Same number. Two very different rulebooks. When a European maintenance organisation opens a site in the United States, the most common assumption I hear is that an EASA Part-145 approval and an FAA Part 145 certificate are roughly the same thing with different letterheads. They are not. Below are seven differences that decide how you staff, document and run a US repair station. Every point is tied to the regulation text.
1. Who may sign the release
Under 14 CFR 145.157(a), a repair station located inside the United States must ensure that each person authorized to approve an article for return to service is „appropriately certificated as a mechanic or repairman under part 65.“ The alternative of training or 18 months of practical experience in 145.157(b) applies only to repair stations located outside the United States. Under EASA Part-145, certifying staff are qualified through the Part-66 licence system and the organisation’s own authorisation (145.A.30 and 145.A.35). A Part-66 licence does not replace a Part 65 certificate at a domestic US station.
2. One manual or two
EASA expects a Maintenance Organisation Exposition (MOE). The FAA expects a Repair Station Manual whose minimum content is listed in 14 CFR 145.209 — from the organisational chart and rosters to the capability list, the training program revision procedure, work at another location and contract maintenance — plus a quality control manual under 145.211. Translating an MOE does not produce a compliant RSM. The structure is different, and FAA inspectors read against 145.209 line by line.
3. Management system and safety risk management
Commission Implementing Regulation (EU) 2021/1963 added a management system to Part-145 (145.A.200), including safety policy, occurrence reporting, safety promotion and safety risk management, plus internal safety reporting with just-culture principles (145.A.202). Existing organisations had until 2 December 2024 to comply. On the FAA side, the Safety Management System final rule of April 2024 extended 14 CFR Part 5 to Part 135 operators, §91.147 air tour operators and certain Part 21 holders. Part 145 repair stations were not included. The FAA stated it „decided not to expand the applicability of this rule beyond the original proposal.“
4. Reporting deadlines
EASA: occurrences are reported within 72 hours of the organisation becoming aware of them, unless exceptional circumstances prevent this (Regulation (EU) No 376/2014 and 145.A.60, as applied by national authorities). FAA: 14 CFR 145.221(a) requires a report „within 96 hours after it discovers any serious failure, malfunction, or defect of an article.“ Two clocks, two triggers, two report formats. A dual-approved organisation needs one internal procedure that meets the stricter timeline.
5. Training program approval
14 CFR 145.163 requires an employee training program „approved by the FAA“ with initial and recurrent training. Individual training records must be kept for at least two years, and program revisions go to the responsible Flight Standards office. EASA does not approve a separate training program in the same way; competence is managed under 145.A.30 and described in the MOE.
6. Human factors
EASA requires that personnel competence includes an understanding of human factors and human performance (145.A.30(e)), with initial training and continuation training in each two-year period (AMC2 145.A.30(e)). The FAA strongly recommends human factors content in the approved training program, but under Part 145 it is not a regulatory requirement, as FAA guidance discussed by ARSA confirmed.
7. Information security
Since 22 February 2026, Part-IS (Implementing Regulation (EU) 2023/203) applies to Part-145 maintenance organisations, with an additional 18-month period to reach full maturity of the information security management system. The text of 14 CFR Part 145 contains no equivalent requirement.
What this means in practice
From my own project work: the gaps rarely sit in the workshop. They sit in the paperwork that connects people, certificates and manuals. A US site that copies its European parent’s system usually fails on point 1 and point 2 first.
Three actions
1. Map every person who signs a release against 145.157(a). Certificate type and number, not job title.
2. Build the RSM from the 145.209 list, then cross-reference the MOE — not the other way round.
3. Write one occurrence-reporting procedure that meets the 72-hour EASA clock and the 96-hour FAA clock.
Sources
- U.S. Government — 14 CFR 145.157, 145.163, 145.209, 145.211, 145.221 (current), law.cornell.edu
- Federal Aviation Administration — Safety Management Systems Final Rule (April 2024), faa.gov
- Federal Register — Safety Management Systems, 89 FR (26 April 2024), govinfo.gov
- Transport Malta — IAN 26 Part-145, Regulation (EU) 2021/1963 changes, Issue 2 (2023), transport.gov.mt
- Transport Malta — IAN 01 Occurrence Reporting, Issue 7, transport.gov.mt
- Transport Malta — IAN 07 Human Factors Training, transport.gov.mt
- ARSA — FAA Releases Inspector Guidance on Human Factors Training Programs (6 September 2008), arsa.org
- Jones Day — Civil Aviation Cybersecurity: EASA Part-IS Sets New Information Security Obligations (February 2026), jonesday.com
- ILT (Netherlands) — Part-IS, english.ilent.nl