To implement a Part 135 SMS, build the four components of 14 CFR Part 5 in dependency order, then operate the system and keep its records. The order that works: (1) designate your accountable executive and sign the safety policy; (2) build your safety risk management process; (3) stand up safety assurance, including a confidential employee reporting system; (4) deliver SMS training and safety communication; and (5) run the system, retain the records, and file your declaration of compliance with the FAA. Every existing Part 135 certificate holder must have this fully implemented by May 28, 2027 — one date, all operators, no fleet-size threshold (14 CFR §5.9). Single-pilot operations get a right-sized SMS, not a later deadline.
This is the pillar guide for the whole SMS topic. If you only have time for one thing first, read the FAA Part 135 SMS 2027 deadline explainer to understand exactly who is covered and by when. Then come back here for the build plan, and run a SMS gap analysis to see how far you already are.
Before you start: who is covered, by when, and what the FAA is actually checking
Part 121 air carriers have run SMS programs for years. The 2024 final rule extended the requirement to Part 135 on-demand and commuter operators, and it is the largest new compliance obligation the segment has faced in a generation. The governing regulation is 14 CFR Part 5, which sits separately from Part 135's operating rules — it is its own standalone framework, and the 2024 rule amended the Part 5 applicability section (§5.1) to cover Part 135 certificate holders and added the compliance dates in §5.9.
It is one deadline — May 28, 2027 — for everyone, with no aircraft-count threshold
Under 14 CFR §5.9(a), every operator authorized under Part 135 (or holding a §91.147 LOA) before May 28, 2024 must implement a compliant SMS no later than May 28, 2027. There is no phased schedule by fleet size and no “ten or more aircraft” cutoff. New applicants on or after May 28, 2024 must already have an SMS at application (§5.9(b)). Single-pilot operations are not on a later date — §5.9(e) exempts certain single-pilot organizations from specific requirements, scaling the SMS down, but the deadline is the same.
The single most important reframe before you build: SMS is not a safety program — it is the documented, operating system that proves you systematically manage safety, and the records are the proof. The FAA does not certify that your flights are safe; during surveillance it checks whether your documentation demonstrates a working process for identifying hazards, assessing risk, monitoring performance, and training people. An excellent operational record with no SMS evidence is still a finding. That is why the back half of this roadmap — operating the system and keeping the records — matters as much as the framework itself, and it is exactly the part most operators underestimate. (For the full FAA development methodology, see FAA guidance in Advisory Circular 120-92D and FAA Notice 8900.700.)
The 5-phase Part 135 SMS implementation roadmap
Part 5 organizes the SMS into four components, but you do not build them all at once — you build them in dependency order, because each one feeds the next. Policy sets the intent and the accountable executive; risk management finds and controls hazards; safety assurance verifies the controls work and surfaces new hazards; safety promotion makes sure everyone can run it; and the final phase is operating the system and capturing the evidence. Here is the order that works.
Phase 01 — Designate the accountable executive & write the safety policy
14 CFR §5.21 · §5.23 · §5.25Everything starts here because §5.21 requires the policy to be signed by a single accountable executive, and §5.23 defines who is accountable for safety across the organization.
What to do
- 1Name one accountable executive — under §5.25 this is the individual who controls the financial and human resources for the operation and retains ultimate responsibility for safety performance (typically the owner, CEO, or president, not the Director of Operations).
- 2Draft the safety policy: §5.21 requires your safety objectives, a safety reporting policy, a defined non-punitive disciplinary policy, an emergency response plan, and the executive's signature.
- 3Define safety accountabilities and authorities under §5.23 — for the accountable executive, management, and employees — and identify which management levels can accept safety risk.
- 4Document and communicate the policy throughout the organization, and set a schedule for the accountable executive to review it.
Records this phase generates
- Signed, dated safety policy statement
- Accountable executive designation
- Safety accountability / authority matrix by role
Phase 02 — Build the Safety Risk Management process
14 CFR §5.51 · §5.53 · §5.55The analytical engine. SRM is how you find hazards and decide how to control them before — and when — operations change. §5.51 tells you when to apply it; §5.53 tells you what to analyze.
What to do
- 1Write a system description per §5.53: function and purpose of the system, its operating environment, an outline of its processes and procedures, the personnel/equipment/facilities needed, and the interfaces with other systems.
- 2Define when SRM applies (§5.51): new systems, revisions to existing systems, new operational procedures, and hazards surfaced by safety assurance.
- 3Build a repeatable hazard identification method and a risk-assessment scheme (likelihood × severity) the team actually uses.
- 4Apply and document risk controls (§5.55), including who has the authority to accept residual risk.
Records this phase generates
- System description document(s)
- Hazard identification worksheets
- Risk assessments with likelihood/severity ratings
- Risk-control decisions and residual-risk acceptance
Phase 03 — Stand up Safety Assurance
14 CFR §5.71 · §5.73 · §5.75The feedback loop that proves the system is working. §5.71 requires you to monitor, audit, investigate, and — critically — run a confidential employee reporting system, then analyze the data you collect.
What to do
- 1Establish processes to monitor operational processes and the operating environment for change (§5.71(a)).
- 2Build an internal audit program for operational processes and systems, and a process to investigate incidents, accidents, and reports of non-compliance.
- 3Stand up a confidential employee reporting system for hazards and safety concerns, and a way to receive hazard notifications from outside the organization.
- 4Analyze the data you collect (§5.71(b)), feed findings back into SRM, and run management reviews to direct corrective action on substandard performance.
Records this phase generates
- Internal audit reports with findings
- Corrective/preventive actions with closure dates
- Safety performance monitoring & SPI data
- Confidential report intake and disposition log
- Management review minutes and outcomes
Phase 04 — Deliver Safety Promotion
14 CFR §5.91 · §5.93A system nobody understands is not a system. §5.91 requires training so each person identified in §5.23 attains and maintains the competencies to perform their SMS duties; §5.93 requires you to communicate safety information.
What to do
- 1Identify everyone with SMS duties (per §5.23) and define the competencies each role needs.
- 2Build and deliver initial and recurrent SMS training so individuals attain and maintain those competencies (§5.91).
- 3Establish safety communication channels (§5.93) — bulletins, safety meetings, lessons learned — so safety-critical information actually reaches the people who need it.
- 4Capture completion and competency records, and keep communication records.
Records this phase generates
- Initial & recurrent SMS training completions per person
- Competency assessments
- Training curriculum / course materials
- Safety communication logs (bulletins, meetings, lessons learned)
Phase 05 — Operate the system, keep the records & declare compliance
14 CFR §5.95 · §5.97 · §5.9Implementation is not a binder — it is a running system that produces evidence. Maintain your SMS documentation (§5.95), keep the records (§5.97), and submit your declaration of compliance to the FAA by the deadline.
What to do
- 1Maintain SMS documentation under §5.95 — your safety policy and your SMS processes and procedures — with version control.
- 2Capture and retain records per §5.97 (see the retention table below): SRM outputs, safety assurance outputs, training records, and communication records.
- 3Run the loop continuously so that, at any moment, you can produce the records a FAA inspector asks for.
- 4Submit your declaration of compliance to the FAA — for existing operators, no later than May 28, 2027 (§5.9). Confirm your specific path with your assigned FSDO.
Records this phase generates
- Maintained SMS documentation (§5.95)
- Complete §5.97 record set, retained per the required periods
- Declaration of compliance to the FAA
A note on sequencing: phases 2 through 4 are a loop, not a straight line. Safety assurance (phase 3) is designed to feed hazards back into safety risk management (phase 2), and training needs (phase 4) often surface from audit findings (phase 3). The build order above gets you to a working system; once it is running, the four components operate continuously and reference each other. For a section-by-section walk-through of what belongs in your written program, see the Part 135 SMS recordkeeping requirements guide.
The records your SMS must keep — and exactly how long (14 CFR §5.97)
Implementation is incomplete until you can retrieve the evidence. Section 5.95 requires you to develop and maintain SMS documentation — your safety policy and your SMS processes and procedures. Section 5.97 sets the record-retention rules, and they are specific. These four lines are what separates an SMS that passes surveillance from one that does not.
| Record category | CFR | Minimum retention |
|---|---|---|
| Safety risk management outputs (hazard analyses, risk assessments, controls) | §5.97(a) | As long as the control remains relevant to the operation |
| Safety assurance outputs (audits, evaluations, monitoring & performance data) | §5.97(b) | Minimum of 5 years |
| Personnel SMS training records | §5.97(c) | As long as the individual is employed |
| Communication records | §5.97(d) | Minimum of 24 consecutive calendar months |
Retention periods per 14 CFR §5.97. SMS documentation (safety policy + processes) must be developed and maintained under §5.97's companion section, §5.95.
Two practical takeaways. First, your internal audit reports and safety performance data are five-year documents — you cannot purge last year's audit just because you closed the findings. Second, a risk assessment for an active operational change stays on file as long as that control is in effect, which can be indefinite. Mapping every SMS record to its retention clock — and being able to produce it on demand — is the part of implementation that fails quietly in shared drives and email threads. For the full picture across your whole certificate, see the aviation records retention schedule and what records a Part 135 operator must keep.
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Five mistakes that derail Part 135 SMS implementation
Treating the SMS manual as the finish line
Writing the manual is the easy 20%. The FAA evaluates the operating system and the records it produces (§5.97), not just the documentation (§5.95). A binder with no audit reports, no hazard assessments, and no training records is not a compliant SMS — it is a description of one.
Picking the wrong accountable executive
Section 5.25 requires the accountable executive to control the financial and human resources and hold ultimate responsibility for safety. Designating the Director of Operations or a safety manager who cannot control the budget is a structural defect the FAA will flag.
Skipping the confidential employee reporting system
Section 5.71 requires a way for employees to report hazards and safety concerns. Operators frequently build the audit program but forget the reporting channel — and then have no intake records to show.
Letting single-pilot status mean "no SMS"
Section 5.9(e) scales the SMS down for qualifying single-pilot operations — it does not exempt them from the May 28, 2027 deadline. A right-sized SMS is still an SMS.
Storing the evidence where it cannot be retrieved
The retrieval problem appears the moment the inspector asks for a specific record. SMS records scattered across email, shared drives, and a safety manager's laptop are functionally invisible during surveillance — even when they technically exist.
Keep going: related Part 135 reading
Where FileFlo fits: the proof layer, not the SMS
FileFlo does not build or run your SMS — it proves your SMS records on demand
Let's be precise about the boundary, because it matters most on SMS. FileFlo is a compliance document intelligence platform — a read-only proof layer. It is not an SMS platform, it does not run your safety management system, it does not author your SMS manual, and it does not replace your safety manager or accountable executive. You (and your SMS software or consultant) build and operate the system. FileFlo classifies, indexes, version-controls, and tracks the expirations on the records that system produces — so when the FAA asks for them, you can produce them.
The reason the document layer is a distinct problem on SMS is that SMS records are dynamic. Unlike a static airworthiness certificate, a risk assessment gets revised when operations change, a corrective action has an open/closed lifecycle, training records accumulate recurrently, and audit reports form a five-year cycle that references prior findings. That is a lot of moving evidence to keep current and retrievable — and it is precisely what falls behind when it lives in folders and inboxes.
Classifies every SMS record against the right Part 5 section
A signed safety policy, an accountable executive designation, an internal audit report, a hazard worksheet, a training certificate — FileFlo classifies each against the specific Part 5 section it satisfies and files it in the right place. You do the safety work; it does the filing.
Tracks the §5.97 retention clocks and recurrent records
Safety assurance outputs are 5-year documents; training records run as long as the person is employed; communication records run 24 months. FileFlo tracks those clocks and surfaces upcoming gaps — recurrent training, the next audit cycle — at 90, 60, and 30 days, before they become findings.
Generates a Part 5-organized evidence binder on demand
When your FAA principal inspector requests SMS documentation, FileFlo assembles a complete, four-component evidence binder indexed by section — instead of you hand-assembling it across drives while the inspector waits. The same binder supports ACSF, IS-BAO, and ARGUS audit prep.
Covers the rest of the Part 135 stack alongside Part 5
SMS records sit next to the records you already keep. FileFlo also classifies pilot currency, GOM/GMM revision history, maintenance and airworthiness records, and drug & alcohol program records — one proof layer across the whole certificate.
Starter Plan
$89/mo
Up to 100 documents/month · 3 users
For solo owner-operators and small teams starting their SMS documentation program.
Professional Plan
$299/mo
Unlimited documents + users · audit trail · employee auto-detection
For Part 135 operators managing the full SMS evidence load across all four components.
Frequently Asked Questions
How do you implement an SMS for Part 135?
Implementing a Part 135 SMS means building, documenting, and operating the four components defined in 14 CFR Part 5 — Safety Policy (§5.21–§5.27), Safety Risk Management (§5.51–§5.55), Safety Assurance (§5.71–§5.75), and Safety Promotion (§5.91–§5.93) — and then keeping the records that prove each one is working. A practical roadmap runs in this order: (1) designate your accountable executive and write the signed safety policy; (2) build your safety risk management process (system description, hazard identification, risk assessment, risk controls); (3) stand up safety assurance (monitoring, internal audit, the confidential employee reporting system, and management review); (4) deliver safety promotion (SMS training and safety communication); then (5) operate the system, capture the records, and submit your declaration of compliance to the FAA. For every existing Part 135 certificate holder, the full system must be implemented by May 28, 2027 (14 CFR §5.9).
What are the Part 135 SMS requirements under 14 CFR Part 5?
14 CFR Part 5 requires four components. Safety Policy (§5.21) must state your safety objectives, define a safety reporting policy, set out a non-punitive disciplinary policy, include an emergency response plan, and be signed by the accountable executive. Safety accountability (§5.23) and the accountable executive (§5.25) assign responsibility and authority. Safety Risk Management (§5.51, §5.53, §5.55) requires you to analyze your systems, identify hazards, assess risk, and apply controls before implementing or changing operations. Safety Assurance (§5.71) requires monitoring of operational processes, auditing, investigation of incidents and reports of non-compliance, and a confidential employee hazard-reporting system. Safety Promotion (§5.91 competencies and training, §5.93 safety communication) ensures everyone can operate the SMS. SMS documentation (§5.95) and SMS records (§5.97) close the loop.
What is the Part 135 SMS deadline?
May 28, 2027. Under 14 CFR §5.9(a), every person already authorized to conduct operations under Part 135 — or holding a §91.147 Letter of Authorization — before May 28, 2024 must develop and implement a Part 5-compliant SMS no later than May 28, 2027. It is a single compliance date that applies to all affected Part 135 operators regardless of fleet size: there is no aircraft-count threshold and no phased, per-size schedule. Anyone applying for a new Part 135 or §91.147 authorization on or after May 28, 2024 must already have an SMS at the time of application (§5.9(b)). The rule also reaches §91.147 air-tour operators and certain Part 21 certificate holders. Part 145 repair stations are not part of this general Part 5 mandate.
How do you build an SMS from scratch?
Build it component by component, in dependency order, because each component feeds the next. Start with Safety Policy because §5.21 requires the accountable executive's signature and the safety objectives that everything else serves. Next build Safety Risk Management: write a system description (§5.53 lists what it must cover — function and purpose, operating environment, processes and procedures, the personnel/equipment/facilities involved, and system interfaces), then your hazard identification and risk assessment process (§5.51, §5.55). Then stand up Safety Assurance (§5.71) — the monitoring, auditing, and confidential reporting that detect when controls are not working. Then deliver Safety Promotion (§5.91 training, §5.93 communication). FAA guidance — Advisory Circular 120-92D and FAA Notice 8900.700 — walks through SMS development and how the FAA evaluates it. The work is not the binder; it is operating the system and capturing the records that prove it runs.
Does a single-pilot Part 135 operator need an SMS, and is the deadline different?
Yes, and no — the deadline is the same. A single-pilot Part 135 operator is still covered by the rule and faces the same May 28, 2027 compliance date as everyone else. Section 5.9(e) does not give single-pilot operations a later deadline; it exempts certain single-pilot organizations (where one pilot is the sole person performing all functions) from specific Part 5 requirements, scaling the SMS to the size of the operation. So a single-pilot operator still implements an SMS by May 28, 2027 — just a right-sized one. Confirm exactly which sections apply to your operation with your assigned FSDO, and see our dedicated guidance on single-pilot Part 135 SMS.
How much does it cost to implement a Part 135 SMS?
There is no single FAA fee — the cost is your time plus whatever tools and outside help you choose. The main drivers are: building the four-component framework (safety policy, SRM process, safety assurance program, training); the staff hours to operate it (hazard reporting, audits, management reviews, recurrent training); and software to manage SMS workflow and to keep the records audit-ready. Smaller operators using FAA guidance (AC 120-92D, the FAA SMS templates) and existing staff spend far less than operators who buy a turnkey SMS program plus a safety manager. FileFlo is not an SMS platform and does not price your SMS build — it is the document layer at $89/mo (Starter) or $299/mo (Professional) that classifies, version-controls, and proves your SMS records on demand. See our deeper Part 135 SMS cost breakdown for the line items.
What is the difference between an SMS manual and the SMS itself?
The SMS manual is the document that describes how your system is built; the SMS is the live set of processes you actually run plus the records they generate. 14 CFR §5.95 requires you to develop and maintain SMS documentation — your safety policy and your SMS processes and procedures — which is what most operators put in their SMS manual. But §5.97 requires the records: safety risk management outputs, safety assurance outputs, training records, and communication records. The FAA does not just read your manual; during surveillance it asks for the records that prove the manual is being followed. A polished manual with no operating records is a compliance failure. See our breakdown of the required SMS manual sections.
What records does a Part 135 SMS have to keep, and for how long?
Per 14 CFR §5.97: safety risk management outputs must be retained for as long as the control remains relevant to the operation (§5.97(a)); safety assurance outputs — audits, evaluations, monitoring and performance data — for a minimum of 5 years (§5.97(b)); personnel SMS training records for as long as the individual is employed (§5.97(c)); and communication records for a minimum of 24 consecutive calendar months (§5.97(d)). SMS documentation under §5.95 (your safety policy and processes) must be developed and maintained on an ongoing basis. These retention rules are exactly what FileFlo is built to enforce — see our full Part 135 SMS recordkeeping requirements guide and the aviation records retention schedule.
Chad Griffith
Founder, FileFlo — compliance document intelligence
This article is written from a compliance-document perspective — how Part 135 operators keep SMS records audit-ready under 14 CFR Part 5. It is not legal advice, and it is not safety-program or SMS-development consulting. FileFlo does not stand up your SMS, author your SMS manual, or replace your safety manager. Always confirm your specific obligations, compliance path, and deadline with your assigned FSDO principal inspector and qualified aviation counsel. Regulatory citations were verified against the Cornell Legal Information Institute eCFR text; FAA Advisory Circular 120-92D and FAA Notice 8900.700 are FAA guidance, not regulation.
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