Delivering Part-66 module exams securely
Delivering Part-66 module exams securely means running each basic knowledge examination so you can show who sat it, how it was run, that the exam stayed intact and that the questions stayed secret. Search for an aviation exam EASA candidates can practice and you mostly find pilot question-bank apps. This post is for a different reader: the exam officer, examination manager or head of training at a Part-147 maintenance training organisation (MTO), or a company that supplies exam software to one.
Since Commission Implementing Regulation (EU) 2023/989 started to apply to Part-147 and Part-66 on 12 June 2024, point 147.A.135(d) has required exams to be performed in a “controlled environment” and has defined that term in four parts. The Regulation does not say which room, software or camera you need. Your MTO exposition (MTOE) and your competent authority fill that gap.
This post turns the definition into controls and records you can keep, compares delivery settings, and lists the attempt rules your exam system must enforce. It is not legal or airworthiness advice. Authorities differ, so check yours before you change a procedure.
Key takeaways
- A controlled environment has four elements in point 147.A.135(d): identity of the students, proper conduct of the examination process, integrity of the examination and security of the examination material. Give each one a control and a record.
- The Regulation text does not mention remote or online module exams, and the distance-learning derogation in point 147.A.100(j) excludes examinations. Ask your competent authority in writing before moving any exam off-site.
- Questions used in the multimedia-based learning program “shall not be used in examinations” (Appendix II, point 1.14), so keep practice and exam question pools separate.
- Part-66 allows three attempts per exam in 12 months and bars a retake earlier than 90 days after a failure, so your system should calculate the earliest permitted sit date.
What does a controlled environment mean for a Part-66 module exam?
A controlled environment is one where four things can be established and verified: the identity of the students, the proper conduct of the examination process, the integrity of the examination and the security of the examination material (point 147.A.135(d), as of October 2026). The MTO performs the exam and describes the setting in its exposition.
Under point 66.A.25(b), basic knowledge exams are conducted by a Part-147 organisation or the competent authority. Point 147.A.100(b) adds that “fully enclosed, appropriate accommodation, separate from other facilities” must be provided for “the conduct of knowledge examinations” (both quoted from Regulation (EU) 2023/989).
The table below separates what the cited texts require from what your authority decides and what you can choose.
| Topic | The text requires | Authority or MTOE decides | You can choose |
|---|---|---|---|
| Setting | Exam in a controlled environment, performed by the MTO and described in the MTOE (147.A.135(d)) | Whether a room, remote site or process meets the definition | Room layout, paper or screen |
| Candidate materials | “only the examination documents may be available to the candidate during the evaluation” (66.B.200(g), quoted) | What counts as an examination document for a module | Where bags and phones are stored |
| Attempts | Three attempts per exam in 12 months; no retake earlier than 90 days after a failure (Appendix II, 1.13 and 1.11) | Who checks the declared attempts | Booking tools and reminders |
| Question material | Learning-program questions not used in exams (Appendix II, 1.14) | How the authority samples your question bank | Pool structure and review cycle |
| Invigilation | MTO staff to conduct knowledge examinations (147.A.105(c)) | Appointment and independence rules in the MTOE | Invigilator ratio and rotation |
Which delivery setting suits an aviation exam EASA competent authorities oversee?
An invigilated room at an address listed in your MTOE is the clearest fit. Other settings work only where your competent authority agrees. Transport Malta, for example, publishes conditions for remote locations. An unsupervised home exam is hard to square with point 147.A.135(d), and the Regulation excludes examinations from the distance-learning derogation.
The table compares three settings using the sources named in each row. It is a reading of those sources, not a ruling.
| Setting | What the sources say | Main gap | Evidence to keep |
|---|---|---|---|
| Approved MTO address, invigilated | Closest fit to points 147.A.100(b) and 147.A.135(d); exams may be held “at any location specified in the MTOE” (147.A.145(b)) | Familiar staff may relax checks | Seating plan, invigilator log, signed attendance |
| Other MTOE location or remote classroom | Transport Malta IAN 27 Issue 2 (13 July 2023): procedures in the MTOE, integrity and independence checks for ad hoc invigilators, classroom exams at remote locations video-recorded with audio daily | Weaker control of room and equipment | Recording copy, invigilator appointment record |
| Browser exam on a candidate’s own device at home | The derogation in 147.A.100(j) “applies only to distance learning and not to the corresponding examination and/or assessment” (quoted); AMC1 147.A.145(c) allows URL-delivered exams only “provided the knowledge examination environment is under the control of the maintenance training organisation” (quoted) | Software alone cannot establish room, devices or other people present | A written authority position and an MTOE procedure |
Authorities differ. The UK CAA, which applies its own version of these rules, limits web-based delivery in its Part-147 guidance to theory and says type training examinations are not to be carried out by those methods. If you hold approvals from more than one authority, keep a separate row per authority.
How do you prove each element of a controlled environment?
Pair each of the four elements with one preventive control and one record. The record lets you verify the element afterward, and verification is what the definition asks for. A control with no record cannot be shown to anyone. Build the pairs once, put them in the MTOE and reuse them for every sitting.
Each row of the next table starts from the wording of point 147.A.135(d) and adds a control and a record. The controls are suggestions, not requirements, unless a row names a source.
| Element | Preventive control | Record to keep |
|---|---|---|
| Identity of the students | Check official photo ID against the booking list before entry; IAN 27 asks that identity be confirmed and, for outside attendees, a signature sample checked | Signed attendance sheet with ID type and checker’s initials |
| Proper conduct of the examination process | Trained invigilator not involved in the candidate’s training (IAN 27); devices off, clear desks, spacing, visible clock | Invigilator log with start, finish, breaks and incidents; invigilator training record |
| Integrity of the examination | One fixed form per candidate, timer set from the module’s allowed time, no answer changes after submission | Exam log with form ID, start, finish, saved answers and timer events |
| Security of the examination material | Exam pool kept apart from learning questions, named authors only, no paper leaves the room | Pool access log, count of papers issued and returned, destruction record for rough notes |
Who can invigilate a Part-66 module exam?
EASA FAQ 19075 treats the person responsible for proper conduct as an invigilator. For multiple-choice questions that person does not need to be a subject expert, but must be trained in the examination process, while essay questions need knowledgeable staff and a standard reply. The FAQ carries no date, so confirm it still matches your authority’s practice.
For a design reference, the Swedish Transport Agency’s invigilator instructions for pilot theory exams (version 26.0, April 2026) set out screen monitoring, a student-to-invigilator ratio and destruction of notes. Those are pilot exam rules, not Part-66 rules, but they show how one authority runs computer-based sittings.
Pro tip: Test The Record, Not The Control. Before a live sitting, ask someone outside the exam team to rebuild from your records alone who sat which form, when they started and who invigilated. Any gap that person finds is a gap a reviewer would find too.
How should you separate practice questions from exam questions?
Keep two pools. Appendix II point 1.14 accepts that the subject matter of questions may be the same, but “the questions used as part of the MBT learning programme shall not be used in examinations” (quoted; MBT is the Regulation’s abbreviation for multimedia-based training). Practice material can teach the topic. No exam item may appear there word for word.
A workable structure has three states, and an item sits in exactly one at a time:
- Learning pool: used in course material and practice quizzes, open to candidates.
- Exam pool: locked, limited to named authors and never shown outside an exam.
- Review queue: new or edited items awaiting approval, which never move straight into the exam pool.
Before each release, compare the text of both pools and flag near-matches. Subject overlap is allowed by point 1.14, but identical wording is not. Item status and version fields, described in the item bank guide for training companies, are what let a system enforce this.
EASA FAQ 19074 says the competent authority does not have to supply examination questions, but it must sample-check the organization’s question data bank and examination process. Keep the review record for each item so a sample check has something to read.
How do you enforce attempt limits and waiting periods?
Part-66 Appendix II allows at most three attempts at each examination in a 12-month period (point 1.13) and bars a retake earlier than 90 days after a failed exam (point 1.11). A Part-147 retraining course shortens the wait to 30 days (as of October 2026). Your system should compute the earliest date from declared attempts.
The UK version of Appendix II adds that applicants declare attempts in writing and that the training organisation or authority checks them. Confirm whether your authority’s text carries the same wording, and whether it counts the 12 months as a rolling window. Then run the same five steps for every booking:
Step 1: Collect the declaration. At booking, record each earlier attempt at that module: date, result and where it was sat.
Step 2: Count the window. Count attempts in the 12 months before the proposed sit date, including attempts at other organizations.
Step 3: Calculate the earliest date. Add 90 days to the date of the last failure, or 30 days if approved retraining is recorded.
Step 4: Block early bookings. Refuse or reschedule any date before that, and log the reason.
Step 5: File the declaration. Store it with the result so the check can be repeated later.
As an invented illustration, a candidate who fails a module on 3 March has a 90-day date of 1 June, or 2 April after recorded retraining. Check how your authority counts days before you rely on either date.
Pro tip: Make The Declaration A Booking Prerequisite. A candidate who learns on exam day that the 90 days have not passed has already paid, traveled and been seen by other candidates. Show the earliest permitted date beside the declaration form so ineligible bookings never reach the room.
What should you ask a software vendor before you rely on it?
Ask for written answers to six questions. None is a regulatory approval question, because the texts cited here place requirements on the MTO and the environment, not on software. A vendor claim such as “EASA approved” needs a source from the regulator, not from the vendor.
- Can exam items sit in a pool separate from practice items, with access limited to named authors?
- Does the exam run from a fixed form with a server-side timer matched to the time allowed in Appendix II point 2?
- Can you export a per-candidate log of start, finish, saved answers and interruptions?
- Does it store attempt history and calculate the earliest permitted sit date, including attempts it did not deliver?
- Can you limit who may open the exam to the time window and room you chose?
- What happens when a connection drops mid-exam, and who authorizes a resume?
For how to set and test timers, start windows and access codes, see the exam security settings checklist. For the choice between in-room and remote supervision, see the proctoring guide for training providers.
What should you do next?
Write a one-page procedure with the four elements, the control for each and the record each produces, then put it in the MTOE. If any exam would run off-site or remotely, get your competent authority’s position in writing first. For the wider list of exam system requirements under Part-147, read the Part-147 examinations post.
Keep watching the rules. EASA’s NPA 2023-10 (Review of Part-147), described in a February 2024 EASA presentation, proposed further examination-integrity measures, including reporting of cheating to the competent authority. Those were proposals, and the sources reviewed for this post did not confirm their adoption as of October 2026.
On tools, SimpliAssess’s features page lists item banking, test management, schedule management and examinee management and describes secure online testing as an aim, but does not describe randomization, timers or access controls. Put the six questions above to any vendor in writing. SimpliTrain’s question bank page describes per-attempt randomization of question and answer order and per-question version control. It has no aviation or Part-66 content and does not mention attempt limits.
Frequently asked questions
What is a controlled environment for a Part-66 exam?
It is an environment where the identity of the students, the proper conduct of the examination process, the integrity of the examination and the security of the examination material can be established and verified. Point 147.A.135(d) of Regulation (EU) 2023/989 defines it, and the MTO must describe it in its exposition. Your competent authority judges whether a given setting qualifies.
Can Part-66 module exams be taken online at home?
The Regulation text does not provide for it. Point 147.A.135(d) requires a controlled environment, and the distance-learning derogation in point 147.A.100(j) does not cover examinations. AMC1 147.A.145(c) allows URL-delivered exams only where the MTO controls the environment. Get your competent authority’s written position before you plan any home-based sitting.
How many times can a candidate sit the same Part-66 module exam?
Appendix II point 1.13 sets a maximum of three attempts for each examination in a 12-month period. Point 1.11 bars a retake earlier than 90 days after a failed exam, or 30 days where approved Part-147 retraining has been completed. Check with your authority how it counts the 12 months and who verifies the declared attempts.
Can practice questions be reused in the real exam?
No. Appendix II point 1.14 says the subject matter of questions may be the same, but questions used as part of the multimedia-based learning program shall not be used in examinations. Keep a separate exam pool with restricted access, and compare it against your practice pool before each release so identical wording does not slip through.
Does the competent authority supply the exam questions?
Not necessarily. EASA FAQ 19074 says the authority does not have to supply examination questions when a Part-147 organisation runs basic exams on its behalf. The authority is still responsible for oversight, so it must sample-check the question data bank and the examination process. Keep review records for every exam item.
Is an exam platform EASA approved for Part-66 exams?
None of the texts reviewed for this post describes approval of exam software. They set requirements for the MTO and the examination environment, and the competent authority assesses the organization’s procedures. Treat any “EASA approved” claim from a vendor as unverified until the regulator confirms it, and test the platform against your own controls.
