Phase 3 in 24 Months
The Evidence Problem No One Wants to Talk About
Head of Training, Director of Flight Operations, Compliance
CEO, Regulatory Affairs
"Most European operators will need a 24-month evidence trail to progress under EBT Phase 3. Almost none of them are building it today."
Key Metrics
Executive Summary
EASA's Evidence-Based Training framework requires more than process compliance — it requires demonstrable, longitudinal evidence of instructor concordance, observable behaviour mapping, and competency progression over a meaningful time window. Most operators are months or years behind on data collection because their existing systems were designed to record outcomes, not behaviours. This paper reads the regulation, models the data debt that builds with each delayed quarter, and walks through a "Carrier D" composite in which an operator started its 24-month evidence accrual by retrofitting Amris onto an existing TMS/LMS stack. It quantifies the audit risk of inaction (rework, deferred Phase 3 progression, delayed crew utilisation gains) and presents a sober deployment timeline that does not require ripping out existing infrastructure.
Key Themes
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