How ready is your operation for the 2 December 2026 SMS mandate?

From 2 December 2026, CASA EX73/24 SMS exemptions end for air transport operators under CASR Parts 119, 121, 133, 135, and 138. Part 91 also has adjacent general operating rules. Affected operators have a 1 September 2026 documentation submission deadline. The framework required is an integrated Safety Management System covering safety policy + accountabilities, hazard identification and risk assessment, safety assurance (internal audit + management review), and safety promotion — aligned with the ICAO Annex 19 / CASR 119 SMS architecture.

It is a directional readiness check, not a CASA-grade audit. The 7 questions cover the same four pillars the mandate requires — safety policy + accountabilities, risk management, safety assurance, safety promotion — plus your current documentation state and MAAT familiarity. The score gives you a tier and a recommended next step; the full diagnostic happens at the intake call for the CASA Documentation Pack, which is where operator-specific edge cases get factored in.

MAAT is the CASA Manual Authoring and Assessment Tool — the CASA-published authoring environment for operator manual submissions. Operators who use MAAT (or have at least seen it) tend to be further along the documentation chain than operators who have not heard of it. The checker scores that as a small bonus, not a hard requirement.

You see the score on-screen the instant you submit the quiz. The email gate is for the durable copy you can forward to your accountable manager, your safety manager, or your board. Joey will also follow up within one business day with a read on which sections of the CASA Documentation Pack address your specific gaps — async, no sales call required to get the diagnostic.

Part 91 has general operating rules that adjoin the air-transport mandate but it is not itself the air-transport SMS regulation. If your operation is purely Part 91 (private operations, no air-transport flying), the December 2026 mandate likely does not require you to submit an SMS framework — but you may still benefit from one operationally. The Part 91 option on the operator-type question scores zero points specifically because the mandate does not cover it as directly as the air-transport parts.

It is a lead-capture tool — we are not hiding that. The scoring logic is deterministic and runs identically on the client and the server; you can audit the source in lib/sms-readiness-checker.ts on the OTGM GitHub repo. The risk-tier framing is honest about being directional, not definitive. If your score comes back AMBER-READY, the recommended next step is a small delta-pack, not the full Documentation Pack — because that is what fits the gap.

Joey Pehrson — commercial helicopter pilot, Grade 2 flight instructor, and the founder of Off The Ground Marketing. The 7 questions are calibrated by someone who has carried the documentation rebuild work by hand at a previous Part 141 operator. That is the difference between a generic compliance quiz and one calibrated by the work it scores.