Guide 1 of 3 · The deadline
The CASA SMS deadline: what must be running by 2 December 2026
The exemption that let small air transport and aerial work operators defer their Safety Management System ends on 1 December 2026. This is what it means, who it applies to, and what you actually need to have working, in plain English.
Written for chief pilots, heads of operations and owner-operators. Updated 2 September 2026. General information only; confirm anything that affects your certificate with CASA or your safety adviser.
The short version
- CASA instrument EX73/24 let operators under CASR Parts 119, 121, 133, 135 and 138 defer implementing a Safety Management System (SMS). The SMS provisions in that exemption cease on 1 December 2026.
- From 2 December 2026 you must be operating a documented SMS that meets the framework in your operator-class Part, and your nominated safety manager must have been accepted by CASA.
- CASA asked for SMS procedures and the safety manager nomination to be submitted by 1 September 2026 so it could be assessed in time. If you missed that date, you are not alone, and you should submit now rather than wait.
- Part 119 air transport operators must also have a Human Factors and Non-Technical Skills (HFNTS) training program in place by the same date, and some must have a Flight Data Analysis Program (FDAP).
- Small operators with ten or fewer operational safety-critical personnel may qualify as a micro-operator, which lets the CEO or head of flying operations also hold the safety manager position.
Who this applies to
| If you hold | Do you need an SMS by 2 December 2026? |
|---|
| Part 119 Air Operator's Certificate (any air transport operation, including small charter under Part 135 and rotorcraft under Part 133) | Yes. All of them. Plus HFNTS, plus FDAP if regulation 119.195 applies to you. |
| Part 138 Aerial Work Certificate | Only if you transport marine pilots, carry fireground personnel, operate multi-engine transport-category rotorcraft over 3,175 kg MTOW, operate multi-engine aeroplanes over 5,700 kg MTOW, or operate turbofan or turbojet aeroplanes. Regulation 138.140 and Chapter 5 of the Part 138 Manual of Standards set the trigger. |
| Part 119 and Part 138 together | Yes, because of the Part 119 certificate. One SMS can cover both operations if it is written that way. |
| Part 142 flight training | Part 142 has carried its own SMS requirement for years. This deadline does not change that. |
| Part 137 aerial application, Part 131 balloons, Part 141 training, Part 91 only | Not caught by EX73/24. Watch Part 5 of CASR, the all-of-industry SMS rule CASA is developing, which will extend a consistent SMS standard to more certificate holders. |
| Part 145 maintenance organisation | Separate SMS pathway under its own framework. If you hold Part 145 alongside a Part 119 AOC you have two SMS streams to coordinate. |
Source: CASA, "Aerial work operators – what you must do" and "Air transport operators – what you must do", flight operations regulations transition pages.
The dates that matter
| Date | What CASA expects |
|---|
| 1 September 2026 | Submit your SMS procedures (exposition or operations manual amendments, or a separate SMS manual) and nominate your safety manager, using the End of transition SMS, FDAP, HFNTS and Safety Manager notification form (CASA form 04-7288), sent to regservices@casa.gov.au, with manuals ideally lodged through MAAT. |
| 1 December 2026 | The SMS provisions of EX73/24 cease. By this date you must have implemented your SMS, have HFNTS in place if you are Part 119, and have your safety manager accepted by CASA. |
| 2 December 2026 onward | You are operating under your SMS. CASA surveillance will look for evidence that the system is being used, not just that a manual exists. |
Missed 1 September? Submit anyway, now. The 1 September date was CASA's request so it could assess and acknowledge submissions before the hard date. A late submission risks CASA's acknowledgment not arriving before 2 December, which is uncomfortable, but a late submission is far better than none. Use the form, attach what you have, and note where you are up to.
What "implemented" actually means
CASA's own words on the transition pages are blunt: "Using the templates on their own do not translate into having an SMS that meets compliance requirements." A manual downloaded from CASA's sample library and lightly edited is a starting point, not an SMS. From 2 December the question an inspector asks is not "do you have a manual?" but "show me it working."
In practice that means you can produce, on request:
- A safety policy signed by your accountable manager (the CEO), with safety objectives and a just-culture statement.
- A hazard register that has entries, risk ratings, controls, owners, and review dates, and that has changed since it was created.
- A safety reporting system your pilots and ground staff actually use, with reports, classifications, and investigations you can show.
- An internal audit program with at least a schedule and a first completed audit or a dated plan for one.
- Management review records, meaning safety meeting minutes with actions and follow-up.
- Training records showing SMS induction for staff and the safety manager's competency.
- An emergency response plan that has been coordinated with the people it names.
Guide 2 walks through the four components and twelve elements CASA uses to assess all of this. Guide 3 turns it into a week-by-week operating rhythm.
The safety manager decision
You must nominate a safety manager and CASA must accept them. The safety manager runs the SMS day to day and should be independent of operational pressure, reporting to the CEO. For most small operators there is no such person, which is why the micro-operator exemption exists.
Micro-operator rule. If you are a Part 119 or Part 138 operator with ten or fewer operational safety-critical personnel, and you are not required to have an FDAP, you may be an eligible micro-operator under CASA EX68/24 and EX72/24 as amended by EX17/26. That lets your CEO, or your Head of Flying Operations (HOFO) or Head of Operations (HOO), also hold the safety manager position. You tick "micro-operator" on the notification form. CASA publishes a separate micro-operator sample SMS manual written for this situation.
Two cautions. First, the same person wearing the CEO hat and the safety manager hat must manage the obvious conflict of interest, and CASA expects your manual to say how. Second, if you are a Part 119 operator who is not a micro-operator and you want your HOFO to be safety manager, that needs a separate approval under regulation 119.025, requested on the same form.
What CASA gives you for free, and where it stops
CASA has published a sample SMS manual for Part 119 and Part 138, a micro-operator sample manual, an emergency response plan template, a gap analysis and implementation planning tool, and an 85-page guide to using the sample manuals. Its online Manual Authoring and Assessment Tool (MAAT) lets you lodge manuals electronically. Use all of it.
What none of it does is run the system for you after 2 December. Every hazard report still has to be classified, every risk assessed, every audit planned and written up, every quarterly review minuted, and every record kept in a form you can hand to an inspector. That ongoing work, done by a chief pilot who also flies the aircraft and runs the business, is the real cost of the mandate.
Your checklist for the next 90 days
- Confirm which row of the "who this applies to" table you are in. If Part 138 only, check the five trigger conditions honestly.
- Decide whether you are a micro-operator. Count your operational safety-critical personnel.
- Choose your safety manager and complete the CASA notification form. Send it, even if late.
- Take CASA's sample manual (or the micro-operator version) and change every placeholder to describe what you will actually do. Delete anything you will not do. A manual that promises audits you never run is worse than a shorter honest one.
- Open the hazard register and put your first ten real hazards in it, with ratings and owners.
- Brief every staff member on how to report, and log the briefing as training.
- Put the first management review meeting in the calendar for December and the first internal audit for the first quarter of 2027.
- Decide where records will live. A folder of Word documents works on day one. It stops working around month three.
Where are you actually up to?
The free SMS Gap Check asks twelve questions about your operation and gives you a scored readiness report against the twelve elements, in about four minutes. No sign-up needed to see your score.
Run the SMS Gap Check
Sources
- CASA, End of transition SMS, FDAP, HFNTS and Safety Manager notification, form CASA-04-7288 v1.2, July 2026.
- CASA, Air transport operators – what you must do and Aerial work operators – what you must do, flight operations regulations transition pages.
- CASA, Multi-Part Advisory Circular AC 119-01 and AC 138-11 v3.0, Safety management systems for air transport and aerial work operators, July 2026.
- CASA, Guide to Sample Safety Management System Manual (SMSM) for Parts 119 and 138 of CASR and Micro-Operator SMSM, April 2026.
- CASA EX73/24, EX68/24, EX72/24 and EX17/26 (Federal Register of Legislation).
- CASA, Part 5 of CASR Safety Management Systems (rule under development).
This guide is general information for operators and is not legal or regulatory advice. Regulations and exemption instruments change; always check the current CASA source before acting.