Part 135 Flight Time, Duty, and Rest Recordkeeping Requirements

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Chad Griffith, Founder & CEO

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Last reviewed · By Chad Griffith

Under 14 CFR Part 135 Subpart F, charter pilots are capped at 1,200 flight hours/year for scheduled ops (135.265) and 1,400/year for unscheduled ops (135.267, 135.269). Daily limits run 8-10 flight hours per 24 hours, with required rest of 9-11 consecutive hours. Operators must keep flight-time records (135.63) for at least 12 months to prove it.

Which Part 135 flight-time and rest rules apply to your operation

The rule that governs your pilots depends on whether you fly scheduled or unscheduled and how many pilots crew the flight. 14 CFR 135.261 sets the applicability: 135.263 covers all certificate holders, 135.265 covers scheduled passenger operations, 135.267 and 135.269 cover unscheduled operations (one/two-pilot and three/four-pilot crews respectively), 135.271 covers helicopter air ambulance, and 135.273 covers flight attendants.

Most on-demand charter operators fall under the unscheduled rules. A single Part 135 certificate can touch several of these sections at once: a two-pilot on-demand flight follows 135.267, the same operator's scheduled commuter leg follows 135.265, and any flight attendant follows 135.273. Per 135.263(a), a certificate holder may assign flight time, and a crewmember may accept it, only when the applicable requirements of 135.263 through 135.271 are met.

One frequent point of confusion: the FAA's newer flight-and-duty regime in 14 CFR Part 117 applies to Part 121 air carriers, not Part 135. Part 117's 100-hour/672-hour limits and fatigue-risk provisions do not govern charter pilots. Part 135 operators are bound by the Subpart F sections below, not Part 117.

Hour caps and required rest by section (summary table)

The table below maps each Part 135 section to its flight-hour caps and minimum rest, so you can match a pilot's operation to the correct limit. Numbers are stated exactly as written in the regulation; verify edge cases against the cited section.

SectionOperationFlight-time capsDaily flight-time limitRequired rest
135.265Scheduled1,200 hrs/calendar year; 120 hrs/calendar month; 34 hrs/7 consecutive days8 hrs in any 24 consecutive hours (1 pilot); 8 hrs between required rest periods (2 pilots)9 hrs (sched. flight time <8 hrs), 10 hrs (8 to <9 hrs), or 11 hrs (9+ hrs) of consecutive rest; plus 24 consecutive hours off in any 7 consecutive days
135.267Unscheduled, 1-2 pilots500 hrs/calendar quarter; 800 hrs/two consecutive quarters; 1,400 hrs/calendar year8 hrs (1 pilot) or 10 hrs (2 pilots) in any 24 consecutive hoursAt least 10 consecutive hours of rest in the 24-hour period preceding the planned completion of the assignment
135.269Unscheduled, 3-4 pilots500 hrs/calendar quarter; 800 hrs/two consecutive quarters; 1,400 hrs/calendar yearNo more than 8 hrs of flight-deck duty in any 24 consecutive hours10 consecutive hours immediately before the assignment and at least 12 hours after; plus 13 rest periods of 24 consecutive hours each per calendar quarter
135.273Flight attendants(Duty-period based, not flight-hour caps)Duty period 14 hrs or less without added crewAt least 9 consecutive hours (reducible to 8 if followed by 10 hrs); extended duty (14-20 hrs) requires 12 hrs, reducible to 10 if followed by 14 hrs

Two recurring penalties: assigning a one-pilot crew more than 8 flight hours in 24 consecutive hours (135.267(b)(1)), and failing to give the required 10 consecutive hours of rest before completing an unscheduled assignment (135.267(d)).

Unscheduled one- and two-pilot crews: the 135.267 limits in detail

For on-demand charter, 14 CFR 135.267 caps a pilot at 8 flight hours in any 24 consecutive hours for a one-pilot crew and 10 hours for a two-pilot crew, with longer-range caps of 500 hours per calendar quarter, 800 per two consecutive quarters, and 1,400 per calendar year (135.267(a)-(b)). These are the limits most charter operators must track day to day.

Rest is built two ways. Under 135.267(d), every assignment must provide at least 10 consecutive hours of rest during the 24-hour period that precedes the planned completion time of the assignment. Under 135.267(c), flight time may exceed the daily 8/10-hour limit if it occurs during a regularly assigned duty period of no more than 14 hours that is immediately preceded and followed by a required rest period of at least 10 consecutive hours, the flight time still does not exceed 8 hours (one pilot) or 10 hours (two pilots), and the combined duty and rest periods equal 24 hours.

When weather or other circumstances beyond control push a pilot past the daily limit, 135.267(e) requires a longer rest before the next assignment: 11 consecutive hours if exceeded by 30 minutes or less, 12 consecutive hours if exceeded by more than 30 but not more than 60 minutes, and 16 consecutive hours if exceeded by more than 60 minutes.

Scheduled operations (135.265), three/four-pilot crews (135.269), and flight attendants (135.273)

Scheduled Part 135 passenger operations follow 14 CFR 135.265: 1,200 flight hours per calendar year, 120 per calendar month, 34 in any 7 consecutive days, and 8 flight hours in any 24 consecutive hours for a one-pilot crew (8 hours between required rest periods for two pilots). Required rest in 135.265(b) scales with scheduled flight time: 9 consecutive hours when scheduled flight time is less than 8 hours, 10 hours when it is at least 8 but less than 9, and 11 hours when it is 9 hours or more, all during the 24 hours preceding completion. Under 135.265(d), each crewmember must be relieved of all duty for at least 24 consecutive hours during any 7 consecutive days.

Three- and four-pilot unscheduled crews follow 135.269, which keeps the same 500/800/1,400-hour caps as 135.267 but limits flight-deck duty to no more than 8 hours in any 24 consecutive hours, caps total duty at 18 hours (three pilots) or 20 hours (four pilots), requires at least 10 consecutive hours of rest immediately before the assignment and at least 12 hours after, and mandates at least 13 rest periods of 24 consecutive hours each per calendar quarter.

Flight attendants follow 135.273. A duty period is the elapsed time between reporting for an assignment involving flight time and release from it; a rest period is time free of all responsibility for work or duty. A flight attendant scheduled to a duty period of 14 hours or less must be given a scheduled rest period of at least 9 consecutive hours, reducible to 8 if followed by a subsequent rest period of at least 10 consecutive hours.

What records you must keep to prove compliance (135.63)

14 CFR 135.63(a)(4) requires every certificate holder to keep an individual record for each pilot that includes the pilot's flight time "in sufficient detail to determine compliance with the flight time limitations" of this part, and 135.63(b) requires those records be kept for at least 12 months. The limits in 135.265 through 135.273 are only enforceable because this recordkeeping rule makes flight time auditable.

The same individual pilot record under 135.63(a)(4) also must show the pilot's full name; certificate type, number, and ratings; aeronautical experience sufficient to determine qualification; current duties and the date assigned; medical certificate; competency and proficiency checks; and training completion. In practice, proving compliance with the daily, weekly, quarterly, and annual caps means an FAA inspector can reconstruct, from your records, every pilot's running flight-time totals against the 24-hour, 7-day, monthly, quarterly, and yearly windows that apply to that pilot's operation.

This is the layer where charter operators most often get caught flat-footed: the duty and rest are scheduled correctly, but the proof is scattered across a scheduling system, paper logs, and spreadsheets, and cannot be produced cleanly on demand during a records request or ramp check.

How FileFlo helps you prove flight-time and rest compliance

FileFlo is the records and proof layer for Part 135 compliance: it classifies each compliance document to its exact CFR citation, tracks expirations, flags missing records, and exports an inspector-ready audit binder. It is not a scheduling, FOS, crew-management, or fatigue-risk system, and it does not assign or limit flight time. Those decisions live in your operations and scheduling tools.

Where FileFlo fits the recordkeeping obligation in 135.63 is on the back end. When pilot records, training certificates, and currency documents land in FileFlo, the platform classifies each to its governing citation (for example, tying a pilot's records to the flight-time and rest sections of Subpart F), tracks the 12-month retention clock, and surfaces what is missing or expired before an inspector does. When the FAA asks for proof, you export a single organized binder instead of assembling it from scattered systems under time pressure.

FileFlo is currently used by charter operators for exactly this proof problem. It is $89 or $299 per month, with a 5-day trial. FileFlo is not yet SOC 2 certified.

Frequently Asked Questions

What is the maximum flight time for a Part 135 charter pilot?

For unscheduled (on-demand) operations under 14 CFR 135.267, a pilot is limited to 8 flight hours in any 24 consecutive hours for a one-pilot crew and 10 hours for a two-pilot crew, with longer caps of 500 hours per calendar quarter, 800 per two consecutive quarters, and 1,400 per calendar year. Scheduled operations under 135.265 are capped at 1,200 hours per calendar year, 120 per month, and 34 in any 7 consecutive days.

How much rest is required between Part 135 flights?

It depends on the operation. Unscheduled one/two-pilot crews need at least 10 consecutive hours of rest during the 24-hour period preceding the planned completion of the assignment (135.267(d)). Scheduled operations require 9, 10, or 11 consecutive hours of rest depending on scheduled flight time (less than 8, 8 to under 9, or 9+ hours) under 135.265(b). Three/four-pilot unscheduled crews need 10 hours immediately before and at least 12 hours after the assignment (135.269).

Does Part 117 apply to Part 135 operators?

No. 14 CFR Part 117 prescribes flight and duty limitations for flightcrew members in passenger operations conducted under Part 121 (scheduled air carriers). It does not apply to Part 135 charter operators. Part 135 pilots are governed by the flight-time and rest sections of Part 135 Subpart F (135.261 through 135.273), not by Part 117's 100-hour/672-hour limits.

What flight-time records does the FAA require Part 135 operators to keep?

Under 14 CFR 135.63(a)(4), a certificate holder must keep an individual record for each pilot that includes the pilot's flight time in sufficient detail to determine compliance with the flight-time limitations, along with name, certificates and ratings, aeronautical experience, current duties, medical certificate, competency checks, and training. Per 135.63(b), these records must be kept for at least 12 months.

What happens if a Part 135 pilot exceeds the daily flight-time limit due to weather?

If a crewmember exceeds the daily flight-time limit because of circumstances beyond the control of the certificate holder or pilot (such as adverse weather), 135.267(e) requires a longer rest before the next assignment: at least 11 consecutive hours if the limit was exceeded by 30 minutes or less, 12 consecutive hours if exceeded by more than 30 but not more than 60 minutes, and 16 consecutive hours if exceeded by more than 60 minutes.

What is the annual flight-time cap for unscheduled vs scheduled Part 135 operations?

Unscheduled operations (135.267 for one/two-pilot crews and 135.269 for three/four-pilot crews) cap a pilot at 1,400 flight hours per calendar year, plus 500 hours per calendar quarter and 800 per two consecutive quarters. Scheduled operations under 135.265 are capped lower, at 1,200 flight hours per calendar year, with 120 hours per calendar month and 34 hours in any 7 consecutive days.

How are flight attendant duty and rest periods handled under Part 135?

14 CFR 135.273 governs flight attendants. A flight attendant scheduled to a duty period of 14 hours or less must be given a scheduled rest period of at least 9 consecutive hours, which may be reduced to 8 hours if followed by a subsequent rest period of at least 10 consecutive hours. Extended duty periods between 14 and 20 hours require additional flight attendants and a scheduled rest period of at least 12 consecutive hours (reducible to 10 if followed by a 14-hour rest).

Can FileFlo schedule pilots or enforce duty limits?

No. FileFlo is the records and proof layer, not a scheduling, FOS, or crew-management system, and it does not assign or limit flight time. It classifies each compliance document to its CFR citation, tracks expirations and the 12-month retention required by 135.63, flags missing records, and exports an inspector-ready audit binder so you can prove compliance with the flight-time and rest limits your scheduling system enforces. FileFlo is $89 or $299 per month with a 5-day trial and is not yet SOC 2 certified.

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