Direct Answer
When a Part 135 Director of Operations, Chief Pilot, or Director of Maintenance leaves, you must notify your responsible Flight Standards office within 10 days of the change or vacancy under 14 CFR §119.69(e)(3). The clock starts on the day of the departure, and it is 10 days — not 10 working days.
Those three positions are required under §119.69(a) for any multi-pilot certificate holder, so a departure is a reportable management change, not just an internal HR event. The same §119.69(e) provision also requires you to keep each position’s duties, responsibilities, and authority documented in your manual and to maintain a current list of the names and business addresses of the people in those positions. A single departure trips all three obligations at once.
The rule fixes the notification deadline; it does not grant a blanket grace period to keep flying indefinitely without a qualified person in the seat. The Part 135 sections are §119.69 and §119.71 — not §119.65, which is the Part 121 management section. For who is qualified to fill the seat, see the Part 135 required management personnel qualifications reference.
If you run the certificate, the mental model is simple: the FAA defines positions you must keep filled (§119.69(a)), defines who is qualified to fill them (§119.71), and requires you to tell your Flight Standards office promptly when one of them changes or goes empty (§119.69(e)(3)). A resignation, a termination, a death, a sudden medical disqualification — any of these starts the same 10-day notification clock. The sections below walk the first 72 hours, the exact text of §119.69(e), the harder question of whether you can keep operating, and the documentary trail that proves you handled it. This is the vacancy-and-notification companion to the hiring guide — for the other half of the appointment, see how to hire a Part 135 Director of Operations.
The First 72 Hours After a Management Departure
The 10-day notification deadline is generous on paper and tight in practice, because a clean notice depends on work you do in the first few days. Here is the sequence that keeps a sudden departure from becoming a compliance problem. Treat this as operational context — the binding requirement is §119.69(e)(3), and your principal operations inspector (POI) is the authority on your specific situation.
Pin the effective date
The 10-day clock under §119.69(e)(3) runs from the change or vacancy. Fix the exact effective date of the departure in writing — last day worked, resignation date, or termination date — because that date anchors everything: your notification deadline and your management-personnel-list update.
Identify interim coverage
A multi-pilot operator must have qualified personnel in the required position under §119.69(a). Determine who is covering the function — a §119.71-qualified interim/acting appointee, or a structure your POI accepts under §119.69(b). This is what your notification will describe, and it is also the substantive fix, not just paperwork.
Draft the §119.69(e)(3) notice
Prepare a dated, written notification to your responsible Flight Standards office identifying the position that changed or became vacant, the effective date, and how the position is being covered or who is proposed to fill it. The rule does not mandate a specific form — a clear, dated written notice is the safe practice.
Update the personnel list
Section 119.69(e)(2) requires a current list of the names and business addresses of the individuals in your required positions. Update it as of the change so the list, the manual, and the notification all tell the same story to an inspector.
“10 days” means calendar days — do not assume the weekend extends it
14 CFR §119.69(e)(3) says “within 10 days,” not “within 10 working days.” Count calendar days from the effective date of the change or vacancy, and do not assume weekends or holidays push the deadline out. If a departure lands on a Friday, the clock is already running over the weekend — which is exactly why the interim-coverage decision and the draft notice should not wait until Monday.
The operators who weather a sudden departure cleanly are the ones who decided in advance who their interim or replacement candidate would be and kept that person’s qualification documents organized. When the seat opens, they are confirming a plan, not building one from zero inside a 10-day window. For the role split that decides whether you are replacing one person or two, see Director of Operations vs. Chief Pilot, and for whether one person can temporarily wear two hats, see Part 135 management with one person in multiple roles.
Could you produce the vacancy paperwork in 10 days — or would you be reconstructing it?
FileFlo classifies and indexes the documents behind every required management position — the §119.71 qualification records, the appointment and OpSpecs acceptance, the operations-manual duties section, and the management-personnel list — so when a departure starts the §119.69(e)(3) clock, the proof is already organized. Starter at $89/mo, Professional at $299/mo. 5-day free trial, no credit card required.
What 14 CFR §119.69(e) Actually Says
The notification obligation does not stand alone — it is one of three standing duties in 14 CFR §119.69(e), which sits under the required-positions rule in §119.69(a). Reading them together is what makes the vacancy obligation make sense.
§119.69(a)The required positions
“Each certificate holder must have sufficient qualified management and technical personnel to ensure the safety of its operations. Except for a certificate holder using only one pilot in its operations, the certificate holder must have qualified personnel serving” as Director of Operations, Chief Pilot, and Director of Maintenance. A single-pilot operator is the carve-out; everyone else must keep these three seats filled with qualified people.
§119.69(e)(1)Document the duties in your manual
You must “state in the general policy provisions of the manual” the duties, responsibilities, and authority of the personnel required or approved under §119.69(a) or (b). When a position turns over, that duties section is the standing record the incoming appointee steps into.
§119.69(e)(2)Keep a current personnel list
You must “list in the manual the names and business addresses of the individuals assigned to those positions.” A vacancy makes that list stale by definition, so updating it is part of handling the change — not an afterthought.
§119.69(e)(3)The 10-day notification — the clock
You must “notify the responsible Flight Standards office within 10 days of any change in personnel or any vacancy in any position listed.” This is the deadline at the center of a management departure: 10 days, any change or vacancy, any listed position. It applies whether someone resigned, was terminated, or the seat is simply empty.
Three things the text settles — and one it does not
It is §119.69(e)(3) for Part 135 — not §119.65
14 CFR §119.65 is the Part 121 management-personnel section (domestic, flag, and supplemental operations). For an on-demand or commuter Part 135 operator, the required positions are in §119.69(a), the qualifications in §119.71, and the 10-day management-change notification in §119.69(e)(3). If a manual template, recruiter material, or checklist cites §119.65 for your Part 135 vacancy notice, the citation is wrong — and an inspector reading your manual will catch a Part 121 section governing a Part 135 obligation.
Note one more wrinkle: §119.69(b) lets the Administrator approve a different management structure — fewer or different categories of personnel — when an operator shows it can operate safely that way given the nature of the operation, the number and type of aircraft, and the area of operations. That deviation is an FAA-accepted arrangement, not something you can declare unilaterally during a vacancy. For the full qualification standard each replacement must meet, see the Part 135 required management personnel qualifications guide, and for the Director-of-Safety / SMS role that sits alongside these positions, see the Part 135 Director of Safety SMS requirement.
Can You Keep Flying While the Seat Is Empty?
This is the question every operator actually asks, and the honest answer is: the rule sets the notification deadline, not a blanket right to keep operating indefinitely with a required seat vacant. The baseline in §119.69(a) is that a multi-pilot certificate holder must have qualified personnel in the Director of Operations, Chief Pilot, and Director of Maintenance positions. A vacancy is, by definition, a gap against that requirement.
Notify within 10 days — regardless
The §119.69(e)(3) notification is not optional and not contingent on whether you keep flying. Whatever you decide about operations, the 10-day notice to your responsible Flight Standards office still has to go out, identifying the change or vacancy.
Cover the function with a qualified person
The realistic way to continue operating is to have a §119.71-qualified interim or acting appointee covering the position, or an FAA-accepted deviation under §119.69(b) for a different structure. Either way it is an arrangement your POI (or PMI, for maintenance) accepts — not a self-declared stopgap.
Treat an unaddressed vacancy as exposure
Operating with a required position simply empty and unaddressed is a compliance exposure, because the rule requires qualified personnel in the seat. The longer a required position sits vacant without an accepted coverage arrangement, the harder that position is to defend in a surveillance review.
Confirm the specifics with Flight Standards
Because §119.69 does not publish a fixed fill-by date, the practical answer for your operation — whether and how you may continue operating, and on what timeline a replacement must be accepted — comes from your responsible Flight Standards office against your specific certificate, not from a generic day-count.
The practical posture
Notify within 10 days, line up §119.71-qualified coverage, and call your POI early rather than waiting to be asked. A proactive operator who notifies on time and shows a credible coverage plan is in a far stronger position than one whose Flight Standards office learns of a long-standing vacancy during a surveillance visit. The notification is the floor; resolving the coverage promptly is the substance.
For the qualification bar an interim or permanent replacement must clear before they can be accepted, see how to hire a Part 135 Director of Operations and the candidate-side path in how to become a Part 135 Director of Operations. For replacing the other seats, see how to become a Part 135 Chief Pilot and the Director of Maintenance responsibilities guide.
The Records That Prove You Handled the Vacancy — and Where FileFlo Fits
This is where FileFlo fits — and where it does not. FileFlo is not a recruiter. It does not source, screen, hire, place, qualify, or certify a replacement, and it does not give legal, career, or HR advice. What it does is classify, index, and track the documents that prove a management transition was handled on time and that the seat was filled by a qualified, accepted individual — so when an inspector asks, the trail is complete and dated, not reconstructed under deadline. Below are the record sets a §119.69(e) vacancy generates.
§119.69(e)(3) Vacancy / Change Notification
14 CFR §119.69(e)(3)What it proves
The dated, written notice to your responsible Flight Standards office identifying the required position that changed or became vacant, its effective date, and how it is being covered — the document at the center of the 10-day clock.
How FileFlo tracks it
FileFlo classifies the notification, captures its date and the effective date of the change, and links it to the position and the incoming appointee for a clean, retrievable record.
Updated Management-Personnel List
14 CFR §119.69(e)(2)What it proves
The current list of the names and business addresses of the individuals in your required positions, updated as of the change so the manual reflects who actually holds each seat.
How FileFlo tracks it
FileFlo indexes the personnel list and its revisions so you can show the list was current as of the change — and flag when a position has gone vacant.
Incoming Appointee Qualification Package
14 CFR §119.71(a)–(e)What it proves
The replacement’s pilot certificate (or A&P certificate for a Director of Maintenance) and the dated §119.71 experience evidence proving they meet the standard for the position.
How FileFlo tracks it
FileFlo classifies the certificate and indexes the supporting experience documents so the qualification proof is organized before the POI or PMI reviews the appointment.
Appointment / FAA Acceptance & OpSpecs
14 CFR §119.69(c)What it proves
The record that the FAA has accepted the named replacement into the required position, reflected in your management structure and Operations Specifications — the appointment is an OpSpecs-level change, not an internal title change.
How FileFlo tracks it
FileFlo stores the appointment and acceptance documentation with dates, tied to the qualification package, for a complete chain from departure to accepted replacement.
Operations Manual — Duties Section
14 CFR §119.69(e)(1)What it proves
The standing record of the position’s duties, responsibilities, and authority that you must maintain — the framework the incoming appointee steps into.
How FileFlo tracks it
FileFlo indexes the manual and its revisions so you can show the documented authority of the position and that the duties section is current through the transition.
Related guides: Management personnel qualifications (§119.71) · How to hire a DO · Chief Pilot duties · First 100 days as DO/Chief Pilot · Management salaries
FileFlo is the proof layer — it is not a recruiter and does not place or qualify replacements
FileFlo is a compliance document intelligence platform. It classifies, indexes, and tracks the records that document a Part 135 management transition — the §119.69(e)(3) notification, the updated personnel list, the replacement’s §119.71 qualification package, the FAA acceptance, and the manual duties section — and surfaces gaps and stale entries. It does not source, screen, 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. You and the FAA qualify and accept the replacement; FileFlo keeps the documentary proof audit-ready.
Frequently Asked Questions
How long do you have to notify the FAA when a Part 135 management position becomes vacant?
Under 14 CFR §119.69(e)(3), a certificate holder must notify the responsible Flight Standards office within 10 days of any change in personnel or any vacancy in a required management position. The required positions are Director of Operations, Chief Pilot, and Director of Maintenance under §119.69(a). The clock is 10 days, not 10 working days — the rule says "within 10 days," so count calendar days from the change or vacancy, and do not assume weekends or holidays extend it. The notification is one of three standing obligations in §119.69(e): keep the duties, responsibilities, and authority of each required position documented in your manual; keep a current list of the names and business addresses of the individuals assigned to those positions; and notify Flight Standards within 10 days of any change or vacancy. A management departure trips all three at once.
My Part 135 Director of Operations quit on Friday — what is the FAA notification clock?
When your Director of Operations leaves, 14 CFR §119.69(e)(3) starts a 10-day clock to notify your responsible Flight Standards office of the change or vacancy. The DO is a required position under §119.69(a), so the departure is a reportable management change — not just an internal HR event. Two things matter in parallel. First, send the §119.69(e)(3) notification within 10 days; it identifies the vacancy and, ideally, the proposed or interim arrangement. Second, address the substantive gap: a multi-pilot Part 135 operator is required to have a qualified Director of Operations, so operating with the seat empty and unaddressed is itself a compliance exposure. The rule sets the notification deadline; it does not grant an automatic grace period to keep flying indefinitely without a qualified DO. Operators who handle a sudden departure well already have a §119.71-qualified replacement or interim candidate identified, so the notification can name how the position is being covered while acceptance is finalized.
Does Part 135 give you a fixed number of days to fill a management vacancy?
14 CFR §119.69(e)(3) fixes the notification deadline — 10 days to tell your Flight Standards office about the change or vacancy — but it does not publish a separate, fixed number of days to fill the seat while you keep operating. The substantive requirement is in §119.69(a): a certificate holder (other than a single-pilot operator) must have qualified personnel in the Director of Operations, Chief Pilot, and Director of Maintenance positions. How a vacancy is handled in practice — whether and how you may continue operations, and on what timeline a replacement must be accepted — is worked through your principal operations inspector against your specific operation, not from a blanket day-count in the rule. So treat §119.69(e)(3)'s 10 days as the hard notification deadline, and treat the vacancy itself as something to resolve promptly with your Flight Standards office rather than something the rule lets you sit on.
What CFR section covers the Part 135 management-change notification — is it 119.65?
For Part 135, the management-change notification is 14 CFR §119.69(e)(3), and the required positions and qualifications live in §119.69 and §119.71. It is NOT §119.65. Section 119.65 is the Part 121 management-personnel section — it covers required management positions for domestic, flag, and supplemental (Part 121) operations. A common error in templates, recruiter materials, and even some internal manuals is to cite §119.65 for a Part 135 operator. If your manual or a checklist points to §119.65 for your on-demand or commuter Part 135 management requirements, the citation is wrong: the 10-day notification you owe is under §119.69(e)(3), the required positions are §119.69(a), and the qualifications are §119.71. Getting the citation right matters because an inspector reviewing your manual will notice a Part 121 section governing a Part 135 obligation.
Who do you send the Part 135 management-vacancy notification to?
14 CFR §119.69(e)(3) requires notification to "the responsible Flight Standards office" — in practice, the Flight Standards District Office (FSDO) or certificate-management office that oversees your certificate, working through your principal operations inspector (POI) and, for a maintenance-position change, your principal maintenance inspector (PMI). The rule does not prescribe a single form or letter format for the notice, but the safe practice is a dated, written notification that identifies the position that changed or became vacant, the effective date of the change, and how the position is being covered or who is proposed to fill it. Because the same §119.69(e) provision requires you to keep a current list of the names and business addresses of the individuals in your required positions, the vacancy notice and the updated management-personnel list go hand in hand.
Can you keep operating Part 135 while a management position is vacant?
It depends on the position and on what your responsible Flight Standards office accepts — the rule does not hand you a blanket right to keep flying indefinitely with a required seat empty. The baseline in 14 CFR §119.69(a) is that a multi-pilot certificate holder must have qualified personnel in the Director of Operations, Chief Pilot, and Director of Maintenance positions. When one of those goes vacant, you owe the §119.69(e)(3) notification within 10 days, and you have to address how the function is covered. Some operators arrange for an interim or acting appointee who meets the §119.71 qualifications, or have a deviation accepted under §119.69(b) for a different management structure, but those are FAA-accepted arrangements, not self-declared ones. Operating with an unaddressed vacancy in a required position is a compliance exposure, so the realistic answer is: notify within 10 days, and resolve the coverage with your POI rather than assuming operations simply continue.
What records prove you handled a Part 135 management vacancy correctly?
The documentary trail has three layers, all tied to 14 CFR §119.69(e). First, the dated §119.69(e)(3) notification to your responsible Flight Standards office identifying the change or vacancy and its effective date. Second, the updated management-personnel list — the names and business addresses of the individuals in your required positions, current as of the change. Third, the qualification package for the incoming or interim appointee: the pilot certificate (or A&P certificate for a Director of Maintenance) and the dated §119.71 experience evidence, plus the appointment and FAA-acceptance documentation reflected in your management structure and Operations Specifications under §119.69(c). Keeping these dated and linked is what lets you show an inspector that the transition was handled on time and that the position was filled by a qualified, accepted individual. FileFlo classifies and indexes those records; it does not source, hire, place, qualify, or certify the replacement.
Does notifying the FAA of a vacancy apply to the Chief Pilot and Director of Maintenance too?
Yes. The 10-day notification in 14 CFR §119.69(e)(3) applies to any change in personnel or any vacancy in any of the required positions listed under §119.69(a) — Director of Operations, Chief Pilot, and Director of Maintenance — not just the Director of Operations. A Chief Pilot departure or a Director of Maintenance departure starts the same 10-day clock, and each replacement has to meet its own §119.71 qualification standard: the Chief Pilot standard in §119.71(c)/(d) and the Director of Maintenance standard in §119.71(e), which requires a mechanic certificate with airframe and powerplant ratings plus the relevant 3-years-in-6 experience. For a maintenance-position change, the notification and qualification review typically run through your principal maintenance inspector rather than your principal operations inspector. The mechanics are the same across all three roles: notify within 10 days, keep the personnel list current, and fill the seat with a qualified, accepted individual.
Keep your management-personnel records current and provable
A Part 135 management departure starts a §119.69(e)(3) clock — 10 days to notify Flight Standards — and that is no time to be hunting for paperwork. FileFlo classifies and indexes the records behind every required position — the §119.71 qualification package, the FAA acceptance, the operations-manual duties section, and the management-personnel list — with expiration and vacancy alerts and a one-click 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. This article is educational and is not legal, career, recruiting, or HR advice. FileFlo is not a recruiter and does not place, qualify, or certify replacements. For your operation’s deadlines and whether you may continue operating during a vacancy, confirm with your responsible Flight Standards office.