EASA Part-147 examinations: what your exam system must support

EASA Part 147 is the approval standard for maintenance training organisations (MTOs) in Annex IV to Regulation (EU) No 1321/2014. For examinations, it asks an MTO to hold knowledge exams in a controlled environment, keep every question secure, follow the Part-66 exam standard and keep the records. This guide turns those rules into a list of what an exam system must support.

It is written for exam officers, examination managers and quality managers at Part-147 organisations who are choosing, configuring or auditing an exam system. It separates what the regulation requires, what EASA guidance describes and what your organization is free to decide. Facts are dated as of October 2026.

Two limits apply. This is not legal or airworthiness advice, and none of the sources reviewed for this post approves exam software: approval attaches to the organization and its procedures. Check with your competent authority, because it oversees your approval and national practice can differ.

Key takeaways

• Regulation (EU) 2023/989, applicable from 12 June 2024, added 147.A.135(d): the exam must take place in a controlled environment where identity, conduct, integrity and security of exam material can be established and verified.
• The Part-66 exam standard sets rules a system can enforce: a 75% pass mark on each multiple-choice module, no penalty marking, and three attempts in a 12-month period.
• Some duties are software features, such as timers and attempt ledgers. Others are processes, such as identity checks and invigilation, which no software can perform alone.
• EASA has consulted on further Part-147 changes (NPA 2023-10). Treat them as proposals until you see an adopted text.

What does EASA Part 147 require of an examination?

EASA Part 147 requires the MTO to run knowledge examinations to the Part-66 standard, in a controlled environment described in its exposition, without training notes, with all questions kept secure and with records retained. The organization holds these duties. Software can only help it show that it met them.

The newest provision is point 147.A.135(d), added by Commission Implementing Regulation (EU) 2023/989. It reads: “The examination shall be performed in a controlled environment by a training organisation approved under this Annex and described in its maintenance training organisation exposition (MTOE).” (quoted)

The same point defines the term. A controlled environment is “an environment where the following can be established and verified: (a) the identity of the students; (b) the proper conduct of the examination process; (c) the integrity of the examination and (d) the security of the examination material.” (quoted)

Older provisions still apply. The text of Annex IV on legislation.gov.uk, which reproduces the EU wording as it stood on 24 March 2020, says in 147.A.135(a): “The examination staff shall ensure the security of all questions.” (quoted) Under 147.A.205(b), basic knowledge examinations must “be conducted without the use of training notes.” (quoted)

Two further points matter for system design. Point 147.A.205(c) requires the exam to cover a representative cross section of subjects from the module, which is a blueprint question. And 147.A.145(b) allows knowledge examinations only at locations identified in the approval certificate or specified in the MTOE.

Which exam-system capabilities does EASA Part 147 imply?

Twelve duties in Part 147 and the Part-66 exam standard translate into things a system or process should be able to show. The table below maps each duty to its source and to the evidence an auditor could ask for, and marks whether software or a human process carries it.

Treat the “Carried by” column as a judgment, not a legal classification. The duties marked “Process” fail in practice when a system has no field to record them, which is why they still appear in the table. A well-run item bank with tags, versions and retirement rules covers the security and version rows.

Who decides what: the regulation, EASA guidance or your organization?

Three parties shape an exam system. The regulation sets binding requirements, EASA’s guidance describes accepted ways to meet them, and the competent authority checks your result. Everything else, including the software you choose, is the MTO’s decision.

• The regulation requires: provisions such as 147.A.135(d) and Appendix II to Part-66 use “shall” and bind every MTO.
• EASA guidance describes: the Decision that issues the acceptable means of compliance says they are “non-binding standards issued by EASA.” (quoted) AMC1 147.A.105 asks for “an examination manager with the responsibility of managing the relevant Part-147 Subpart C or Subpart D examination system.” (quoted)
• The authority oversees: EASA FAQ 19074 says the competent authority does not supply exam questions, but “must sample check and review the organisations’ question data bank” and the examination process. (quoted in part)
• You decide: the platform, the delivery mode inside a controlled environment, how identity is checked and who invigilates.

Can an EASA Part 147 knowledge exam be delivered online?

It can be delivered by computer, but only inside a controlled environment that the MTO runs. EASA’s guidance accepts exam questions reached through a web address if the organization controls the exam setting. The distance-learning allowance does not extend to examinations, so an uncontrolled home setting is a question for your competent authority.

Two texts support this reading. AMC1 147.A.145(c) in the Part-147 AMC and GM (Issue 2, Amendment 3) states that “Knowledge examinations may also be conducted by accessing the examination questions via uniform resource locator” provided “the knowledge examination environment is under the control of the maintenance training organisation.” (quoted, as read in the published document)

Point 147.A.100(j) is the second. It lets an MTO deliver distance learning at a location it does not control, after briefing the student, but states that “This derogation applies only to distance learning and not to the corresponding examination and/or assessment.” (quoted)

In practice, a browser-based exam in your own classroom or an approved location fits. Remote exams from a candidate’s home need a way to establish and verify identity, conduct, integrity and material security, and the sources reviewed do not say how an authority will judge that. Ask before you build. For the wider picture, read online assessment in aviation training: what regulators expect; for secure delivery of Part-66 modules, see delivering Part-66 module exams securely.

How should the system set the clock and pass mark?

Set the clock from the module’s time allowance and the pass mark at 75% of each multiple-choice paper. Appendix II to Part-66 bases timing on a nominal 75 seconds per multiple-choice question and fixes the pass mark for each module and sub-module. Penalty marking cannot decide a pass.

The Part-66 Appendix II text on legislation.gov.uk states in point 1.7: “The pass mark for each module and sub-module multi-choice part of the examination is 75 %.” (quoted) Point 1.10 adds: “Penalty marking systems shall not be used to determine whether a candidate has passed.” (quoted) Both points were left unchanged by Regulation (EU) 2023/989.

The arithmetic can be checked against the figures printed in Regulation (EU) 2023/989 for Module 7. Category A lists 76 multiple-choice questions and 95 minutes: 76 questions at 75 seconds is 5,700 seconds, or 95 minutes. Category B2 lists 60 questions and 75 minutes, which also matches. Confirm current counts in the latest consolidated Appendix II, because question numbers have been amended before.

Partial exams add a second calculation. Appendix II point 1.12 lets exams with more than 90 minutes allowed be split into two partial exams. Each partial exam must have similar allowed time, a number of questions that is a multiple of four, and a pass at 75% or more. Take an illustrative 80-question paper with 100 minutes allowed:

• Split it into two partial exams of 40 questions each, which is a multiple of four.
• Allow 50 minutes for each, so the allowed times are similar.
• Require 30 correct answers out of 40 in each part. Results are listed separately and are not averaged.

The 80-question figure is for the arithmetic only. A system should refuse any split that breaks these rules, and it should apply your randomization and timing choices consistently, as covered in this guide to exam security settings for randomization, timers and access rules.

Pro tip: Stamp the Rule Version On Every Paper. Store which amendment of Appendix II, which question count and which time allowance applied to each paper, next to the result. When the rules change, you can show an auditor why a 2025 sitting used different values from a 2027 one.

How should an exam system handle retakes and attempt limits?

A system should keep a dated attempt ledger and block rebooking inside the waiting period. Appendix II allows a retake after 90 days, or 30 days after tailored retraining at a Part-147 organisation, and a maximum of three attempts in a 12-month period. The system can only count attempts it has seen.

The attempt limit is where software and process meet. Point 1.13 requires the applicant to give a written statement of “the number, and dates of attempts” in the preceding 12 months and the organization where they took place. The MTO or the authority “is responsible for checking the number of attempts within the applicable time frames.” (quoted in part)

That means your ledger covers your own sittings, and a signed declaration covers everyone else’s. Store the declaration with the candidate record, and block a booking when your own count already reaches three.

What evidence should you be able to produce for one exam sitting?

You should be able to rebuild any sitting from records alone: who sat it, who ran it, what they saw, what they scored and what went wrong. Point 147.A.125 requires the organization to “keep all student training, examination and assessment records for an unlimited period” in the version read on legislation.gov.uk. (quoted)

A practical record for each sitting holds these items:

• Candidate, module, category and the Appendix II version applied.
• Location, and the approval or MTOE entry that covers it.
• Identity check, with the name of the person who made it.
• Invigilator and, where essays are set, the marker, linked to their records under 147.A.110.
• Paper version, question identifiers, start and finish times, and the score by part.
• Incident notes, including any disqualification and its date.
• Attempt number and the signed attempt statement.

EASA FAQ 19075, last updated in 2015, says an “examiner” there means an invigilator who need not be a subject expert for multiple-choice papers. Essay marking, though, “has to be conducted by knowledgeable personnel with the help of a standard reply.” (quoted) Record which person played which role.

Pro tip: Run a Reconstruction Drill. Pick one sitting from last year and ask a colleague who was not there to rebuild it from the system alone. Every question they cannot answer, such as who verified identity, marks a field to add before an audit finds it.

What is EASA proposing to change in Part 147?

EASA has consulted on a wider review of Part 147 but, as of October 2026, the primary sources reviewed do not show an adopted text. Treat the proposals below as signals about direction, and check EASA’s rulemaking pages and your competent authority before you rely on any of them.

EASA’s briefing slides for NPA 2023-10 (the Part-147 review, RMT.0544, dated February 2024) list proposals that touch exam systems. They include “Emphasis on the security of the database at all times”, reporting of cheating and fraud in the examination process, an exam plan submitted to the competent authority, an increase in the prohibition period after cheating from 12 to 48 months, and a decrease in the training records retention period from unlimited to 10 years. They also describe examiners as approved people with personnel authorisation, not invigilators.

These items fit one design rule: build the system so that the role, incident and retention fields can change without rebuilding your exam data.

What should you do next?

Take the table above and mark each row Met, Partly met or Missing for your current system, with the record that proves it. Then bring the Partly met and Missing rows to your examination manager and ask your competent authority how it expects them to be shown.

When you compare platforms, ask each vendor to demonstrate the rows rather than describe them: an attempt ledger, a split paper, an incident log and an exported sitting record. SimpliAssess is a white-label, API-first platform, and its features page lists item banking, test management, examinee management, schedule management and analytics and reporting. Its published pages do not describe identity checks, controlled-environment features or Part-147 functions, so confirm any of those directly.

Frequently asked questions

Does EASA approve exam software for Part 147?

No source reviewed for this post says so. Approval attaches to the maintenance training organisation, and the examination must be described in its exposition. The competent authority does not supply questions but samples your question data bank and examination process. Treat any “EASA approved” software claim as a vendor statement to verify with your authority.

Who can run Part-66 basic knowledge examinations?

Point 66.A.25(b) says the basic knowledge examinations must meet the Appendix II standard and may be conducted by a Part-147 maintenance training organisation or by the competent authority. Whether your organization holds that privilege depends on the scope of its approval, which your competent authority can confirm.

What is the pass mark for a Part-66 module exam?

For the multiple-choice part of each module and sub-module, the pass mark in Appendix II point 1.7 is 75%. Penalty marking cannot be used to decide a pass. If an exam is split into partial exams, each partial exam must also be passed with 75% or more of questions answered correctly, and the results are not averaged.

How many times can a candidate retake a Part-66 module exam?

The maximum is three attempts for each examination in a 12-month period. After a failed attempt, a candidate waits 90 days, or 30 days at a Part-147 organisation after a retraining course tailored to the failed subjects. The candidate states earlier attempts in writing, and the organization or authority checks the count.

Can a Part-147 exam use training notes or question reuse from learning programs?

No to both. Point 147.A.205(b) requires basic knowledge examinations to be conducted without training notes. Appendix II point 1.14 says the questions used as part of the multimedia-based training learning programme must not be used in examinations, although the subject matter may be the same.

Can candidates sit a Part-147 knowledge exam at home?

The sources reviewed do not give a simple yes or no. Point 147.A.135(d) requires a controlled environment where identity, conduct, integrity and material security can be established and verified, and 147.A.100(j) excludes examinations from the distance-learning derogation. Ask your competent authority whether your proposed remote setup meets that test.