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 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.
What Is the Real Challenge?
Submitting the 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. Falling short won’t automatically remove your approval, but it does expose you to repeat findings, increased oversight and risks to business continuity.
The harder part is proving it works in practice: procedures applied, hazards actively managed, performance monitored. From inside the goldfish bowl, blind spots are easy to miss, this is where an external perspective can help.
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
Tick-box implementation won’t reveal the reality your people face at the point of delivery. A working SMS surfaces weak signals, makes risk visible, and turns insight into action. To unlock that potential, it must be lived day-to-day and backed by a culture that matches the safety policy and objectives. That’s exactly what SRG 1776 probes and where many stumble.
Key SRG 1776 markers to get right:
• Reporting and hazard identification: Confidential, trusted reporting that captures errors, hazards and near-misses and is actually used. Look for evidence of psychological safety, simple reporting channels, timely feedback to reporters, and visible learning actions. Without genuine reporting, weak signals stay hidden and small issues become costly disruptions.
• Data analysis and trend monitoring: Beyond counting reports: analyse, spot patterns, prioritise risks, and close the loop. Show how data informs decisions, resourcing and interventions (not just dashboards). Treat safety data as a business asset, link trends to rework, delays, warranty returns and customer complaints to target the biggest value.
• Safety performance indicators and risk control verification: Define a small set of meaningful Safety Performance Indicators (SPIs) tied to your top operational risks. Verify that controls work in practice (assurance checks, sampling, observations) and act when they don’t. SPIs and verification should prevent repeat issues, protect on-time delivery and cut hidden costs, not just satisfy an audit.
• Leadership and culture: Leaders set the tone by walking the talk: they respond fairly to reports, ask learning-focused questions, and resource fixes. Staff should see consistency between messages and behaviour, or trust erodes and reporting dries up. Look for routine leadership touchpoints that discuss risk, performance and learning outcomes.
Hidden Challenges of Self‑Assessment
Markers such as confidence in reporting, fair treatment, use of data, meaningful SPIs and visible leadership are subjective and hard to judge internally.
An external, objective review surfaces blind spots and provides evidence to move from present to operating.
Turning Compliance Into Competitive Advantage
Treat risk management as a performance tool. When hazards are identified early and controls are embedded, you cut unplanned downtime and avoid hidden costs.
A learning culture prevents repeats and Safety Performance Indicators provide real‑time visibility of what’s working and where to invest resources.
Result: better delivery, stronger reputation, healthier margins.
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
A focused 2–3 day assessment validating your SRG 1776 submission through evidence sampling and interviews.
We test whether reporting is trusted and processes are implemented, then give you a clear roadmap to reach Operating and Effective maturity.
Scaled to your size and complexity, an efficient alternative to a full Management System Performance Assessment.
Safety Management System (Safety Element) Maturity Workshop
A one-day interactive workshop for leadership and key staff to interpret SRG 1776 results, self-assess maturity, explore good practice and build a high-level action plan aligned to business objectives.
Ideal for smaller organisations or as a starting point for a broader programme.
Take the Next Step Now
July 2026 isn’t far. Closing findings, engaging staff, embedding risk management and evidencing culture takes time.
Treat SMS as a strategic investment, not just a regulatory requirement, and you’ll gain a competitive edge.
If you want confidence you’re on the right path to Operating maturity and to realise the business benefits of SMS, get in touch at hello@bainessimmons.com. We’ll turn your SRG 1776 evaluation into a practical, risk-based roadmap that strengthens safety and performance.