Implementing ISMS While SMS is Still Taking Shape
The aviation industry is no stranger to regulatory changes, but the recent and upcoming requirements from EASA are placing significant pressure on Maintenance, Repair, and Overhaul (MRO) organizations. The introduction of Safety Management Systems (SMS) for MROs, now mandatory, has already been a major undertaking. However, with the requirement for an Information Security Management System (ISMS) coming into force on February 22, 2026, many MROs are questioning whether the timeline is realistic.
Two Major Compliance Challenges in Quick Succession
SMS implementation has been a transformative change for MROs, requiring the integration of proactive safety management into existing quality and compliance frameworks. For many organizations, the challenge has been not just in setting up SMS but in ensuring it becomes fully operational and effective. This involves cultural shifts, new reporting mechanisms, and enhanced risk management practices—none of which happen overnight.
Now, as MROs are still refining their SMS practices, they are faced with the additional challenge of implementing ISMS. The goal of ISMS is clear: to protect sensitive aviation data, prevent cyber threats, and ensure compliance with increasing digital security demands. However, the concern lies in the short transition period between these two major regulatory shifts.
Could the EASA Timeline Have Been More Practical?
While the need for enhanced safety and security is undisputed, the close timing of these requirements raises questions about the practicality of their implementation. Regulatory transitions should allow for sufficient time to establish, optimize, and sustain new systems before additional mandates take effect. The concern is that MROs will still be fine-tuning their SMS when they need to divert attention and resources toward ISMS, potentially impacting the effectiveness of both.
A more phased approach—allowing SMS to mature before introducing ISMS—could have eased the burden on MROs, ensuring that each system is robust before moving on to the next challenge. This would have enabled organizations to leverage lessons learned from SMS implementation when tackling ISMS requirements, leading to more effective compliance and integration.
What Can MROs Do to Prepare?
Despite the tight timeline, MROs must take proactive steps to ensure smooth implementation of both SMS and ISMS. Here are some key strategies:
- Integrate Compliance Efforts – Align SMS and ISMS efforts where possible, leveraging existing risk management and reporting frameworks to streamline processes.
- Early ISMS Planning – Even if SMS is still evolving, MROs should begin assessing their cybersecurity posture and data protection measures now.
- Leverage Industry Resources – Engaging with industry groups, consultants, and regulatory guidance can help MROs navigate these transitions more effectively.
- Invest in Training – Ensuring staff are well-prepared for both SMS and ISMS requirements will be critical for successful implementation.
Final Thoughts
The aviation industry’s commitment to safety and security is unwavering, but the speed of regulatory changes must also be practical. MROs need time to establish and refine new systems before shifting focus to the next challenge. While ISMS is an essential requirement in today’s digital landscape, the industry could benefit from a more structured and phased approach to its implementation.
What are your thoughts on this transition? Should EASA have provided more time between SMS and ISMS implementation?
