Other activities related to air navigation service providers and functions

    In addition to the certification and regulatory control processes, DSANA carries out other activities necessary for the safe and efficient provision of air navigation services and functions:

Revision of changes in functional systems

    Prior to the introduction of changes to its functional system or of changes that may affect that functional system, the service provider must send the corresponding notification to EASA, in accordance with the applicable regulations.

    In order to provide guidance to facilitate the application and understanding of the Regulation to new air navigation service providers as regards notification, DSANA has developed guidance material making available to the user:

    Based on the information received in the notification, EASA decides in each case whether or not to review the safety argument associated with the implementation of the change. If you decide to review it, you will submit the change to an approval process that will require a favourable Resolution necessary for the effective introduction of the change.

    For the realisation of security arguments and the management of functional changes, service providers must have functional change management procedures expressly approved by EASA.

    Service providers shall report changes to their functional systems or affecting their functional systems through the administrative procedures available at the EASA website. They also have here the administrative procedure for the application for approval of procedures for the management of functional changes.

    The rules determining the procedure are as follows:

    • Commission Implementing Regulation (EU) 2017/373 of 1 March 2017 laying down common requirements for providers of air traffic management/air navigation services and other air traffic management network functions and their oversight, repealing Regulation (EC) No 482/2008 and Implementing Regulations (EU) No 1034/2011, (EU) No 1035/2011 and (EU) 2016/1377 and amending Regulation (EU) No 677/2011.
    • Royal Decree 515/2020 of 12 May 2020 regulating the procedure for certification of civil service providers and functions of air traffic management and air navigation and their regulatory control.

    In the FAQs section, you can find answers to frequently asked questions related to functional changes.


Notification and management of non-functional changes

    Changes in service provision, management system or security management system of the service provider that do not affect the functional system are classified as changes requiring pre-implementation approval and changes that do not require prior approval and are subject to the continuous monitoring process.



    From EASA, as Competent Authority, changes in the provision of the service, management system or safety management system that do not affect the functional system of air traffic management/air navigation service providers and other network functions (hereinafter referred to as service providers) are processed and managed:

    The notification and management of changes in service provision, management system or security management system of the service provider that do not affect the functional system shall be in accordance with requirement ATM/ANS.OR.A.040 Changes — General paragraphs (a)(2) and (b) of Regulation (EU) 2017/373.

    Within the non-functional changes two groups have been identified:

    1. Changes requiring approval by EASA.
    2. Changes that do NOT require approval by EASA.



    Where the supplier intends to make any of the changes for which approval is required by EASA prior to its implementation, listed in the table attached below, it shall submit by electronic registration the following documentation:

    • Application for approval, according to the established format, for the notification of changes subject to approval.
    • Documentation for which approval is requested.

    AESA shall acknowledge receipt of such request within a maximum of 10 working days of receipt of the request.

    The administrative procedure associated with the process is available at AESA’s electronic headquarters:

    Notification of non-functional changes requiring approval shall be made at least 30 working days prior to the entry into force of the change, unless a separate additional period is established by national law.

    Notification of the change will require the submission by official registration of the documentation subject to approval together with a form that includes at least the following fields (See the associated administrative procedure form) (For the change of certificate, see the Certification section), once the application has been completed and the required documents attached, the corresponding registration will be made and a supporting document with the number and date of registration will be returned.



    The administrative procedure associated with the process is available at AESA’s electronic headquarters:

    Request for notification of non-functional changes not subject to approval in accordance with Implementing Regulation (EU) 2017/373

    Below is the list of non-functional changes that need to be notified to EASA but do not require approval by the Authority. Such changes shall be subject to continuous supervision (regulatory control)

    Notification of the changes identified in the list does not require the submission of attached documentation, however, the notification form for non-functional changes not subject to approval must be completed.

    Notifications of non-functional changes shall be made by official registration, the notification format established in the electronic site and code CSNA-20-PGR-113-F02 must be submitted, with the addition of the notified changes in Word or Excel format, and bimonthly, with the following exceptions:

    • Certification bases and their evidence will be notified with ANUAL CHARACTER.
    • Changes in the incumbents of the following posts: responsible Director (accountable manager ATM/ANS.OR.B.020), responsible for safety, quality, protection and financial and human resources (ATM/ANS.OR.B.020), safety manager (ATS.OR.200 and AMC1 ATS.OR.200(1) (ii)(iii) and compliance monitoting manager (ATM/ANS.OR.B.005c), will be notified with IMMEDIATE CHARACTER.

    In addition, in the event that air navigation service providers wish to implement non-functional changes that, without being subject to approval, consider that they have a sufficient entity to involve EASA in the implementation process, they shall notify such non-functional changes in order to obtain technical advice thereon, so as to ensure their safe implementation.

Verification of systems

    Regulation (EU) 2018/1139, which repeals Regulation (EC) No 552/2004, provides that Articles 4,5,6, 6a and 7 of Regulation (EC) No 552/2004 (and Annexes III and IV thereto) shall continue to apply on a transitional basis until the date of application of the delegated acts developing the Articles on the interoperability of systems and to the extent that those acts cover the subject of the relevant provisions of Regulation (EC) No 552/2004, and by 12 September 2023.

    Thus, in accordance with Article 6(2) of Regulation (EC) No 552/2004, before a system enters into service, the air navigation service provider concerned shall draw up an EC declaration of verification confirming compliance with the essential requirements and interoperability implementing measures applicable to it when integrated into the European air traffic management network, and send it to the national supervisory authority accompanied by a technical file.

    AESA should supervise the EC declarations of verification submitted to AESA’s Directorate for Airport Safety and Air Navigation (DSANA) as the national supervisory authority within its competences.

    To guide the air navigation service provider in the preparation of EC Declarations of Verification (and its associated documentation), DSANA has developed a guide material which it makes available to the user.

    The administrative procedure governing the process is accessible through the following link:


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