When EASA suspended Pakistan International Airlines’ Third Country Operator authorisation in 2020 it was not only sanctioning a single carrier. The agency was flagging a loss of confidence in the competence of the state regulator that certified that carrier. That distinction matters because the pathway back to Europe for PIA runs through restoration of effective oversight by Pakistan’s Civil Aviation Authority, not just paperwork from the airline.

EASA’s approach since 2020 has evolved into what I will call an oversight restoration model. It is layered, evidentiary and conditional. At its core the model asks three things: demonstrate that systemic shortcomings identified by others are closed; show that the national regulator can perform the oversight tasks it delegated to the operator; and allow independent verification by European experts or partners. That sequence explains why clearance for PIA has been linked repeatedly to reforms at the PCAA rather than only to fixes inside the airline.

How the model works in practice

1) Close the Significant Safety Concern or equivalent finding. In Pakistan’s case the ICAO USOAP process targeted serious weaknesses in personnel licensing. An on‑site ICAO audit in late 2021 was the first formal step to test whether corrective action plans were genuine and effective. EASA treats ICAO outcomes as necessary but not always sufficient; the agency expects the state’s remedial steps to be demonstrable and durable before operator authorisations are restored.

2) Submit and substantiate a corrective action plan. States and operators must do more than promise reforms. They must submit concrete corrective action plans with milestones and evidence. Pakistan submitted a corrective action plan that was reviewed in Brussels and discussed during technical exchanges in 2024. Removal from the European Commission’s so called concern list reflected progress on those deliverables, but it did not automatically translate into a return of air operator rights. EASA continues to reserve the right to run its own verification.

3) Allow targeted verification by EASA or its designees. EASA’s restoration model contemplates its own assessments. That can include sample audits of airlines, focused reviews of licensing files, and direct evaluation of the regulator’s staffing, procedures and segregation from service providers. In 2020 the agency went further and warned member states about scheduling flights with pilots whose licences were in doubt. That step illustrates the model’s emphasis on personnel competence as an essential building block of oversight.

4) Demonstrate sustainable institutional change, not a one off fix. EASA looks for signs that the regulator has reformed processes, hired or trained competent staff, and implemented systems to prevent recurrence. Structural measures such as clearer separation of regulatory and service provider functions, modernised exam and validation procedures, and robust human resources capacity are the kinds of durable reforms that satisfy restoration criteria.

Why the model is defensible

Regulators must protect passengers and states must be able to rely on documented evidence of oversight. By conditioning authorisation on restoration of the regulator’s capabilities EASA reduces the risk that a carrier will briefly comply on paper only to relapse into unsafe practice. The layered verification also leverages ICAO’s global oversight tools while preserving EASA’s mandate to protect EU airspace. That duality is sensible from both legal and safety standpoints.

Where the model falls short

There are four predictable problems that merit attention. First, the model can feel opaque. Operators and foreign regulators are left guessing which specific metrics will satisfy EASA. Second, timelines are often open ended. Restorations that depend on institutional change will vary by state, but the absence of published milestones imposes commercial uncertainty. Third, the model risks duplicating effort already completed under ICAO if EASA does not clearly explain the incremental checks it requires. Fourth, smaller states or airlines may not have capacity to meet complex documentary demands without technical assistance. Each of these gaps can be fixed without undermining safety.

Practical recommendations

  • Publish a restoration roadmap template. A standard template would ask states to map measures against discrete oversight functions such as licensing, airworthiness and flight operations, and provide expected documentary evidence for each. This will make expectations transparent and reduce needless back and forth.

  • Use tiered verification. Where ICAO has validated corrective actions, EASA should adopt a proportionate verification that focuses on residual risks. Full reaudits should be reserved for cases where ICAO evidence is weak or significant new risks are identified.

  • Offer conditional, phased authorisations. Where the regulator has closed systemic findings but needs to demonstrate sustained performance, EASA could permit limited operations under strict monitoring rather than an all or nothing restoration.

  • Support capacity building. When oversight gaps are genuine and solvable, technical assistance and twinning with EU authorities can accelerate durable reform. That is both pragmatic and in the EU’s own interest.

Conclusion

EASA’s oversight restoration model is pragmatic in principle. It recognises that restoring access to a regulator’s airspace is a state capacity problem as much as an airline compliance issue. The model is strongest when it combines ICAO validation, transparent remediation plans, and targeted EASA verification. But to be effective and fair it needs clearer public criteria, proportionality in verification, and mechanisms to help states close capability gaps. If EASA publishes those tools the agency will protect safety while providing operators and states with a predictable path back to international markets.