EU Regulation 2025/2143: What It Means for ATCO Training Organisations

On 23 October 2025, the European Commission adopted Implementing Regulation (EU) 2025/2143, amending Regulation (EU) 2015/340. The deadline is 1 January 2029. That sounds distant — but for ANSPs and ATCO training units, the structural changes required make early preparation not optional.

This article breaks down the key requirements, what they demand operationally, and where training organisations typically underestimate the effort involved.

What the regulation actually introduces

Regulation 2025/2143 does three things that matter for training units:

First, it mandates competency-based training and assessment (CBTA) across initial, unit, continuation, instructor, and assessor training. This is a hard requirement aligned with ICAO Doc 9868 and Doc 10056. Training programmes must be redesigned around observable behaviours and performance criteria, not hours in a simulator.

Second, it formally recognises virtual and distance training, including the concept of “visual classroom” for geographically distributed training scenarios. This opens a significant door for ANSPs managing training across multiple sites or countries.

Third, it tightens the requirements for instructors and assessors, applying CBTA logic to their own performance standards, not just to the trainees they evaluate.

The part most organisations underestimate

The regulation does not describe what a compliant programme looks like in practice. It sets the what, not the how. That gap is where most training units will struggle.

Specifically, compliance requires:

• A documented competency model per rating (TWR, APP, En Route…), linked explicitly to performance objectives and Particular Control Situations (PCS).
• Simulator exercises that demonstrably cover the required competencies, with traceable distribution of PCS across sessions and cohorts.
• Standardised KSA (Knowledge, Skills, Attitudes) assessment forms, consistently applied across instructors and sites.
• Audit-ready records — not a collection of spreadsheets, but structured evidence that regulators can inspect without a three-week preparation effort.

For organisations still relying on manual exercise design and fragmented documentation, building this infrastructure from scratch by 2029 is a significant undertaking. The actual workload tends to surface only when teams attempt to map their existing materials against the new framework.

The multi-site dimension

For ANSPs operating across multiple training units or countries, Regulation 2025/2143 adds another layer: the requirement for harmonised training outcomes across sites. Two trainees completing the same rating at different locations must be assessed against the same performance criteria and receive equivalent training coverage.

Without centralised management of exercises, assessments and progress data, this consistency is nearly impossible to verify, let alone demonstrate to an oversight authority.

The key question is no longer ‘What is CBTA?’ — it is: how do we redesign our training, upskill our instructors and document competence in a way that works in our local context, while staying compliant and operational?

Where ICAO guidance fits in

Regulation 2025/2143 operates alongside, and explicitly references, ICAO’s CBTA framework. Doc 9868 (Procedures for Air Navigation Services — Training) defines the competency model structure, while Doc 10056 (Manual for the Oversight of Fatigue Management Approaches) addresses the assessment dimension. Eurocontrol’s Common Core Content provides the specific catalogue of performance objectives for each ATCO rating.

In practice, compliant programme design requires cross-referencing all three. For organisations without prior CBTA experience, this intersection is where delays accumulate.

A practical timeline for preparation

The 2029 deadline creates a false sense of comfort. Realistic preparation, accounting for procurement cycles, instructor training, data migration, and regulatory review, looks more like this:

1. 2026: Competency gap analysis, map existing training materials against CBTA requirements. Identify what needs to be rebuilt, not just updated.
2. 2026–2027: Tool selection and implementation. Systems that structure CBTA-aligned exercise design and assessment will need time to configure, populate, and validate with real cohorts.
3. 2027–2028: Instructor and assessor upskilling. Behavioural indicators, standardised assessment reports, and collaborative dashboards require genuine adoption, not a one-day training session.
4. 2028: Trial audits and evidence review before the compliance deadline.

Organisations that start in 2027 will be compressing all four phases into two years while running live training programmes. That is technically achievable, but it creates unnecessary risk.

What this means for simulator-based training specifically

The pre-OJT phase is where CBTA compliance is most complex to implement. Exercise design must satisfy methodological constraints while remaining pedagogically coherent and individually traceable.

This is not a problem you solve with a spreadsheet or a generic LMS. It requires tools specifically built for the ATCO domain, capable of linking competency objectives to PCS, generating homogeneous exercise sets, and feeding evaluation data back into a centralised record that withstands audit scrutiny.

Sources: EASA Newsroom, October 2025 — SKYbrary, Regulation 2025/2143 — ICAO Doc 9868 & Doc 10056 — Eurocontrol Common Core Content