Direct Answer
In a Part 135 operation, the Director of Operations is accountable for the operation; the Chief Pilot is accountable for the pilots and the flying standard. Both are required management positions under 14 CFR §119.69(a).
The Director of Operations is the management official responsible for the overall conduct and operational direction of flight operations — operational-control administration, scheduling and flight-following oversight, and operational policy. The Chief Pilot is the management pilot responsible for crewmember standards — pilot training and checking, crew currency, standardization, and the pilot-facing portions of the operations manual. Operational control rests with the certificate holder, and the DO is the position most associated with administering it; the Chief Pilot administers flight standards but does not hold operational control.
They carry different qualification standards under 14 CFR §119.71 (not the Part 121 section §119.65): the DO standard in §119.71(a)/(b) centers on supervisory/operational-control experience, while the Chief Pilot standard in §119.71(c)/(d) centers on recent pilot-in-command experience. One person can hold both titles only if the FAA authorizes a deviation under §119.69(b) and that person independently meets each role's §119.71 standard.
Where Both Roles Come From in the Rule
Both positions exist because the FAA requires them. The requirement lives in 14 CFR §119.69, titled “Management personnel required for operations conducted under part 135 of this chapter.” Subsection (a) requires each certificate holder — except one using only one pilot in its operations — to have qualified personnel serving as a Director of Operations, a Chief Pilot, and a Director of Maintenance. The qualifications for each of those Part 135 positions are then set in 14 CFR §119.71.
Cite §119.69 / §119.71 for Part 135 — not §119.65
14 CFR §119.65 is the Part 121 management-personnel section. For an on-demand or commuter (Part 135) operator, the required positions are in §119.69 and the qualifications are in §119.71. This is a common citation error — when you reference the DO or Chief Pilot requirement for a Part 135 operator, you are always in the §119.69 / §119.71 pair.
The rule gives you the what (two required positions) and §119.71 gives you the who (the qualifications). What it does not lay out as a tidy comparison is the practical division of labor — which is what this article does. For the full qualification standard behind both roles, see our required management personnel qualifications guide, and for the surrounding framework, the FAA aviation compliance hub.
Why Getting the Split Right Is a Certificate-Level Issue
These are not internal job titles the operator invented — they are FAA-accepted required positions reflected in the certificate holder's management structure and Operations Specifications. That has a direct consequence: the areas each role administers are exactly the areas a principal inspector examines during surveillance. When the FAA asks “is this pilot current and qualified to fly this trip,” the answer comes out of the Chief Pilot's function. When the FAA asks “is this operation being controlled, scheduled, and run within its authorizations,” that lands on the Director of Operations' function.
Blurring the two roles — or assuming one title quietly covers the other — is how operators end up with gaps that surface at the worst possible time. An operator that knows precisely which role owns which obligation, and can produce the records to match, is in a fundamentally different posture during a certification or surveillance event than one reconstructing accountability after an inspector has already asked. And because both positions are required, a vacancy in either one is itself a compliance exposure: the operator must notify the FAA within 10 days under §119.69(e), and operating without a qualified, accepted person in a required position is a finding.
The one distinction that resolves most confusion
Operational control itself rests with the certificate holder; the DO is the management position most associated with administering it, which is exactly why the §119.71(a)/(b) qualification standard for the DO centers on supervisory or managerial experience exercising operational control. The Chief Pilot's §119.71(c)/(d) standard, by contrast, centers on recent pilot-in-command experience — because the role is about the flying. For the duty-level detail on each side, see the Chief Pilot duties guide and how to become a Part 135 Director of Operations.
Not sure which role owns a given record — or whether either function has a gap? Run the free readiness check.
Check FAA Readiness ScoreDirector of Operations vs. Chief Pilot — Side by Side
The two positions are easy to confuse because both are management pilots and, in small operators, can be the same person. But the FAA defines them around different functions and applies different qualification standards. The table below is the cleanest way to hold the distinction.
| Dimension | Director of Operations | Chief Pilot |
|---|---|---|
| Core focus | Overall conduct and operational direction of flight operations | Crewmember standards and the way flights are flown |
| Operational control | The position most associated with administering it (control rests with the certificate holder) | Does not hold operational control — administers flight standards |
| Day-to-day work | Operational-control administration, scheduling and flight-following oversight, operational policy | Pilot training and checking, crew currency, standardization, the pilot manual |
| Qualification rule | §119.71(a)/(b) — supervisory/operational-control experience (≈3 yrs in the past 6) | §119.71(c)/(d) — recent pilot-in-command experience (≈3 yrs in the past 6) |
| Certificate generally needed | ATP (§119.71(a)) or commercial (§119.71(b)), per the operation | ATP (§119.71(c)) or commercial + instrument (§119.71(d)), per the operation |
| Typical reporting | Senior operational position; crews/Chief Pilot fall under the DO’s direction | Generally under the operational direction of the Director of Operations |
| Inspector’s lens | Is the operation controlled, scheduled, and run within authority? | Are crews trained, qualified, current, and standardized? |
| Records owned | Operational-control / scheduling documentation, OpSpecs conformance, operational policy | Training, checking, currency, certificates/medicals, pilot manual sections |
The qualification standards in one breath
Both standards generally call for the appropriate pilot certificate plus roughly 3 years of relevant experience within the past 6 years — but the kind of experience differs. For the Director of Operations (§119.71(a)/(b)), it is supervisory or managerial experience exercising operational control over Part 121/135 operations (with a PIC pathway in the alternative). For the Chief Pilot (§119.71(c)/(d)), it is experience as pilot in command under Part 121/135, with qualification as PIC in at least one aircraft used in the operation. A person who previously held the same role for a Part 121/135 certificate holder is relieved of the 6-year recency window. We break down each standard in the qualifications guide.
A note on pay (a top search question)
Compensation for both roles varies widely with aircraft type, fleet size, region, and whether the person also flies the line. As public-market references, ZipRecruiter data (June 2026) for FAA Part 135 Director of Operations roles in the U.S. shows most salaries between roughly $75,500 and $135,500 per year (average around $108,000), while 135 Chief Pilot roles show most salaries between roughly $122,000 and $207,000 per year (average around $163,000), with top earners near $228,000. Treat these as broad, date-stamped ranges, not targets — and note that FileFlo is a compliance-records tool, not a salary, hiring, or career-advice service. For more, see the Part 135 management salary guide.
Can each role prove its records are current — today?
FileFlo classifies and indexes the records that sit under both management positions — the Chief Pilot's training, checking, currency, certificate and medical records, and the operational-control and appointment documentation tied to the Director of Operations — and tracks expirations so a lapsed check or a stale appointment surfaces before an inspector finds it. Starter at $89/mo, Professional at $299/mo. 5-day free trial, no credit card required.
Can One Person Be Both the DO and the Chief Pilot?
This is the single most-asked question about Part 135 management roles, and the honest answer is: sometimes — but it is an FAA-authorized structure, not a default and not a self-declared shortcut. The starting point under §119.69(a) is three distinct required positions: Director of Operations, Chief Pilot, and Director of Maintenance. Consolidating titles in one or two people is a deviation.
The default is three distinct positions
Under §119.69(a), a multi-pilot certificate holder must have qualified people serving as Director of Operations, Chief Pilot, and Director of Maintenance. A true single-pilot operator is the one stated exception to needing all three.
Combining roles requires an FAA-authorized deviation
Under §119.69(b), the Administrator may authorize a deviation — a different number or different categories of management positions — if the operator shows it can perform the operation safely under the direction of fewer or different personnel, judged against the kind of operation, the number and type of aircraft, and the area of operations. Combining the DO and Chief Pilot is exactly that kind of deviation.
The person must meet each role’s §119.71 standard independently
Even with one person holding both titles, that individual must separately satisfy the Director of Operations qualifications in §119.71(a)/(b) and the Chief Pilot qualifications in §119.71(c)/(d). Meeting one standard does not confer the other — the experience requirements are different.
Both sets of duties still have to be performed
Consolidating the titles does not consolidate the work. The operational-control administration and the crew-standards administration both still have to happen, and the records that prove each function still have to exist. Practically, this makes the records discipline harder for a small operator, not easier.
You will also see this framed around certificate type. Operators sometimes describe a “Basic” Part 135 structure that consolidates management roles versus a “Standard” structure with separate positions; those labels describe operational categories and the management arrangement the FAA has accepted for a given operator, all still flowing from the §119.69 / §119.71 framework. The regulation does not hand out a one-size org chart — it requires the functions and qualifications, and accepts a management structure for each operator. For the certificate-category angle, see Part 135 certificate types (single-pilot, basic, standard) and the consolidated-role mechanics in one person, multiple roles.
Don't forget the Director of Maintenance
The DO-vs-Chief-Pilot comparison is about the two management pilots, but §119.69(a) requires a third position: the Director of Maintenance, who owns airworthiness and the maintenance record set, with its own qualification standard in §119.71(e) (a mechanic certificate with airframe and powerplant ratings plus the required experience). It is a different discipline entirely. See the Director of Maintenance responsibilities guide.
The Records Each Role Owns
The cleanest way an operator can prove the split is correct — and that both functions are actually being performed — is the documentary record. During surveillance, each role's function is judged by whether its records are complete and retrievable. Below are the record sets that sit under each position and how a document-intelligence layer keeps them audit-ready. FileFlo does not fly, train, schedule, control, or qualify anyone — it keeps the documentary proof each role is responsible for.
Director of Operations owns
Operational-control / scheduling documentation
The records showing how operational control is administered, how trips are released and tracked, and that the operation runs within its authorizations.
Operations Specifications conformance
Evidence that the operation conducted matches the OpSpecs the FAA issued — the kinds of operations, areas, and limitations authorized.
Operational policy / GOM operational sections
The current, accepted operational policies and the operations-management portions of the manual that direct how the operation is run.
DO appointment / FAA acceptance & §119.69(e) trail
The record that the FAA has accepted the individual in the required Director of Operations position, plus the change/vacancy notification trail.
Chief Pilot owns
Pilot training & checking records
Initial, transition, recurrent, and requalification training plus proficiency/competency checks and line checks for each crewmember.
Crew currency & recent-experience tracking
The live currency picture — recent experience, instrument currency where required, SIC currency where applicable — that determines trip eligibility.
Pilot certificate & medical copies
Each pilot’s certificate and ratings and a current medical of the appropriate class; a lapsed medical can ground a pilot immediately.
Pilot manual sections & CP appointment
The current, accepted crew-facing manual sections, plus the FAA-acceptance record for the Chief Pilot position and its §119.69(e) trail.
How FileFlo keeps both sets audit-ready
Related guides: Part 135 pilot records · Training program recordkeeping · Single-pilot operator records · Records master index · Management vacancy & FAA notification
FileFlo is the proof layer, not the operational, training, or HR system
FileFlo is a compliance document intelligence platform — it classifies, indexes, and tracks the records both management positions own, and surfaces expirations and gaps. It is not a dispatch system, a flight operations management system (FOS), a training-management system, or a crew-scheduling system, and it does not hire, place, recruit, train, or qualify people — the operator and the FAA do that. FileFlo keeps the documentary proof audit-ready alongside whatever operational and training systems you run.
A third management dimension is arriving: the safety program
Beyond the DO and Chief Pilot, the FAA's Safety Management System (SMS) rule extends formal SMS to Part 135 operators, with a single compliance date of May 28, 2027. SMS introduces accountable-executive and safety-management responsibilities that sit alongside — not inside — the DO and Chief Pilot roles, and generates its own document set. See the Part 135 SMS 2027 deadline, the SMS requirements overview, and the Director of Safety position.
Frequently Asked Questions
What is the difference between a Director of Operations and a Chief Pilot in a Part 135 operation?
Both are required management positions under 14 CFR §119.69(a), but they govern different things. The Director of Operations (DO) is the management official responsible for the overall conduct and operational direction of flight operations — operational control administration, scheduling and flight-following oversight, operational policy, and the operation as a whole. The Chief Pilot is the management pilot responsible for crewmember standards and the way flights are actually flown — pilot training and checking, crew currency and qualifications, standardization, and the pilot-facing portions of the operations manual. In short: the DO is accountable for the operation; the Chief Pilot is accountable for the pilots and the flying standard. They also carry different FAA qualification standards under §119.71 — the DO standard centers on supervisory/operational-control experience, the Chief Pilot standard on recent pilot-in-command experience.
Does a Part 135 operator need both a Director of Operations and a Chief Pilot?
Yes, with one stated exception. Under 14 CFR §119.69(a), each Part 135 certificate holder must have qualified personnel serving as a Director of Operations, a Chief Pilot, and a Director of Maintenance — except a certificate holder using only one pilot in its operations. So a true single-pilot operator is the carve-out. Separately, §119.69(b) lets the Administrator authorize a deviation — a different number or different categories of positions — if the operator shows it can perform the operation safely under the direction of fewer or different management personnel, judged against the kind of operation, the number and type of aircraft, and the area of operations. For most multi-pilot on-demand and commuter operators, both a DO and a Chief Pilot are required, FAA-accepted positions.
Can one person be both the Director of Operations and the Chief Pilot on a Part 135 certificate?
It can happen, but it is not automatic and it is not self-declared. The default under §119.69(a) is three distinct required positions. Combining the DO and Chief Pilot titles in one person is a deviation the operator must request and the FAA must authorize under §119.69(b) — it is judged on whether the operation can be conducted safely with that structure. Critically, even when one person holds both titles, that person must independently meet the qualification standard for each role under §119.71 (the DO standard in §119.71(a)/(b) and the Chief Pilot standard in §119.71(c)/(d)), and the duties of both roles still have to be performed. Many small operators do consolidate management titles; the point is that consolidation is an FAA-authorized structure, not a shortcut.
What are the qualification requirements for a Part 135 Director of Operations vs. a Chief Pilot?
They are set in 14 CFR §119.71 — not §119.65, which is the Part 121 section. For the Director of Operations, §119.71(a) (operations requiring an ATP) and §119.71(b) (operations requiring only a commercial certificate) require the appropriate pilot certificate plus, in general, at least 3 years of supervisory or managerial experience within the past 6 years exercising operational control over Part 121 or 135 operations — with a pilot-in-command experience pathway in the alternative. For the Chief Pilot, §119.71(c) (ATP operations) and §119.71(d) (commercial operations) require the appropriate certificate with the ratings to act as pilot in command in the operation, qualification as PIC in at least one aircraft used, and at least 3 years of experience within the past 6 years as pilot in command under Part 121 or 135. A person who previously held the same role for a Part 121/135 certificate holder is relieved of the 6-year recency window. The DO standard is about operational-control management; the Chief Pilot standard is about recent line-flying command.
Who does the Chief Pilot report to in a Part 135 operation?
In the typical Part 135 management structure, the Chief Pilot and the operating crewmembers fall under the operational direction of the Director of Operations, who is the management official responsible for the overall conduct of flight operations. The Director of Operations is generally the higher-level operational position, and crew-standards activity the Chief Pilot administers feeds into the DO's responsibility for the operation as a whole. That said, the exact reporting lines are described in the certificate holder's management structure and General Operations Manual, and in small operators the two roles may be held by the same person or by two people who coordinate as peers. The regulation requires both positions and defines their qualifications; it does not prescribe a single org chart for every operator.
Does the Director of Operations or the Chief Pilot hold operational control?
Operational control — the authority over initiating, conducting, or terminating a flight — rests with the certificate holder. The Director of Operations is the management position most associated with administering that operational-control authority on the certificate holder's behalf, which is why the §119.71(a)/(b) qualification standard centers on supervisory/managerial experience exercising operational control. The Chief Pilot administers flight standards — how crews are trained, checked, kept current, and standardized — but does not hold operational control. This is one of the cleanest ways to separate the two roles: the DO is associated with controlling the operation, while the Chief Pilot owns the standard the pilots fly to.
How does the FAA hold the Director of Operations and Chief Pilot accountable, and what happens if one position is vacant?
Both are FAA-accepted required management positions reflected in the certificate holder's management structure and Operations Specifications, so the areas each one administers are exactly what a principal inspector examines during surveillance. A principal operations inspector looks to the Chief Pilot's function for crew qualification, currency, training and checking records, and standardization; the Director of Operations' function is examined for whether the operation is controlled, scheduled, and run within the operator's authorizations. If either position becomes vacant, the certificate holder must notify the responsible Flight Standards office within 10 days of the change or vacancy under §119.69(e). The rule allows continued operation while a vacancy is filled only to the extent the FAA authorizes a deviation under §119.69(b); operating without a qualified, accepted person in a required position is itself a finding.
What are the salary ranges for a Part 135 Director of Operations vs. a Chief Pilot?
Compensation for both roles varies widely by aircraft type, fleet size, region, and whether the person also flies the line, so treat any figure as a broad, date-stamped range rather than a target. As public-market references, ZipRecruiter data (June 2026) for FAA Part 135 Director of Operations roles in the United States shows most salaries between roughly $75,500 and $135,500 per year (average around $108,000), while 135 Chief Pilot roles show most salaries between roughly $122,000 and $207,000 per year (average around $163,000), with top earners near $228,000. The two roles are genuinely different jobs, and a small piston/turboprop operator and a large jet-fleet operator compensate very differently. FileFlo does not provide salary, hiring, or career advice — we track the qualification and currency records each role owns.
Keep your management-personnel records current and provable
Whichever way your operator divides the Director of Operations and Chief Pilot roles — two people or one — FileFlo classifies and indexes the qualification, training, currency, and appointment records each role owns, against the governing requirements, with expiration and vacancy alerts and a one-click POI surveillance binder. AI document classification. 600+ document types. Starter at $89/mo, Professional at $299/mo. No credit card required for the 5-day free trial.
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Reviewed by Chad Griffith, Founder, FileFlo — compliance document intelligence. June 15, 2026. Regulatory citations verified against Cornell LII (14 CFR §119.69 and §119.71) as of publication date; salary figures cite ZipRecruiter (June 2026) as dated ranges. This article is educational and is not legal, career, or HR advice.