Runway excursions, unstable approaches, and take-off performance gaps. These aren’t new risks, but as of 1 January 2028, how your Flight Data Monitoring programme addresses them will be subject to a new, more demanding standard.
On 2 December 2025, EASA published ED Decision 2025/020/R, issuing amendments to the Acceptable Means of Compliance (AMC) and Guidance Material (GM) governing FDM programmes under Part-ORO and Part-SPA. For the first time, EASA has defined concrete, measurable minimum performance conditions for FDM programmes — moving from broad guidance to specific, auditable requirements.
Personally, I welcome the updates as there has been a fair amount of misuse of the term “Flight Data Monitoring” recently. This new publication will help clear up any remaining ambiguity.
If you’re a Safety Manager at a commercial operator, this affects you directly. The good news: you have until 1 January 2028 to comply, and two years is enough time to prepare properly if you start now. The less-good news: some of what’s required will demand changes inside your organization that take longer than you might expect — particularly around your Safety Management System documentation and crew representative agreements.
This post walks through the eight key areas of the new standard, what each means in practice, and where Sky Analyst already positions your programme ahead of the curve.
If you are new to Flight Data monitoring, be sure to check out our complete Flight Data Monitoring Guide for information about what FDM is, how to get started and how to ensure you have an effective program.
Why Did EASA Act Now?
EASA identified five gaps in how FDM programmes were being run across European operators:
- No defined minimum performance standards for data recovery, processing, or analysis.
- No mandatory minimum set of safety risks an FDM programme must cover.
- Guidance that hadn’t kept pace with modern FDM technology.
- Insufficient connection between FDM programmes and operators’ Safety Management Systems.
- Unclear rules around data protection when FDM data is used alongside other safety sources.
These gaps weren’t theoretical. They were surfaced through standardization inspections, accident investigation reports, and safety recommendations from the French BEA and UK AAIB — both of which specifically called on EASA to mandate take-off performance monitoring after incidents where FDM programmes simply weren’t capturing what mattered.
The result is a set of AMC and GM amendments that define, for the first time, what a properly performing FDM programme actually looks like.
What the New Requirements Cover
1. Flight Data Recovery — The 80% Collection Rate
This is a big one for operators that are currently just “checking a box”: Your FDM programme must achieve an 80% global flight collection rate across your in-scope fleet on a rolling 12-month basis. This is a fleet-wide metric, not a per-aircraft one — a deliberate concession to operational realities like spare parts delays and infrequently used aircraft.
Two important alleviations worth knowing: operators with fewer than 20 in-scope aircraft receive a less stringent version of this objective. And aircraft that performed fewer than 50 flights in the past 12 months are excluded from the calculation entirely.
What this means for you: You need to be able to demonstrate your collection rate on request — not just achieve it. That means the metric needs to be tracked, visible, and reportable. If your FDM programme is running on spreadsheets or manual reviews, this is the requirement that exposes that gap most clearly.
Sky Analyst: Collection rate tracking is built into Sky Analyst at both the fleet and individual tail level. Your collection performance is visible at any time and reportable on demand. With our premium service, we can even ingest your flight schedule during data processing, automating the process entirely.
2. Failure Detection — 10 Flights or 22 Calendar Days
When an individual aircraft stops transmitting data, you must have a systematic means of detecting that failure within 10 flights or 22 calendar days — your choice of criterion. Once detected, you have 120 days to correct it.
What this means for you: This is an alerting obligation, not just a monitoring one. A manual review process where someone eventually notices a tail has gone quiet doesn’t meet the standard. You need a systematic, documented process — ideally automated — that catches data collection failures before they become prolonged gaps.
Sky Analyst: Sky Analyst monitors data receipt at the individual aircraft level and flags tails that have stopped reporting, supporting the detection window required by the new AMC. Customers of our full service offering receive proactive notification from their lead analyst as soon as recovery rates drop.
3. Processing Timeliness — 22 Calendar Days or 10 Subsequent Flights
For at least 80% of flights collected over the preceding 12 months, your FDM software must process the data within 22 calendar days of the flight, or before the aircraft completes 10 further flights — again, your choice.
This is a direct performance standard on your FDM service. If you outsource FDM processing, you need to be able to demonstrate your service provider meets it.
What this means for you: Review your current FDM service agreement. Does it include a processing SLA? If not, this requirement gives you the basis to request one — and to verify it’s being met.
Sky Analyst: Sky Analyst’s processing pipeline is designed to significantly exceed the 22-day standard for all collected flights. In fact, your data is available for review within minutes of uploading, 24 hours a day, 7 days a week. This is a formal part of our service commitment and can be documented for your compliance records. Our recommendation has always been to upload data no less frequently once every two weeks (preferably weekly) so that flight details are fresh in the flight crew’s memory if you ever need to ask them for more information on the flight.
4. Minimum Risk Coverage — The Risks You Must Monitor
This is the most substantively new requirement in the Decision, and the one most likely to require changes to your event library.
EASA has defined a minimum set of risk areas that every FDM programme must cover. For aeroplane operators, this is explicitly tied to three safety issues in EASA’s Annual Safety Review:
SI-0007 — Approach path management. Unstable approaches, high energy on final, deviations from glidepath. These events are the leading precursors to runway excursion and controlled flight into terrain.
SI-0015 — Entry of aircraft performance data. Monitoring for indications that incorrect performance data may have been entered before departure. This was the subject of a serious incident involving a Boeing 737-800 at Kuusamo Airport in 2021.
SI-0017 — Take-off performance gap. The difference between certified take-off performance and what is actually achieved in operations. This was specifically called out by the French BEA following a serious incident involving an Airbus A340 at Bogotá in 2017. At least two separate safety investigation authorities have recommended to EASA that this be mandated — and now it is.
In addition, your programme must include monitoring for indications that airworthiness may be affected — structural or systems anomalies detectable through flight parameter deviations.
What this means for you: Audit your current event library against these three risk areas. Approach path management is well covered by most programmes. Performance data entry and take-off performance monitoring are where gaps are most commonly found, particularly take-off performance, which requires more sophisticated event logic than a simple exceedance trigger.
Sky Analyst: Sky Analyst’s event library covers all three mandated risk areas. Approach management events are a core part of the standard event set. Our new event detection engine, EDEN, can compare FMS entered gross weight to flight planned weight where available, making it possible to identify data entry errors. We are also actively strengthening our aircraft performance monitoring capabilities ahead of the 2028 deadline to include more automation related to take-off performance events. These enhancements will be available to all customers.
5. Event Validation — Knowing What Your Events Actually Mean
The new AMC formally defines two terms that have previously been used inconsistently across the industry: a significant FDM event (one that warrants investigation and potential intervention) and validating an FDM event (the process of confirming an event represents a genuine operational occurrence rather than a data artefact).
Operators must have a documented understanding of their validation principles and a process for validating significant events within a defined timeframe.
What this means for you: You need to be able to explain and demonstrate your event validation process — not just to your own team, but to your competent authority if asked. The documentation doesn’t need to be a controlled formal document; it just needs to exist and be producible on request.
Sky Analyst: Sky Analyst’s event detection and validation methodology is documented and available to our customers in a format suitable for regulatory submission. We can provide this documentation as part of your compliance preparation. And unlike some service providers, Scaled Analytics validates ALL events — not just high severity events. Our advanced event detection engine, EDEN, makes this possible by producing a false to valid ratio of under 3% across all of our service customers.
6. Data Retention — Two Years of Raw Data
Your programme must retain at least 80% of raw or decoded flight data on a rolling two-year basis. Data must remain available for reprocessing by FDM software, though it no longer needs to be instantly accessible.
One critical carve-out: if you change FDM software or service provider, the two-year retention objective does not apply for two years from the date of the switch. The clock resets from your new deployment date.
What this means for you: Check your current data retention policy. If you’re deleting flight data earlier than two years, update the policy before 2028. If you’re considering switching FDM providers before then, be aware that the transition carve-out explicitly protects you during the changeover period.
Sky Analyst: As part of Scaled Analytics’ comprehensive Data Retention Policy, Sky Analyst retains decoded flight data in accordance with the two-year rolling window required by the new AMC.
7. FDM as Part of Your Safety Management System
This is the requirement that will create the most internal work — and it’s also the most important structural change in the Decision.
FDM is no longer treated as a standalone monitoring activity. It must now be formally embedded in your Safety Management System. Specifically:
Your Safety Manager must have defined FDM responsibilities. Your Safety Review Board must include the FDM programme in its remit. FDM data must formally feed your Safety Risk Management process — hazard identification, risk assessment, and mitigation monitoring. FDM procedures must be referenced in your compliance monitoring framework.
This isn’t a software change. It’s an organizational and procedural one.
What this means for you: This is where your two years of preparation time matters most. You will likely need to revise your Safety Management documentation, define how FDM outputs feed your risk register, and potentially update your agreement with crew representatives to reflect updated data protection procedures. Depending on the current state of your program, you may want to start this work in 2026, not 2027.
Sky Analyst: Sky Analyst produces outputs — trend reports, event summaries, risk indicator data — that are structured to feed directly into your SRM process. Our service customers receive monthly or quarterly report booklets that feed directly into those customers’ SMS programs. Our Enterprise customers can generate these reports and booklets on demand. Customers of our Sky Analyst ASR software benefit from having full, integrated access to the FDM data directly within the SMS software.
8. Documentation — On Request, Not on Demand
After significant industry pushback during the consultation process, EASA clarified that operators do not need to maintain a library of controlled, perpetually-updated documents. They need only be able to produce the required documentation when their competent authority asks for it. EASA explicitly noted that this documentation can be automatically or semi-automatically generated by FDM software.
Required documentation includes the source and performance characteristics of flight parameters used in your FDM algorithms, the algorithms themselves, and the principles you apply to ensure FDM outputs are of adequate quality.
What this means for you: This is more manageable than it first appeared when the draft was published. You don’t need a formal document management system for FDM. You need a process by which you could produce this information within a defined timeframe if asked.
Sky Analyst: Sky Analyst can generate on-demand documentation covering monitored events, the logic applied to produce them, and the parameter sources used. Our system utilizes industry standard FRED files, making parameter reporting simple and straightforward. This capability directly addresses the documentation requirement and removes the compliance burden from your team.
What You Should Do Now
The 2028 deadline is far enough away that there’s no reason to panic, but close enough that decisions made in 2026 will determine whether your programme is ready or scrambling. Here’s a practical way forward:
This year: Review your current event library against SI-0007, SI-0015, and SI-0017. Identify any gaps in approach path, performance data entry, and take-off performance monitoring. Confirm your FDM service provider meets the 22-day processing standard and can document it. Check your data retention policy.
In 2026–2027: Begin the SMS documentation work. Assign FDM responsibilities explicitly to your Safety Manager role. Define how FDM data feeds your risk assessment process. If a crew representative agreement is in place, review whether it needs updating to reflect the new identity-protection provisions in the AMC.
Before January 2028: Verify your collection rate reporting is auditable. Ensure your failure detection process is systematic rather than manual. Confirm your event validation documentation is producible on request.
A Note on the Transition Carve-Out
One detail worth flagging for operators who are considering reviewing their FDM service arrangements: EASA has built an explicit two-year grace period into the data retention requirement for operators who change FDM software or service providers. If you make a switch, the 80% retention objective doesn’t apply until two years after your new deployment date. This provision was deliberately included to remove a compliance barrier to platform migration. If concerns about a data gap during transition have kept you from evaluating your options, that concern no longer applies.
The Bottom Line
The January 2028 effective date is a genuine deadline, not a soft target. EASA’s amendments to the AMC aren’t aspirational — they define the minimum standard against which your programme will be assessed by your competent authority.
The operators who will handle this transition most smoothly are those who start the SMS integration work early, verify their event coverage now, and work with an FDM service provider who can demonstrate compliance rather than just promise it.
If you’re a Sky Analyst customer, we’ll be in touch well ahead of the 2028 deadline to walk through your programme’s readiness. If you’re not yet a customer and want to understand how Sky Analyst positions you against the new requirements, we’re more than happy to discuss this with you. You can reach us at info@scaledanalytics.com or fill out a contact request form and we will get back to you shortly.
In the coming weeks, we will post additional blogs and short videos discussing each of these 8 areas in more detail. If you’d like to be kept up to date, subscribe to our newsletter, or check back here often.
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