Written by Simon Nicholls, Principal Consultant at Baines Simmons
By now, most UK approved Part‑145 and Part‑21 organisations have completed their initial CAA SMS Evaluation Tool (SRG 1776) submission and received feedback on how “present” and “suitable” their safety management arrangements are. For maintenance organisations this means the Safety Management System (SMS), whereas for design and production organisations it is the Safety Management Element (SME).
As part of the implementation process, organisations were required to submit their “implementation changes” before 24 November 2024 so that the UK Civil Aviation Authority (CAA) could review the material, raise any findings and allow time for closure. The next milestone is less than a year away: by 1 July 2026 organisations must demonstrate that their management system and procedures are both “present” and “suitable”. The UK CAA expects the full implementation process to be completed well before this deadline.
After 1 July 2026 the UK CAA will continue to use the evaluation tool during oversight to verify that the system has progressed to the “operating” level and to support continuous improvement. Achieving these milestones can feel like just another compliance box to tick, but it doesn’t have to.
What Is the Real Challenge?
Submitting an evaluation is only the starting point. The UK CAA will audit organisations to confirm that all the enablers of a functioning SMS are present and suitable — sampling evidence and potentially interviewing staff.
By 1 July 2026 any outstanding implementation findings must be closed, otherwise your approval status may be affected. After that date, the regulator’s focus shifts by using SRG 1776 in continuing oversight to determine whether your system is operating. That means procedures are not only documented but applied in practice, hazards are actively managed, and safety performance is monitored. Falling short won’t automatically remove your approval, but it does expose you to repeat findings, increased oversight and risks to business continuity.
The difficulty is that many of the areas SRG 1776 probes — staff confidence in reporting, leadership commitment, meaningful data analysis, and verification of risk controls — are challenging to judge from inside the organisation. Working in the “goldfish bowl” makes blind spots easy to miss. Too often, an SMS is still treated as a compliance exercise with manuals updated and boxes ticked, but questions remain about whether reporting is trusted, data is driving decisions, and risk controls are truly effective. Without an external perspective, these gaps may stay hidden until they emerge as delays, rework or regulatory findings.
Significance of Safety Management Systems
The UK CAA makes it clear that an SMS is much more than a manual and a set of procedures. In its guidance, the UK CAA describes SMS as “a systematic and proactive approach for managing safety risks,” woven into the fabric of the organisation and integrated into day‑to‑day activities.
It goes beyond compliance with prescriptive regulations to a business‑like approach that uses goal‑setting, performance indicators and continuous monitoring. In other words, an effective SMS isn’t just about being safe – it enables risk‑based decision making that makes the entire business more resilient, efficient, and cost effective.
Why SMS Is More Than Compliance
Many organisations treat SMS implementation as a compliance exercise. They update manuals, complete the forms and tick the boxes. Yet the UK CAA will verify not only that procedures exist, but that they are working. As part of the approval process, the regulator will sample evidence, interview staff and confirm that all the enablers of a functioning SMS are present and suitable.
On or after 1 July 2026, if a UK approved maintenance organisation has not closed the implementation findings, its approval certificate must be revoked, limited or suspended. More importantly, a paper-based SMS misses the real opportunity. A mature SMS reduces the likelihood of undesired events or unforeseen issues such as rework, missed deadlines and near‑misses because hazards are identified early, risks are managed, and performance is monitored. To unlock the true potential of an SMS, it must be integrated into day‑to‑day activities and supported by a culture that reflects the safety policy and objectives.
Consider some of the markers in SRG 1776 that are easily overlooked:
• Hazard identification and reporting: The evaluation tool asks whether there is a confidential reporting system that captures errors, hazards and near‑misses and whether staff trust it. Without genuine reporting, you can’t see the weak signals that lead to costly disruptions.
• Data analysis and trend monitoring: It checks that organisations analyse safety data, identify trends and use them to drive decisions. Treating data as a compliance requirement rather than a business asset means missing opportunities to improve efficiency.
• Safety performance indicators and risk control verification: SRG 1776 asks whether you have meaningful safety performance indicators and whether risk controls are monitored for effectiveness. These are not just metrics for regulators, they are management tools to prevent delays, rework and cost overruns.
• Leadership and culture: The UK CAA’s guidance emphasises that an effective SMS is driven from the top and embedded in an organisation’s safety culture. Leadership must “walk the talk”. If your safety messaging isn’t matched by behaviour, staff will stop taking it seriously – and reporting will dry up.
Hidden Challenges of Self‑Assessment
Many of the SRG 1776 markers that underpin these benefits are subjective and hard to self‑evaluate. For example, one marker asks whether personnel express confidence and trust in the organisation’s reporting policy and whether surveys confirm that reports are treated fairly. Another checks whether data is analysed and used to identify trends, with corrective actions taken and followed up. The tool also probes whether safety performance indicators are defined and monitored whether risk controls are verified for effectiveness and whether leadership visibly “walks the talk”.
These elements may not be visible to those immersed in daily operations as reporting levels may seem adequate, data may be collected but not analysed, and leaders may believe they model safety but be perceived differently by staff. An external perspective helps uncover these blind spots and provides objective evidence to support your journey from “present” to “operating”.
Turning Compliance Into Competitive Advantage
So how do you convert your SRG 1776 feedback into an SMS that delivers business benefits? Start by recognising that risk management is a performance tool. When hazards are identified early and risk controls are embedded, you reduce unplanned downtime and avoid the hidden costs of failures. A culture that encourages reporting and treats honest mistakes as learning opportunities uncovers inefficiencies and prevents repeat issues. Safety performance indicators provide real‑time visibility of what’s working and where to invest resources. Ultimately, a robust SMS supports on‑time delivery, protects your reputation and improves the bottom line.
How Baines Simmons Can Help
At Baines Simmons we’ve developed two new services to help organisations achieve compliance and advance into performance:
Pathway to ‘Operating’ Assessment
This 2–3 day assessment validates your SRG 1776 evaluation by sampling evidence and interviewing selected personnel. We analyse how well your processes are implemented, test whether reporting is trusted and provide a roadmap to achieve “Operating” and “Effective” maturity. This assessment is scoped to scale with your organisation’s size and complexity, offering a cost‑effective alternative to a full Management System Performance Assessment.
Safety Management System (Safety Element) Maturity Workshop
In this one‑day interactive workshop, we bring together your management team and key staff to interpret your SRG 1776 results, self‑assess current maturity and explore best practices. We help you create a high‑level action plan that aligns safety improvements with business objectives. This workshop is ideal for smaller organisations or as an entry point to a wider engagement.
Take the Next Step Now
July 2026 may seem far away, but developing an effective SMS takes time. Working through your implementation findings, engaging your staff, embedding risk management and demonstrating a culture of safety cannot be rushed. The organisations that view SMS as a strategic investment, rather than just a compliance requirement, will gain a competitive edge.
If you want to ensure you’re on the right path to “Operating” maturity and gain the business benefits of your SMS, get in touch at hello@bainessimmons.com. Our consultants can help you transform your SRG 1776 evaluation into a practical, risk‑based roadmap that enhances safety and performance.