10 training duties across 7 instruments binding Defence & Aerospace, plus 10 that bind you whatever your sector — statute, rulebook, statutory guidance and licence conditions. Every one traced to its clause, its date and its published source, and each one labelled with what makes it a training duty.
Aviation is one of the few areas anywhere that sets a real interval. The gaps sit either side of it.
Part-145 requires recurrent training every two years and says what it must cover. That clarity is genuinely useful and generally well managed.
But three separate clocks run alongside it that are not training cycles at all — a currency rule, a licence validity rule and a record-retention rule that outlives the employee. An organisation tracking only its recurrent programme is tracking none of them.
Each clause carries a label saying why it is a training duty. Where the instrument does not use the word, we cite the guidance or the case that makes training the way you discharge it. Where we cannot cite anyone, it is not listed as a training duty at all.
| Clause | Who must be trained or assessed | What is required | Interval | Evidence required |
|---|---|---|---|---|
| Part-145 (retained EU law) | ||||
| 145.A.35(d) says train | named roles — quoted: "all certifying staff and support staff" | The organisation shall ensure that all certifying staff and support staff receive sufficient recurrent training in each 2 year period to ensure that they have up to date knowledge of relevant technologies, organisation procedures and safety management, including human factor issues. | every 2 years (24 months) | Personnel records including qualifications, training and experience — 145.A.55(d) |
| 145.A.35(f) competence | named role — certifying staff | Before issuing a certification authorisation, the organisation must assess all certifying staff for their competency, qualifications and capability to carry out their intended certifying duties. | trigger-based — prior to issuing a certification authorisation | Personnel records including qualifications, training and experience — 145.A.55(d) |
| Part-CAMO (retained EU law) | ||||
| CAMO.A.305(g) competence | defined population — personnel involved in compliance monitoring, safety management, continuing airworthiness management, airworthiness reviews or recommendations | The organisation must establish and control the competency of those personnel. The competency assessment must include an understanding of safety management and human factors principles appropriate to the person's function. | none specified — no recurrent interval stated, unlike Part-145 | Personnel records — CAMO.A.220(c), retained for as long as the person works for the organisation and until 3 years after they leave |
| CAMO.A.310(c) and CAMO.A.310(d), with CAMO.A.220(c)(2) competence | named role — airworthiness review staff | New airworthiness review staff require satisfactory completion of an airworthiness review under supervision, by the CAA or by experienced organisation staff, before authorisation. The procedure must be approved by the CAA as part of the CAME. Aircraft airworthiness review staff must additionally demonstrate appropriate, recent continuing airworthiness management experience on an ongoing basis. | trigger-based on authorisation; 'recent' experience thereafter, with no interval defined | Records of the qualification and experience of all airworthiness review staff, retained until 3 years after the person leaves — CAMO.A.220(c)(2) |
| Commission Regulation (EU) No 1321/2014, Annex III (Part-66), as retained in UK law | ||||
| 66.A.20(b)(2) competence | named role — licence holders exercising certification privileges | To exercise the privileges of the licence the holder must have had 6 months of maintenance experience in accordance with the privileges granted, within the preceding 2-year period, or have met the provision for the issue of the appropriate privileges. | 6 months of relevant experience in any preceding 2-year period | Evidence of relevant maintenance experience within the window |
| 66.A.25, 66.A.30 and 66.A.40, with records at 66.B.20(c)-(d) says train | named role — certifying staff seeking or holding a licence | Basic knowledge must be demonstrated by examination against the appropriate subject modules, with training courses and examinations completed within the 10 years prior to application, and knowledge credits expiring 10 years after issue. Practical maintenance experience requirements range from 1 to 5 years depending on category and prior training, and must fall within the 10 years preceding application. A licence becomes invalid 5 years after its last issue or change unless submitted to the CAA for verification. | 10-year validity on examinations, credits and experience; 5-year licence validity | CAA-held records: application documentation, licence copies, examination records and credit reports. Basic application materials retained at least 5 years after the end of licence validity; examination records retained indefinitely. |
| Commission Recommendation (EU) 2019/1318 on internal compliance programmes for dual-use trade controls under Regulation (EU) 2021/821 | ||||
| Core element 3 — Training and awareness raising says train | two populations — all dual-use trade control staff (compulsory, periodic training), and employees at all relevant levels (awareness raising) | Training and awareness raising is one of seven core elements essential for an effective ICP. The company ensures via training that dual-use trade control staff are aware of all relevant export control regulations as well as the company's ICP and all amendments to them, and carries out awareness raising for employees at all relevant levels. The steps involved include providing COMPULSORY, PERIODIC TRAINING for all dual-use trade control staff, and ensuring via training that all concerned employees are aware of all relevant laws, regulations, policies and control lists and all amendments to them AS SOON AS THEY ARE MADE PUBLIC by the competent authorities. | "periodic" for control staff — no interval stated; amendments to be covered as soon as made public | The ICP itself, as a documented programme; recordkeeping and documentation is a separate core element |
| Export control compliance code of practice — checklist of internal export control compliance procedures (Export Control Joint Unit, gov.uk) | ||||
| Checklist of internal export control compliance procedures — training section says train | quoted, and extraordinarily broad: "all employees who have the ability to make exports (including everyone with access to email, telephone and fax can potentially export technology)" | Those employees must have received the necessary induction, training or retraining. Personnel records should be regularly checked to confirm that all staff capable of making exports have completed appropriate induction and training, and records of personnel involved in export control must be kept up to date. | none stated — but 'retraining' is expressly contemplated alongside induction | Up-to-date records of personnel involved in export control, checked regularly. ECJU compliance inspectors examine export and transfer records on audit. |
| Commission Regulation (EU) No 1321/2014, Annex I (Part-M), as retained in UK law | ||||
| M.A.606(b), (e), (f) and (i); M.A.607(a)(2), (b) and (c) competence | defined populations — all personnel involved in maintenance and airworthiness reviews; certifying staff; personnel performing specialised tasks; and airworthiness review staff | The qualification of all personnel involved in maintenance and airworthiness reviews shall be demonstrated and recorded (M.A.606(e)). A person or group must be nominated as responsible for ensuring continuous compliance and must demonstrate relevant knowledge and experience (M.A.606(b)). Personnel performing specialised tasks such as welding and non-destructive testing must hold qualifications in accordance with an officially recognised standard (M.A.606(f)). Certifying staff must demonstrate compliance with Part-66 point 66.A.20 and have an adequate understanding of the relevant aircraft or components (M.A.607(a)(2)). For ELA1 airworthiness review staff, M.A.606(i) requires certifying staff authorisation, a minimum of three years' certifying experience, independence from continuing airworthiness management, formal acceptance by the CAA after performing an airworthiness review, and at least one airworthiness review performed in the last twelve-month period. | at least one airworthiness review in any 12-month period for ELA1 review staff; no training interval otherwise | Demonstrated and recorded qualification for all maintenance and airworthiness review personnel; a current list of certifying and airworthiness review staff with scope of approval in the organisation manual (M.A.607(c)) |
| Regulation (EU) 2021/821 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items | ||||
| Article 2(21) (definition of internal compliance programme), with recital 18 competence | not specified in the Regulation — the ICP's training element is supplied by Commission Recommendation (EU) 2019/1318 | Quoted, Article 2(21): an internal compliance programme or ICP means "ongoing effective, appropriate and proportionate policies and procedures adopted by exporters to facilitate compliance with the provisions and objectives of this Regulation and with the terms and conditions of the authorisations implemented under this Regulation, including, inter alia, due diligence measures assessing risks related to the export of the items to end-users and end-uses". Recital 18 states that exporters using global export authorisations should implement an ICP unless the competent authority considers it unnecessary. Recital 7 notes that the size and organisational structure of exporters must be taken into account when developing and implementing ICPs. | "ongoing" is built into the definition itself | The ICP as a documented set of policies and procedures |
10 further obligations sit outside Defence & Aerospace regulation and bind you as an employer or as a deployer of AI. They are the ones a sector-by-sector review misses, because nobody who reads only their own rulebook ever reaches them.
| Clause | Who must be trained or assessed | What is required | Interval | Evidence required |
|---|---|---|---|---|
| EU AI Act (Reg (EU) 2024/1689) | ||||
| Article 4 (AI literacy) says train | defined population — quoted from the pre-amendment text: "their staff and other persons dealing with the operation and use of AI systems on their behalf" | AS ENACTED: providers and deployers were to take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account technical knowledge, experience, education and training, the context of use, and the persons on whom the systems are used. AS AMENDED from 2026-07-27 by the Digital Omnibus on AI: AI literacy remains an obligation on providers and deployers, but no specific or 'sufficient' level is mandated; the Commission and Member States take a stronger role in promoting AI literacy. The obligation on deployers of HIGH-RISK AI systems to ensure staff are trained for human oversight remains in place. | none specified | none specified |
| Article 26(2) says train | named population — the natural persons assigned to exercise human oversight | Quoted: "Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support." | none specified | none specified in this paragraph |
| Employment Rights Act 2025 | ||||
| Whole Act — training provisions at s.65 and related says train | named role — trade union equality representatives, not the general workforce | The Act's training provisions concern whether a trade union equality representative has undergone sufficient training to carry on those activities, with notice requirements on the union and reference to a relevant ACAS or Secretary of State Code of Practice. It is not a mandatory workforce training duty of the kind the rest of this map records. | none specified | Written notice from the trade union to the employer |
| Equality Act 2010 | ||||
| Section 109(4), with section 109(1) case law Allay (UK) Ltd v Gehlen [2021] UKEAT/0031/20 — stale or inadequate training defeats the s.109(4) 'all reasonable steps' defence, making training the operative discharge. | all staff — the defence turns on steps taken to prevent employees doing discriminatory acts | An employer is liable for anything done by a person in the course of their employment. Quoted from 109(4): "In proceedings against A's employer (B) in respect of anything alleged to have been done by A in the course of A's employment it is a defence for B to show that B took all reasonable steps to prevent A—(a) from doing that thing, or (b) from doing anything of that description." | none specified | The employer must SHOW the steps taken. The burden sits with the employer. |
| UK GDPR | ||||
| Article 24, read with Article 5(2) guidance UK GDPR Article 39(1)(b) — read at source 2026-08-12 — names staff training as an element of compliance with the Regulation: the data protection officer must "monitor compliance with this Regulation... including the assignment of responsibilities, awareness-raising and training of staff involved in processing operations, and the related audits". LIMIT OF THIS CITATION, stated plainly: Article 39 applies only where Article 37 requires a DPO to be appointed, so it does not by itself establish a training duty for every controller. It establishes that the Regulation treats staff training as part of compliance. The unconditional citation would be the ICO Accountability Framework, which has NOT been read — see not_yet_searched. | not specified — training is not expressly named in Article 24 | Quoted: "the controller shall implement appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is performed in accordance with this Regulation." Those measures must be reviewed and updated where necessary, and are to include appropriate data protection policies where proportionate to the processing activities. Article 5(2) supplies the accountability principle itself: "The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1" — that is, with all six data protection principles: lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; and integrity and confidentiality. | measures to be reviewed and updated where necessary — no interval | The controller must be able to DEMONSTRATE compliance. This is the accountability limb. |
| The Regulatory Reform (Fire Safety) Order 2005 | ||||
| Article 21, with articles 3 and 6 says train | all staff — quoted: "his employees" | Quoted, 21(1): the responsible person "must ensure that his employees are provided with adequate safety training (a) at the time when they are first employed; and (b) on their being exposed to new or increased risks because of" transfer or change of responsibilities, new or changed work equipment, new technology, or a new or changed system of work. 21(2): that training must "(a) include suitable and sufficient instruction and training on the appropriate precautions and actions to be taken by the employee in order to safeguard himself and other relevant persons on the premises; (b) be repeated periodically where appropriate; (c) be adapted to take account of any new or changed risks; (d) be provided in a manner appropriate to the risk identified by the risk assessment; and (e) TAKE PLACE DURING WORKING HOURS." | Trigger-based, not periodic: on first employment AND on each of four listed changes. "Repeated periodically where appropriate" — no interval stated. | none specified in the article |
| The Management of Health and Safety at Work Regulations 1999 | ||||
| Regulation 13(2), with 13(1) and 13(3) says train | all staff — every employee, on recruitment and again on each triggering change | Quoted, 13(2): "Every employer shall ensure that his employees are provided with adequate health and safety training— (a) on their being recruited into the employer's undertaking; and (b) on their being exposed to new or increased risks because of— (i) their being transferred or given a change of responsibilities within the employer's undertaking, (ii) the introduction of new work equipment into or a change respecting work equipment already in use within the employer's undertaking, (iii) the introduction of new technology into the employer's undertaking, or (iv) the introduction of a new system of work into or a change respecting a system of work already in use within the employer's undertaking." 13(1) separately requires the employer, "in entrusting tasks to his employees, [to] take into account their capabilities as regards health and safety." | No fixed interval. The duty is TRIGGER-BASED — on recruitment, and on each of the four changes listed in 13(2)(b). | Not specified in the regulation itself. |
| Health and Safety at Work etc. Act 1974 | ||||
| Section 2(2)(c), with section 2(1) says train | all staff — scoped by what is 'necessary to ensure' their health and safety | Quoted, s.2(2)(c): the employer's general duty extends in particular to "the provision of such information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of his employees." This is the primary-legislation parent of the MHSWR reg 13 duty. Note the double qualifier: training is owed only so far as it is BOTH 'necessary to ensure' health and safety AND 'reasonably practicable'. | None. The measure is necessity, not interval. | Not specified in the section. |
| Council Directive 89/391/EEC (the Framework Directive) on the introduction of measures to encourage improvements in the safety and health of workers at work | ||||
| Article 12(1) and 12(4) says train | all staff — 'each worker' | Quoted, 12(1): "The employer shall ensure that each worker receives adequate safety and health training, in particular in the form of information and instructions specific to his workstation or job: — on recruitment, — in the event of a transfer or a change of job, — in the event of the introduction of new work equipment or a change in equipment, — in the event of the introduction of any new technology. The training shall be: — adapted to take account of new or changed risks, and — repeated periodically if necessary." Quoted, 12(4): "The training referred to in paragraphs 1 and 3 MAY NOT BE AT THE WORKERS' EXPENSE... The training referred to in paragraph 1 MUST TAKE PLACE DURING WORKING HOURS." | No fixed interval. Trigger-based on four named events, PLUS two standing qualities the UK implementation does not spell out as clearly: adapted to new or changed risks, and "repeated periodically if necessary". | Not specified in Article 12. |
| Article 12(2) says train | named population — workers from OUTSIDE undertakings and/or establishments engaged in work in your undertaking. Contractors, agency staff, visiting engineers, maintenance crews. | Quoted in full: "The employer shall ensure that workers from outside undertakings and/or establishments engaged in work in his undertaking and/or establishment HAVE IN FACT RECEIVED appropriate instructions regarding health and safety risks during their activities in his undertaking and/or establishment." | None — triggered by the outside workers being engaged in work in your undertaking. | Not specified, but note the wording: the employer must ensure they "have in fact received" the instructions. That is a verification duty, not a provision duty — it is not discharged by having issued something. |
1 provisions that sit alongside the duties above without themselves requiring training. They are here because they are the ones most often mistaken for training duties, or most often missed when scoping them. We separate them rather than pad the count.
| Clause | Who it concerns | What is required | Interval | Evidence required |
|---|---|---|---|---|
| Part-145 (retained EU law) | ||||
| 145.A.55(d) related Record itself declares this is not a training duty. | n/a — record-keeping duty | The organisation must retain personnel records covering qualifications, training and experience. | n/a | Records retained for the duration of the person's employment plus 3 years after they leave the organisation. |
145.A.35(d) requires training sufficient to maintain up-to-date knowledge across three areas: relevant technologies, organisation procedures, and safety management including human factor issues. A programme built around technical content meets the clock and not the scope.
145.A.35(f) then requires a competence assessment against the specific duties a person is about to be authorised for, before the authorisation is issued. Completing the recurrent training does not discharge it.
66.A.20(b)(2) — privileges require 6 months of relevant maintenance experience in any preceding 2-year period. This fails silently in one predictable case: the engineer promoted into a supervisory role who keeps the licence but stops doing hands-on work.
66.A.25 and 66.A.30 — examinations, credits and qualifying experience all carry a 10-year window. 66.A.40 — the licence itself becomes invalid 5 years after its last issue or change unless submitted to the CAA.
145.A.55(d) and CAMO.A.220(c) both require personnel records covering qualifications, training and experience to be retained for the duration of employment plus three years after the person leaves.
A system that deprovisions a leaver puts the organisation in breach during a period when the record that would reveal the gap is the one that was deleted.
A maintenance organisation running a two-year recurrent cycle under Part-145 will often assume the same cadence answers Part-CAMO. CAMO.A.305(g) sets no interval at all — it requires competency to be established and controlled, with human factors built into the assessment rather than delivered as a separate course. Organisations holding both approvals frequently run one programme against two differently-shaped duties.
This map states what it did not check as well as what it did. A map that quietly omits its own gaps is worth less than one that marks them.
10 obligations across 7 instruments, each read directly from the published source on 2026-08-10.
Recorded because “we searched and found nothing” is a different fact from “we did not search”.
Their absence is not evidence that they contain no training duty.
Ten minutes on where your obligations actually sit. Fifteen watching a module built live from your own source documents. Five on whether there is a next step. Nothing to prepare and nothing to send beforehand.