The DPO Is Coming

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Stephen attended EASA’s ATM/ANS Equipment Conformity Assessment Workshop in Cologne on 9–10 June 2026, and it made clear that 2026 is the year industry needs to act. The Design and Production Organisation (DPO) regime introduced by Regulations (EU) 2023/1768 and 2023/1769 is no longer a future concept. With the transition window closing at the end of October 2028, organisations that design or produce ATM/ANS equipment, and the service providers that depend on them, are now translating regulation into operational change.

What the regime actually is

The DPO framework is the European Union’s first harmonised approach to the design and production of ATM/ANS equipment. Implementing Regulation (EU) 2023/1769 sets out the organisational approval — how an entity becomes a DPO. Delegated Regulation (EU) 2023/1768 sets out the conformity assessment framework for the equipment itself, structured around three routes: Article 4 certification by EASA for the highest-criticality equipment; Article 5 Declaration of Design Compliance, which EASA reviews, registers and publishes; and Article 6 Statement of Compliance, a lighter transitional route.

The choice between routes is not preference-led. It is driven by the equipment’s category and criticality as defined in 2023/1768 and its Detailed Specifications.

Cologne and the workshop themes

The workshop put the practical questions front and centre. Three topics dominated the two days: how equipment classification is determined in practice and which route each product falls under; the life-cycle data, configuration records and design assurance artefacts a DPO must maintain; and the mechanics of registering a Declaration of Design Compliance, which is the area with the steepest learning curve because the DDC route is genuinely new.

Things to look out for

EASA has published most of the supporting Acceptable Means of Compliance and Guidance Material, including ED Decisions 2023/016/R, 2024/001/R and 2024/002/R, and the consolidated Easy Access Rules for ATM/ANS Equipment (25 November 2024). Two gaps remain: AMC/GM for Part-DPO.AR and for Part-ATM/ANS.EQMT.DEC. Until those are published, organisations will need to infer expectations from the regulation text and from EASA practice.

The transition is also more nuanced than a single deadline. October 2028 closes the legacy Statement of Compliance path for new and modified equipment, but the right transition point for any given organisation is driven by product roadmap and modification cadence, not by the calendar alone.

For organisations already operating under (EU) 2017/373, the DPO regime deliberately inherits its management system, oversight model and change-control mechanics — a meaningful opportunity to re-use existing evidence rather than build everything from scratch.

What it means

For manufacturers, the practical work clusters around organisational approval under 2023/1769, route selection per product line, design assurance evidence to an EASA-visible standard, and a transition plan mapped against October 2028. For ANSPs and service providers, EASA-visible design assurance artefacts upstream should make safety cases and change submissions more efficient over time — provided suppliers are engaged early and equipment classification is well understood.

The DPO regime is one of the most significant structural changes in European ATM/ANS oversight in a generation. The Cologne programme has made clear the framework is now real, the routes are now defined, and the transition clock is running. The organisations that come out of this strongest will be the ones that engage while there is still time to plan rather than react.