FAA Part 135 Charter Operations Compliance

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Chad Griffith, Founder & CEO

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Last reviewed · By Chad Griffith

14 CFR Part 135 ('Operating Requirements: Commuter and On-Demand Operations') governs commercial commuter and on-demand operations including charter, air taxi, and small commuter airline services. Part 135 carriers must hold an Air Carrier Certificate, operate under detailed Operations Specifications, maintain training and maintenance programs, comply with drug and alcohol testing rules under Part 120, and follow operational control protocols. Part 135 is the typical regulatory framework for charter jet operators, helicopter EMS (HEMS), small commuter operations, and air taxi services.

Air Carrier Certificate Requirements

Part 135 operating certificate requires: business documentation; key personnel (Director of Operations, Chief Pilot, Director of Maintenance; required positions vary by Part 135 type); operations and maintenance manuals; training programs; aircraft eligibility verification; drug and alcohol testing program; and demonstration of operational capability. Certification typically takes 12-18 months for a new operator. The FAA classifies Part 135 carriers as 'commuter' (scheduled), 'on-demand' (non-scheduled), or both.

Pilot Qualifications

Part 135 pilot requirements depend on the type of operation: VFR-only Part 135 PIC requires 500 hours flight time; IFR Part 135 PIC requires 1,200 hours total time, 500 cross-country hours, and an instrument rating; SIC for IFR Part 135 requires 100 hours flight time and instrument rating. All Part 135 pilots must complete recurrent training every 12 calendar months and pass an annual proficiency check.

Maintenance Programs

Part 135 maintenance can use one of three programs under Section 135.411: Continuous Airworthiness Maintenance Program (CAMP) required for aircraft of 10 or more passenger seats; Approved Aircraft Inspection Program (AAIP) for aircraft of 9 or fewer seats; Manufacturer's program for some smaller aircraft. CAMP-required carriers operate similar to Part 121 maintenance with comprehensive recordkeeping and continuous surveillance.

Operational Control

Part 135 carriers must maintain operational control over their flights: the carrier (not the customer) makes operational decisions about safe conduct of the flight. Operational control violations are a frequent enforcement issue, particularly when 'wet leases' or 'dry leases' blur the line between customer-driven scheduling and operator-controlled operations. The carrier's Director of Operations is responsible for operational control.

SMS and the 2027 Compliance Deadline

The FAA's Safety Management System final rule (14 CFR Part 5), published in 2024, extends SMS requirements beyond Part 121 airlines to all Part 135 on-demand and commuter operators, with a compliance deadline in 2027. A compliant SMS spans four components (Safety Policy, Safety Risk Management, Safety Assurance, and Safety Promotion), and each generates documentation the FAA expects on demand: the SMS manual, hazard reports and risk assessments, safety-performance monitoring records, management-review minutes, and recurrent SMS training records.

For most Part 135 operators the hard part is the documentation, not the safety concepts. Safety Assurance in particular depends on continuous, dated records: an SMS assembled the week before an audit fails it. Operators that already keep clean training and maintenance records are best positioned for the 2027 deadline.

Records Behind a Part 135 Certificate

Part 135 operating authority rests on documentation the FAA can inspect at any time. The required recordkeeping spans pilot qualification and training records (initial, recurrent, and checkride dates under the operator’s approved training program); aircraft maintenance and airworthiness records, including inspection sign-offs under 14 CFR 91.409; the General Operations Manual and General Maintenance Manual required by 14 CFR 135.21; Operations Specifications (OpSpecs) issued by the FAA; drug and alcohol testing records under Part 120; and, by 2027, SMS records.

FileFlo is the compliance document layer for these records: it classifies them, tracks expirations, and proves the paperwork behind a Part 135 certificate, training program, maintenance program, and SMS. It does not run your operation or replace your training or safety program; it keeps the documents that prove them audit-ready. Run a free FAA readiness check →

Frequently Asked Questions

What is the difference between Part 91 and Part 135 for corporate flights?

Part 91 covers non-commercial operations including most corporate flight departments (where the company owns and operates the aircraft for its own employees and guests). Part 135 covers commercial operations where the operator is paid to provide transportation. Many corporate flight departments operate under Part 91 by structuring operations to avoid the compensation triggers that activate Part 135. Charter aircraft sold to the public or third parties operate under Part 135.

What is a Part 135 letter of authorization?

A Letter of Authorization (LOA) is an FAA-issued document granting specific approvals beyond standard Operations Specifications, for example RNP authorization, Class II navigation, or specific airport approvals. LOAs supplement OpsSpecs and require demonstrated operator capability for the authorized procedure.

Does Part 135 require drug and alcohol testing?

Yes. Part 135 carriers and contractor pilots performing safety-sensitive functions must comply with Part 120 drug and alcohol testing program. The program covers pre-employment, random, post-accident, reasonable suspicion, return-to-duty, and follow-up testing. Records retention: 5 years for positive tests, 1 year for negative tests, 5 years for refusal-to-test records.

How often must Part 135 pilots complete recurrent training?

Every 12 calendar months: recurrent ground training and recurrent flight training plus a proficiency check. The proficiency check (often called a 135.293 check) evaluates the pilot's ability to operate the aircraft to ATP standards. Failure of a proficiency check requires retraining and re-check before resuming Part 135 PIC duties.

What is the FAA SMS rule, and when must Part 135 operators comply?

The FAA's 2024 SMS final rule (14 CFR Part 5) requires all Part 135 on-demand and commuter operators to implement a Safety Management System, with a compliance deadline in 2027. SMS has four components (Safety Policy, Safety Risk Management, Safety Assurance, and Safety Promotion), and each must be supported by continuous, dated records the FAA can review.

What are Operations Specifications (OpSpecs) for a Part 135 operator?

OpSpecs are the FAA-issued authorizations that define exactly what a Part 135 operator may do: aircraft, areas of operation, kinds of operation (for example IFR, single-pilot, or helicopter air ambulance), and special authorizations. They are part of the certificate and must be kept current. Operating outside your OpSpecs is a violation even when the underlying activity would otherwise be legal.

Which documents must a Part 135 operator keep audit-ready?

At minimum: pilot training and qualification records, aircraft maintenance and airworthiness records, the General Operations and General Maintenance Manuals, current OpSpecs, drug and alcohol testing records under Part 120, and, by 2027, SMS records. The FAA can request any of these during a records inspection or ramp check.

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