Press release · 25 May 2026
Seven-question diagnostic targets Part 119/121/133/135/138 operators facing the 1 September 2026 documentation submission window
Brisbane Aviation Agency Launches Free CASA SMS Readiness Checker Ahead of December 2026 Deadline
Off The Ground Marketing has published a free Safety Management System readiness self-assessment for Australian air transport and aerial work operators affected by the expiry of CASA EX73/24 on 2 December 2026. The tool scores documentation maturity against the ICAO Annex 19 / CASR Part 119 four-pillar framework and surfaces the gaps operators must close before the 1 September 2026 submission deadline.
Brisbane, Australia — 26 May 2026
Off The Ground Marketing, an aviation-specialist marketing and compliance agency based at Archerfield Airport in Brisbane, has launched a free CASA SMS Mandate Readiness Checker for Australian air transport and aerial work operators affected by the 2 December 2026 expiry of the Civil Aviation Safety Authority’s EX73/24 Safety Management System deferral. The tool is available at offthegroundmarketing.com/tools/sms-mandate-readiness-checker.
The checker is a seven-question self-assessment that produces a 0–100 readiness score, a four-tier risk classification, and a recommended next step. It is calibrated to the CASR Part 119 framework requirements and the ICAO Annex 19 four-pillar architecture that CASA reviewers assess submissions against.
The Regulatory Backdrop
From 2 December 2026, the SMS provisions inside the CASA Flight Operations Regulations Supplementary Exemptions and Directions Instrument 2024 (EX73/24) cease to have effect. Affected operators — those certified under CASR Part 119, Part 121, Part 133, Part 135, and Part 138 — must from that date be operating a documented Safety Management System that complies with the framework requirements inside their operator-class Part.
The date most operators have not yet absorbed is the one that decides whether they get there comfortably: CASA expects affected operators to submit their SMS documentation by 1 September 2026 so it can be assessed and acknowledged before the 2 December hard date. Operators pacing toward December are already running three months behind.
The affected operator population covers scheduled and non-scheduled aeroplane air transport, rotorcraft air transport, smaller aeroplane charter, and aerial work operations such as survey, agricultural application, sling-load, and aerial photography.
“Most Part 141 schools and Part 135 charter operators I talk to know the December date exists, but they are treating it like another box-tick to come back to. The Readiness Checker takes seven minutes and tells them whether they are closer to operationally ready or closer to grounded. The real deadline is 1 September, not 2 December — and an operator who starts the documentation work in August is going to have a hard time.”
The Gap CASA Reviewers See Most Often
Off The Ground Marketing’s compliance practice cites three recurring failure modes across operator conversations. The first — the most common — is a safety policy statement signed by the accountable manager but with no functioning framework underneath it: no active hazard register, no risk assessment process, no internal audit cadence, no management review minutes. CASA reviewers can identify the pattern within minutes of opening the documentation package, and acknowledgment is unlikely.
The second is documentation that exists in scattered form across email threads, shared drives, and individual notebooks, never assembled into a single inspector-readable submission. The third — the highest-risk segment for the September deadline — is operators who have been heads-down on operations for the past 18 months and have not yet engaged with the EX73/24 transition at all.
The Readiness Checker is designed to surface which of those positions an operator sits in within seven minutes of completing the self-assessment.
How the Checker Works
The seven questions cover an operator’s current SMS documentation state, safety policy and named accountabilities, hazard identification and risk assessment maturity, change management process, safety assurance cadence (internal audit plus management review), safety promotion and culture, and familiarity with the CASA Manual Authoring and Assessment Tool (MAAT).
Scoring is deterministic and weighted toward the most direct readiness signals — current documentation state carries 25 points of the 100 available, with the four ICAO Annex 19 pillars allocated according to operational impact. The math runs identically on the client browser and on the server, and the scoring logic is open in the lib/sms-readiness-checker.ts file of the agency’s public GitHub repository.
Outputs are mapped to four risk tiers: AMBER-READY (80–100), WORK TO DO (50–79), HIGH RISK (20–49), and CRITICAL (0–19). Each tier returns a tier-specific next step rather than a generic upsell. A score in the AMBER-READY band, for instance, returns a recommendation for a smaller delta-pack scoped to the remaining gaps — not the full documentation pathway.
The Agency Position
Off The Ground Marketing operates a hybrid aviation marketing and compliance practice from Archerfield Airport. The agency was founded in 2018 by Joey Pehrson, an active commercial helicopter pilot and CASA Grade 2 flight instructor who served as the general manager of a Part 141 flight training organisation before founding the agency. The compliance practice runs alongside the agency’s sector-marketing work for flight schools, charter operators, aircraft management firms, FBOs, and MRO businesses.
The checker is the diagnostic front end of a broader compliance offer that includes a fixed-fee CASA Documentation Pack — Operations Manual templates, the full SMS framework, MAAT-populated drafts, instructor-signed at the end — and an Audit-Defensible CBTA Pack for Part 141 and Part 142 flight training organisations carrying Part 61 competency mapping obligations alongside the air transport SMS requirement.
The deep-dive technical reference behind the checker is available at offthegroundmarketing.com/blog/casa-sms-mandate-december-2026-what-au-operators-need-to-know.
About Off The Ground Marketing
Off The Ground Marketing is an aviation-specialist marketing and compliance agency headquartered at Archerfield Airport in Brisbane, Queensland. Founded in 2018 by Joey Pehrson — an active commercial helicopter pilot, CASA Grade 2 flight instructor, and former general manager of a Part 141 flight school — the agency works exclusively with aviation operators, with active engagements across Australia, the United Kingdom, Ireland, Germany, the Netherlands, France, the United States, Canada, New Zealand, and the United Arab Emirates. The compliance practice was established to give Australian operators a fixed-fee, instructor-signed pathway through the CASA documentation work the December 2026 SMS mandate requires.
Media Contact
Joey Pehrson — Founder, Off The Ground Marketing — joey@offthegroundmarketing.com
Tool: https://offthegroundmarketing.com/tools/sms-mandate-readiness-checker
Technical reference: https://offthegroundmarketing.com/blog/casa-sms-mandate-december-2026-what-au-operators-need-to-know
Press contact
Press, trade publications, and editorial enquiries are welcome.
info@offthegroundmarketing.com →Documented client outcomes are published at /work.
The case-study figures cited in this release — including the J2 Air CPL reduction and flight-school enquiry growth — are verifiable against the named case studies on the agency's portfolio page.