Moving a Part 147 School From Paper Exams to Online: A Migration Plan
Moving a school that delivers Part 147 training from paper exams to online is safest as six gated phases: scope, map the paper process, prepare the items, agree the change with your authority, pilot beside paper, then cut over and review. It includes a paper-to-online mapping table and a worked parallel-run example.
It is for exam officers, examination managers, quality managers and heads of training at EASA Part-147 maintenance training organisations (MTOs) and FAA Part 147 aviation maintenance technician (AMT) schools. It covers your own course exams, not the FAA mechanic tests under part 65. Facts were checked in November 2026.
This is not legal or airworthiness advice. In the sources reviewed, approval attaches to the organization’s exposition or quality control system, not to software. Check with your competent authority or FAA oversight contact before you change how an exam is delivered.
Key takeaways
- For an EASA MTO, an online exam must run in a controlled environment where identity, conduct, exam integrity and security of the material can be established and verified, and the exposition must describe it (point 147.A.135(d), applicable from 12 June 2024).
- Tell your authority before you change, not after: point 147.A.150(a) asks for notice of proposed changes before they take place, and exposition amendments need approval.
- Run the online exam beside paper before you switch, because the ITC and ATP guidelines say that when a program moves from paper, results should be checked for unexpected technology effects.
- Keep every paper record: the Part-147 text reviewed asks for student examination records for an unlimited period.
What changes when Part 147 training exams move from paper to online?
The delivery changes and the duties stay the same. Your exam standard, pass mark, security duty and records duty carry over. What moves is where answers are captured and how you prove identity, conduct and integrity. Treat it as a change to procedures, not a software install.
Three parties share the decisions:
- The regulation sets the duties, such as a controlled environment for EASA exams or a quality control system for FAA schools.
- Your authority decides whether your changed procedures are acceptable.
- You decide the platform, the phase order, the pilot design and your exit criteria.
Which Part 147 training rules and approvals does an online exam touch?
For EASA MTOs, an online exam touches the exposition, the approved exam locations, the controlled-environment test and the records point. For FAA schools it touches the quality control system, recordkeeping procedures and the pass-rate duty. The sources reviewed set no migration procedure.
The table lists each provision as read in November 2026 and what it means for the move.
| Provision | What it says (paraphrased unless marked) | What it means for the move |
|---|---|---|
| EASA 147.A.135(d) | The exam “shall be performed in a controlled environment” (quoted) by the approved organization and described in the MTOE. | Write the online sitting into the MTOE before the first live exam. |
| EASA 147.A.145(b) | Knowledge exams may only be held at locations identified in the approval certificate or the exposition. | List every room where candidates will sit online. |
| EASA 147.A.140(b), (c) | Exposition amendments are approved by the authority; minor ones can go through an exposition procedure (indirect approval). | Ask which route your change takes. |
| EASA 147.A.150(a) | Proposed changes that affect the approval are notified “before any such change takes place” (quoted). | Date your notice ahead of the pilot. |
| FAA 14 CFR 147.23 | A quality control system is approved by the Administrator if the school is not accredited; it must cover “recordkeeping, assessment, issuing credit, issuing of final course grades, attendance” (quoted). | Update those procedures for online delivery. |
| FAA 14 CFR 147.25 | At least 70 percent of students who take an FAA mechanic test “within 60 days after graduation” (quoted) must pass, over the most recent 3 years. | Watch pass rates through the move. |
Two cautions. The Annex IV text on legislation.gov.uk reproduces the EU wording as of 24 March 2020 and has no paragraph (d); that was added by Regulation (EU) 2023/989, applicable to Part-147 from 12 June 2024. For the FAA side, the eCFR text of Part 147 reviewed on 1 November 2026 states no notice step for changing how a school delivers its own tests, so ask your FAA oversight contact.
This plan does not repeat the full requirements: see our guides to EASA Part-147 examinations and FAA Part 147 and ACS-based testing.
What are the six phases of a paper-to-online migration plan?
The phases are scope, map, prepare, agree, pilot and cutover, followed by a 90-day review. Each ends with a gate, evidence that must exist before the next phase starts, and paper stays available until the last gate is passed.
The table gives the work and gate for each phase. The gates are suggested practice, not regulatory steps.
| Phase | Work | Gate (evidence) |
|---|---|---|
| 1. Scope | Pick the first exam type, the sites and the devices. Leave essays and practical assessments on paper at first. | One-page scope note naming a paper-fallback owner |
| 2. Map | Walk one paper sitting end to end and list every artifact it produces. | Mapping table reviewed by the quality manager |
| 3. Prepare | Convert items, tag them, set keys and rules, then mark old scripts in the system. | System marks match hand marks on every old script |
| 4. Agree | Draft exposition or quality control changes, give advance notice, ask which approval route applies. | Authority’s reply on file; changes in force before the first live sitting |
| 5. Pilot | Run mock sittings, then a parallel run; brief invigilators; rehearse a failure. | Written exit criteria met |
| 6. Cut over | Hold the first live sitting with paper ready, then review after 90 days. | Review note: incidents, pass rates, candidate feedback |
How do you map each paper step to its online equivalent?
List every artifact a paper sitting produces and decide which online record replaces it. Paper proves identity, conduct, integrity and security through physical objects. Online, the same proof must come from logs and procedures.
The table pairs each paper artifact with its online equivalent.
| Paper artifact | Online equivalent | Watch out for |
|---|---|---|
| Papers in a locked cabinet | Versioned items released to a named sitting | 147.A.135(a) says “The examination staff shall ensure the security of all questions.” (quoted) Control who can see items early. |
| Signed register and ID check | Check-in record naming the person who checked | A password proves an account, not a person. |
| Invigilator walking the room | Invigilator log plus fixed room and seating rules | Do not assume a remote view of the room. |
| Handwritten answer sheet | Timestamped response record | Keep unscored responses, not only the score. |
| Hand marking against a key | Automatic scoring with a log of any override | A wrong key now affects every candidate at once. |
| Essay answers | Typed answers, or scanned handwriting | Appendix II to Part-66 says “Each essay question requires the preparation of a written answer.” (quoted) Ask whether typed answers qualify. |
How do you convert paper papers into an item bank without changing what they measure?
Convert items, not pages. Load each question once, tag it to its module or subject, record its version and key, and rebuild papers from the bank by rule. Then check the online version behaves like the paper one.
The ITC and ATP Guidelines for Technology-Based Assessment (2022 edition; check for a newer one) say: “when a paper-and-pencil fixed form is converted to a computer-based testing format, item performance may change.” (quoted) They focus on technology-enhanced items, but the reasoning applies to converted multiple-choice items.
Four checks catch most conversion errors:
- Keep three options and one correct answer for Part-66 basic knowledge multiple-choice items; do not let an import template add a fourth.
- Preview every figure and diagram on the screens candidates will use. The guidelines give “screen size, or the amount of scrolling needed” (quoted) as examples of interface differences to study.
- Tag each item to a module or ATA chapter, as in our post on structuring an aviation question bank.
- Keep pilot items out of live papers, and pilot sittings out of your attempt ledger.
Pro tip: Convert A Retired Paper First. Load a paper you have already retired, then mark ten old scripts both by hand and in the system. Any mismatch is a key, format or rule error found before a live candidate is affected.
How do you run a parallel run, and what result is good enough?
Run matched forms on paper and online with similar candidates, in both orders, then compare mean scores and pass or fail decisions. No source reviewed sets a pass threshold for this, so write your exit criteria first. A small pilot can flag problems; it cannot prove the two modes are equivalent.
The ITC and ATP guidelines also advise surveying test takers about the new technology (guideline 1.2) and giving tutorials and practice items first (1.4 and 1.14). Build both in. The numbers below are invented to show the arithmetic.
Take 24 candidates and two matched 40-item forms. Half sit Form A on paper then Form B online; half sit Form B on paper then Form A online. Swapping the forms cancels differences in form difficulty and practice. Use your own pass mark; 75 percent is assumed.
| Measure (illustrative) | Paper | Online | Reading |
|---|---|---|---|
| Mean score | 78.1% | 77.4% | Gap of 0.7 points |
| Candidates at or above 75% | 17 of 24 | 16 of 24 | One fewer pass online |
| Same pass or fail decision in both modes | 21 of 24 (87.5%) | Three decisions changed, all within 4 points of the pass mark | |
| Candidates reporting a problem | 3 of 24 | All three mention scrolling on diagram items | |
Suppose your exit criteria were a mean gap under 2 points, decision agreement of at least 85 percent and no unresolved usability complaint. Those are example thresholds, not a standard. The first two are met, but the scrolling complaint blocks exit: fix the diagram layout and rerun the affected items. The three changed decisions sit near the pass mark, where small shifts flip outcomes in any mode, yet with 24 candidates you cannot separate chance from a mode effect.
What should cutover day and the first term look like?
Cut over with paper still available, a named person who can call a switch back, and invigilators trained on the new procedure. Start with one exam type at one site and review after 90 days. Moving everything at once hides which change caused a problem.
Before the first live sitting, have these in place:
- A written procedure for the online sitting, including what the invigilator does when a device fails.
- A candidate tutorial and practice items covering navigation and, as the guidelines put it, “how to respond (including how to change a response)” (quoted).
- Paper fallback papers printed, with fallback sittings tagged separately in the records.
- Before-and-after pass rates by exam, so a drop shows early.
Pro tip: Name The Switch-Back Trigger Now. Write down the events that send a sitting back to paper, such as lost responses or a failed identity check, before the first live sitting. Deciding with candidates waiting leads to inconsistent calls.
What happens to your paper records and old exams?
Nothing is discarded because you went online. In the version reviewed, Part-147 point 147.A.125 says the organization “shall keep all student training, examination and assessment records for an unlimited period” (quoted). The sources reviewed do not say whether scans may replace paper originals, so ask your authority before you shred anything.
After cutover, pull one paper-era sitting and one online sitting and confirm you can show the same facts for both: candidate, version, identity check, marks and incidents. Label each record paper or online. Our post on aviation exam records, retention and traceability sets out what a full record set holds.
What should you do next?
Take one exam type and walk a single paper sitting from question release to filed script. Fill in the mapping table, mark each row Covered, Partly covered or Missing online, then draft the change note for your authority. That completes phases 1 and 2 without buying anything.
When you compare software, ask each vendor to import a retired paper in your format and show the sitting record it exports. SimpliAssess’s features page lists item banking and “Bulk Import” as labels, with no detail on file formats or aviation use, so ask for specifics. SimpliTrain’s question bank page says it supports QTI-format import and export, per-attempt randomization and per-question version control; it does not mention Part-147 exams, so test your own items first.
Frequently asked questions
Can a Part 147 school run its exams online?
Possibly, with conditions your authority judges. For EASA MTOs, point 147.A.135(d) requires a controlled environment where identity, conduct, integrity and material security can be established and verified, described in the exposition. FAA schools should confirm their procedures with their oversight contact. No source reviewed approves a platform.
Do you need your authority’s approval before moving exams online?
Tell it before the change. Point 147.A.150(a) asks for notice of proposed changes before they take place, and 147.A.140(b) and (c) cover exposition approval, including indirect approval for minor amendments. The text does not name online exams, so ask which route applies and get the reply in writing.
How long should a paper and online parallel run last?
No source reviewed sets a duration or sample size. Run it until your written exit criteria are met for each exam type, with candidates sitting in both orders. A run of 24 candidates can flag problems such as unreadable diagrams but is too small to prove the modes equivalent.
Can essays and practical assessments stay on paper while written exams go online?
Yes, nothing in the sources reviewed requires every exam to move together. Appendix II to Part-66 describes an essay answer as a written answer, and the sources do not say whether typed answers qualify. Keep essays on paper until your authority confirms.
Does going online change the pass rate an FAA Part 147 school must keep?
No. Section 147.25 sets a 70 percent pass rate over the most recent 3 years for students who take an FAA mechanic test within 60 days after graduation. That rate relates to FAA tests, not your own course exams, but track your pass rates through the move.
