Skip to main content
Aviation Compliance — FAA Part 135 Management Roles

Part 135 Director of Maintenance: The Airworthiness & Records the DOM Owns

The Director of Maintenance is one of the three required Part 135 management positions — and the one that owns airworthiness, the maintenance program, AD compliance, return-to-service authority, and the records that prove the aircraft are legal to fly. This guide breaks down the DOM's responsibilities from the literal text of the regulation, including the A&P-plus-experience requirement most candidates trip on.

Chad Griffith, Founder & CEOReviewed June 202613 min read

Chad Griffith, Founder, FileFlo — compliance document intelligence. This guide explains the Director of Maintenance role and the documentation behind it from a compliance-document perspective. It is not legal advice, not career or HR advice, and not a substitute for your FSDO principal maintenance inspector or aviation counsel. Salary figures are third-party ranges, not guarantees. Always confirm your specific obligations, role qualifications, and manual requirements with your assigned FSDO.

HomeBlogAviation CompliancePart 135 Director of Maintenance
Direct Answer

A Part 135 Director of Maintenance (DOM) is the management person an operator designates to oversee aircraft airworthiness and the maintenance program. 14 CFR §119.69(a) requires the position (with the Director of Operations and Chief Pilot), and §119.71(e) requires the DOM to hold an A&P mechanic certificate plus three years of qualifying maintenance experience in the past six — including the same category and class of aircraft the operator flies. The DOM's job is the airworthiness side of the house: ensuring aircraft are maintained under the operator's manual and part 43 (§135.413), running an adequate maintenance organization (§135.423), maintaining the program and records the manual requires (§135.427), tracking AD compliance, and controlling return-to-service authority. The catch worth knowing: under §135.413(a) the certificate holder — not the DOM personally — is primarily responsible for airworthiness, so the records that prove the DOM's oversight are what an inspector actually checks.

Required
DOM is 1 of 3 required Part 135 management positions (DO / CP / DOM)
14 CFR §119.69(a)
A&P + 3 yrs
Mechanic certificate (A&P) plus 3 years’ qualifying experience in the past 6
14 CFR §119.71(e)
Operator
The certificate holder is primarily responsible for airworthiness — the DOM oversees it
14 CFR §135.413(a)

If you searched “part 135 director of maintenance,” “dom duties aviation,” or “part 135 dom requirements,” you are usually after one of two things: what the DOM is actually on the hook for, or what it takes to qualify for the role. This page answers both from the literal text of the regulation — and it draws a clean line between the DOM's job and the certificate holder's legal responsibility, because that distinction is where a lot of small operators (and a lot of ranking pages) get it wrong. The companion piece on Part 135 required management personnel qualifications is the reference for all three positions; this one goes deep on the DOM.

What the Director of Maintenance Actually Owns

§119.69(a) requires the position; it does not spell out the DOM's duties line by line. Instead, the certificate holder's manual has to define each management position's duties, responsibilities, and authority, and in practice the DOM's scope is set by the maintenance regulations the operator must comply with. Here is the airworthiness and records workload that lands on the DOM, each tied to the section that creates it.

The responsibility nuance that matters

Under §135.413(a), the certificate holder is primarily responsible for airworthiness — not the DOM as an individual. And §135.413(b)(2) makes clear that even when maintenance is outsourced to a repair station or another mechanic, the certificate holder must ensure that work is done under its own manual and the regulations. The DOM is the management person the operator designates to carry out and prove that responsibility. That is why this role is so document-heavy: the DOM's real deliverable is airworthy aircraft plus the records that demonstrate they were kept that way.

Airworthiness oversight

§135.413(a)

Ensure each aircraft is airworthy and maintained under the operator’s manual and part 43, with defects repaired between required maintenance. The certificate holder is primarily responsible; the DOM makes it happen.

The maintenance program & procedures

§135.427(b)

Maintain the maintenance, preventive-maintenance, and alteration program and the procedures the operator’s manual is required to contain — routine and non-routine methods, inspection procedures, and personnel qualifications.

AD compliance & inspection status

part 43 / §135.427

Track Airworthiness Directive compliance (method of compliance, recurring actions), inspection status, total time in service, and life-limited part status for airframe, engines, propellers, and rotors.

Return-to-service authority

§135.427(a),(c)

Control who is authorized to approve aircraft and components for return to service, and keep the list of persons arranged to perform required inspections, maintenance, and alterations.

An adequate maintenance organization

§135.423(a)

Ensure the certificate holder — and anyone it arranges work with — has an organization adequate to perform the maintenance, preventive maintenance, and alterations it does.

The maintenance record system

§135.427(c)

Keep the system that retains a description of the work, the identity of who performed it, and the approval for return to service — the records that prove the aircraft is legal to fly.

The inspection-integrity rule the DOM has to respect

§135.427 protects the integrity of required inspections: an inspector's decision to reject an article as not airworthy may not be countermanded except by supervisory personnel of the inspection unit, or by a person at the level of administrative control over both the inspection function and the other maintenance functions. For a DOM, that is a structural reality — the maintenance program has to keep inspection and maintenance authority separated enough that a return-to-service call cannot simply be overruled by whoever is in a hurry to dispatch the aircraft. Building that separation into the manual, and documenting it, is part of the role.

All of this lives next to the rest of the operator's records. If you want the full inventory of what a Part 135 operator has to retain — maintenance and otherwise — start with what records a Part 135 operator must keep, and for the mechanical-irregularity and discrepancy side specifically, the maintenance log discipline matters as much as the program itself.

See where your maintenance documentation stands. The free FAA readiness score flags airworthiness and records gaps an inspector is most likely to find — in about 3 minutes, no signup.

Check FAA Readiness Score

Part 135 Director of Maintenance Requirements (§119.71(e)) — and the Experience Trap

This is the most-searched piece of the DOM question, and the place candidates most often get tripped up. The qualification rule lives in 14 CFR §119.71, and the DOM-specific paragraph is §119.71(e). Note this is Part 135's management-qualification section — not §119.65, which applies to Part 121 air carriers. Here is what §119.71(e) requires, broken out.

DOM Qualifications

14 CFR §119.71(e)–(f)

Baseline certificate

§119.71(e)

Hold a mechanic certificate with airframe and powerplant ratings (an A&P certificate). This is required regardless of which experience path the candidate uses.

Experience — Path 1

§119.71(e)(1)

3 years of experience within the past 6 years maintaining aircraft as a certificated mechanic, including — at the time of appointment as DOM — experience maintaining the same category and class of aircraft the certificate holder uses.

Experience — Path 2

§119.71(e)(2)

3 years of experience within the past 6 years repairing aircraft in a certificated airframe repair station, including 1 year in the capacity of approving aircraft for return to service.

Deviation for comparable experience

§119.71(f)

The FAA may authorize a deviation to employ a person who does not meet the experience requirements if it finds the person has comparable experience and can effectively perform the position’s functions under the chapter and the operator’s manual.

The “same category and class” trap

Path one (§119.71(e)(1)) does not just want three years of recent maintenance experience — it wants experience, at the time of appointment, on the same category and class of aircraft the certificate holder uses. A seasoned fixed-wing A&P is not automatically qualified to be the DOM at a helicopter operator, and a turbine-fleet background is not automatically the right fit for a piston operation. This is the single most common reason a candidate who “looks qualified” on paper gets a second look from the FSDO. The repair-station path (§119.71(e)(2)) is the alternative, and it adds the requirement of one year approving aircraft for return to service. When neither path fits cleanly, §119.71(f) is the deviation valve for comparable experience.

One more structural point people miss: §119.69(a) requires the DOM position, but §119.69(b) lets the FAA authorize a deviation for fewer or different categories of management personnel based on the kind of operation, the number and type of aircraft, and the area of operations. That is the mechanism behind small-operator structures where one person wears more than one hat — but it is an FAA-approved deviation reflected in your operations specifications, not a free-for-all. And whenever the person in the role changes, §119.69(e) requires the operator to notify its responsible Flight Standards office within 10 days. We cover that vacancy mechanic in the required management personnel qualifications reference.

The DOM's job is half airworthiness, half proof

AD compliance, inspection status, return-to-service approvals, the maintenance program in your manual — an inspector verifies the records, not your intentions. FileFlo's free FAA readiness score takes about 3 minutes and flags which maintenance and airworthiness documentation gaps are most likely to surface in a Part 135 surveillance evaluation. No signup required. Free.

5-day free trial · No credit card required · Cancel anytime

DOM vs. Director of Operations vs. Chief Pilot: Who Owns What

All three are required §119.69(a) positions, and the qualifications for each are in §119.71. The cleanest way to keep them straight: the DO owns operational control, the Chief Pilot owns flight standards and crew, and the DOM owns airworthiness. Here is the split.

PositionOwnsCore qualification
Director of OperationsOperational control — flight ops, crew scheduling, dispatch/flight release, conduct of flights under the op specs.Pilot certificate & managerial flight-ops experience (§119.71(a)–(b)).
Chief PilotFlight standards, training oversight, crew qualification and currency, line-pilot supervision.Pilot certificate appropriate to the operation & required experience (§119.71(c)–(d)).
Director of MaintenanceAirworthiness — maintenance program, inspections, AD compliance, return-to-service authority, maintenance records.A&P mechanic certificate + maintenance experience (§119.71(e)).

At a small operator, §119.69(b) may allow one person to hold more than one of these roles by FAA-approved deviation — but only if they are qualified for each, and the responsibilities themselves stay distinct. The DOM's qualification path (A&P + maintenance experience) is fundamentally different from the pilot-credential path the DO and Chief Pilot need, which is why the DOM is the management seat least likely to be doubled up by someone who came up through flight operations. For the full side-by-side of all three positions and their qualification thresholds, the required management personnel qualifications guide is the reference. And because the 2024 SMS rule layers a separate set of safety roles on top of these positions, it is worth understanding how the Part 135 Director of Safety / SMS roles interact with the §119.69 management structure before the May 28, 2027 SMS deadline.

Part 135 Director of Maintenance Salary (2026 Ranges)

“Part 135 director of maintenance salary” is one of the highest-volume searches on this role, so here is an honest answer: there is no single number. Pay swings widely with fleet size, aircraft type (piston vs. turbine vs. rotorcraft), and region, and the public aggregators report ranges. Treat the figures below as a directional snapshot, date-stamped to when they were pulled — not a quote.

~$75K
Reported U.S. average for an Aviation Director of Maintenance
ZipRecruiter, Apr 2026
~$52.5K–$87.5K
Middle band (25th–75th percentile)
ZipRecruiter, Apr 2026
up to ~$162K
Top of the range for FAA Part 135 director-level postings
ZipRecruiter Part 135 listing, 2026

Why the spread is so wide

A DOM at a single-aircraft piston charter and a DOM overseeing a multi-aircraft turbine fleet are different jobs with different scopes of authority, different AD and inspection burdens, and different pay. Top-of-band compensation generally tracks larger, more complex fleets and broader return-to-service responsibility. Compensation, hiring, and HR are outside the scope of this compliance-document guide — for the regulatory requirements to fill the seat, the controlling text is §119.71(e), covered above.

Salary sources: ZipRecruiter “Aviation Director of Maintenance Salary” (national average and percentile bands, accessed April 2026) and ZipRecruiter “FAA Part 135 Director” job listing (posting range, 2026). Figures are third-party estimates that change over time and by market; verify current data before relying on it.

Where FileFlo Fits: Keeping the DOM's Airworthiness Records Provable

FileFlo holds the proof — it does not perform maintenance, qualify your DOM, or run your maintenance program

FileFlo is a compliance document intelligence platform — the proof layer. It classifies, indexes, version-controls, and tracks the expiration of the maintenance and airworthiness records the DOM has to keep current. It is not a maintenance-tracking or MRO system, does not perform or sign off maintenance, does not approve aircraft for return to service, and does not hire, recruit, place, or qualify a Director of Maintenance. It does not give legal, career, or HR advice. What it does is keep the documents that prove your maintenance program and airworthiness oversight audit-ready, so the DOM can produce them on demand.

The DOM's real audit exposure is documentary. §135.413 makes the operator responsible for airworthiness; §135.427 requires the maintenance program, the manual content, and the record system; AD compliance has to be demonstrable on paper. When a principal maintenance inspector shows up, the question is never “do you intend to comply” — it is “show me the current inspection status, the AD compliance record, and the return-to-service approval.” Keeping that set organized, current, version-controlled, and retrievable for years is precisely the document problem FileFlo is built for.

Maintenance & Airworthiness Records, Classified by CFR

Inspection records, AD compliance documentation, return-to-service approvals, and component/overhaul tracking are classified against the section they satisfy (§135.413, §135.423, §135.427, part 43) and version-controlled — so the current, signed record is one search away.

Expiration & Recurrence Tracking

Inspections, recurring ADs, life-limited part times, and program intervals carry recurrence clocks. FileFlo surfaces upcoming items 90/60/30 days out so an aircraft does not quietly drift out of inspection status or AD currency between events.

One-Click Maintenance Evidence Binder

When the FAA — or an ACSF, IS-BAO, or ARGUS auditor — asks for maintenance and airworthiness documentation, FileFlo generates an organized evidence binder in seconds, indexed by aircraft, component, and the governing CFR section.

Coverage Across the Full Part 135 Stack

The DOM’s maintenance records sit alongside the rest of the operator’s compliance file. FileFlo classifies 600+ document types against the governing regulation — GMM/maintenance manual revisions, pilot and training records, inspection logs and more — so the whole compliance picture lives in one audit-ready place.

Starter Plan

$89/mo

Up to 100 documents/month · 3 users

For solo owner-operators and small flight departments organizing their maintenance and airworthiness records.

Professional Plan

$299/mo

Unlimited documents + users · audit trail · employee auto-detection

For Part 135 operators managing maintenance records alongside the full compliance document load.

Frequently Asked Questions

What are the responsibilities of a Part 135 Director of Maintenance?

The Director of Maintenance (DOM) is the management person a Part 135 certificate holder designates to oversee aircraft airworthiness and the maintenance program on the certificate holder's behalf. 14 CFR §119.69(a) requires the position (alongside the Director of Operations and Chief Pilot), and the certificate holder's manual sets out the DOM's specific duties, responsibilities, and authority. In practice those duties track the maintenance regulations: ensuring aircraft are airworthy and maintained under the operator's manual and part 43 (§135.413), running an organization adequate to perform the work (§135.423), maintaining the maintenance program and procedures the manual requires (§135.427), tracking Airworthiness Directive (AD) compliance, scheduling inspections, controlling who is authorized to approve aircraft for return to service, and keeping the maintenance records that prove all of it. The key legal nuance: §135.413(a) makes the certificate holder — not the DOM personally — primarily responsible for airworthiness, but the DOM is the person the operator puts in charge of making that happen and proving it.

What are the Part 135 Director of Maintenance requirements under §119.71?

Under 14 CFR §119.71(e), a person serving as Director of Maintenance for a Part 135 operator must hold a mechanic certificate with airframe and powerplant ratings (an A&P) and meet one of two experience paths. Path one (§119.71(e)(1)): three years of experience within the past six years maintaining aircraft as a certificated mechanic, including — at the time of appointment — experience maintaining the same category and class of aircraft the certificate holder uses. Path two (§119.71(e)(2)): three years of experience within the past six years repairing aircraft in a certificated airframe repair station, including one year in the capacity of approving aircraft for return to service. The "same category and class" hook in path one is the experience trap most candidates miss — a fixed-wing A&P background does not automatically qualify someone to be the DOM at a rotorcraft operator, and vice versa. §119.71(f) lets the operator request an FAA deviation for a candidate with comparable experience who can effectively perform the functions.

Does a Part 135 operator have to have a Director of Maintenance?

Yes — 14 CFR §119.69(a) lists Director of Maintenance as one of the three required management positions for a Part 135 certificate holder, together with the Director of Operations and the Chief Pilot. The certificate holder also has to list the names and business addresses of the people in those positions in its manual and document each position's duties, responsibilities, and authority. There is a relief valve: under §119.69(b), the FAA may authorize a deviation that lets an operator use fewer or different categories of management personnel based on the kind of operation, the number and type of aircraft, and the area of operations — which is how a small operator may have one person cover more than one management role, or how a single-pilot or basic operator's structure differs. But the default rule is that the DOM position exists and is filled, and §119.69(e) requires the operator to notify its responsible Flight Standards office within 10 days of any change in, or vacancy in, that position.

Who is responsible for airworthiness under Part 135 — the DOM or the operator?

The certificate holder is. 14 CFR §135.413(a) states that each certificate holder is primarily responsible for the airworthiness of its aircraft — including the airframe, engines, propellers, rotors, appliances, and parts — and must have its aircraft maintained under the chapter and have defects repaired between required maintenance under part 43. That responsibility stays with the operator even when maintenance is outsourced: §135.413(b)(2) says that when a certificate holder arranges for another person to perform maintenance, preventive maintenance, or alteration, the certificate holder must ensure that work is performed under the certificate holder's manual and the chapter. The Director of Maintenance is the management person the operator designates to carry out and oversee that responsibility day to day — but the legal accountability for airworthiness is the certificate holder's, which is exactly why the DOM's oversight and the records behind it matter so much.

What is the difference between a Director of Maintenance and a Director of Operations?

They are two of the three required §119.69(a) management positions, and they own different halves of the operation. The Director of Operations (DO) is responsible for the operational control side — flight operations, crew, dispatch/flight release, and the day-to-day conduct of flights under the operator's operations specifications. The Director of Maintenance (DOM) is responsible for the airworthiness side — the maintenance program, inspections, AD compliance, return-to-service authority, and the maintenance records that prove the aircraft are legal to fly. Their qualification requirements differ accordingly: the DO must hold or have held an airline transport or commercial pilot certificate and have managerial flight-operations experience under §119.71(a)-(b), while the DOM must hold an A&P mechanic certificate and meet the maintenance-experience paths in §119.71(e). At a small operator, §119.69(b) may permit one person to hold more than one of these roles by deviation — but the responsibilities themselves stay distinct.

Can one person be the Director of Maintenance and another management position at a Part 135 operator?

Sometimes — but only with FAA approval, and only if they are qualified for each role. The default under §119.69(a) is that the Director of Operations, Chief Pilot, and Director of Maintenance are distinct required positions. §119.69(b) gives the FAA authority to approve a deviation allowing fewer or different categories of management personnel based on the kind of operation, the number and type of aircraft, and the area of operations — which is the mechanism a small operator uses to combine roles. The practical limits are real: combining the DOM role with the Chief Pilot role, for example, requires a person who holds both the required pilot credentials under §119.71(c)-(d) and the A&P mechanic certificate plus maintenance experience under §119.71(e). Whatever structure you run, it has to be reflected in your manual and approved through your operations specifications — and any change or vacancy still triggers the 10-day notification under §119.69(e).

What records does a Part 135 Director of Maintenance have to keep?

The DOM is effectively the custodian of the maintenance and airworthiness record set, even though the recordkeeping obligation legally runs to the certificate holder. That set includes the maintenance, preventive-maintenance, and alteration records and the maintenance/inspection program documentation required by §135.427; the airworthiness records and return-to-service approvals; AD compliance records showing each AD's method of compliance and recurring-action status; total time-in-service and current inspection status for the airframe, engines, propellers/rotors, and life-limited parts; component overhaul and time-since-overhaul tracking; and the list of persons authorized to approve work for return to service. §135.427 also requires the operator's manual to describe the maintenance organization and the procedures, and it protects the integrity of inspections by providing that an inspector's decision may not be countermanded except by supervisory personnel of the inspection unit or a person at the level of administrative control over both inspection and maintenance. Keeping all of that current, retrievable, and provable is the DOM's documentation burden — and where it most often goes wrong in an audit.

How much does a Part 135 Director of Maintenance make?

Public salary aggregators put aviation Director of Maintenance pay in a broad range rather than a single number, and it varies heavily by fleet size, aircraft type, and region. As of April 2026, ZipRecruiter reported a U.S. average around $75,000 per year for an Aviation Director of Maintenance, with most salaries falling roughly between about $52,500 (25th percentile) and about $87,500 (75th percentile) and top earners (90th percentile) near $126,500. ZipRecruiter's separate listing for FAA Part 135 director-level roles shows postings ranging from roughly $75,000 to $162,000. Treat these as ranges, not guarantees — a DOM at a single-aircraft piston operator and a DOM overseeing a large turbine fleet are very different jobs with very different pay, and compensation, hiring, and HR decisions are outside the scope of this compliance-document guide.

Keep your maintenance records current and provable.

Your DOM owns airworthiness; FileFlo keeps the documents that prove it — inspection status, AD compliance, return-to-service approvals, and the maintenance program in your manual — classified against the right CFR section and ready for your FSDO. Starter at $89/mo · Professional at $299/mo · No credit card required.

Check FAA Readiness Score About FileFlo

5-day free trial · No credit card required · Cancel anytime

FAA ramp inspection prep

Free Part 91/121/135/145 readiness audit. 15 questions across airworthiness, pilot records, AD compliance, operating manuals, and drug/alcohol + training. 14 CFR-cited gap report.

Part 91/121/135/145
AD + currency tracking
3 min, no signup

Free: FAA Compliance Calendar (Part 91/121/135/145)

Annual inspection schedule, AD compliance tracking matrix, pilot recurrent training calendar, Part 120 D&A program calendar.

Delivered free to your inbox · No commitment, no sales calls without your permission · Unsubscribe anytime

You Might Also Like

More Related Articles

Aviation Compliance

12 articles on this topic

Explore Aviation Compliance solutions