AS9110 is the standard that sets quality management system requirements for aviation maintenance organizations. Its current version, AS9110C, contains the ISO 9001:2015 quality management system requirements and adds requirements, definitions and notes specific to civil and military aviation maintenance and continuing airworthiness. The standard is owned by the International Aerospace Quality Group (IAQG) and published in the Americas by SAE International.
According to SAE's records, AS9110C was published on 4 November 2016; the first version dates back to January 2003. According to the IAQG, AS9110 does not replace an aviation authority's maintenance organization approval; in Türkiye that approval is granted under the SHT-145 instruction of the Directorate General of Civil Aviation (SHGM).
In short:
- AS9110C is a standalone quality standard for maintenance, repair and overhaul (MRO) organizations and continuing airworthiness management organizations (CAMO); it is not tied to AS9100 (IAQG).
- The certificate does not replace approvals, licences or permits issued by authorities such as SHGM or EASA; it is a management system layer on top of them (IAQG).
- The next revision is being prepared as IA9110; until it is published, AS9110C applies.
What is AS9110 and who is it for?
According to the IAQG, 9110 standardizes quality management system requirements to the greatest extent possible and was developed for aviation and defence organizations providing maintenance services. The IAQG's FAQ draws the scope more precisely: the standard applies mainly to MROs, but airlines and CAMOs can also use it, in both civil and military sectors. The 2016 edition also extended the scope to continuing airworthiness management services.
According to the same document, external providers without an authority approval and military maintenance organizations can also seek 9110 certification. AS9110 in the Americas and EN 9110 in Europe are technically equivalent.
What is the difference between AS9110 and AS9100?
Both belong to the 9100 family, but they are written for different jobs. AS9100D targets organizations that design and produce; AS9110C focuses on the specific needs of maintenance. According to the IAQG's FAQ, 9110:2016 is no longer built on 9100; it is based directly on ISO 9001:2015 and addresses the needs of the maintenance organization rather than the original equipment manufacturer. Meeting all 9100 requirements is therefore not a prerequisite for 9110.
Concrete examples from the same IAQG document show the difference:
- Airworthiness: any article to be installed on an aircraft, engine or propeller must be in a condition for safe operation as defined by an approved design (such as type design, TSO or PMA).
- Post-delivery activities: for an MRO these are limited to offering corrective actions and investigation results after a quality escape or warranty event; for a CAMO they concern the continuing airworthiness deliverables in the contract.
- Quality manager: the quality manager (or a similar title such as compliance monitoring manager) establishes an independent audit programme and a quality feedback reporting system to the accountable manager.
- Accountable and nominated managers: the standard's note on "nominated post holders" may cover positions such as the Part-M or CAMO post holder, depending on the jurisdiction.
What does AS9110C require on safety management?
According to the IAQG, the 2016 edition was written to align better with Annex 19 of the International Civil Aviation Organization (ICAO) on safety management. Product safety and risk-based thinking are built into several clauses. The new requirements the IAQG lists are: a safety policy and objectives (clause 5.2.3); operational risk management, hazard identification and assessment, product safety and measurement of safety performance (clauses 8.1.1 and 8.1.3); and improvement of safety performance (clause 10.1).
There is an important limit: according to the IAQG, 9110 does not impose a safety management system (SMS) in the ICAO Annex 19 sense on all organizations; that is required only where the applicable authority imposes it. ICAO elements such as emergency response planning, for example, are not 9110 requirements. In other words, AS9110C does not replace the safety management an authority requires; it offers a quality framework consistent with it.
Does AS9110 replace SHGM or EASA Part-145 approval?
No. The IAQG's FAQ states it explicitly: 9110 certification does not replace the approvals, certificates, ratings, licences and permits required by the responsible authority.
In Türkiye, organizations maintaining civil aircraft or components are authorized under SHGM's Approved Aircraft Maintenance Organizations Instruction (SHT-145). According to its text, SHT-145 was issued under the Continuing Airworthiness Regulation (SHY-CA), published in Türkiye's Official Gazette on 5 November 2022, and prepared in line with EU Regulation 1321/2014. This article is not a legal interpretation; SHGM's current text prevails.
In practice the two systems overlap rather than conflict. The IAQG publishes correlation tables mapping 9110:2016 against EASA Part-145 and FAA Part-145. An approved maintenance organization can compare its existing maintenance organization exposition and procedures with these tables to see AS9110's additional requirements. According to the IAQG, a separate quality manual is not required; the QMS can be described in the existing exposition or in another structure.
When will IA9110 be published, and what will change?
Under the IAQG's new publishing arrangement, the next revisions of the 9100 family carry the "IA" prefix; AS9110C's successor is IA9110. The IAQG's 9110 page already hosts "IA9110 Key Changes" documents dated June 2024. Among the draft changes they highlight:
- The role of the QMS in establishing a culture of quality, and the importance of ethical behaviour.
- Leadership promoting an ethical work environment free of retaliation.
- A safety policy revised for safety objective setting, confidential safety reporting and continual improvement.
- A counterfeit part definition expanded with software and electronic device examples.
This is a list of draft changes. As of 13 November 2026, the IAQG's 9110 and published standards pages show no publication of IA9110; AS9110C remains the applicable requirement. The IAQG and certification bodies will announce publication and the transition timetable.
Conclusion: where does AS9110 preparation start?
AS9110C lets maintenance organizations build an ISO 9001-based, safety-focused quality management system on top of their authority approval; it complements, and does not replace, SHGM or EASA approval. An efficient start is to map the existing maintenance organization exposition against the IAQG's Part-145 correlation tables and list the gaps specific to AS9110. The draft IA9110 changes, especially on culture, ethics and safety reporting, can already be brought into internal processes today.
AS9110C aviation maintenance organization quality management is part of Orient Global's corporate training catalogue; details are on the trainings page.
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