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On-premise and air-gapped AI for aviation and defence

What Part-IS (Regulations (EU) 2023/203 and 2022/1645) asks an aviation organisation to assess before it adopts an AI assistant, the four deployment models and the interfaces each one creates, what air-gapped operation really requires, and seven questions to put to any vendor.

Oguz HicdurmazFounder and Managing Director, Lavionic GmbH10 min read

An on-premise AI assistant runs inside the organisation's own infrastructure, so the documents it reads, the questions staff ask and the answers it gives never leave the network. An air-gapped deployment goes one step further and runs with no connection to the internet at all, which means the language model itself has to run locally. For aviation organisations the choice stopped being a preference when Part-IS arrived: Regulation (EU) 2022/1645 has applied to design and production organisations since 16 October 2025, and Regulation (EU) 2023/203 applies to maintenance organisations, CAMOs, operators, training and ATM organisations from 22 February 2026. Both require an information security management system that identifies every system and data element the organisation depends on, every interface with another organisation, and every risk with a potential impact on aviation safety. An AI tool that sends the exposition or the type design to a third party is an interface to be assessed, and the assessment is easier when there is no interface.

Four ways to deploy an AI assistant

ModelWhere documents and answers liveWhere the language model runsInterfaces to assess under Part-IS
Shared cloud serviceThe vendor's multi-tenant platform, alongside other customersThe vendor's, or a model provider'sThe vendor, the model provider, every other tenant's isolation, the vendor's subprocessors
Dedicated instance on the vendor's cloudInfrastructure the vendor operates for you aloneThe vendor's, or a model provider'sThe vendor as a contracted organisation under IS.I.OR.235, plus the model provider
Dedicated instance in your own cloud accountYour account, your region, your access controlA model endpoint you choose, external or inside your accountThe cloud provider, and the model provider if external
On-premise, optionally air-gappedYour servers, inside your networkLocally, on your hardwareNone during operation. The software supplier, for updates only

The first two rows are what most general AI products offer, including those sold as "private". The last two are what a Part-IS risk assessment tends to lead to once design data, customer maintenance data or operational records are in scope.

What Part-IS actually asks of you

Point IS.I.OR.200 requires the organisation to set up an information security management system with an information security policy, a risk assessment, risk treatment measures, internal and external reporting schemes, incident detection and response, controls on contracted activities, personnel requirements, record-keeping, compliance monitoring, and protection of the confidentiality of information received from other organisations according to its sensitivity. Point IS.D.OR.200 places the same obligations on design and production organisations.

Point IS.I.OR.205 is the one that decides the deployment question. The organisation must identify all elements that could be exposed to information security risks, including its activities, facilities, resources and services, and the equipment, systems, data and information that contribute to them. It must identify the interfaces with other organisations that could result in mutual exposure. For each risk with a potential impact on aviation safety it must assign a level according to a predefined classification that takes into account the potential of occurrence of the threat scenario and the severity of its safety consequences. The assessment must be reviewed whenever the elements, the interfaces, the knowledge used to assess them, or the lessons from incidents change.

Point IS.I.OR.210 then requires measures that control the circumstances that contribute to the threat scenario, reduce the safety consequences or avoid the risk, and those measures must not introduce any new unacceptable risk. Point IS.I.OR.235 covers contracting: when any part of the ISMS activities is contracted out, the contracted activities must comply with the regulation, the contracted organisation must work under the organisation's oversight, and the competent authority must be able to access the contracted organisation on request. Point IS.I.OR.250 requires all of this to be described in an information security management manual that the authority approves.

Where an AI assistant lands in that assessment

Part-IS requirementWhat it means for an AI assistantWhat an on-premise deployment answers
IS.I.OR.205(a)(2): identify systems, data and informationThe assistant holds the exposition, procedures, design data and records. It is an asset in the register, and so are its index, its logs and its backupsAll of them sit on infrastructure already in the register, under the existing controls
IS.I.OR.205(b): identify interfaces with other organisationsA cloud AI vendor and a model provider are interfaces through which your documents and questions flowWith a local model there is no operational interface to identify
IS.I.OR.205(c): assign a risk level per threat scenarioTwo scenarios dominate: exfiltration of controlled data, and manipulation of what the assistant knows so that it gives wrong answers with confidenceExfiltration requires a network path that does not exist. Manipulation is addressed by a read-only user boundary and controlled ingestion
IS.I.OR.210(a): measures must not introduce new unacceptable risksAn assistant that can write to controlled records, or whose knowledge base any user can change, is a new riskThe assistant proposes, people decide; ingestion is a privileged, reviewed step
IS.I.OR.235: contracted activities under oversight and open to the authorityIf the assistant runs on a vendor's infrastructure, that vendor is a contracted organisation the authority may need to inspectThe only contracted element is the software. The running system is inspected as part of your own ISMS
IS.I.OR.200(a)(13): confidentiality of information received from other organisationsCustomer maintenance data under CAMO.A.325, design approval holder data under 145.A.45, operator contracts and records all end up in the corpusThe data stays where the contract that supplied it expects it to stay

None of this makes on-premise deployment mandatory. Part-IS asks for an assessment and for measures that match the assessed risk. It does mean that the assessment has to be written, that the AI vendor appears in it by name, and that "the vendor says it is secure" is not a risk treatment measure.

What air-gapped really requires

An air-gapped deployment is not an on-premise deployment with the internet switched off. Four things have to be true, and they are worth checking before a vendor's claim is accepted.

  • The model runs locally. If any part of answering a question calls an external model, the deployment is not air-gapped, whatever the contract says about data retention. A local model runs on the organisation's own hardware, and the hardware has to be sized for it.
  • Nothing phones home. No licence check, no telemetry, no error reporting, no update check during operation. The deployment must work indefinitely with no route to the outside.
  • Updates arrive as packages. Software, model and regulatory corpus updates are delivered as signed packages and installed by the organisation's own administrators under its change procedure. The regulatory corpus, for example a new revision of the Easy Access Rules, enters through the same controlled ingestion step as everything else.
  • Logs and backups stay inside. Every question asked and every answer given is itself information about the organisation. The audit log and the backups belong in the same network, under the same record-keeping controls as the documents.

There is a trade-off, and it should be stated plainly. A local model is smaller than the largest cloud models. For open-ended writing the difference shows. For compliance work it matters less than people expect, because the assistant's answers are bounded by the documents in the corpus and shown with their citations, so the reader is checking a paragraph reference rather than trusting prose. The RDB-1 Regulated Document Benchmark measured this on a technical report from a completed regulatory assessment: the best local model on Wingman360 Teammate scored 74 out of 100, level with the best cloud model on the same harness and above a frontier model on a general agent tool. The same maintenance data requirements apply either way: point 145.A.45(g) makes the organisation responsible for keeping the data current, and point 145.A.45(e) requires electronic work card databases to be protected against unauthorised alteration and backed up within 24 hours. Whatever sits next to those records has to meet that bar.

Seven questions for any vendor

  1. Where, physically and organisationally, are the documents, the index, the model, the logs and the backups?
  2. Can the system operate with no internet connection, and for how long?
  3. What leaves the network during normal operation, and what leaves during an update?
  4. Who can change what the assistant knows, and is that separated from everyday use?
  5. How are software and model updates delivered, signed and verified?
  6. Can our ISMS auditor and our competent authority inspect the running system, as point IS.I.OR.235(b) may require?
  7. If we stop using it, can we export everything, and what is deleted where?

Our own answers to the seven questions, for Wingman360 Teammate as deployed, are on the trust page.

The conditions for trusting the answers themselves are the four in Can AI be trusted for aviation compliance documentation?, and the way to introduce an assistant into a maintenance or CAMO organisation is in the Part 145 and CAMO guide. Deployment is the third leg: the answers can be right and the process can be sound, and the tool can still fail the risk assessment because of where it runs.

How Wingman360 Teammate is deployed

Every Wingman360 Teammate deployment is a dedicated single-tenant instance, either in the organisation's own cloud account or on its own premises. There is no shared platform and no data pooled across customers. With the local model option the model runs inside the organisation's network, so no model call, no document and no question leaves it, and the deployment can run air-gapped. Administrators control what enters the knowledge base through a privileged ingestion step; everyone else has read-only access and receives cited answers. Updates are delivered as packages for the organisation's administrators to install. Security in this model comes from isolation and from the organisation's own controls, which is also why it fits inside an ISMS rather than beside it.

Frequently asked questions

Does Part-IS apply to my organisation?
Regulation (EU) 2023/203 applies from 22 February 2026 to organisations approved under the continuing airworthiness, air operations, aircrew, ATM/ANS and U-space rules, among them Part 145 maintenance organisations, CAMOs, air operators, training organisations and air navigation service providers, with exceptions for some small or Part-ML-only cases. Delegated Regulation (EU) 2022/1645 applies from 16 October 2025 to Part 21 design and production organisations and to aerodrome operators, with an exception for organisations solely involved in ELA2 aircraft. Check Article 2 of each regulation and your competent authority's guidance for the exact scope.
Is a dedicated cloud deployment enough, or do we need on-premise?
That is a risk assessment question under point IS.I.OR.205, not a preference. A dedicated single-tenant deployment in your own cloud account keeps documents and answers under your control and removes the shared-tenancy risk, but the cloud provider and any external model provider remain interfaces you must identify and assess. On-premise deployment with a local model removes the model interface entirely. Organisations that handle design data, customer maintenance data or defence material usually conclude that the local option is the one they can defend.
Do local models give worse answers than cloud models?
A local model is smaller than the largest cloud models, and for open-ended writing the difference is noticeable. For compliance work the model matters less than the corpus and the retrieval: the assistant answers from your approved documents and shows the paragraph, so the quality of the answer is bounded by whether the right paragraph was found, not by how eloquently it is paraphrased. Measure citation accuracy on your own questions before deciding, as described in the Part 145 guide.
Does an on-premise assistant need an internet connection for updates?
No. Software, model and regulation updates can be delivered as signed packages and installed by your own administrators under your change procedure, in the same way that other software on a segregated network is updated. The regulatory corpus is updated when the person responsible for the knowledge base ingests the new revision, which is a controlled step whether or not the network is connected.
What changes for a defence organisation?
The reasoning is the same and the constraints are stricter. Material handled on classified or segregated networks cannot pass through any external service, so the assistant, its index, its model and its logs must all run inside that network, and updates must arrive through the channel the organisation already uses for other software. A deployment that meets Part-IS for a civil organisation is the starting point, not the finish.
Is a vendor's "private" cloud the same as on-premise?
No. A private or dedicated instance on the vendor's infrastructure still means your documents, questions and answers are stored and processed by another organisation. Under point IS.I.OR.235 that is a contracted activity: it must comply with the regulation, work under your oversight, and be open to your competent authority on request. On-premise means the software runs on infrastructure you control, and the only contracted element is the software itself.

Sources

  1. Easy Access Rules for Information Security (Regulations (EU) 2023/203 and (EU) 2022/1645), August 2024 revision, European Union Aviation Safety Agency. Annex II (Part-IS.I.OR) points IS.I.OR.200, IS.I.OR.205, IS.I.OR.210, IS.I.OR.235, IS.I.OR.240, IS.I.OR.250 and their AMC and GM
  2. Commission Implementing Regulation (EU) 2023/203 on requirements for the management of information security risks with a potential impact on aviation safety, applies from 22 February 2026 (Article 16)
  3. Commission Delegated Regulation (EU) 2022/1645 on requirements for the management of information security risks with a potential impact on aviation safety for organisations covered by Regulations (EU) No 748/2012 and (EU) No 139/2014, applies from 16 October 2025 (Article 8)
  4. Easy Access Rules for Continuing Airworthiness (Regulation (EU) No 1321/2014), September 2025 revision, European Union Aviation Safety Agency. Points 145.A.45(e) and (g) and CAMO.A.325 on maintenance data

All documents cited on this site, with revision and date checked, are listed in the sources register; terms are defined in the glossary.

About the author

Oguz Hicdurmaz

Founder and Managing Director, Lavionic GmbH

Senior aerospace engineer with more than 20 years in manned and unmanned aircraft certification, airworthiness compliance and safety engineering. EASA Part 21 certification basis development, airworthiness management plans and compliance verification.

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