Flying Internationally: What SMS Coverage Do I Need?

Flying internationally brings more than just new destinations and airspace, it also means stepping into a different regulatory environment. While the FAA governs U.S. operations, once you cross borders, the International Civil Aviation Organization (ICAO) standards apply.

ICAO’s Annex 19 requires all commercial operators, and in many cases, general aviation operators, to maintain a functioning Safety Management System (SMS). Authorities abroad can, and often do, ask for proof that you have a system in place to manage safety proactively and that it meets international SMS requirements aviation authorities expect.

The Four ICAO SMS “Pillars”

To align with ICAO Annex 19, your SMS must include all four pillars:

1. Safety Policy – A documented leadership commitment to safety and clear policies to guide operations.

2. Safety Risk Management – Processes for identifying hazards, assessing risks, and putting mitigations in place.

3. Safety Assurance – Ongoing monitoring, audits, and data collection to confirm your SMS is working.

4. Safety Promotion – Training, communication, and initiatives that reinforce safety culture.

   
   

FAA vs. ICAO: What’s the Difference in International SMS Requirements for Aviation?

• FAA (U.S. Domestic): FAA Part 5 currently applies to Part 121 airlines and will be required for Part 135 charter operators by 2027. Part 91 private operators aren’t mandated to have SMS domestically… yet.

  
  

• ICAO (International): All operators crossing borders may be asked to show compliance with Annex 19, regardless of whether the FAA requires it for your operation type.

  
  

The level of SMS coverage you’ll need depends on your operation type. Some operators only need to show alignment with ICAO standards, while others must demonstrate full compliance with both FAA and ICAO requirements. Here’s how that breaks down:

• Part 91 (Private/Corporate): Domestically, not required, but internationally you should be prepared to show a documented SMS aligned with ICAO. Ramp inspectors may ask about hazard reporting processes, safety policies, or how you evaluate risk before a flight. Being prepared to show them on your phone or ipad will go a long way.

  
  

• Part 135 (Charter/Commercial): Already facing an FAA mandate by 2027. Internationally, authorities expect you to have a mature, active SMS with evidence of use (FRATs completed, hazards tracked, audits performed).

  
  

• Part 121 (Airlines): Already required to comply with FAA Part 5, which aligns closely with ICAO. Inspections typically focus on proof of effective implementation, not just the existence of a manual.

  
  

• Part 145 (Maintenance/Repair Stations): Increasingly under scrutiny abroad. Authorities may ask to see how your safety program applies to ground operations, documentation of audits, and employee reporting mechanisms.

  
  

What Happens During a Ramp Inspection Abroad?

Foreign Civil Aviation Authorities (CAAs) often perform ramp inspections to verify international operators are meeting ICAO obligations. These are not casual conversations, they are structured checks. Common areas of focus include:

• Documentation: Inspectors may ask to see your SMS manual, risk assessment forms, hazard reports, or recent audits.

  
  

• Processes: They might ask who is responsible for reviewing hazards, how you track corrective actions, or how safety information is shared with crews.

  
  

• Evidence: It’s not enough to have a policy, you may be asked to show proof that it’s being used. For example:

  
  

  • Copies of completed FRATs or hazard reports

  • Records of mitigations and follow-up actions

  • Evidence of safety meetings, advisories, or training materials

    
    

• Questions you may face:

  • “How do your crews report hazards?”

  • “What’s your process for evaluating and mitigating risk before departure?”

  • “Who is responsible for reviewing SMS data?”

  • “Can you show me the last safety audit or corrective action plan?”

    
    

Being unprepared for these questions can delay your flight or even ground your operation until compliance is demonstrated.

Why It Matters

If you’re flying internationally without an SMS, you run the risk of failing an inspection. Even if you operate privately under Part 91, not having a documented SMS could create friction with authorities who expect all operators to meet ICAO standards. For charter and commercial operations under Part 135 or 121, it’s not optional, both FAA and ICAO require you to have a full, functioning SMS that is auditable and actively used.

Final Thought

If you’re flying internationally, you need an SMS that:

• Aligns with ICAO Annex 19 (all four pillars).

• Demonstrates compliance with your home authority (FAA Part 5 in the U.S.).

• Provides records and documentation you can show abroad if asked.

  
  

At RISE SMS, our platform is designed to satisfy both FAA Part 5 and ICAO Annex 19 requirements. With our SMS Suite subscription tier, you’ll be covered whether your flights are domestic or international, keeping your operation safe, compliant, and prepared everywhere you fly.