New Assessment
Score each question 0–5 against the maturity descriptors, or mark Not Seen when evidence is ambiguous (excluded from scoring). Add an evidence reference for each score.
1
Strategic Planning & Risk Management0/12 scored
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Foundational governance: implementation planning, regulatory engagement, safety risk assessment, pilot communication, and Just Culture / data protection. The operator must prove a deliberate, safe transition from task-based to competency-based training.
Regulatory anchors
- ICAO Annex 6 Part I §9.4.4 — "equivalent level of safety" must be evidenced
- EASA ARO.OPS.226(c)(2)(iii) — records-keeping system verified as PRECONDITION to EBT approval
- ICAO Doc 9995 Ch. 5 + Ch. 6 · EASA ORO.FC.231(c) · IATA EBT IG §2.10 + App. I
P1 · Q1P0 criticalGovernanceAUDIT
Has the operator developed and submitted a formal Implementation Plan to the CAA that explicitly states the transition phase strategy (Prep → Mixed → Baseline) with named milestones and timeline?
L0 No Implementation Plan exists. Programme launched ad-hoc.
L3 Plan exists, documented, CAA-acknowledged. Phase milestones named with target dates.
L5 Plan + quarterly review with CAA. Programme has demonstrably progressed through phases on schedule with evidence of phase-gate-criteria achievement.
📚 ICAO Doc 9995 Ch. 1 §1.1 + EASA ORO.FC.231(c)
P1 · Q2P0 criticalGovernanceAUDIT
Has a formal, documented Safety Risk Assessment (SRA) been conducted for the EBT transition, signed off by the accountable manager and accepted by the CAA?
L0 No SRA. Programme launched as a syllabus change.
L3 SRA exists, signed, CAA-accepted. Hazards identified, mitigations documented and operational.
L5 SRA + annual review cycle. New hazards from operational learning are folded back. SRA is a living document.
📚 ICAO Annex 6 Part I §9.4.4 + EASA ORO.FC.231(c)
P1 · Q3P0 criticalGovernanceMOU
Is there a formal Just Culture / Data Protection MoU or Agreement between airline management and pilot representatives governing EBT data use, de-identification, and non-punitive principles?
L0 No agreement. EBT data flows freely; pilots fear disciplinary use.
L3 MoU signed, in force, gatekeeper identified, de-identification process documented and audited.
L5 MoU + annual review with pilot reps. Appeals process functional. Independent audit of data access. Zero incidents of misuse.
📚 EASA ORO.FC.231(c) + IATA EBT IG §2.11.2; Cockpit Crew Handbook §35/§37/§44
P1 · Q4ProceduralAUDIT
Has a formal Pilot Communication Plan been delivered to ALL pilots prior to EBT implementation — briefing them on EBT principles, competency framework, assessment methods, grading scale, and Just Culture protections?
L0 No briefing. Pilots discovered EBT via the syllabus.
L3 All pilots briefed before implementation. Materials documented. Attendance recorded.
L5 Briefing + annual refresher. Pilot understanding measured via survey/assessment. Continuous communication on programme evolution.
📚 ICAO Doc 9995 Ch. 5 + IATA EBT Implementation Guide §2.6
P1 · Q5GovernanceAUDIT
Is the EBT programme led by a named, accountable Project Manager / Programme Owner with documented responsibility for the Prep → Mixed → Baseline transition?
L0 No named owner. Distributed responsibility.
L3 Named owner, documented responsibility, sits in or reports to GMT-level management.
L5 Named owner + governance committee + quarterly programme reviews + executive sponsorship cadence.
📚 EASA AMC1 ORO.FC.231; JD Chapter 8 §8.8
P1 · Q6GovernanceAUDIT
Has the operator conducted a formal regulatory-conformance Gap Analysis against ICAO Doc 9995 / EASA AMC1 ORO.FC.231 / IATA ICATM, with documented findings + remediation plan?
L0 No Gap Analysis. Programme assumed conformant.
L3 Gap Analysis completed, findings documented, remediation plan with named owners + dates.
L5 Gap Analysis + annual refresh + regulator engagement on closure status.
📚 Whole regulatory dossier — anchored on EASA ARO.OPS.226
P1 · Q7P0 criticalInstrumentAMELIAAUDIT
Has the records system (TPMS or equivalent) been formally audited by the CAA or accountable manager for SUITABILITY to host EBT data at the granularity required (per-OB Level-2 capture)?
L0 No audit. System assumed suitable.
L3 Audit conducted, gaps identified, suitability statement signed off.
L5 Audit + continuous monitoring + system enhancement cycle.
📚 EASA ARO.OPS.226(c)(2)(iii) — PRECONDITION to EBT approval
P1 · Q8GovernanceAUDIT
Is the operator's current EBT phase (Prep / Mixed / Baseline) clearly identified, with time-in-phase consistent with regulatory expectations (Prep ≤1 yr; Mixed 3–5 yrs typical; Baseline indefinite)?
L0 No phase identified. Stuck without a progression plan.
L3 Current phase clearly named in documentation. Progression plan exists. Time-in-phase within regulatory expectations.
L5 Current phase + phase-gate criteria + measurable progress + on-schedule progression history.
📚 IATA EBT IG Ed. 2 §2.10 + EASA EBT Manual Section I
P1 · Q9GovernanceMOU
Are pilot union / pilot-representative bodies meaningfully consulted on EBT programme governance, data use, and grievance handling?
L0 No consultation. Programme imposed unilaterally.
L3 Formal consultation cadence + documented union/rep input + addressed concerns.
L5 Active partnership. Pilot reps participate in ICAP design + appeals + data governance.
📚 EASA ORO.FC.231(c) data protection procedures
P1 · Q10GovernanceMOU
Is there a documented appeals process for pilots to dispute EBT assessments, line-check failures, or training-programme outcomes?
L0 No appeals process. Outcomes final.
L3 Appeals process exists, documented, used. Independent panel or review mechanism.
L5 Appeals + statistical monitoring of appeal outcomes + systemic learning from upheld appeals.
📚 EASA ORO.FC.231(d)(iii) data integrity + Just Culture principles
P1 · Q11GovernanceAUDIT
Is the EBT programme tied to executive sponsorship at MD/CEO level with a quarterly-or-more-frequent reporting cadence?
L0 No executive sponsorship. Below-the-radar programme.
L3 Named executive sponsor + quarterly reporting cadence + safety-review-committee visibility.
L5 Executive sponsorship + board-level reporting + linked to corporate strategy and ramp-up plan.
📚 EASA ARO.OPS.226(d) periodic oversight + IATA EBT IG stakeholder demands
P1 · Q12GovernanceAUDIT
Has the operator quantified the cost of training failure (per-candidate failure cost, replacement cost, productivity loss) to inform the EBT business case?
L0 No cost-of-failure analysis. Failures absorbed as overhead.
L3 Cost-of-failure model exists. Used for business cases and resource allocation.
L5 Cost-of-failure + cost-of-improvement modelling + ROI analysis on EBT initiatives.
📚 Operational governance + IATA EBT IG cost-benefit framing
2
Adapted Competency Model & Grading System0/13 scored
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3
IE Standardisation & ICAP0/12 scored
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4
Data-Driven Curriculum Design0/12 scored
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5
EBT Module Execution0/11 scored
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6
Training System Performance & Feedback Loop0/13 scored
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