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Aviation Compliance Education — FAA Part 135

How to Become a Part 135 Chief PilotThe Certificate, Experience, and FAA Qualification Path

There is no standalone “Chief Pilot certificate” from the FAA. Becoming a Part 135 Chief Pilot means clearing a specific certificate-plus-experience bar in 14 CFR §119.71 and being accepted into a required management position. This is the practical map: the pilot certificate the operation demands, the pilot-in-command experience that qualifies you, how FAA acceptance works, and the records that document the appointment.

Chad Griffith, Founder, FileFloLast reviewed: June 15, 202613 min read

Compliance document perspective — not legal, career, or HR advice. This article explains the regulatory framework and the document requirements tied to the Part 135 Chief Pilot position. It is not a substitute for an aviation attorney, your FAA principal inspectors, or professional career counsel for any specific question.

HomeBlogAviation ComplianceHow to Become a Part 135 Chief Pilot

Direct Answer

There is no separate FAA “Chief Pilot certificate.” You become a Part 135 Chief Pilot by meeting the qualification standard in 14 CFR §119.71(c)/(d) and being accepted by the FAA into the required position under §119.69(a).

The bar is a certificate plus experience. The certificate scales to the operation: an airline transport pilot (ATP) certificate with appropriate ratings for operations requiring an ATP (§119.71(c)), or at least a commercial pilot certificate for operations requiring only a commercial certificate (§119.71(d)) — plus an instrument rating if any pilot in command for that operator must hold one. You must also be qualified to serve as pilot in command in an operation conducted by the certificate holder. The experience is 3 years as pilot in command within the past 6 years in aircraft operated under Part 121 or Part 135. A person who has previously served as a Chief Pilot can meet the PIC requirement without the 6-year recency window.

The Part 135 sections are §119.69 and §119.71 — not §119.65, which is the Part 121 management section. This guide is the career-path view; for the precise qualification standard line by line, see our required management personnel qualifications guide.

§119.71(c)/(d)
Sets the Chief Pilot certificate-plus-experience qualification standard
14 CFR §119.71
3 years PIC
Of pilot-in-command experience within the past 6 years (Part 121/135)
14 CFR §119.71(c)/(d)
§119.69(a)
Makes Chief Pilot a required Part 135 management position
14 CFR §119.69(a)

If you are aiming for the Chief Pilot seat at a charter or on-demand operator, this is the most useful framing: the FAA does not issue you a Chief Pilot credential. It defines a position the operator must fill (§119.69), defines who is qualified to fill it (§119.71), and then accepts a specific named individual into the role. Your job as a candidate is to build the qualifying pilot-in-command experience and the documentation that proves it; the operator's job is to propose you to its principal operations inspector. The sections below walk both halves — and how the Chief Pilot role differs from the Director of Operations it sits alongside.

What the FAA Rule Actually Requires

Two regulations define the Chief Pilot. The first creates the position; the second sets who can hold it.

§119.69 — the position is required

14 CFR §119.69 is titled “Management personnel required for operations conducted under part 135 of this chapter.” Subsection (a) states that each certificate holder must have sufficient qualified management and technical personnel to ensure the safety of its operations, and that — except for a certificate holder using only one pilot in its operations — the certificate holder must have qualified personnel serving in (or equivalent to) the positions of Director of Operations, Chief Pilot, and Director of Maintenance. So the Chief Pilot is a mandatory position for any multi-pilot Part 135 operator.

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 live in §119.69 and the qualifications live in §119.71. Citing §119.65 for a Part 135 Chief Pilot is a common error — and an easy way for an inspector or an attorney to discount the rest of your paperwork.

Two more parts of §119.69 matter to a prospective Chief Pilot. Subsection (b) lets the Administrator approve different positions or numbers of positions if the operator shows it can perform the operation with the highest degree of safety under fewer or different categories of management personnel — judged against (1) the kind of operation, (2) the number and type of aircraft, and (3) the area of operations. That is the mechanism behind consolidated roles at small operators (for example, a single person holding both the Chief Pilot and Director of Operations titles). And subsection (c) requires the titles of these positions to be set forth in the certificate holder's Operations Specifications — which is why your acceptance into the Chief Pilot seat is a documented, OpSpecs-level event, not an internal HR title.

§119.71 — who is qualified to hold it

14 CFR §119.71 sets the qualifications. The Chief Pilot standard lives in subsections (c) and (d), and it splits by the kind of operation the certificate holder conducts:

§119.71(c)Operations requiring an ATP certificate

To serve as Chief Pilot under §119.69(a) for a certificate holder conducting any operations for which the pilot in command is required to hold an airline transport pilot certificate, a person must hold an ATP certificate with appropriate ratings, hold an instrument rating if an instrument rating is required for any pilot in command for that certificate holder, be qualified to serve as pilot in command in an operation conducted by the certificate holder, and — for a person becoming Chief Pilot for the first time ever — have at least 3 years experience, within the past 6 years, as pilot in command of an aircraft operated under Part 121 or Part 135 (a person with previous Chief Pilot experience needs 3 years as PIC without the 6-year window).

§119.71(d)Operations requiring only a commercial certificate

To serve as Chief Pilot for a certificate holder that only conducts operations for which the pilot in command is required to hold a commercial pilot certificate, a person must hold at least a commercial pilot certificate, hold an instrument rating if an instrument rating is required for any pilot in command for that certificate holder, be qualified to serve as pilot in command in an operation conducted by the certificate holder, and meet the same experience structure: for a first-time Chief Pilot, 3 years experience within the past 6 years as pilot in command of a Part 121 or Part 135 aircraft; for a person with prior Chief Pilot experience, 3 years as PIC without the 6-year window.

Read the two paths carefully: the experience bar is 3 years of pilot-in-command time either way, and what scales with the operation is the certificate (ATP vs. commercial) and whether an instrument rating is required. Unlike the Director of Operations standard in §119.71(a)/(b) — which lets you qualify through management/operational-control experience or PIC time — the Chief Pilot standard is built specifically around recent pilot-in-command experience. For the full text of every position's standard — DO, Chief Pilot, and Director of Maintenance — see our Part 135 required management personnel qualifications guide, which is the qualifications reference this career-path article points back to.

Can your operator prove its Chief Pilot is qualified — on demand?

FileFlo classifies and indexes the documents that establish a Chief Pilot is qualified and accepted — pilot certificate and ratings, the recent pilot-in-command experience behind the §119.71 path, and the appointment/OpSpecs acceptance — and tracks them so the package is complete before an inspector asks. Starter at $89/mo, Professional at $299/mo. 5-day free trial, no credit card required.

The Certificate & Experience Path — How Candidates Actually Get There

The regulation gives you the destination. The route there is a career progression that ends with the §119.71(c)/(d) Chief Pilot standard satisfied. Below is the realistic shape of that progression for most candidates. This is context, not a regulatory checklist — the binding requirement is §119.71(c)/(d), and your FAA principal operations inspector is the authority on whether your specific background meets it.

Build recent PIC time at a certificated operator

The core of the Chief Pilot standard is 3 years experience, within the past 6 years, as pilot in command of aircraft operated under Part 121 or Part 135. This is the line many captains build naturally: recent, documented PIC time at a certificated operator is itself the qualifying experience for a first-time Chief Pilot under §119.71(c) or (d).

Hold the right certificate — and an instrument rating if required

Match your pilot certificate to the operation: an ATP with appropriate ratings for an operation that requires an ATP (§119.71(c)), or at least a commercial pilot certificate for an operation that only requires a commercial certificate (§119.71(d)). On the §119.71(d) commercial path, the Chief Pilot must hold an instrument rating if any PIC for that operator must hold one; an ATP under §119.71(c) already includes one.

Stay qualified to serve as PIC for the operator

Both §119.71(c) and (d) require the Chief Pilot to be qualified to serve as pilot in command in an operation conducted by the certificate holder. In practice that means staying current and qualified to the operator’s standards — checkrides, training, and currency that keep you PIC-eligible, not just a management title on paper.

Returning Chief Pilot advantage

If you have previously served as a Chief Pilot for a Part 121 or 135 certificate holder, the PIC requirement drops the 6-year recency window — the rule requires 3 years as PIC of Part 121/135 aircraft without the "within the past 6 years" limit. Prior Chief Pilot experience is recognized in the rule itself.

What the rule does — and does not — pin down

It does set a 3-year pilot-in-command experience minimum and frames it as recent PIC time at a Part 121 or Part 135 operator.
It does scale the required pilot certificate (ATP vs. commercial) to the kind of operation, and requires an instrument rating if any PIC for the operator must hold one.
It does require the Chief Pilot to be qualified to serve as pilot in command in an operation conducted by the certificate holder.
It does NOT specify a raw total flight-hour number for the Chief Pilot position the way pilot-certificate rules do — the qualifying experience is the PIC time, not an hour count.
It does NOT make the title self-declared — acceptance is an FAA, OpSpecs-level event under §119.69(c).

One decision shapes the path more than any other: the Chief Pilot is a different job from the Director of Operations, even though small operators sometimes put both in one person. The Chief Pilot owns crewmember standards and how flights are flown; the DO owns operational control and the overall direction of the operation. Where one person holds both titles, that is an FAA-accepted consolidation under §119.69(b), and the individual must independently meet both qualification standards (the Chief Pilot standard in §119.71(c)/(d) and the DO standard in §119.71(a)/(b)). We cover the role split in Director of Operations vs. Chief Pilot and the consolidated structure in Part 135 management with one person in multiple roles. For the day-to-day of the seat once you are in it, see Part 135 Chief Pilot duties and responsibilities.

How FAA Acceptance Into the Chief Pilot Position Works

Meeting §119.71(c)/(d) makes you eligible. You actually become a Part 135 Chief Pilot when a certificate holder appoints you and the FAA accepts you into the position. That happens through the operator, not through an individual application — there is no Chief Pilot test or rating to go take on your own.

1

The operator proposes you

The certificate holder identifies you for the position and submits your qualifications to its FAA principal operations inspector (POI). Because §119.69(c) requires the titles of these positions to appear in the operator’s Operations Specifications, your acceptance is reflected at the OpSpecs level — it is a documented change to the operator’s management structure.

2

The POI evaluates against §119.71(c)/(d)

The inspector reviews whether you meet the applicable §119.71(c) or (d) standard — the right pilot certificate and ratings for the operation, an instrument rating if any PIC must hold one, that you are qualified to serve as PIC for the operator, and the 3-year PIC experience requirement. This is where your documentation matters: certificate copies, currency/qualification records, and a clear, dated record of the pilot-in-command experience that satisfies the 3-year requirement.

3

You are reflected as the accepted Chief Pilot

Once accepted, you are the operator’s Chief Pilot of record, named in its management structure and OpSpecs. The operator must keep a current list of management personnel and maintain a record of the position’s duties, responsibilities, and authority in its operations manual.

4

Vacancies are time-sensitive

If a required management position — including the Chief Pilot — changes or becomes vacant, the operator must notify the responsible Flight Standards office within 10 days of the change or vacancy under §119.69(e). Operating without a qualified, accepted Chief Pilot is itself a compliance exposure, which is why a clean appointment-and-qualification record matters on day one.

The practical takeaway for a candidate: the strongest thing you can bring to a Chief Pilot appointment — beyond the qualifying experience itself — is the evidence of it, organized and ready. A POI accepting you wants to see the certificate, the currency/qualification record, and the PIC experience cleanly. An operator considering you wants to know the appointment will not get hung up in inspector review. And the operator's 10-day vacancy clock under §119.69(e) is a reminder that the Chief Pilot seat is one the FAA actively tracks. For how the vacancy and notification mechanics work, see notifying the FAA of a Part 135 management vacancy, and for the parallel path into the seat next door, see how to become a Part 135 Director of Operations.

A note on Chief Pilot pay (a top search question)

Chief Pilot compensation is one of the most-searched aspects of the role, and it varies widely with aircraft type, fleet size, region, and the scope of the operation. As a public-market reference, ZipRecruiter data (June 2026) for Chief Pilot roles in the U.S. shows most salaries between roughly $122,000 (25th percentile) and $207,000 (75th percentile), with a national average near $163,000 per year and top-of-market listings near $228,000 (90th percentile) and up to about $235,000. That national figure folds in corporate and airline chief-pilot roles outside Part 135, so treat it as a broad, date-stamped reference, not a target — and note that FileFlo is a compliance-records tool, not a salary, hiring, recruiting, or career-advice service. We compare Chief Pilot, DO, and DOM pay in our Part 135 management salaries guide.

The Records That Document a Chief Pilot Appointment

This is where FileFlo fits — and where it does not. FileFlo does not hire, recruit, place, or qualify anyone, and it does not give legal, career, or HR advice. What it does is classify, index, and track the documents that establish a Chief Pilot is qualified and accepted, so the package is complete and provable when an FAA principal operations inspector asks. Below are the record sets that sit under a Chief Pilot appointment.

Pilot Certificate & Ratings

14 CFR §119.71(c)/(d) · Part 61

What it proves

The Chief Pilot’s airline transport pilot or commercial pilot certificate with appropriate ratings — plus an instrument rating where any PIC for the operator must hold one. The certificate must match the kind of operation the certificate holder conducts; it is the eligibility floor for the position.

How FileFlo tracks it

FileFlo classifies the certificate as a document class, captures certificate level and ratings, and keeps it tied to the individual’s management appointment record.

PIC Qualification & Currency

14 CFR §119.71(c)/(d) · Part 135 training/checking

What it proves

The records that show the Chief Pilot is qualified to serve as pilot in command in an operation conducted by the certificate holder — checkrides, training, and currency that keep the Chief Pilot PIC-eligible to the operator’s standards.

How FileFlo tracks it

FileFlo tracks the underlying competency-check and currency documents with expiration dates, so the "qualified to serve as PIC" element of the standard is provable and not silently lapsed.

Qualifying PIC Experience Record

14 CFR §119.71(c)/(d) experience path

What it proves

The dated evidence behind the 3-year requirement — pilot-in-command experience, within the past 6 years, in aircraft operated under a Part 121 or Part 135 certificate holder (or the prior-Chief-Pilot path without the 6-year window).

How FileFlo tracks it

FileFlo indexes the supporting documents (prior-position letters, logbook summaries, employment records) so the experience that satisfies §119.71(c)/(d) is organized and retrievable rather than reconstructed during inspector review.

Chief Pilot Appointment / FAA Acceptance

14 CFR §119.69(c) · OpSpecs

What it proves

The record that the FAA has accepted the individual into the required Chief Pilot position, reflected in the certificate holder’s management structure and Operations Specifications.

How FileFlo tracks it

FileFlo stores the appointment and FAA-acceptance documentation with dates, tied to the qualification package for a complete, audit-ready chain.

Operations Manual — Chief Pilot Duties Section

14 CFR §119.69 · General Operations Manual

What it proves

The record of the Chief Pilot position’s duties, responsibilities, and authority that the operator is required to maintain, plus the current management-personnel list naming the Chief Pilot.

How FileFlo tracks it

FileFlo indexes the manual and its revisions so the operator can show the Chief Pilot’s documented authority and that the management-personnel list is current.

Vacancy / Change Notification Trail

14 CFR §119.69(e)

What it proves

The §119.69(e) notification record when the Chief Pilot position changes or becomes vacant — the 10-day notice to the responsible Flight Standards office and the documentation of the new appointee.

How FileFlo tracks it

FileFlo keeps the change-and-notification documentation dated and linked to the incoming Chief Pilot’s qualification package, so a management transition leaves a clean record.

Related guides: Management personnel qualifications (§119.71) · Chief Pilot duties & responsibilities · Part 135 pilot records · Training program recordkeeping · First 100 days as Chief Pilot/DO

FileFlo is the proof layer — it does not place or qualify candidates

FileFlo is a compliance document intelligence platform. It classifies, indexes, and tracks the records that document a Chief Pilot appointment — certificate and ratings, PIC qualification/currency, qualifying-experience evidence, FAA acceptance, and the manual/notification trail — and surfaces gaps and expirations. It does not hire, recruit, place, qualify, or certify anyone, it is not a dispatch or flight operations management system, and it does not provide legal, career, or HR advice. The FAA and the certificate holder qualify and accept the Chief Pilot; FileFlo keeps the documentary proof audit-ready.

Becoming a Chief Pilot vs. doing the job vs. the qualifications text

Three closely related questions, three different guides — so you land on the one that matches what you actually need:

This guide — the path in

The certificate, the recent-PIC experience, and FAA acceptance that get you into the Chief Pilot seat under §119.71(c)/(d).

The job itself

What the Chief Pilot actually does day to day — see Chief Pilot duties & responsibilities.

The qualifications text

The full §119.71 standard for all three positions — see the management personnel qualifications guide.

Frequently Asked Questions

How do you become a Part 135 Chief Pilot?

You become a Part 135 Chief Pilot by being appointed to the position by a certificate holder and meeting the qualification standard in 14 CFR §119.71(c) or (d). The position itself is required under §119.69(a). There is no separate FAA "Chief Pilot certificate" — the rule sets a certificate-plus-experience bar: the right pilot certificate for the kind of operation (an airline transport pilot certificate for operations that require an ATP, or at least a commercial pilot certificate for operations that only require a commercial certificate, with an instrument rating if any pilot in command for that operator must hold one), you must be qualified to serve as pilot in command in an operation conducted by the certificate holder, and you need 3 years of pilot-in-command experience within the past 6 years in aircraft operated under Part 121 or Part 135 (the 6-year window is dropped if you have previously been a Chief Pilot). The operator then proposes you to its FAA principal operations inspector, who accepts you into the position.

What are the Part 135 Chief Pilot requirements under the FAA rules?

The requirements come from two regulations. 14 CFR §119.69(a) makes Chief Pilot a required management position for any Part 135 operator that uses more than one pilot. 14 CFR §119.71(c)/(d) sets the qualifications: the appropriate pilot certificate for the operation (an airline transport pilot certificate for operations requiring an ATP under §119.71(c); at least a commercial pilot certificate for operations requiring only a commercial certificate under §119.71(d)), an instrument rating if an instrument rating is required for any pilot in command for that certificate holder, being qualified to serve as pilot in command in an operation conducted by the certificate holder, and 3 years of pilot-in-command experience within the past 6 years in aircraft operated under Part 121 or Part 135 (a person who has previously been a Chief Pilot can meet the PIC requirement without the 6-year window). Note: the Part 135 sections are §119.69 and §119.71 — §119.65 is the Part 121 management section.

What pilot certificate does a Part 135 Chief Pilot need?

It depends on the kind of operation the certificate holder conducts. Under 14 CFR §119.71(c), if the operation is one for which the pilot in command is required to hold an airline transport pilot (ATP) certificate, the Chief Pilot must hold an ATP certificate with appropriate ratings. Under §119.71(d), if the certificate holder only conducts operations for which the pilot in command is required to hold a commercial pilot certificate, the Chief Pilot must hold at least a commercial pilot certificate. On the commercial-certificate path (§119.71(d)), if an instrument rating is required for any pilot in command for that operator, the Chief Pilot must also hold an instrument rating; an ATP held under the §119.71(c) path already includes one. Either way, the Chief Pilot must be qualified to serve as pilot in command in an operation conducted by the certificate holder. The certificate scales with the operational demands of the certificate the operator holds.

How many hours or years of experience do you need to be a Part 135 Chief Pilot?

Three years, expressed as pilot-in-command time rather than a raw flight-hour number. Under both 14 CFR §119.71(c) and (d), a person becoming a Chief Pilot for the first time ever must have at least 3 years experience, within the past 6 years, as pilot in command of an aircraft operated under Part 121 or Part 135. A person who has previously served as a Chief Pilot meets the requirement with 3 years experience as pilot in command of a Part 121 or Part 135 aircraft, without the "within the past 6 years" window. The regulation frames the experience as recent PIC time at a certificated operator — it does not set a separate minimum total-flight-hour figure for the Chief Pilot position the way pilot-certificate rules do. Your FAA principal operations inspector is the authority on whether your specific background satisfies the standard.

Does a Part 135 Chief Pilot need an ATP, or is a commercial certificate enough?

Both are possible — it depends on the operation. Under 14 CFR §119.71(c), an operation that requires its pilot in command to hold an airline transport pilot certificate requires a Chief Pilot who holds an ATP certificate with appropriate ratings. Under §119.71(d), an operation that only requires its pilot in command to hold a commercial pilot certificate requires a Chief Pilot who holds at least a commercial pilot certificate. Many on-demand and commuter operators fall under the commercial-certificate path, so an ATP is not universally required for a Part 135 Chief Pilot. On the commercial-certificate path (§119.71(d)), if an instrument rating is required for any pilot in command for that operator, the Chief Pilot must also hold an instrument rating; the ATP required on the §119.71(c) path already includes one. The certificate floor is set by what the operator's operations demand of a pilot in command.

Can the Chief Pilot also be the Director of Operations on a Part 135 certificate?

Sometimes, but it is not automatic. The default under 14 CFR §119.69(a) is three distinct required positions — Director of Operations, Chief Pilot, and Director of Maintenance. Combining the Chief Pilot and DO titles in one person depends on the operator demonstrating, and the FAA accepting under §119.69(b), that it can conduct operations safely with fewer or different categories of management personnel given the kind of operation, the number and type of aircraft, and the area of operations. Even where the FAA accepts a consolidated structure, the individual must independently meet the qualification standard for each role they hold — the Chief Pilot standard in §119.71(c)/(d) and the DO standard in §119.71(a)/(b). Small operators do consolidate titles; the point is that it is an FAA-accepted structure, not a self-declared shortcut.

What is the difference between a Chief Pilot and a Director of Operations?

They are two distinct required positions with different domains. The Chief Pilot owns crewmember standards and the way flights are flown — the conduct of flight crewmembers, training and checking standards, and the operational standards pilots fly to. The Director of Operations owns the overall conduct and operational direction of the certificate holder's flight operations — operational control, scheduling, dispatch/flight-following, and operational policy. The qualification standards even differ slightly: the Chief Pilot standard in §119.71(c)/(d) is built entirely around recent pilot-in-command experience, while the DO standard in §119.71(a)/(b) lets you qualify through either operational-control/management experience or pilot-in-command time. They can be the same person at a small operator only through an FAA-accepted consolidation under §119.69(b). We compare the two positions in detail in a separate guide.

What is the salary range for a Part 135 Chief Pilot?

Compensation varies widely by aircraft type, fleet size, region, and the scope of the operation. As a public-market reference, ZipRecruiter data (June 2026) for Chief Pilot roles in the United States shows most salaries between roughly $122,000 (25th percentile) and $207,000 (75th percentile), with a national average near $163,000 per year and top-of-market listings near $228,000 (90th percentile) and up to about $235,000. Treat these as a broad, date-stamped range rather than a target — a Chief Pilot at a small single-aircraft on-demand operator and one at a multi-aircraft jet operation are very different jobs, and the figure folds in corporate and airline chief-pilot roles outside Part 135. FileFlo does not provide salary, hiring, recruiting, or career advice; we track the qualification and appointment records the role depends on.

Keep your management-personnel records current and provable

Whether you are stepping into a Chief Pilot seat or running the operator that appoints one, FileFlo classifies and indexes the records that document the appointment — pilot certificate and ratings, the §119.71(c)/(d) recent-PIC experience, PIC currency, FAA acceptance, and the §119.69(e) notification trail — 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 a dated range. This article is educational and is not legal, career, or HR advice.

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