a copy, but also in a

position to assess whether the conditions laid down in Article 8(3) and (4) of Regulation (EU)

2023/2117 are fulfilled.

An amendment of Article 8 would relieve the Agency and the NCAs from the administrative burden,

and limit the risk that they both may have different opinions on the validity of the request.

2.1.2. Who is affected by the issue

The affected stakeholders are the European Commission, the NCAs, the safety investigation

authorities and the Agency.

2.1.3. Conclusion on the need for rulemaking

EASA concluded, as explained further in Chapter 3 below, that an intervention was necessary and that

non-regulatory actions cannot effectively address the issue. Therefore amendments to Regulation

(EU) 2023/2117 are required.

6 Regulation (EC) No 1049/2001 of the European Parliament and of the Council of 30 May 2001 regarding public access to European Parliament, Council and Commission documents (OJ L 145, 31.5.2001, p. 43, http://data.europa.eu/eli/reg/2001/1049/oj).

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2. In summary — why and what

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2.2. What we want to achieve — objectives

The overall objectives of the EASA system are defined in Article 1 of the Basic Regulation. The

regulatory material presented here is expected to contribute to achieving these overall objectives by

addressing the issues described in Section 2.1.

More specifically, with the regulatory material presented here, EASA intends to ensure that the

repository only contains the necessary information objects that can be exchanged, are relevant for

the authorised users and bring added value, according to a priority system that ensures the effective

cooperation between the Agency and the NCAs. By removing from Annex I those information object

categories which have no added value, unnecessary costs for the NCAs and EASA are avoided.

While proposing the amendments to Annex I, the Agency aims at also correcting three specific

provisions in the Regulation regarding the user access interface, data analysis and dissemination of

information.

2.3. How we want to achieve it — overview of the proposed amendments

The following changes are proposed:

Annex I – List of information objects

16 information objects are proposed to be removed from Annex I:

— Aerodrome equipment certificate

— ATM/ANS systems and ATM/ANS constituents – Statement of compliance

— Decision of a Member State on the designation of a single common information service provider

— Permit to fly

— Permit to fly – approval of flight conditions

— Declaration as provider of training for UAS operators

— Cabin crew medical report

— Maintenance Review Board (MRB) Report approval

— Theoretical knowledge examinations (ECQB)

— Airworthiness directives (ADs), Safety directives, Safety Information Bulletins (SIBs)

— Draft recommendations for reply to ICAO State Letters

— Recommendations for reply to ICAO State Letters

— Alternative means of compliance requests

— Application form for pilot medical certificate

— Pilot medical examination forms and supporting medical certificates

— Maintenance organisation approvals (MOA) – Part M Subpart F EASA Form 3-MF

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2. In summary — why and what

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Amendment to paragraph 4 in Article 3 – Establishment of the repository

Paragraph 4 of Article 3 is proposed to be amended as follows: ‘The User Access interface referred to

in paragraph 1 shall provide for an online and secure query and read access to the exchanged

information. (…)’ instead of ‘….the stored information’.

New paragraph 5 in Article 4 – Management of the repository

A new paragraph 5 is proposed to be added to Article 4: ‘The Agency may analyse the information in

the repository to support the tasks of the Agency and the national competent authorities relating to

certification, oversight and enforcement.’

Amendment to Article 8 – Arrangements for the dissemination of information

Article 8 is proposed to be amended to leverage the wording of the Basic Regulation ‘where relevant’

in Article 74(6) second subparagraph, and to interpret it such that it is only relevant for the Agency to

disseminate information that originates from it. This amendment uses the concept of ‘competent

authority’, indirectly requiring the applicant to lodge the request with the competent authority.

Consequential amendments to that of Article 8

New recital

As the competent authority responsible for issuing an information object stored in the repository has

the best knowledge of that information object, the responsibility for handling requests from

interested parties concerning such information objects should lie with that competent authority.

Amendment to Article 2 – Definitions

(h) ‘competent authority’ means either the Agency or the national competent authority designated

by a Member State, that has issued the information object included in the repository, in accordance

with Article 62(4) of Regulation (EU) 2018/1139 regarding the performance of tasks related to

certification, oversight and enforcement.

Targeted applicability of the regulatory material

EASA intends to issue an Opinion in 2026 Q2, ahead of the planning in Volume II of EPAS 2026, so that

the implementing act can be adopted by 2026 Q4. No transition period or deferred applicability date

is provided for.

Legal basis

The legal basis for amending Regulation (EU) 2023/2117 is Article 74(8) of the Basic Regulation.

2.4. Stakeholders’ views

Overall, the RSC members largely agreed during its last meeting in February 2026 with the EASA

proposals.

— RSC agreed with the removal of the proposed information objects in Annex I.

An additional survey related to the removal of medical data showed that the members of the

RSC agreed with the proposal.

— RSC largely agreed to the amendments to Articles 3 and 4 of Regulation (EU) 2023/2117.

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— Even though EASA was still developing the amendment to Article 8 of Regulation (EU)

2023/2117 during the said meeting, the RSC agreed to the envisaged changes.

With regard to the removal of the two medical objects pending the development to address the known

issues, the Medical Expert Group was consulted through a survey; twenty-seven out of the twenty-

eight respondents agreed with such removal.

2.5. Other relevant information

The proposed amendments in this NPA stem from the rulemaking activity under RMT.0479, Subtask

3.

In 2025, NPA 2025-103 (RMT.0479, Subtask 2) proposed a set of amendments to Regulation (EU)

2023/2117 related to the entry into force and application of Article 18 and to the priority group for a

few information objects in Annex I.

After the focused consultation of NPA 2025-103, EASA and the European Commission discussed the

overall approach for this rulemaking task, in the context of the rule simplification project. It was agreed

that Subtask 2 and Subtask 3 should be merged, leading to a single Opinion.

For that reason, the processing of Subtask 2 has been put on hold and will resume along with the

processing of Subtask 3.

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3. Expected benefits and drawbacks of the proposed regulatory material

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3. Expected benefits and drawbacks of the proposed regulatory material

When developing the proposed regulatory material, EASA identified different regulatory options on

how to achieve the objectives described in Section 2.2 and assessed their impacts. See Appendix 1

that contains the detailed impact assessment for the changes proposed to Annex I to the Regulation.

Based on the impact assement, two policy options are available:

— Do nothing, and

— Implement the changes as proposed in this NPA.

The impact assessment shows that while there is no impact on safety for both options, doing nothing

would lead to a total cost for the NCAs and EASA of €4M over a period of five years.

This rulemaking task was identified as a short-term action under the EASA rule simplification

programme. The proposed changes contribute to rule simplification, notably through the cost savings

that would be realised for both competent authorities and EASA if the proposals are adopted.

The proposed regulatory material has been developed in view of the better regulation principles, and

in particular the regulatory fitness principles.

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4. Proposed regulatory material

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4. Proposed regulatory material

4.1. Annex I to Regulation (EU) 2023/2117 is amended as follows:

ANNEX I

LIST OF INFORMATION OBJECTS

Information object Priority groups

Licences

[…] […]

Certificates – Organisations

[…] […]

Aerodrome operator certificate B

[…] […]

Certificates – Personnel

[…] […]

Certificates – Products/Equipment

[…] […]

Certificates – Medical

[…] […]

Application form for pilot medical certificate C

Pilot medical examination forms and supporting medical certificates C

Declarations

[…] […]

ATM/ANS systems and ATM/ANS constituents – Statement of compliance B

Declaration of provider of training for UAS operators C

[…] […]

Attestations and reports

[…] […]

Cabin crew medical report C

Exemptions

[…] […]

Approvals

Permit to fly – approval of flight conditions C

Permit to fly C

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4. Proposed regulatory material

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Maintenance Review Board (MRB) Report approval C

Theoretical knowledge examinations (ECQB) C

[…] […]

Maintenance Organisation approvals (MOA) – Part M Subpart F EASA Form 3-MF B

[…] […]

Decisions

[…] […]

Decision of a Member State on the designation of a single common information service provider

B

Measures

[…] […]

Others

[…] […]

Airworthiness directives (AD), Safety directives, Safety Information Bulletins (SIB) C

Draft recommendations for reply to ICAO State Letters C

[…] […]

Recommendations for reply to ICAO State Letters C

Alternative Means of Compliance requests C

4.2. A new recital is added:

As the competent authority responsible for issuing an information object stored in the repository has

the best knowledge of that information object, the responsibility for handling requests from

interested parties concerning such information objects should lie with that competent authority.

4.3. A new definition is added in Article 2 of Regulation (EU) 2023/2117:

(g) […]

(h) ‘competent authority’ means either the Agency or the national competent authority designated

by a Member State, that has issued the information object included in the repository, in accordance

with Article 62(4) of Regulation (EU) 2018/1139 regarding the performance of tasks related to

certification, oversight and enforcement.

(i) […]

4.4. Paragraph 4 of Article 3 of Regulation (EU) 2023/2117 is amended as follows:

3. […]

4. The User Access interface referred to in paragraph 1 shall provide for an online and secure query

and read access to the stored exchanged information. […]

5. […]

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4. Proposed regulatory material

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4.5. A new paragraph 4 is added to Article 5 of Regulation (EU) 2023/2117:

3. […]

4. The Agency may analyse the information in the repository to support the tasks of the Agency and

the national competent authorities relating to certification, oversight and enforcement.

4.6. Article 8 of Regulation (EU) 2023/2117 is amended as follows:

1. The Agency competent authority may, upon request of an interested party, provide such interested

party with the information contained in the repository subject to the specific conditions of use set out

in this Article. The interested parties shall address their request to the competent authority

responsible for issuing the information object included in the repository.

If the competent authority receives a request for an information object included in the repository, for

which another competent authority is responsible, it shall refer the request without undue delay to

that competent authority. If the interested party is unable to identify the authority that issued the

information object contained in the repository, it shall submit its request to the Agency.

2. […]

3: When receiving a request, the Agency competent authority shall verify that:

(a) the request is made by an interested party; and

(b) the interested party demonstrates that the requested information is strictly necessary to the

interested party’s own operations.,

unless that information has been or is publicly available in accordance with Regulation (EU)

2018/1139.

4: The Agency competent authority shall evaluate whether the request is justified and if the conditions

laid down in paragraph 5 are met, it shall provide the interested party with the information requested.

5: The Agency competent authority shall provide the requested information to the interested party

only under the following conditions:

(a) the interested party does not receive access to the entire content of the repository;

(b) the information is strictly necessary for the interested party’s own operations;

(c) no personal data is disseminated unless such data concerns the interested party itself or if such

dissemination is strictly necessary to perform the operations of the interested party.

6. The Agency shall make available to the authorised users an updated list of requests received and

action taken by the Agency.

7 6. The interested party shall:

(a) use the information only for the purpose specified in the request form;

(b) not disclose the information received without the authorisation of the authorised users;

(c) take the necessary measures to ensure the confidentiality of the information received.

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5. Monitoring and evaluation

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5. Monitoring and evaluation

No specific monitoring or evaluation of the proposed amendments is envisaged.

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6. Proposed actions to support implementation

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6. Actions to support implementation

No specific action to support the implementation of the proposed amendments is envisaged.

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Appendix 1 — Impact assessment(s)

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7. References

n/a

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Appendix 1 — Impact assessment

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Appendix 1 — Impact assessment

1. Introduction

This proposed amendment is intended to prevent unnecessary costs by removing a number of

information object categories from Annex I to Regulation (EU) 2023/2117. Therefore, the impact

assessment quantifies the costs for the NCAs and EASA which would likely occur if this regulatory

change would not be implemented.

2. What are the possible options

The available options are: do nothing or reduce the scope of Annex I

Table 1: Selected policy options

Option

No

Short title Description

0 No policy change

1 Remove unnecessary elements from Annex I to Regulation (EU)

2023/2117 as proposed

3. Methodology and data (optional)

(a) Methodology applied

EASA calculated estimates for the implementation costs if policy option 0 (the baseline) is taken, which

assumes that none of the information object categories would be deleted from Annex I to Regulation

(EU) 2023/2117. The estimates for the implementation by the NCAs are based on a number of

assumptions, as reliable data for more accurate calculations is not available. NCAs are welcome to

comment on these estimates. For EASA’s own costs, a more reliable estimate can be made by drawing

a direct comparison with the Priority A information object categories as sufficient experience has been

gained from their implementation.

(b) Data collection

EASA sent surveys in 2025 and 2026 to the NCAs before preparing the data models for the Priority A

and B information object categories; these surveys included information on the volume of objects

which was used for this impact assessment. In addition, data was used which is available in EASA

information systems and or reports available at the EASA website. In a limited number of cases (for

the object categories ‘Declaration as provider of training for UAS operators’ and ‘Theoretical

knowledge examinations (ECQB)’), an estimation had to be made.

The costs are calculated for implementation by the NCAs (including EASA) to establish machine-to-

machine connections or alternatively, to upload (low volume data) manually to TRACE. Secondly, the

costs for EASA to develop the data models in TRACE are calculated over a five-year period, reflecting

both the one-time investment and the recurring annual costs under the multiannual contract.

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TRACE IMPLEMENTATION — NCAs

The number of certificates is estimated using surveys sent out to the NCAs, using data available in

EASA information systems and or reports available at the EASA website. Estimations are made using

the following assumptions:

1. Only one NCA per EASA Member State needs to implement TRACE.

2. 30 % of the EASA Member States (typically the larger ones) use digitalised systems (or will

develop a digitalised system) to manage the certificates; these NCAs are referred to as the

‘digitalised NCAs’. These digitalised NCAs manage 70 % of the total certificates in the EASA

Member States.

Whenever it is likely that digitalised systems already exist, the calculation will use a lump sum

of €10K to connect the systems to TRACE; otherwise, it uses a lump sum of €30K to establish

such a system.

3. The remaining 30 % of the certificates will be manually entered by 70 % of the NCAs, referred

to as the ‘non-digitalised NCAs’.

When the manual upload costs are higher than the costs to digitalise all of the non-digitalised

NCAs, the costs to digitalise all NCAs will be applied.

4. When the Agency is the only NCA, the Agency will opt for either the cheapest solution of manual

entry or digitalising the process.

The actual costs are likely to exceed these estimates, as annual maintenance costs have not been

included and the number of certificates derived from the surveys may be underestimated, given that

complete datasets were not available from all NCAs.

TRACE IMPLEMENTATION — EASA

The costs for EASA to extend the scope of TRACE can be calculated more accurately than the costs for

the implementation by the NCAs, because of the experience gained by implementing the first 15

object categories. These costs consist of the preparation of the data model, the costs to extend the

‘back-end’ (database and APIs), the costs to build the ‘front-end’ (the user interface) and the costs for

testing the entire system. Some object categories have more complex data models, leading to higher

costs. In both cases, the costs have been calculated for a five-year period, allowing for both annual

and one-time costs to be taken into account.

The implementation of a non-existing object category (Aerodrome equipment certificate) and a

discontinued object category (Maintenance Organisation approvals (MOA) – Part M Subpart F EASA

Form 3-MF) are not calculated as costs for the NCAs, as there are no certificates to upload. However,

EASA would need to extend TRACE with these objects. Similarly, since the deletion of the two medical

information objects is considered as a postponement of the implementation, no cost-saving for the

NCA is calculated. However, the costs for the implementation by EASA is listed as significantly higher

costs than for other information object categories, due to the need for a ‘medical broker’ and

increased information security measures. These extra costs are totally arbitrary and will probably be

higher than estimated.

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4. What are the impacts

The calculations provided in the tables below show that the estimates for the implementation by the

NCAs would lead to a five-year running cost of almost €2.5M, whereas the five-year costs for the

implementation in TRACE by EASA would lead to a cost of almost €1.6M.

Therefore:

— policy option 0 (do nothing) would lead to the above-mentioned costs; and

— policy option 1 (amend Annex I to Regulation (EU) 2023/2117 as proposed) would avoid these

costs.

(a) Safety impact

In the preparation phase of this NPA, it was already concluded that the object categories which are

proposed for permanent removal do not bring any added value, so there is has no impact on safety.

The exchange of the medical objects would have a positive impact on aviation safety; however, if these

were to be implemented under the current circumstances, the implementation would be ineffective,

expensive and lead to higher information security risks. Therefore, it was agreed with the MAB and

the Medical Expert Group that the implementation should be postponed, allowing for investigations

on how these object categories can be implemented better.

(b) Environmental impact

No impact.

(c) Social impact

No impact

(d) Economic impact

The economic impact of this regulatory proposal relates to the costs that would be incurred by the

NCAs and EASA if the information object categories proposed for removal were to remain in Annex I

(i.e. under Option 0, ‘do nothing’). The implementation of Option 1 would avoid these costs.

The costs quantified in this impact assessment are predominantly one-off adjustment costs. They

represent the investments that NCAs and the Agency would need to make to adapt their information

systems and processes to enable the exchange of the relevant information objects through the

repository (TRACE). For the NCAs, these costs consist of establishing machine-to-machine connections

between national systems and TRACE, or, where digitalised systems do not exist, building such

systems or manually entering data. For the Agency, the costs consist of creating the data models,

developing the back-end and front-end components of TRACE, and testing the system.

The costs are presented over a five-year period because the implementation of several information

object categories requires commitments that extend beyond a single budget year. In particular, the

development of IT back-end infrastructure (e.g. SAP-based services) entails multi-annual contractual

arrangements, and the phased roll-out of new data models means that implementation efforts are

spread over several years.

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Table 2: Summary of the average yearly adjustment cost

Average yearly adjustment costs Share of total average yearly

adjustment costs

Adjustment costs for EASA €324 320 40 %

Adjustment costs for NCAs €479 730 60 %

Table 3: Estimated adjustment costs avoided under Option 1 (five-year period)7

TRACE IMPLEMENTATION AT NCAS AND EASA

Administrative activity Competent authority

Number of certificates

Hours per certificate

if done manually

One-time costs if data

already digitalised

One-time costs if data to

be digitalise

d

Five-year costs Average

yearly costs

Aerodrome equipment certificate

NCA 0 0 €10 000 €30 000 €0 €0

ATM/ANS systems and ATM/ANS constituents – Statement of compliance

NCA 160 4 €10 000 €30 000 €125 674 €25 135

Decision of a Member State on the designation of a single common information service provider

NCA 25 2 €10 000 €30 000 €92 787 €18 557

Permit to fly NCA 2 900 2 €30 000 €593 292 €118 658

Permit to fly – approval of flight conditions

NCA 1 100 2 €30 000 €392 628 €78 526

Permit to fly – approval of flight conditions

EASA 300 2 €30 000 €30 000 €6 000

Declaration as provider of training for UAS operators

NCA 25 2 €10 000 €30 000 €92 787 €18 557

Cabin crew medical report

NCA 22 000 2 €30 000 €900 000 €180 000

Maintenance Review Board (MRB) Report approval

EASA 30 2 €10 000 €30 000 €6 000 €1 200

Theoretical knowledge examinations (ECQB)

NCA 1 000 2 €10 000 €30 000 €201 480 €40 296

Airworthiness directives (AD), Safety directives, Safety Information Bulletins (SIB)

EASA 500 8 €12 000 €50 000 €12 000 €2 400

Draft recommendations for reply to ICAO State Letters

EASA 7 2 €10 000 €30 000 €1 400 €280

7 The following hourly rates have been used for cost calculations: €37.16 for competent authorities (Eurostat ISCO-3 default) and €100 for EASA IT resources (average cost of EASA staff and IT consultants).

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Recommendations for reply to ICAO State Letters

EASA 7 2 €10 000 €30 000 €1 400 €280

Alternative Means of Compliance requests

EASA 100 8 €10 000 €30 000 €10 000 €2 000

Application form for pilot medical certificate

NCA 0 0 €12 000 €50 000 €0 €0

Pilot medical examination forms and supporting medical certificates

NCA 0 0 €12 000 €50 000 €0 €0

Maintenance Organisation approvals (MOA) – Part M Subpart F EASA Form 3-MF

NCA 0 0 €10 000 €30 000 €0 €0

TECHNICAL IMPLEMENTATION OF TRACE AT EASA

Competent authority

EASA hours for

preparation

EASA hours for front

end

EASA hours for testing

Five-year SAP costs

for backend

Five-year implementation

costs

Average yearly costs

Aerodrome equipment certificate

EASA 80 248 64 €30 000 €69 200 €13 840

ATM/ANS systems and ATM/ANS constituents – Statement of compliance

EASA 80 248 64 €30 000 €69 200 €13 840

Decision of a Member State on the designation of a single common information service provider

EASA 80 248 64 €30 000 €69 200 €13 840

Permit to fly EASA 80 248 64 €30 000 €69 200 €13 840

Permit to fly – approval of flight conditions

EASA 80 248 64 €30 000 €69 200 €13 840

Declaration as provider of training for UAS operators

EASA 80 248 64 €30 000 €69 200 €13 840

Cabin crew medical report

EASA 80 248 64 €30 000 €69 200 €13 840

Maintenance Review Board (MRB) Report approval

EASA 80 248 64 €30 000 €69 200 €13 840

Theoretical knowledge examinations (ECQB)

EASA 80 248 64 €30 000 €69 200 €13 840

Airworthiness directives (AD), Safety directives, Safety Information Bulletins (SIB)

EASA 80 312 80 €50 000 €97 200 €19 440

Draft recommendations for reply to ICAO State Letters

EASA 80 248 64 €30 000 €69 200 €13 840

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Recommendations for reply to ICAO State Letters

EASA 80 248 64 €30 000 €69 200 €13 840

Alternative Means of Compliance requests

EASA 80 248 64 €30 000 €69 200 €13 840

Application form for pilot medical certificate

EASA 160 500 160 €200 00

0 €282 000 €56 400

Pilot medical examination forms and supporting medical certificates

EASA 160 500 160 €200 00

0 €282 000 €56 400

Maintenance Organisation approvals (MOA) – Part M Subpart F EASA Form 3-MF

EASA 80 248 64 €30 000 €69 200 €13 840

EASA €1 621 600 €324 320

NCAs €2 398 648 €479 730

TOTAL (EASA and NCAs) €4 020 248 €804 050

In addition to the one-off adjustment costs quantified above, the continued inclusion of these

information object categories in Annex I would, once implemented, give rise to administrative costs

for NCAs. These would stem from the obligation to keep the repository data up to date (e.g. uploading

new certificates, updating existing records, and removing expired ones on an ongoing basis). Such

recurring activities constitute administrative obligations and would represent recurring administrative

costs on the NCAs.

However, since the information object categories in question have not been implemented in TRACE,

and the purpose of this regulatory proposal is precisely to prevent their implementation, these

administrative costs have not been incurred and will not materialise under Option 1. In accordance

with the principle of proportionality, to avoid spending resources on an analysis with a self-evident

outcome, a detailed quantification of these future administrative costs has not been undertaken. Their

magnitude would in any case be very small relative to the one-off adjustment costs presented above,

as they would consist primarily of staff time for routine data entry and maintenance activities across

a limited number of records.

Under Option 0 (‘do nothing’), the total estimated adjustment costs over a five-year period amount

to approximately €2.4 million for the NCAs and approximately €1.6 million for the Agency, resulting in

a combined cost of approximately €4 million. Under Option 1 (‘amend Annex I as proposed’), these

costs are avoided with no negative impact on safety.

(e) General Aviation and proportionality issues

No impact.

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5. Conclusion

(a) Comparison of the options

As outlined above, doing nothing would require the implementation of information object categories

which do not exist, have no added value or of which the implementation under the current

circumstances would require significant investments while being ineffective.

Table x: ‘Comparison of the options’

Impact criteria Option 0 ‘do nothing’ Option 1 ‘amend Annex 1’

Safety impact No impact. No impact.

Economic impact Cost would be incurred as

planned if there would be no

amendment to the Annex I.

Estimated savings amounting

€4M over five years.

(b) Question to stakeholders

Stakeholders are invited to provide any other quantitative information they find necessary to bring to

the attention of EASA. EASA will consider that information when finalising the impact assessment.

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Appendix 2 — Quality of the NPA

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Appendix 2 — Quality of the NPA

To continuously improve the quality of its documents, EASA welcomes your feedback on the quality

of this document with regard to the following aspects:

Please provide your feedback on the quality of this document as part of the other comments you have

on this NPA. We invite you to also provide a brief justification, especially when you disagree or strongly

disagree, so that we consider this for improvement.Your comments will be considered for internal

quality assurance and management purposes only and will not be published (e.g. as part of the CRD).

1. The regulatory proposal is of technically good/high quality

Please choose one of the options

Fully agree / Agree / Neutral / Disagree / Strongly disagree

2. The text is clear, readable and understandable

Please choose one of the options

Fully agree / Agree / Neutral / Disagree / Strongly disagree

3. The regulatory proposal is well substantiated

Please choose one of the options

Fully agree / Agree / Neutral / Disagree / Strongly disagree

4. The regulatory proposal is fit for purpose (achieving the objectives set)

Please choose one of the options

Fully agree / Agree / Neutral / Disagree / Strongly disagree

5. The regulatory proposal is proportionate to the size of the issue

Please choose one of the options

Fully agree / Agree / Neutral / Disagree / Strongly disagree

6. The regulatory proposal applies the ‘better regulation’ principles[1]

Please choose one of the options

Fully agree / Agree / Neutral / Disagree / Strongly disagree

7. Any other comments on the quality of this document (please specify)

[1] For information and guidance, see:

− https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-

how_en

− https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-

how/better-regulation-guidelines-and-toolbox_en