Is EWIS training mandatory? The short answer is that it depends entirely on the target group — and that “mandatory” is the wrong frame for an AMC in the first place. Both halves of that sentence matter, and most articles on this subject only give you one of them.

Here is the position in two lines. For Target Groups 1 and 2 — the people who maintain and inspect wiring systems — a training obligation genuinely exists in the implementing rules, and AMC 20-22 is the accepted means of meeting it. For Target Groups 3 through 8, EASA states in the AMC itself that there is no direct regulatory requirement for EWIS training. Neither half cancels the other.

This article sits alongside our pillar guide, EASA EWIS Training: The Complete Guide to AMC 20-22, which covers the syllabus and the programme structure in full.

What an AMC is, and what it is not

AMC 20-22 is contained in AMC-20, Annex to ED Decision 2022/001/R. Acceptable Means of Compliance are issued by the Agency by Executive Director Decision. They are not the implementing rule. The rule lives in the Regulation; the AMC describes a way of satisfying it.

The AMC says this about itself, in Section 3: “This AMC describes acceptable means, but not the only means, of compliance with the appropriate certification, maintenance and operating regulations.” That sentence does two things. It confirms that compliance is with the regulations, not with the AMC — and it confirms that an organisation may use an alternative means, provided it can demonstrate the same result to its competent authority.

So “is EWIS training mandatory?” decomposes into a better question: does an underlying regulatory obligation apply to this person, and is AMC 20-22 how we intend to meet it? For most organisations the answer to the second part is yes, because using the published AMC is the path of least friction with an authority. That is a pragmatic choice, not a legal compulsion to use this specific document.

Is EWIS training mandatory? The split that decides the answer: Groups 1-2 versus Groups 3-8

AMC 20-22 draws the line itself, in Section 2:

“The training syllabus and curriculum for those personnel directly involved in the maintenance and inspection of EWIS, identified as Target Group 1 and 2, are in Appendix A and C to this AMC. This AMC also provides guidance on the development of EWIS training programmes for personnel who are not directly involved in the maintenance and inspection of EWIS. Although there is no direct regulatory requirement for EWIS training of these personnel, operators may choose to provide EWIS training. The training syllabus and curriculum for these personnel, identified as Target Groups 3 through 8, are in Appendix B and C to this AMC.”

That is as clear a statement of scope as EASA gives on this subject, and it is worth reading twice. Groups 1 and 2 are treated as personnel directly involved in EWIS maintenance and inspection — the population the training obligation attaches to. For Groups 3 to 8, the AMC says plainly that there is no direct regulatory requirement, and that operators may choose to provide the training.

If you are unsure which side of that line a given person sits on, resolve the allocation first — the answer to the mandatory question changes with it. Our companion article sets out all eight target groups in full, including why membership follows duties rather than licence category.

Where the real obligation lives

The AMC does not invent an obligation; it points at the ones already in the Regulations. Section 2 lists them: “This AMC has been published in order to provide the approved organisations with acceptable means of compliance to comply with 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.”

Two observations for the reader holding a Part-145 approval. First, the Part-21 references bear on POA and DOA holders — they are not the hook for a line maintenance organisation, so do not cite them in your own procedures as though they were. Second, the obligation you are actually meeting is a competence obligation in 145.A.30 and 145.A.35. EWIS training is the substance you put behind it. That distinction matters when you write your MOE or exposition wording: you are not complying with AMC 20-22, you are complying with Part-145 by the means AMC 20-22 describes.

One housekeeping point that trips up otherwise careful documents: Reg (EC) No 216/2008, Reg (EC) No 1702/2003 and Reg (EC) No 2042/2003 are all superseded. If they still appear in your training manual, that alone is a finding waiting to happen. The current instruments are Regulation (EU) No 1321/2014 and Regulation (EU) No 748/2012.

What an auditor would expect to see

This section is Raven’s own operational view rather than regulatory text, so read it as such. In our experience, an auditor examining EWIS training does not ask “did you buy a course?”. They work backwards from the syllabus and the records, and we would expect them to look for:

• A target group allocation with a rationale. Not a list of names against groups, but the reasoning that put each person there — based on duties, per the AMC’s own rule that people may fall into more than one group and must then fulfil all objectives of the associated groups.
• Coverage traceable to syllabus items. The AMC’s Appendix A and B allocate numbered items 1-41 to groups. A training record that maps to those item numbers answers the coverage question in one step; a certificate that says only “EWIS training completed” does not.
• Evidence the objectives were met. Section 8(a) states that “the most important criteria are to meet the objectives of the Lesson Plans – Appendix C (using classroom discussion, computer-based training or hands-on practical training)” and that “assessment or achieving the objectives should be at the discretion of the training organisation (such as written test, oral test or demonstration of skills).” The method is yours to choose; being able to show the objectives were met is not optional.
• A refresher interval you actually hold to. Section 8(b): refresher training “should be conducted in a period not exceeding two years”, following the Appendix A or B programme for that particular target group. We look at how organisations manage that cycle in our article on the two-year EWIS refresher.

Why organisations train Groups 3-8 anyway

Given there is no direct requirement, why does anyone train cleaners, planners, cargo loaders or cabin crew? Because EASA published a syllabus for them and set out the safety case for doing so, in the same document that says the requirement does not exist.

Section 2 states: “It is believed that training personnel in these groups would greatly enhance awareness of the importance of EWIS safety in the overall safe operation of aeroplanes. Although these groups are not directly involved in the maintenance of EWIS, they have the potential to have an adverse impact on EWIS. This can occur through inadvertent contact with EWIS during aeroplane cleaning or when individuals perform unrelated maintenance that could impact the integrity of EWIS. Mechanics leaving drill shavings on wire bundles is one example of how this could occur.”

The background in Section 7 gives the reason that argument carries weight: “Over the years there have been a number of in-flight smoke and fire events where contamination sustained and caused the fire to spread. Regulators and Accident Investigators have conducted aircraft inspections and found wiring contaminated with items such as dust, dirt, metal shavings, lavatory waste water, coffee, soft drinks, and napkins.” The same section records that “Aviation Accident Investigators have specifically cited the need for improved training of personnel to ensure adequate recognition and repair of potentially unsafe wiring conditions”, and notes that “a person performing an inspection of an electrical power centre or avionics compartment may inadvertently cause damage to wiring in an adjacent area.”

The AMC also makes its intent explicit in Section 1: it “promotes a philosophy of training for all personnel who come into contact with aeroplane EWIS as part of their job and tailors the training for each workgroup to their particular needs.” And Section 3 adds that “this AMC can be applied to any aeroplane training programme.”

Our own view, offered as such: the honest reading is that Groups 3-8 training is a safety management decision rather than a compliance one. If your safety management system has identified swarf on wire bundles or contamination during cleaning as a hazard, an untrained population in proximity to EWIS is difficult to defend — not because a paragraph requires the training, but because you have already written down why it matters.

Where to start

Allocate your people to target groups first, then match the training. EWIS Target Groups 1 & 2 is the full programme for the population where the obligation is real. EWIS Target Groups 6, 7 & 8 covers the awareness end — service staff in proximity to EWIS, flight deck crew and cabin crew. Raven maps each Waypoint 1:1 to a single AMC 20-22 syllabus item, so your records can point at item numbers rather than a course title. Terminology such as swarf and arc tracking is defined in our EWIS glossary.

Frequently asked questions