Ask five quality managers how often EWIS refresher training is due and you will get five answers, most of them wrong in an interesting way. The regulatory text on this point is short — three sentences — and almost every misconception about EWIS recurrency comes from not reading those three sentences closely enough.

This article sets out exactly what AMC 20-22 says about refresher training, what its wording does and does not oblige you to do, and how to plan the cycle across eight target groups without losing track of who is current. It is a companion to our pillar guide, EASA EWIS training, and to Is EWIS training mandatory?

What AMC 20-22 actually says about EWIS refresher training

Section 8(b) of AMC 20-22, in AMC-20, Annex to ED Decision 2022/001/R, reads in full:

“Refresher training should be conducted in a period not exceeding two years. It could consist of a review of previously covered material plus any new material or revisions to publications. Refresher training will follow the EWIS Minimum Initial Training Programme – Appendix A or B for that particular target group.”

That is the whole of it. Three sentences carrying three separate ideas, and each one deserves attention.

“Refresher”, not “recurrent” and not “continuation”

The AMC’s own heading is Refresher Training. That matters when you write your procedures. Part-145 people are used to “continuation training” under 145.A.35 and to “recurrent training” in other domains, and it is tempting to fold EWIS into whichever term your MOE already uses. In our experience that folding is where audit findings begin: an inspector looking for the AMC’s programme finds a continuation-training entry that covers human factors and a fuel tank safety refresher, and no evidence of the EWIS syllabus at all. Use the regulator’s word in the procedure, then cross-reference it to your internal terminology — not the other way round.

Note also that Section 2 of the AMC describes the programme as usable “for the minimum requirements for initial and recurrent training (see training matrix)”. So the AMC does use “recurrent” in passing. The safe position is to make clear in your documentation that the two words describe the same obligation.

“Not exceeding two years”

This is a ceiling on the interval, not an annual event and not a calendar-year requirement. Two years is the maximum period between deliveries of the programme for a given person. It says nothing about grace periods, nothing about anniversary months, and nothing about whether you may run the cycle shorter. Many organisations align EWIS refresher with an existing 24-month continuation cycle, which is sound planning, provided the content is genuinely the AMC’s programme and not a slide bolted onto a human factors day.

“Should”, in an AMC, is not “shall”, in a Regulation

Here is where we have to be precise, because the internet is not. Section 3 of AMC 20-22 states that “This AMC describes acceptable means, but not the only means, of compliance with the appropriate certification, maintenance and operating regulations.” An AMC is an acceptable means of compliance. Its “should” is the language of a recommended method, not the “shall” of a hard rule in Regulation (EU) No 1321/2014.

Do not mistake that for permission to skip it. The obligations the AMC hangs from are real: Section 2 refers to “their training obligations as required in paragraphs 21.A.145 and 21.A.245 of Part-21, 145.A.30 and 145.A.35 of Part-145 and M.A.706 of Part-M with respect to EWIS.” For Groups 1 and 2 — the personnel “directly involved in the maintenance and inspection of EWIS” — the underlying duty to have competent, appropriately trained staff is a Regulation-level duty. In our view an organisation that trained its EWIS staff once in 2019 and never again would struggle badly to demonstrate continued competence in the face of that duty, whatever the grammatical mood of the AMC. Deviating from an AMC is permitted; deviating without an alternative means and a rationale in your exposition is not a strategy.

The part that surprises people: refresher is not a cut-down course

The third sentence is the one that catches organisations out. “Refresher training will follow the EWIS Minimum Initial Training Programme – Appendix A or B for that particular target group.”

Not a subset. Not “the highlights”. The same programme, for that person’s target group. The AMC does soften the delivery — refresher “could consist of a review of previously covered material plus any new material or revisions to publications” — so the treatment of familiar material can legitimately be a review rather than a first teaching. But the scope stays the same: the same syllabus line items, from the same seven blocks (A General EWIS Practices, B Wiring Practices Documentation, C Inspection, D Housekeeping, E Wire, F Connective Devices, G Connective Device Repair), at the same levels the matrix specifies for that group.

Anyone who has bought a “1-hour EWIS refresher” for a Group 1 licensed engineer should reconcile that product against this sentence. The two-year event is a re-run of the programme with updated content, not a token.

This is, incidentally, why Raven builds its EWIS courses the way it does. Each Waypoint maps one-to-one to a single AMC 20-22 syllabus line item, and the Waypoints are grouped into Lessons A to G matching the AMC’s own blocks. Target-group courses are then assembled from those Waypoints per the Appendix B matrix. Because refresher follows the same Appendix A or B programme as initial training, the same Waypoints serve both — you are not maintaining two parallel curricula, and the traceability from a syllabus item to the evidence of delivery is the same in year zero and year two.

Groups 3 to 8: a two-year cycle on a voluntary obligation

The interaction that confuses planners most is between the refresher interval and the scope split in Section 2. Groups 1 and 2 take their syllabus from Appendix A and C. For Groups 3 through 8 the AMC is explicit: “Although there is no direct regulatory requirement for EWIS training of these personnel, operators may choose to provide EWIS training”, with the syllabus in Appendix B and C.

So for Groups 3 to 8 there is no regulatory requirement to start, and therefore no regulatory requirement to repeat. The two-year figure still applies as the AMC’s stated method — if you have decided to train those groups, the AMC’s answer to “how often” is the same “not exceeding two years”. Our operational view is straightforward: if you have taken the trouble to train your planners, avionics engineers and cabin crew, let the currency lapse and you have the worst of both worlds — a training record that suggests a controlled competence you are no longer maintaining. Either run the cycle or state in your procedure that the training is awareness-level and untracked. Do not leave it ambiguous.

Two syllabus items are worth flagging for Groups 6, 7 and 8: item 16 “Wiring system damage” and item 27 “Typical damage and areas found” are specified at “Low level” for those groups in the AMC’s table. Low level is still a level. A cabin crew refresher that omits them is not following Appendix B.

Practical planning across eight groups

The administrative problem is not the two years. It is knowing, on any given day, which of eight programmes each named individual is current against. A few things we see work:

• Record the group, not just the course. “EWIS — completed” in a training record is useless at audit. “EWIS Target Group 2, Appendix A programme, completed 14 March 2025, next due by 13 March 2027” is evidence.
• Handle multi-group staff explicitly. Section 2 is direct on this: “Depending on the duties, some may fall into more than one target group and, therefore, must fulfil all objectives of the associated target groups.” A licensed engineer who also does planning work sits in more than one group, and the union of objectives is what must be delivered — and refreshed.
• Anchor the due date to delivery, not to the payroll year. Tempting as a single annual training week is, a person trained in November is not covered by a January cycle two years later.
• Treat “new material or revisions to publications” as a live input. The AMC allows refresher to add new material; a refresher that has not changed since 2022 has probably missed CDCCL notes, SB-driven changes to wiring practices manuals, and your own internal findings.
• Feed your own findings back in. Section 7 of the AMC lists what investigators have actually found on wiring — “dust, dirt, metal shavings, lavatory waste water, coffee, soft drinks, and napkins”. If your zonal inspections are finding the same, that is your most persuasive refresher content.

When someone changes duties mid-cycle

This is the scenario that breaks most matrices. A Group 4 engineer — “performing general maintenance/inspections not involving wire maintenance”, where an LRU change is expressly not considered wire maintenance — moves onto a role doing wiring repairs, which is Group 1. What is due?

The AMC does not spell out a transfer rule, so this is Raven’s operational view rather than regulatory text: treat the move as triggering initial training for the new group, not a refresher. The person has never received the Group 1 objectives, and the duties rule in Section 2 says they must fulfil all objectives of the associated target groups. Deliver the delta — the Appendix A items their Group 4 course did not cover, at the levels Group 1 requires — before they exercise the new duties, then set the two-year clock from that date. If your matrix cannot express “current for Group 4, not yet current for Group 1”, it will let someone work on wiring on the strength of a course that never taught them to. Read Which EWIS target group am I? alongside your job descriptions before you build that matrix.

Frequently asked questions

Where to go next

If you are building or rebuilding an EWIS training programme, start from the target-group mapping, because everything else — initial scope, refresher scope, currency tracking — follows from it. Our EWIS Target Groups 1 and 2 course covers the Appendix A programme for staff directly involved in EWIS maintenance and inspection, and the same Waypoints serve the two-year refresher. For the wider population, EWIS Target Groups 4 and 5 and EWIS Target Groups 6, 7 and 8 follow the Appendix B matrix, including the “Low level” treatment of items 16 and 27 where the AMC specifies it.

Getting the vocabulary right is the other half of the job — see our glossary of EWIS terminology for the AMC’s own Section 6 definitions.