NPA 2025-11
THE STRATEGIC GUIDE TO TRANSFORMING YOUR ETSO APPROVAL INTO A DOA
THE CHANGE IMPOSED BY EASA
With the publication of NPA 2025-11, EASA is sending a clear signal to the entire aeronautical equipment industry: the historical model of ETSO holders limited to product responsibility is reaching maturity. The agency is initiating a structural shift towards a framework where design responsibility, risk management and the supervised autonomy of organisations become central.
This NPA is not limited to a marginal regulatory adjustment. It profoundly redefines the place of ETSO Holders in the European airworthiness ecosystem, giving them access to privileges traditionally reserved for Design Approval Holders (DOAs), subject to organisational and methodological alignment.
For equipment manufacturers, this development represents both a constraint and a major strategic opportunity.
The observation: harmonisation of requirements
For several years, EASA has been pursuing a consistent path:
In this context, the status of a simple ETSO Holder, focused on the initial compliance of a standard item, is no longer sufficient. NPA 2025-11 introduces a logic whereby holding an ETSO implies a demonstrated ability to control design over time, including post-certification developments, modifications and corrections.
The challenge: anticipate rather than react
Although the NPA is not yet an enforceable regulation, experience shows that:
Anticipating the ETSO → DOA transition means:
We have analysed this NPA for you and written a white paper to help ETSO holders understand the regulations.
If you are affected by this issue, please contact us at: [email protected]
This NPA is not limited to a marginal regulatory adjustment. It profoundly redefines the place of ETSO Holders in the European airworthiness ecosystem, giving them access to privileges traditionally reserved for Design Approval Holders (DOAs), subject to organisational and methodological alignment.
For equipment manufacturers, this development represents both a constraint and a major strategic opportunity.
The observation: harmonisation of requirements
For several years, EASA has been pursuing a consistent path:
- convergence of Part 21 frameworks,
- increased accountability of organisations,
- reduction of the Agency's direct involvement in low-risk decisions.
In this context, the status of a simple ETSO Holder, focused on the initial compliance of a standard item, is no longer sufficient. NPA 2025-11 introduces a logic whereby holding an ETSO implies a demonstrated ability to control design over time, including post-certification developments, modifications and corrections.
The challenge: anticipate rather than react
Although the NPA is not yet an enforceable regulation, experience shows that:
- processing times increase significantly as the effective dates approach,
- EASA resources are becoming a limiting factor,
- customers (OEMs, integrators, operators) are already anticipating these requirements in their calls for tenders.
Anticipating the ETSO → DOA transition means:
- securing your ability to deliver and modify your products without excessive dependence on the Agency,
- preserving your commercial competitiveness,
- transforming a future regulatory obligation into an immediate operational advantage.
We have analysed this NPA for you and written a white paper to help ETSO holders understand the regulations.
If you are affected by this issue, please contact us at: [email protected]
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