
Exam Security for Aviation Authorities and Approved Training Organisations
Aviation exam security is the set of rules and controls that protect licensing and approval theory exams: who can see the questions, who can sit the exam, how the room or screen is supervised, and what happens when cheating is suspected. The result decides who is trusted to hold a licence or sign off maintenance, so a compromised exam is a safety problem, not only an academic one.
Responsibility is split. In some systems the authority runs the exam. In others an Approved Training Organisation (ATO) or a Part-147 maintenance training organisation (MTO) runs it on the authority’s behalf. This post sorts out which rule sits with whom, using published EASA, FAA and national authority documents as of October 2026, and ends with a leaked-question response plan. It is a reading aid, not legal or airworthiness advice, so check your competent authority before you act on any point.
Key takeaways
- Work out who runs your exam first: EASA pilot theory exams are run by the competent authority from the European Central Question Bank, while Part-66 basic exams can be run by a Part-147 MTO, so the security duty lands in a different place.
- The sources read agree on five room controls: identity check, separated candidates, restricted materials, continuous supervision and confidential papers.
- Authorities differ on a suspected-cheating incident: the FAA order says to discontinue the test immediately, while the Swedish Transport Agency’s invigilator instructions say the exam is not to be immediately terminated. Follow your own authority.
- Records decide whether a leak can be contained: EASA’s bulletin on a Part-147 fraud case said investigations were “nearly impossible” because of incomplete records.
Who is responsible for aviation exam security: the authority or the training organization?
It depends on who runs the exam. EASA pilot theory exams are run by the competent authority, which must set integrity procedures. EASA Part-66 basic exams can be run by a Part-147 MTO on the authority’s behalf. FAA airman knowledge tests follow FAA Order 8080.6H. The security duty follows whoever runs the sitting.
For EASA pilot theory, ARA.FCL.300 in the EASA Easy Access Rules for Aircrew says examinations “shall be done in written or computer-based form” (quoted) and that the competent authority selects the questions from the European Central Question Bank (ECQB). It also says “The competent authority shall establish appropriate procedures to ensure the integrity of the examinations.” (quoted, ARA.FCL.300(d))
For Part-66 basic exams, EASA’s FAQ n.19074 (last updated 13 April 2015) says the authority does not have to supply questions but “must sample check and review the organisations’ question data bank and the examination process” (quoted). The MTO’s own quality system must also monitor “the integrity of knowledge examinations and practical assessments” (quoted from 147.A.130(b)(1), as shown on EASA’s FAQ page). That puts the question bank in the MTO’s hands.
For the FAA, Order 8080.6H, Conduct of Airman Knowledge Tests (issued 22 September 2017 and listed as active), governs testing centers, and 14 CFR 61.37 sets the consequences of applicant misconduct.
The table shows who runs the sitting, who protects the questions, and what the candidate faces, based on the sources named in each row.
| System | Who runs the sitting | Who protects question content | Candidate consequence as published |
|---|---|---|---|
| EASA pilot theory (ATPL, CPL, instrument rating) | The competent authority (ARA.FCL.300) | The authority selects from the ECQB, which EASA holds | Proven cheaters are banned from further examinations for at least 12 months (ARA.FCL.300(f)) |
| EASA Part-66 basic exams at a Part-147 MTO | The MTO, on behalf of the authority (EASA FAQ n.19074) | The MTO’s question data bank, which the authority samples and reviews | Not covered by the EASA pages read; ask your authority |
| FAA airman knowledge tests | Testing centers under FAA Order 8080.6H | Item banks kept “within a secure test maintenance and delivery application/network” (quoted, chapter 3, para 14.a) | One year barred from applying for a certificate, rating or test; held certificates may be suspended or revoked (14 CFR 61.37; 65.18 for Part 65 tests) |
What do the rules say about aviation exam security in the exam room?
The documents read for this post agree on five controls: confirm identity, separate candidates, restrict materials and electronics, supervise continuously, and keep papers confidential until the session ends. They differ in detail, such as seating distance and the response to suspected cheating. The table lines the controls up by source.
The table below is this post’s comparison. Each cell paraphrases or quotes the cited paragraph. The Part-147 column pairs an EASA FAQ with one national authority’s notice, so it shows one approved setting, not a universal rule.
| Control | EASA pilot theory (AMC1 ARA.FCL.300) | Part-147 setting (EASA FAQ n.19077; Transport Malta IAN 27, issue 2, 13 July 2023) | FAA testing center (Order 8080.6H, 2017) |
|---|---|---|---|
| Identity | Confirmed before the exam (para c) | Checked before the exam, passport if needed (IAN 27, 3b) | Valid, current proof of identification (ch. 3, para 1.a) |
| Separation | Seated so papers cannot be read; speak only to invigilators (para d) | No student can read another’s paper or computer screen (FAQ); at least 1 m apart, visible face-on (IAN 27) | Unit member must “clearly and fully view all applicants at all times” (quoted, ch. 3, para 7) |
| Materials | Only needed paper and tools; no other electronic equipment (paras f, i) | Phones, tablets and laptops off and removed, except the exam device; bags where the invigilator can see them (IAN 27) | No written materials other than the supplement book; phones kept out (ch. 3, paras 6.a, 4.a) |
| Supervision | All papers handed back at the end (para e) | Always supervised; invigilator does no other work; remote-location theory exams video and audio recorded daily (IAN 27) | Surveillance of applicants at all times |
| Content | Papers confidential until the session ends (para b) | Marking sheet never taken into the room (IAN 27); authority samples the question bank (FAQ n.19074) | Item banks in a secure maintenance and delivery network (ch. 3, para 14.a) |
| Suspected cheating | Assessed with a view to failing the applicant (ARA.FCL.300(e)) | Organizations asked to report suspicions of fraud and cheating to their authority (EASA SIB 2014-32R1) | “Must immediately discontinue the test,” then notify the ODA administrator and FSDO (quoted, ch. 3, para 8.b) |
For larger groups, EASA’s FAQ n.19077 says “two or more examiners may be used to ensure the integrity of the examination” (quoted). Candidate numbers are limited only indirectly, by the size and layout of the room.
Who can invigilate a Part-147 exam?
An invigilator must be trained, but need not be a subject expert for multiple-choice exams. EASA’s FAQ n.19075 says “the invigilators must be trained to the examination process” (quoted). Transport Malta’s IAN 27 adds that invigilators must not have been involved in the applicant’s training, and that ad-hoc invigilators are valid only where a procedure checks their integrity and independence. Another authority may set different conditions.
Why is the question bank the main target in aviation exam security?
Aviation theory exams draw on a bank that is reused across many sittings, so anyone who obtains questions early gains an unfair edge for every candidate who follows. EASA’s 2015 Opinion 07/2015 described organizations that “released focused information on the content of the upcoming examination to their students” (quoted). Protecting the bank matters more than protecting any single paper.
EASA says the ECQB holds some 10,000 multiple-choice questions and that national authorities run the exams that use it. In 2020 the European Ombudsman backed EASA’s refusal of public access, saying, as reported by AIN, that “the integrity of the exams must be protected” (quoted). Opinion 07/2015 added that the fraud it described happened mostly away from the MTO’s base, “where oversight by the CA is more difficult to exercise” (quoted).
What did the HATA case show about exam records?
It showed that records decide how far a fraud can be unwound. In EASA Safety Information Bulletin 2014-32R1 (11 January 2017), the Hellenic authority revoked a Part-147 approval on 26 February 2014 over alleged exam fraud and cancelled certificates where cheating was confirmed.
Investigations were inconclusive, so the European Commission issued Decision (EU) 2016/2357 ending recognition of certain certificates and the Part-66 licences based on them. The bulletin states that “investigations are nearly impossible to carry out due to incomplete records” (quoted) and asks organizations to “Report to their CA all suspicions regarding fraud, cheating” (quoted).
How do you protect the question bank in aviation exam security?
Treat the bank as controlled material: limit who can read, edit and release items, log every export, release questions to a sitting only when it starts, and keep item-level delivery records. These are good-practice controls drawn from the sources above, not requirements. No regulation read for this post lists them.
- Separate roles. Keep item authors, reviewers, exam assemblers and invigilators distinct where size allows. EASA’s terms of reference for its Part-147 review name conflict of interest as a problem to reduce.
- Give least access. Most staff deliver exams and do not need to read the whole bank. Separate read, edit, export and release rights.
- Release at start. Papers and answer keys should reach the room only when the session begins.
- Track exposure. Count how often each item has been delivered and retire items on a rule. Our guide to building an item bank covers usage counts and retirement.
- Keep delivery records. Record which candidate saw which items, on which form, in which session and room, with which invigilator. Without it, a leak cannot be scoped.
Randomization and timers are a separate layer, covered in our exam security settings checklist. For which control answers which cheating method, see reducing cheating without full proctoring.
Pro tip: Run a Leak Drill. Pick one item, assume it has appeared in a chat group, and time how long it takes to list every candidate who saw it, on which form and in which session. If the answer takes days or needs paper files, fix the records before the next exam.
Can aviation theory exams be delivered online or remotely?
Computer-based delivery is allowed in the sources read, but they assume a supervised room. ARA.FCL.300 allows a “computer-based form” (quoted), and none of the documents read describes unsupervised home delivery as accepted. Whether remote invigilation is acceptable depends on your competent authority, so ask in writing before you plan around it.
The documents read treat the screen as part of the room. EASA’s FAQ says “no student can read the paperwork or computer screen of any other student” (quoted). Transport Malta’s IAN 27 allows virtual exams at remote locations only if they are video-recorded with audio each day and the MTO keeps a copy.
The Swedish Transport Agency’s invigilator instructions (version 26.0, 24 April 2026) say “Under no circumstances shall a student undergo an examination on his/her own computer” (quoted). CASA’s PEXO page requires a secure browser and an invigilator in the room. The part of FAA Order 8080.6H read for this post covers in-person testing centers only.
Pro tip: Ask for the Authority Document. When a vendor says its tool meets EASA or FAA requirements, ask which authority document and paragraph it relies on, and whether your authority has said so in writing. The rules read describe controls, not products.
What should you do when a question leaks or cheating is suspected?
Follow your authority’s rule for the sitting, document the evidence, report through the channel in your approved procedures, then use delivery records to scope who saw what. Authorities differ on the first step, so write your procedure from your own authority’s documents. This sequence is this post’s synthesis.
Step 1: Handle the sitting as your authority says. FAA Order 8080.6H says the unit member “must immediately discontinue the test” (quoted). The Swedish Transport Agency’s instructions say the exam shall not be started or immediately terminated for a student found cheating or not complying (section 1.7).
Step 2: Document the evidence. Record what was found, when and by whom. The Swedish instructions ask for photographs and a written report in a set format, and say not to send copies of ID. Norway’s authority tells invigilators to confiscate evidence such as drafts or notes.
Step 3: Report. Norway’s authority asks to be notified as soon as possible, and the FAA order names the testing center’s ODA administrator and the local FSDO. EASA’s bulletin asks organizations to report suspicions of fraud to their competent authority.
Step 4: Scope the exposure. Use delivery records to list the candidates, forms and sessions that included the item.
Step 5: Replace and log. Retire the exposed items, record the decision, and ask your authority which results to hold.
Are the Part-147 exam rules changing?
EASA’s Part-147 review (RMT.0544) lists reducing exam cheating and fraud as an objective, and NPA 2023-10 discussed exam security. As of October 2026, this post could not confirm a published Opinion or adopted text from that review. Check EASA’s rulemaking page and your authority before relying on the current wording.
EASA’s terms of reference aim to “eliminate or reduce the examination cheating and fraud/conflict of interest within Part-147 organisations” (quoted). NPA 2023-10 (part A, comments closed 4 March 2024) listed “Ensuring the security of examination material” and inspector attendance at examinations in unapproved locations among its topics. These were proposals, not rules.
What should you do next?
Build your own version of the second table. List each exam you run, who runs the sitting, which authority document governs it, and the paragraph of your approved procedure covering each control. Every blank cell is a gap to close, and every unclear cell is a question for your authority, ideally in writing.
If you are choosing software, put the questions from the sections above to every vendor in writing. SimpliAssess’s features page describes a platform for “secure & scalable online tests” with item banking and an API-first design, but its published pages do not describe proctoring, randomization, access control or audit-log features, so ask about those directly.
SimpliTrain is a separate product from the same company. Its question bank page states that it randomizes question selection and answer order for every exam attempt and lets administrators set draw rules by topic and difficulty tier. The page does not describe security controls, so ask about those too. For maintenance exams, see our guide to delivering Part-66 module exams securely.
Frequently asked questions
What is aviation exam security?
Aviation exam security is the set of controls that protect the integrity of exams used for licences, approvals and course completion in aviation. It covers confidential questions, verified identity, supervised delivery and a defined response to cheating. Authorities such as EASA and the FAA set core rules, and organizations add procedures of their own.
Who is responsible for exam security at an Approved Training Organisation?
It depends on the exam. For EASA pilot theory exams, the competent authority runs the exam and must set integrity procedures, and in Norway an ATO registers its candidates through the authority. For Part-66 basic exams, a Part-147 organisation can run exams on the authority’s behalf and owns its question bank. Confirm the split with your authority.
Can aviation exams be taken online or from home?
Computer-based exams are allowed, but the sources read assume a supervised room. EASA’s ARA.FCL.300 allows a “computer-based form”, while the Swedish Transport Agency says no student may sit an exam on their own computer. Acceptance of remote invigilation depends on your competent authority, so ask in writing before you plan around it.
What happens if a candidate cheats in an aviation exam?
The authority sets the consequence. Under EASA’s ARA.FCL.300(f), applicants proven to be cheating are banned from further examinations for at least 12 months. Under 14 CFR 61.37, an FAA applicant found to have cheated cannot apply for any certificate, rating or test for one year, and held certificates may be suspended or revoked.
Does EASA or the FAA approve exam software?
None of the rules or authority documents read for this post lists approved exam software. They describe controls for the room, the candidate and the question content. Treat a vendor claim of “EASA compliant” or “FAA approved” as the vendor’s statement, and ask which authority document and paragraph it relies on.


