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Aviation Compliance Education — FAA Part 135

How to Become a Part 135 Director of OperationsThe Experience Path and What the FAA Requires

There is no standalone “Director of Operations certificate” from the FAA. Becoming a Part 135 DO 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 experience that qualifies you, the pilot certificate the operation demands, 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 Director of Operations 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 Director of Operations

Direct Answer

There is no separate FAA “Director of Operations certificate.” You become a Part 135 DO by meeting the qualification standard in 14 CFR §119.71(a)/(b) 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 for operations requiring an ATP (§119.71(a)), or at least a commercial pilot certificate for operations requiring only a commercial certificate (§119.71(b)). The experience is one of two paths: 3 years of supervisory or managerial experience within the last 6 years in a position that exercised operational control over Part 121 or Part 135 operations, or 3 years as pilot in command within the past 6 years of Part 121 or Part 135 aircraft. A person who has previously served as a DO can use the pilot-in-command path 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(a)/(b)
Sets the DO certificate-plus-experience qualification standard
14 CFR §119.71
3 years
Of operational-control OR pilot-in-command experience (within the past 6)
14 CFR §119.71(a)/(b)
§119.69(a)
Makes Director of Operations a required Part 135 management position
14 CFR §119.69(a)

If you are aiming for the Director of Operations seat at a charter or on-demand operator, this is the most useful framing: the FAA does not issue you a DO 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 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.

What the FAA Rule Actually Requires

Two regulations define the Director of Operations. 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 DO 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 DO 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 DO. 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. 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 DO 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 Director of Operations standard splits by the kind of operation the certificate holder conducts:

§119.71(a)Operations requiring an ATP certificate

To serve as Director of Operations 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 and either: (1) have at least 3 years supervisory or managerial experience within the last 6 years in a position that exercised operational control over any operations conducted under Part 121 or Part 135; or (2) for a person becoming DO 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 DO experience needs 3 years as PIC without the 6-year window).

§119.71(b)Operations requiring only a commercial certificate

To serve as Director of Operations 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 and meet the same experience structure: (1) 3 years supervisory or managerial experience within the last 6 years exercising operational control over Part 121 or Part 135 operations; or (2) 3 years as pilot in command within the past 6 years of Part 121 or Part 135 aircraft (first-time DO), or 3 years as PIC without the 6-year window for a person with prior DO experience.

Read the two paths carefully: the experience bar is 3 years either way, and you can clear it through the management route (operational control) or the pilot route (pilot in command). The certificate, not the experience, is what scales with the operation. 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 DO is qualified — on demand?

FileFlo classifies and indexes the documents that establish a Director of Operations is qualified and accepted — pilot certificate, the experience record 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 Experience Path — How Candidates Actually Get There

The regulation gives you the destination. The route there is a career progression that ends with one of the two §119.71 paths 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(a)/(b), and your FAA principal operations inspector is the authority on whether your specific background meets it.

Path A — the management route

Build 3 years of supervisory or managerial experience, within the last 6 years, in a position that exercised operational control over Part 121 or Part 135 operations. In practice this means time in roles like assistant DO, operations manager, or operational-control/dispatch leadership at a certificated operator — work where you held real authority over initiating, conducting, or terminating flights, not just an administrative title.

Path B — the pilot-in-command route

Build 3 years of experience, within the past 6 years, as pilot in command of aircraft operated under Part 121 or Part 135. This is the path many line captains take into management: the recent, documented PIC time at a certificated operator is itself the qualifying experience for a first-time DO under §119.71(a)(2)/(b)(2).

Hold the right certificate

Match your pilot certificate to the operation: an ATP for an operation that requires an ATP (§119.71(a)), or at least a commercial pilot certificate for an operation that only requires a commercial certificate (§119.71(b)). The certificate scales to the operation the certificate holder runs — a higher-demand operation requires a higher-certificate DO.

Returning DO advantage

If you have previously served as a Director of Operations for a Part 121 or 135 certificate holder, the PIC path drops the 6-year recency window — §119.71(a)(2)(ii) and (b)(2)(ii) require 3 years as PIC of Part 121/135 aircraft without the "within the past 6 years" limit. Prior DO experience is recognized in the rule itself.

What the rule does — and does not — pin down

It does set a 3-year experience minimum and frames it as operational-control or pilot-in-command time over a stated period.
It does scale the required pilot certificate (ATP vs. commercial) to the kind of operation.
It does NOT specify a raw total flight-hour number for the DO position the way pilot-certificate rules do — the qualifying experience is the operational-control or 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 more decision shapes the path: at small operators, the DO is sometimes the same person as the Chief Pilot. That is an FAA-accepted consolidation under §119.69(b), and the individual must independently meet both qualification standards (the DO standard in §119.71(a)/(b) and the Chief Pilot standard in §119.71(c)/(d)). If you are eyeing a small-operator role, expect the question of whether you can clear more than one bar. We cover the consolidated structure in Part 135 management with one person in multiple roles and the role split in Director of Operations vs. Chief Pilot.

How FAA Acceptance Into the DO Position Works

Meeting §119.71 makes you eligible. You actually become a Part 135 Director of Operations 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 DO 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

The inspector reviews whether you meet the applicable §119.71(a) or (b) standard — the right pilot certificate for the operation and one of the two experience paths. This is where your documentation matters: certificate copies, and a clear, dated record of the operational-control or pilot-in-command experience that satisfies the 3-year requirement.

3

You are reflected as the accepted DO

Once accepted, you are the operator’s Director of Operations 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 DO — 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 DO 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 DO appointment — beyond the qualifying experience itself — is the evidence of it, organized and ready. A POI accepting you wants to see the certificate and the experience record 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 DO 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 hiring side of the same event, see how to hire a Part 135 Director of Operations.

A note on DO pay (a top search question)

Director of Operations 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 FAA Part 135 Director of Operations roles in the U.S. shows most salaries between roughly $75,500 (25th percentile) and $135,500 (75th percentile), with an average near $107,680 per year and top-of-market listings reaching the low $160,000s. Treat that as a broad, date-stamped range, not a target — and note that FileFlo is a compliance-records tool, not a salary, hiring, recruiting, or career-advice service. We compare DO, Chief Pilot, and DOM pay in our Part 135 management salaries guide.

The Records That Document a DO 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 Director of Operations 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 DO appointment.

Pilot Certificate & Ratings

14 CFR §119.71(a)/(b) · Part 61

What it proves

The DO’s airline transport pilot or commercial pilot certificate — the certificate that must match the kind of operation the certificate holder conducts. 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.

Qualifying Experience Record

14 CFR §119.71(a)/(b) experience path

What it proves

The dated evidence behind the 3-year requirement — either the operational-control/management experience within the last 6 years, or the pilot-in-command experience within the past 6 years at a Part 121 or 135 operator.

How FileFlo tracks it

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

DO Appointment / FAA Acceptance

14 CFR §119.69(c) · OpSpecs

What it proves

The record that the FAA has accepted the individual into the required Director of Operations 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 — DO Duties Section

14 CFR §119.69 · General Operations Manual

What it proves

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

How FileFlo tracks it

FileFlo indexes the manual and its revisions so the operator can show the DO’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 DO 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 DO’s qualification package, so a management transition leaves a clean record.

Related guides: Management personnel qualifications (§119.71) · Part 135 pilot records · Records master index · First 100 days as DO/Chief Pilot

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 Director of Operations appointment — certificate, 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 DO; FileFlo keeps the documentary proof audit-ready.

Frequently Asked Questions

How do you become a Part 135 Director of Operations?

You become a Part 135 Director of Operations by being appointed to the position by a certificate holder and meeting the qualification standard in 14 CFR §119.71(a) or (b). The position itself is required under §119.69(a). There is no separate FAA "DO certificate" — instead the rule sets a certificate-plus-experience bar: the right pilot certificate for the kind of operation (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) plus one of two experience paths — 3 years of supervisory or managerial experience within the last 6 years in a position that exercised operational control over Part 121 or Part 135 operations, or 3 years of pilot-in-command experience within the past 6 years in aircraft operated under Part 121 or Part 135. The operator then proposes you to its FAA principal operations inspector, who accepts you into the position.

What are the Part 135 Director of Operations requirements under the FAA rules?

The requirements come from two regulations. 14 CFR §119.69(a) makes Director of Operations a required management position for any Part 135 operator that uses more than one pilot. 14 CFR §119.71(a)/(b) sets the qualifications: the appropriate pilot certificate for the operation (ATP for operations requiring an ATP under §119.71(a); at least a commercial pilot certificate for operations requiring only a commercial certificate under §119.71(b)), plus the experience standard — 3 years of supervisory or managerial experience within the last 6 years exercising operational control over Part 121 or Part 135 operations, OR 3 years as pilot in command within the past 6 years of Part 121 or Part 135 aircraft. A person who has previously served as a Director of Operations can satisfy the PIC path without the 6-year recency window. Note: the Part 135 sections are §119.69 and §119.71 — §119.65 is the Part 121 management section.

How much experience do you need to be a Part 135 Director of Operations?

Three years, under both qualification paths in 14 CFR §119.71(a)/(b). You either show 3 years of supervisory or managerial experience within the last 6 years in a position that exercised operational control over Part 121 or Part 135 operations, or 3 years of pilot-in-command experience within the past 6 years in aircraft operated under Part 121 or Part 135. The first-time-ever DO must meet the 6-year recency window; a person who has previously held the DO role can use the pilot-in-command path without that window. The regulation does not specify a minimum total flight-hour number for the DO position the way pilot-certificate rules do — the qualifying experience is framed as operational-control or pilot-in-command time over the stated period, not a raw hour count.

What pilot certificate does a Part 135 Director of Operations need?

It depends on the kind of operation the certificate holder conducts. Under 14 CFR §119.71(a), if the operation is one for which the pilot in command is required to hold an airline transport pilot (ATP) certificate, the Director of Operations must hold an ATP certificate. Under §119.71(b), if the certificate holder only conducts operations for which the pilot in command is required to hold a commercial pilot certificate, the Director of Operations must hold at least a commercial pilot certificate. In short, the DO's certificate has to match the operational demands of the certificate the operator holds — a higher-certificate operation requires a higher-certificate DO.

Does a Part 135 Director of Operations have to be a pilot?

Effectively yes, in terms of certification. Both qualification paths in 14 CFR §119.71(a) and (b) require the person to hold a pilot certificate — an airline transport pilot certificate for operations requiring an ATP, or at least a commercial pilot certificate for operations requiring only a commercial certificate. The experience path can be satisfied through management/operational-control experience rather than recent line flying, so a DO does not necessarily have to be an actively flying line pilot, but the certificate requirement means the person holds the relevant pilot certificate. The position is a management role responsible for the conduct and operational direction of flight operations, not a flying assignment.

Can the Director of Operations also be the Chief Pilot 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 DO and Chief Pilot 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 DO standard in §119.71(a)/(b) and the Chief Pilot standard in §119.71(c)/(d). Small operators do consolidate titles; the point is that it is an FAA-accepted structure, not a self-declared shortcut.

What does a Part 135 Director of Operations do?

The Director of Operations is the management official responsible for the overall conduct and operational direction of the certificate holder's flight operations. In practice that means administering operational control on behalf of the certificate holder, overseeing scheduling and flight-following/dispatch, setting and enforcing operational policy, ensuring the operation runs within its Operations Specifications, and being the management point of contact the FAA holds accountable for how the operation is run. The DO is distinct from the Chief Pilot, who owns crewmember standards and the way flights are flown. We compare the two positions in detail in a separate guide. The DO role is also where the operator's operational-control discipline — and the records that prove it — lives.

What is the salary range for a Part 135 Director of Operations?

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 FAA Part 135 Director of Operations roles in the United States shows most salaries between roughly $75,500 (25th percentile) and $135,500 (75th percentile), with an average around $107,680 per year and top-of-market listings reaching the low $160,000s. Treat these as a broad, date-stamped range rather than a target — a DO at a small single-aircraft on-demand operator and one at a multi-aircraft jet operation are very different jobs. 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 Director of Operations seat or running the operator that appoints one, FileFlo classifies and indexes the records that document the appointment — pilot certificate, the §119.71 qualifying-experience evidence, 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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