ICAO Doc 9841 Manual on the Approval of Training Organizations is the document a CAA opens when it audits your Training Unit. The 3rd edition (2018) spells out, in Appendices A and B, around fifty specific requirements: training manual structure, pedagogical chain, trainee records, quality system, coherence matrix, risk profile, three-year retention of audit evidence. It’s the list of things that must exist, be traced, and survive an inspection.

The practical question for a head of training or quality manager: how many of these requirements can your ATO demonstrate today in a few clicks, without rebuilding eighteen months of history by hand?

Where EDS does the work for you

We’ve mapped Appendices A and B of Doc 9841 against the functional coverage of EDS. Of roughly fifty detailed requirements:

  • 20 are native (the information is produced by construction, with no manual action)
  • 15 are assisted (EDS structures and feeds the data; light human finalisation)
  • 15 stay organisational: governance, HR, SMS, facilities (EDS doesn’t play there)

The pedagogical layer, which is the bulkiest and least audited in most Training Units today, is automated by construction.

What EDS produces natively

CBTA pedagogical chain (App. A, section 3). Performance objectives with Bloom verbs (levels 4/5/6), weighted PCS, algorithmically generated exercises, KSA assessment forms per exercise. Exact nominal scope of §3.3 (Competency-Based syllabi).

Records and traceability (App. A §5 + App. B §19). xAPI LRS, timestamping, audit trail, configurable retention. Normalised export. The day a CAA asks for the assessment history of a trainee who graduated eighteen months ago, the export takes seconds instead of days of reconstruction.

Continuous monitoring and PDCA (App. B §16-17-18). Analytics on pass rate, training duration, control load, inter-instructor deviations, inter-site deviations. The Plan-Do-Check-Act cycle applies natively to pedagogical quality.

Corrective actions on the pedagogical side (App. B §8). Drift detection, traceability of corrective actions on exercises, on assessors, on trainee progression.

Multi-site / satellite ATOs (App. B §20). Pull/Push/Hybrid/Offline synchronisation, central consolidation, inter-site reports. Each site is handled as a satellite with consolidated QA — one of the sharpest architectures on the market on that point.

What EDS doesn’t do (and that’s deliberate)

EDS doesn’t replace your quality manager. Governance, the org chart, the SMS, internal instructor training (App. A §2), QS roles (App. B §10-14), facilities outside the simulator stay in your organisational scope.

A tool that claims to cover everything is a tool that covers nothing properly. EDS automates the layer that’s most time-consuming and least audited. The rest, you already hold.

The coherence matrix: the piece that eats months

App. B §7 requires a tabulated document listing each regulatory requirement against its associated process and responsible manager. It’s the document a quality manager typically spends weeks building, and has to maintain every time a procedure evolves.

EDS doesn’t produce the matrix for you. But it radically simplifies maintenance: pedagogical processes are already documented, traced and versioned in the platform. The matrix references auditable software functions instead of brittle paper procedures.

The argument fits in one sentence in front of a CAA: deploy EDS and half the work is already done.

Why this matters now

EU regulation 2025/2143 mandates CBTA compliance for every member-state ANSP by 2029. Doc 9841 is the operational tool of that compliance: it defines what an ATO has to produce and keep current to retain its certificate.

Four years is short to rebuild a records system and a pedagogical quality system by hand. It’s plenty to deploy a platform that produces them natively from day one.

Request the full matrix

The detailed Doc 9841 ↔ EDS mapping, requirement by requirement (Appendix A and Appendix B), backs our RFI responses and serves as a pre-populated base for coherence matrices requested by CAAs.

To request it or set up a demo: fgenteur@edware.fr