Yes. When AS9100 is revised, there is normally a defined transition period, but it is not open-ended and it is controlled by IAQG and the accredited certification bodies, not by individual organizations.
How AS9100 transition periods work
For each new revision of AS9100 (e.g., from Rev C to Rev D), IAQG and accreditation bodies publish:
- A date when the new revision is released and becomes auditable.
- A start date when certification bodies may begin issuing certificates to the new revision.
- A deadline after which certificates to the previous revision are no longer valid.
Within this window, organizations are expected to:
- Perform a gap assessment against the new revision.
- Update their QMS processes, documented information, and quality manual.
- Implement required changes on the shop floor and in supporting functions.
- Train relevant personnel and be able to demonstrate competence.
- Accumulate enough operational evidence to show effective implementation during an audit.
What is and is not flexible
Some aspects are fixed at the scheme level:
- Deadlines: The transition deadline is set by IAQG and accreditation bodies. After that date, your old-revision certificate cannot be maintained.
- Audit expectations: Certification bodies must audit against the new revision after defined cutover points.
Some aspects can vary:
- Audit scheduling: Your specific transition audit may be aligned with a surveillance or recertification audit, subject to your certification body’s rules and capacity.
- Transition approach: How you phase changes across plants, product lines, or business units is up to you, as long as you can show effective implementation by the audit.
Organizations should not assume that a long informal grace period exists beyond the published transition dates. Missing the formal deadline can result in suspension or lapse of certification.
Implications for brownfield and regulated environments
For aerospace and defense manufacturers with established MES, ERP, PLM, and legacy QMS tools, transitioning between AS9100 revisions usually means:
- Updating document control rules, records retention, and evidence trails across multiple systems.
- Adjusting audit trails, logs, and approvals to align with new or clarified requirements.
- Revising procedures and work instructions in parallel with ongoing production to avoid downtime.
- Coordinating changes with customer and regulatory requirements where they reference specific AS9100 clauses.
Because these environments are highly validated and integrated, a full, big-bang replacement of systems during a revision transition is rarely practical. Most organizations layer incremental changes on top of existing infrastructure, with strong change control and impact assessment, to avoid re-qualification of entire stacks.
Practical steps during a transition period
Typical activities during an AS9100 transition window include:
- Formal gap analysis against the new revision, with documented actions and owners.
- Change-controlled updates to QMS documentation and linked procedures/work instructions.
- Training plans and records to show personnel understand the revised requirements.
- Internal audits targeted at new/changed clauses to generate objective evidence.
- Risk assessment of any system or process changes introduced to meet the new revision.
The level of effort and risk will depend heavily on existing process maturity, configuration management discipline, and how tightly your shop-floor and back-office systems are integrated.
