14 sections · 66 audit questions · Implementing Rule, AMC and GM · v2025-11-25
Part-DTO governs declared training organisations — a lighter regulatory regime than Part-ORA, deliberately structured around an annual self-assessment rather than an ongoing approval. The audit grain is set by GM2 to ORA.FSTD.100 and the M.A.616 Appendix VIII model, both reproduced verbatim where they appear.
Authoring this Part meant accepting that the audit checklist is the internal-review document — there is no separate audit-vs-review distinction for DTOs. The checklist reflects DTO.GEN.270’s annual-review obligations directly, and includes DTO.GEN.150 and DTO.GEN.210 because those leaves drive what the annual review has to verify.
Click a row's citation to jump to it. The audit-question count shows how many auditable rows the checklist generates from that leaf (zero means the leaf is informational only).
| Citation | Kind | Title | Audit questions |
|---|---|---|---|
| DTO.GEN.150 | IR | Findings | 4 |
| DTO.GEN.210 | IR | Personnel requirements | 15 |
| DTO.GEN.210(a)(1)(i)((a)(1)(i)) | GM | Personnel requirements — occurrence-reporting system compliant with Reg (EU) No 376/2014 (GM) | 11 |
| DTO.GEN.210(a)(1)(ii)((a)(1)(ii)) | AMC | Personnel requirements — safety policy (AMC) | 5 |
| DTO.GEN.210(a)(2)((a)(2)) | AMC | Personnel requirements — qualification and experience of the head of training (AMC) | 4 |
| DTO.GEN.210(a)(2)((a)(2)) | GM | Personnel requirements — sufficient experience of the head of training (GM) | 1 |
| DTO.GEN.210(c)((c)) | GM | Personnel requirements — circumstances under which a person cannot be trusted (informational) | 0 |
| DTO.GEN.210(d)&(e)((d)(e)) | AMC | Personnel requirements — DTO instructors list (AMC) | 1 |
| DTO.GEN.210(d)&(e)((d)(e)) | GM | Personnel requirements — resources (instructors) (GM) | 2 |
| DTO.GEN.270 | IR | Annual internal review and annual activity report | 4 |
| DTO.GEN.270(a)((a)) | AMC | Annual internal review and annual activity report — scope of the annual internal review (AMC) | 10 |
| DTO.GEN.270(b)((b)) | AMC | Annual internal review and annual activity report — content of the annual activity report (AMC) | 7 |
| DTO.GEN.270(c)((c)) | AMC | Annual internal review and annual activity report — submission to the competent authority (AMC) | 1 |
| DTO.GEN.270(c)((c)) | GM | Annual internal review and annual activity report — recommended submission time frame (GM) | 1 |
The Compliance Matrix is the verification document — every paragraph in scope on one PDF. The audit checklist bundle is the per-question working document (66 questions, 5 artefact formats).