DGCA SMS Requirements Under CAR Section 1 Series C Part I: What Indian Operators Must Hold

Written for the people who produce the evidence: the safety manager assembling an SMS manual, the quality head mapping findings to elements, the accountable manager who signs. By the end you should be able to name each of the twelve elements, say which document proves it, and sequence the work from a standing start.

The rule, and where it comes from

DGCA's State Safety Programme states that "Civil Aviation Requirement Section 1 Series C Part I issued under Rule 133A and Rule 29D of the Aircraft Rule 1937, sets out operational regulations and implementation policies for the applicable service providers to implement their SMS as part of their certification process."

Two things follow. The SMS is part of certification, not a parallel compliance exercise, so a weak SMS is a certification problem. And the enabling rule is Rule 29D, requiring that "each applicable service provider including International General Aviation operators conducting operations of large or turbojet aeroplanes as required in ICAO Annex 19 shall establish and maintain a Safety Management System". The lineage is ICAO Annex 19, and the SSP notes India's rule goes further by taking in domestic operators.

Get the designation right in your documents: Section 1 (General), Series C, Part I. Cross-references that stop at "Series C" do not survive an audit trail review. [NEEDS SOURCE: the current Issue and Revision of CAR Section 1 Series C Part I and its effective date. The DGCA portal serves CARs through a dynamic viewer that could not be retrieved for this article; verify on the DGCA site before citing it in a manual]

Who must hold an SMS, and under which certification CAR

The SSP lists the applicable service providers and the certification CAR each one's SMS is assessed against:

Service provider	Certification CAR referenced in the SSP
Commercial air transport operators (scheduled and non-scheduled)	CAR Section 8 Series 'O' Parts II to IV
General aviation operators of large or turbojet aeroplanes	CAR Section 8 Series 'O'; see SSP Circular 03 of 2017
Air traffic service providers	CAR Section 9 Series 'E' Part I
Civil aerodromes	CAR Section 4 Series 'B' or 'F' Part I
Maintenance organisations	CAR 145
Training organisations	CAR Section 7 Series 'D' Part I
Design and production organisations	CAR 21, Subparts JA and G

The National Aviation Safety Plan 2024-2028 also names ground handling service providers in scope. On timing, the SSP says only that it "lays out the phased approach for the development and acceptance of service provider's SMS". [NEEDS SOURCE: SMS implementation phase deadlines and compliance dates per service provider category]

The twelve elements and the evidence each one demands

The framework is ICAO's: four components, twelve elements. The regulation names the elements; it does not say what an assessor asks to see.

Component / element	Documented evidence	Typical gap
1.1 Management commitment	Signed, dated safety policy from the current accountable manager; review minutes showing resources allocated against safety actions	Policy signed by a predecessor who left two years ago; no minute showing money moved by a safety decision
1.2 Safety accountabilities	Organisation chart with named accountabilities; safety responsibilities in line manager job descriptions	Accountability written only into the safety manager's job description, so the operational chain owns nothing
1.3 Key safety personnel	Appointment letters and qualification evidence for the safety manager; terms of reference for the Safety Review Board and Safety Action Group	The SAG exists on the chart but has no terms of reference, quorum rule or minutes
1.4 Emergency response coordination	ERP with interfaces to the aerodrome operator, ATS and mutual aid parties; exercise records with actions closed	Exercised internally only, never against the interfaces; contact list stale
1.5 SMS documentation	SMS manual under revision control, plus the records the manual says exist	Manual describes a process the organisation does not run; no revision history
2.1 Hazard identification	Hazard log with source, date, reporter and operational context; mandatory, confidential and voluntary reporting forms	Log fed only by occurrence reports, so no proactive or predictive input
2.2 Risk assessment and mitigation	Risk matrix with defined severity and likelihood criteria; assessments traceable to hazards; register with owners, dates, residual risk	Residual risk never recorded, so nothing demonstrates the control worked
3.1 Safety performance monitoring	SPI definitions with data source and calculation; alert levels and targets; evidence the set was agreed with DGCA	SPIs are activity counts, not outcome or precursor rates; no alert level, so nothing triggers
3.2 Management of change	Change procedure plus completed change safety assessments for real changes (new base, type, contractor, terminal)	Procedure exists; no completed assessment for the last actual change
3.3 Continuous improvement	Internal SMS audit programme and schedule; corrective action register with root cause, owner, due date, verified closure	Findings closed by asserting the action was taken, with no verification record
4.1 Training and education	Role-differentiated syllabus including the accountable manager; attendance and competency records; recurrent schedule	One generic induction deck for everyone; accountable manager never trained
4.2 Safety communication	Bulletins and alerts, lessons circulated, evidence of feedback to reporters	Reports go in and nothing comes back, which is why reporting volume falls

The SMS manual

The SMS manual is the controlled document describing the system, and the first thing an assessor opens. It needs the safety policy and objectives, scope, accountabilities and structure, the hazard identification and risk management procedures with the matrix, safety assurance including internal audit and management of change, the SPI set with alert and target levels, training and communication arrangements, emergency response coordination, records and retention, and a revision record.

It must stay consistent with the operations manual, maintenance organisation exposition or aerodrome manual: assessors read them together, and disagreeing cross-references become findings against both. [NEEDS SOURCE: the clause-level list of SMS manual contents prescribed by CAR Section 1 Series C Part I, and whether DGCA approves or accepts the manual]

The accountable manager and the appointment letter

The accountable manager is one named individual, not a committee and not a title floating between people. The clearest published Indian wording is in CAR Section 3 Series C Part III, which requires a non-scheduled operator to designate "a suitable person having knowledge of aviation regulations and with adequate financial authority to act as accountable manager", plus an alternate, with prior notification to the regional DGCA office when either changes.

Read "adequate financial authority" literally. If the named person cannot authorise spending to close a safety action without going to a parent company, the appointment does not meet the intent, and the first mitigation with a cost attached exposes it. The appointment letter should name the individual, state the scope of accountability and the financial authority explicitly, be signed by the appointing authority rather than the appointee, be dated, and be reissued when the person changes. Keep the superseded letters: when an assessor asks who was accountable on the date of an occurrence eighteen months ago, the answer is a document.

The same CAR requires a Safety division headed by a person meeting its qualification requirements, and "a safety management system acceptable to the DGCA, which as a minimum: identifies safety hazards; provides for continuous monitoring and regular assessment of the safety level achieved; ensures that remedial action necessary to maintain an acceptable level of safety takes place on a continual basis." [NEEDS SOURCE: qualification requirements for the head of the Safety division in each applicable CAR]

Hazard identification and risk management

The SSP is specific about data sources: "safety studies, occurrence reporting, safety surveys, safety audits and safety investigation". A hazard log fed only by occurrence reports is a reactive system being called an SMS. Collection and holding is covered by SSP Circular 02 of 2020 on the Safety Data Collection and Processing System (SDCPS), and voluntary reporting carries its own protection: "No information derived from safety data collection and processing systems relating to report classified as confidential, voluntary or equivalent category, is used as the basis for enforcement action." Quote that in your reporting policy; it is what makes the channel usable.

Each hazard needs four things on the record: the consequence assessed (the outcome, not the event), the initial rating against a defined matrix, the mitigation with a named owner and date, and the residual risk once verified. The fourth is usually absent.

Safety performance indicators, alert levels and targets

India's Acceptable Level of Safety Performance has three declared components: "No fatal accidents in Commercial Aircraft Operation"; "Effective Implementation of SPIs and achievement of SPTs"; and "Enhancement of Safety Oversight capability to achieve at least 85 % effective implementation". The SSP says the ALoSP "has facilitated a top down Safety Performance Indicators (SPIs) and Safety Performance Targets (SPTs) setting for all applicable aviation service providers in India", and that "The SPIs & SPTs are agreed between the DGCA and the applicable service provider." Agreed, not declared: you propose, DGCA agrees, and the agreed set is what you are measured against.

The NASP adds that "Service providers are required to develop SPIs, associated SPTs and alert levels by analysing the safety data captured under SDCPS", and sets the national direction: "The desired safety outcome is to reduce number of reported events/rate defined for each SPI by 3% every year as applicable." National SPIs sit under eight National High Risk Categories including mid-air collision, controlled flight into terrain, runway excursion, runway incursion, loss of control in flight, wildlife strike, ramp safety and deficient maintenance, each expressed as a rate (per 10,000 departures, per million movements) with year-on-year targets.

Three design rules follow. Express indicators as rates, not counts: a count of unstabilised approaches falls when flying falls. Set an alert level as well as a target: the target is where you intend to be, the alert level is what triggers action. And cover the spectrum, which the SSP describes as "(a) low probability/high severity events, (b) high probability/low severity events and (c) process performance". [NEEDS SOURCE: the method DGCA expects for calculating alert levels, including whether standard deviation bands over a defined baseline are prescribed]

Safety assurance, change management and promotion

Internal SMS audit is not the quality audit. The quality audit asks whether you followed the procedure; the SMS audit asks whether the safety processes are working and reducing risk. Schedule it, cover every element across the cycle, and close findings with verification evidence.

Management of change has the weakest paper trail almost everywhere. The test: name the last significant change (a new station, a new type, a new ground handling contractor, a terminal reconfiguration) and produce the change safety assessment for it. If it does not exist, the element is not implemented.

Safety promotion is training plus communication. Records need role-differentiated content, recurrent cycles, and the accountable manager, often the only person with no SMS training record. [NEEDS SOURCE: SMS training frequency and record retention periods required by DGCA]

What a DGCA SMS assessment looks at

SMS oversight is not a separate visit. The SSP says "Oversight of service provider's SMS is carried out periodically as part of Annual Surveillance Programme", and the NASP confirms that "DGCA assesses the progress of each service providers' SMS as part of Annual Surveillance Programme". The published focus areas read as an agenda:

• "Appropriate integration of regulatory safety risk controls into individual service provider's SMS"
• "Effectiveness of the safety risk controls"
• "Appropriate resource allocation"
• "Periodic review of each service provider's SPIs and SPTs to assess their performance and effectiveness"

Note what is examined: not whether the manual exists, but whether controls work, whether resources followed the risk, and whether the SPIs are performing. DGCA has also committed to "progressively transition to risk based approach for regulatory oversight". [NEEDS SOURCE: the DGCA SMS assessment checklist or maturity scoring used by inspectors]

Implementation sequence from a standing start

Steps 1 to 4 are prerequisites. Doing them out of order is the commonest cause of a rewritten manual.

1. Appoint the accountable manager in writing: name, scope, explicit financial authority, signed by the appointing authority, dated. Appoint the alternate at the same time and notify the regional DGCA office.
2. Run a gap analysis against the twelve elements, one row per element with current evidence, gap, owner and target date. This becomes the implementation plan and later the assessment response document.
3. Issue the safety policy, signed by the accountable manager, stating the reporting policy and the boundary the SSP draws between gross negligence and wilful deviation and internally resolvable deviations.
4. Stand up mandatory, confidential and voluntary reporting channels. Publish the confidentiality protection and build the SDCPS-aligned data structure now; retrofitting fields into a year of reports is expensive.
5. Build the hazard log and risk matrix, defining severity and likelihood criteria before the first assessment rather than during it.
6. Constitute the Safety Review Board and Safety Action Group: terms of reference, membership, frequency, quorum, minutes. The SRB is chaired by the accountable manager.
7. Draft the SMS manual, only now that steps 1 to 6 describe things that exist.
8. Define SPIs, alert levels and targets, mapped where sensible to the National High Risk Categories, and take them to DGCA for agreement rather than as settled.
9. Deliver role-differentiated SMS training, accountable manager included, with attendance and competency records.
10. Run the first internal SMS audit and the first change safety assessment. Until both exist as records, safety assurance and management of change are unevidenced.
11. Assemble the evidence pack: manual, appointment letters, gap analysis, hazard and risk registers, SPI charts with alert levels, training matrix, audit reports, corrective action register.

Where teams get this wrong

The manual is written before the system exists. A consultant produces an excellent 120-page manual describing a Safety Action Group that has never met. The assessor asks for the last three sets of SAG minutes.

Safety accountability is confined to the safety department. With no written accountabilities for line managers, the safety manager owns risks they have no authority over, and mitigations stall where someone has to spend money.

SPIs measure the SMS instead of the operation. Reports received, training completion, audits closed on time are process measures, and belong in a small supporting family rather than the whole set.

Occurrence closure without root cause. "Crew counselled" tells nobody why the crew did what they did, and verification of closure is what gets skipped at quarter end.

The accountable manager changes and nothing else does. New person, old signature on the policy, no new appointment letter, no notification to the regional office, no training record. Three findings from one personnel change.

What to automate, and what not to

Automate the record-keeping failures: intake and de-duplication of reports across channels, routing and reminders so investigations do not sit unassigned, the risk register with owner and due-date tracking, SPI calculation derived from the occurrence data rather than typed in, revision control on the manual, and the training matrix with expiry dates. These fail quietly and are expensive to reconstruct at assessment time.

Do not automate the judgement. Severity and likelihood assessment, root cause analysis and the decision that a residual risk is tolerable are human calls a system should record and timestamp, not make. Nor will a tool fix governance: if the accountable manager does not chair the Safety Review Board, software changes nothing.

Where a system helps

The practical value of an SMS in software is traceability: one report becoming a hazard, a risk assessment, a mitigation with an owner, a residual rating and a line in an SPI, all linked, so that when an assessor asks how an occurrence was closed you show the chain rather than assemble it. That is what KreupAI's aviation safety management is built for.

FAQ

Which CAR mandates SMS in India, exactly? CAR Section 1, Series C, Part I, issued under Rule 133A and Rule 29D of the Aircraft Rules 1937. Quote all three parts of the designation in your manual, and confirm the current Issue and Revision on the DGCA site before citing it.

Does DGCA approve the SMS manual, or accept it? The SSP describes a "phased approach for the development and acceptance of service provider's SMS" and refers to review of the SMS manual during oversight visits, which points to acceptance rather than approval. [NEEDS SOURCE: whether DGCA approves or accepts the SMS manual, and the submission route]

Who can be the accountable manager? One named individual with knowledge of aviation regulations and adequate financial authority, per CAR Section 3 Series C Part III, with an alternate appointed and the regional DGCA office notified before either changes. In most Indian operators this is the CEO or managing director, because the financial authority test rules out anyone below.

Are voluntary reports safe from enforcement? The SSP states that information relating to reports classified as confidential, voluntary or equivalent is not used as the basis for enforcement action. Gross negligence and wilful deviation stay outside that protection.

Related reading

• KB-015: What Is DGCA? India's Civil Aviation Regulator and Its Safety Remit

Sources

• DGCA, State Safety Programme India, Second Edition, June 2021
• DGCA, National Aviation Safety Plan 2024-2028
• ICAO Safety Management Manual, Chapter 9: Safety Management Systems
• DGCA CAR Section 3 Series C Part III, Issue II Rev 7, 21 May 2021
• Ministry of Civil Aviation, Directorate General of Civil Aviation