Expert Help for India’s DGCA’s Special Audit add CREDIBILITY?

By Sandy Murdock • June 22, 2025
JDA Aviation Technology Solutions

 

The DGCA of India, soon after the AI171 tragedy, has issued a “new ‘comprehensive special audit’ framework for India’s aviation sector.” The last three words were carefully crafted to minimize the public’s likely reaction that this new policy was catalyzed by the accident.

  • What is special about this NEW initiative? In the past, this aviation safety regulatory body exercised its oversight duties through routine regulatory audits through various directorates—such as Flight Standards, Airworthiness, and Air Safety—each responsible for inspecting specific domains like airlines, airports, and maintenance organizations. Their inspection techniques included

Scheduled and unscheduled audits

      • Ramp checks
      • Document reviews and personnel interviews
      • SMS evaluations, though often in a fragmented, department-specific manner.[1]

The Comprehensive Special Audit framework, described below, includes a lot of jargon like:

  • “…evaluate the aviation ecosystem holistically, moving away from fragmented oversight models..”
  • “…360-degree evaluation of the aviation ecosystem, reflecting both its strengths and areas needing improvement.”
  • “…special audits will be carried out by multidisciplinary teams led by senior officials from the regulator…”
  • “…include personnel from various DGCA divisions — such as flight standards, air safety, airworthiness, aerodrome standards, and air navigation — and may also bring in external experts when needed.”
  • ►THE EFFECTIVENESS OF AN ORGANISATION’S SAFETY MANAGEMENT SYSTEM (SMS), ◄
  • THE ROBUSTNESS OF ITS OPERATIONAL PRACTICES, AND
  • COMPLIANCE WITH REGULATORY PROVISIONS.
  • “…either routinely, such as through annual assessments or post-implementation reviews, or in response to specific triggers like serious incidents, regulatory violations, or findings by UN body International Civil Aviation Organisation (ICAO).[2]”

All well said, but the past reviews by the FAA under IASI has pointed out deficiencies in the DGCA’s technical staff and the size of the organization;

This new regimen will be FACING SIGNIFICANT CHALLENGES, which may limit the effort’s efficacy; such as:

  • The integrated team will likely not have had much experience working together; reaching consensus will be difficult under such circumstances
  • Their primary investigative tool, SMS, appears to have missed flags Determining what if anything was done then, will not be easy and again only probably, there were no public actions.
  • The Comprehensive Special Audit team will have as primary targets to determine
    • (a)“what went wrong” in the past identification of these warning signs from the data;
    • (b) whether the DGCA was not aware of such safety flags, and WHY;
    • (c) if the SMS indicators did reach the regulators, did they respond appropriately;
  • Objective analysis will be touchy; for example, as the team assesses the pilot or AMT training, the team member, whose expertise was involved in these judgments in the past, will likely be protective of the people involved in this case. The team may have been “DE-Siloed”, but the team members have worked in one of them. Looking into the other silos could involve less than objective conclusions.

There is a large number of consulting firms with experience in helping CAAs create their SMS, with helping these safety organization prepare for audits and with extensive knowledge of what a certificate holder must do to comply.

The DGCA’s press statement includes a telling phrase. In naming the categories of the Comprehensive Special Audit team; it referenced the possible need for external experts. To assure that the work product of this team receives the level of confidence from Indian public, international travelers, EASA, FAA and ICAO, the Director should use his stated option- including third party experts with no investment in any silo and with AVIATION SAFETY AS THE ONLY MISSION. There is a large number of consulting firms with experience in helping CAAs create their SMS, with helping these safety organization prepare for audits and with extensive knowledge of what a certificate holder must do to comply.

 

DGCA launches comprehensive special audit plan to end siloed safety checks

DGCA’s new special audit framework moves beyond siloed inspections to assess safety, compliance and operations across airlines, airports, MROs and other aviation entities

The DGCA has also made it clear that enforcement will follow in cases where findings are not addressed.

The Directorate General of Civil Aviation (DGCA) has rolled out a new ‘comprehensive special audit’ framework for India’s aviation sector.

With this, it aims to move beyond siloed safety assessments and carry out integrated evaluations across airlines, airports, maintenance firms, training institutes, and ground handling agencies.

“Traditionally, regulatory and safety oversight functions within Indian aviation have been conducted in SILOS, with different directorates (of DGCA) performing inspections and audits specific to their respective domains. These activities include planned/unplanned surveillance inspections, random spot checks and ramp inspections. [NOTE[3]: this quote does not mention SMS directed safety reviews in response to data trends!!!]They primarily assess compliance and safety within individual aviation segments,” the regulator stated.

The new framework, described as a “significant paradigm shift”, aimed to evaluate the aviation ecosystem holistically, moving away from fragmented oversight models.

On June 12, Air India’s London-bound AI171 flight crashed shortly after take off from Ahmedabad, killing 229 passengers, 12 crew members, and 34 people on the ground.

Issued on JUNE 19, THE DGCA CIRCULAR mentioned the need for “a 360-degree evaluation of the aviation ecosystem, reflecting both its strengths and areas needing improvement.”

Going beyond the annual surveillance audits currently in place, the special audits will be carried out by multidisciplinary teams led by senior officials from the regulator.

These teams will include personnel from various DGCA divisions — such as flight standards, air safety, airworthiness, aerodrome standards, and air navigation — and may also bring in external experts when needed.

 

The audits will examine three broad areas: THE EFFECTIVENESS OF AN ORGANISATION’S SAFETY MANAGEMENT SYSTEM (SMS), THE ROBUSTNESS OF ITS OPERATIONAL PRACTICES, AND COMPLIANCE WITH REGULATORY PROVISIONS.

Each audit will involve a combination of techniques, including on-site inspections, document reviews, interviews with operational staff, safety data analysis, and training record checks.

“These audits will be over and above the regulatory audits carried out according to the annual surveillance program,” the DGCA said.

They will apply to all major players in the civil aviation system, not just airlines and airports but also maintenance, repair and overhaul (MRO) providers, training academies, and even entities that manage emergency response systems and supply chains.

The regulator will initiate these audits either routinely, such as through annual assessments or post-implementation reviews, or in response to specific triggers like serious incidents, regulatory violations, or findings by UN body International Civil Aviation Organisation (ICAO).[4]

In urgent cases, audits may begin without notice. Otherwise, entities will be given between three and 14 working days to prepare.

“Audited entities must submit a corrective action plan… detailing root cause analysis, remedial actions, preventive measures, implementation timelines, and success metrics,” the circular stated.

The DGCA has also made it clear that enforcement will follow in cases where findings are not addressed.

“Non-compliance… may result in progressive enforcement actions, including advisory guidance, formal warnings, operational restrictions, financial penalty, suspension, or revocation of licenses,” it noted.

To encourage transparency, the regulator has promised confidentiality of audit findings in line with international norms. “The special audit upholds a confidential approach, aligned with ICAO Annex 19 principles, to foster open reporting and positive safety culture,” it said.

The new audits, DGCA said, will “provide a holistic evaluation of the aviation sector, meticulously examining safety, operational efficiency, and regulatory compliance.”

The goal is to proactively identify systemic vulnerabilities, enhance resilience, and ensure alignment with international standards and India’s own aviation safety objectives.

Audit findings will be categorised by severity. The most critical ones will require corrective action within seven days, while others may be resolved over 30-90 days.

[1] This summary reflects an AI search of the DGCA’s inventory of policy and procedure documents. Oddly, below

[2] NO MENTION OF SMS DATA TREND THAT MERITS CLOSER SURVEILLANCE!!!!

[3] See fn. 1 above.

[4] NO MENTION OF SMS DATA TREND THAT MERITS CLOSER SURVEILLANCE!!!!

 

Posted in News by Sandy Murdock • June 22, 2025

Sandy Murdock

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