Direct Answer: What Medical Certificate Does Part 135 Require?
A Part 135 pilot in command needs a first-class medical certificate when the operation requires an ATP certificate — passenger-carrying operations of turbojet airplanes, airplanes with 10 or more passenger seats, or multiengine airplanes in commuter operations under 14 CFR §135.243(a)(1) — and at least a second-class medical for Part 135 PIC duty outside the §135.243(a) ATP-required categories and for required SIC duty, because those pilots exercise commercial pilot privileges under §61.23(a). BasicMed never qualifies. Durations run by calendar month from the examination date under §61.23(d): first-class supports ATP privileges for 12 calendar months (under age 40 at the exam) or 6 calendar months (age 40 or older); first- and second-class both support commercial privileges for 12 calendar months regardless of age. The operator's pilot record under §135.63(a)(4)(v) must show the effective date and class of each pilot's medical, and the operator — not the pilot — answers for it at a surveillance visit.
The expiration is computed, not printed: the certificate shows the examination date, and the deadline falls at the end of the last day of the 6th or 12th month after the month of examination for Part 135 privileges. There is no grace month for medicals — the §135.301(a) month-before/month-after provision covers Part 135 tests and checks, not medical certificate duration.
A lapsed medical converts every subsequent flight into a violation
A pilot whose medical lapsed on June 30 is not qualified for Part 135 duty on July 1 — and every revenue leg flown after that date is an operation by an unqualified crewmember. Civil penalties under 49 U.S.C. §46301 reach $75,000 per violation for operators other than individuals or small business concerns — $1,875 per violation for individuals and small business concerns — under the inflation-adjusted penalty table at 14 CFR §13.301 (violations on or after December 30, 2024). Because the expiration is computed rather than printed, the medical is the easiest document in the per-crewmember file to get silently wrong.
Quick context check before the detail: medical standards and issuance live in 14 CFR Part 67 (the aviation medical examiner's territory), the class-and-duration rules live in §61.23 (the pilot's obligation), and the recordkeeping obligation lives in §135.63 (the certificate holder's obligation). This post covers the second and third layers — what the operator must understand and what the operator must keep. Want the full file context first? Start with every record a Part 135 operator must keep.
Which Class for Which Part 135 Duty
Part 135 itself never names a medical class — §135.243 and §135.245 specify pilot certificates and experience, and the medical class follows from §61.23(a), which keys the class to the privileges being exercised. That two-step is where tracking errors start: the class a pilot needs is a function of the operation flown, not the certificate in the wallet.
PIC of ATP-required operations → first-class medical
Under §135.243(a)(1), the PIC in passenger-carrying operations of a turbojet airplane, an airplane with a passenger-seat configuration of 10 seats or more (excluding each crewmember seat), or a multiengine airplane in a commuter operation must hold an ATP certificate. That pilot is exercising ATP pilot-in-command privileges, and §61.23(a)(1) requires a first-class medical certificate when exercising them. For a charter operator running a light jet, every PIC on the jet is on the first-class renewal cycle — 6 calendar months at a time for any captain who was 40 or older at the exam.
PIC of commercial-certificate operations → second-class minimum
For Part 135 operations outside the §135.243(a) categories — the (a)(1) airplane trio, plus (a)(2) scheduled interstate helicopter operations and (a)(3) certain powered-lift operations, all of which require an ATP — the PIC may fly on a commercial pilot certificate: §135.243(b) covers VFR operations (commercial certificate with appropriate category and class ratings, at least 500 hours total time including 100 cross-country and 25 night) and §135.243(c) covers IFR operations (commercial certificate with an instrument rating, at least 1,200 hours total time including 500 cross-country, 100 night, and 75 hours of instrument time, at least 50 of them in actual flight). That pilot exercises commercial pilot privileges, and §61.23(a)(2) requires at least a second-class medical when exercising the privileges of a commercial pilot certificate in an aircraft other than a balloon or glider. A first-class certificate also works, of course — it carries second-class privileges through its 12th month.
Required second in command → second-class minimum
Under §135.245(a), a required SIC must hold at least a commercial pilot certificate with appropriate category and class ratings and an instrument rating (with a narrow exception in §135.245(b) for certain helicopter VFR operations). Exercising commercial privileges pairs with a second-class medical under §61.23(a)(2). Note the contrast with Part 121: the rules in §61.23(a)(1)(ii) and (a)(1)(iii) that push certain SICs and age-60-plus crewmembers to a first-class medical are, by their own terms, Part 121 provisions — they do not import into Part 135. SIC files have their own pitfalls beyond the medical; the training-record requirements apply to every required crewmember.
The privileges-exercised principle
§61.23(a) attaches the medical class to the privileges being exercised on the flight. An ATP-certificated pilot flying a Part 135 operation for which a commercial certificate suffices is exercising commercial privileges, and the second-class durations govern that flight. The same pilot moved onto the operator's jet the next morning is exercising ATP PIC privileges, and the first-class window — possibly already closed if the pilot is over 40 and more than 6 months past the exam — governs instead. One pilot, one certificate, two different expiration dates depending on the tail flown. Operators that track a single medical expiry date per pilot are modeling the regulation wrong.
Is your crew roster modeled by privileges — or by a single expiry column?
FileFlo's free FAA Readiness Score evaluates your documentation posture against the key Part 135 record requirements, including per-pilot medical tracking. No signup required — takes under 3 minutes.
Run the FAA Readiness Score — FreeThe §61.23(d) Duration Table, Translated for Part 135
The duration table in 14 CFR §61.23(d) runs on three inputs: the class of certificate held, the pilot's age on the date of examination for the most recent medical certificate, and the class of operation being conducted. Every interval ends at the end of the last day of a calendar month — the standard phrasing is that the certificate expires at the end of the last day of the 12th month after the month of the date of examination shown on the medical certificate (or the 6th, 24th, or 60th month, depending on the row).
The useful mental model for an operator: a medical certificate does not expire once. It steps down — a first-class certificate stops supporting ATP privileges first, keeps supporting commercial privileges through the 12th month, and keeps supporting private-pilot privileges long after it is useless for Part 135 duty. Only the first two steps matter for your roster.
| Class Held | Privileges Being Exercised | Under 40 at Exam | 40 or Older at Exam | Part 135 Relevance |
|---|---|---|---|---|
| First class | ATP pilot-in-command privileges — §61.23(a)(1) | End of the 12th month after the month of examination | End of the 6th month after the month of examination | PIC of turbojet, 10+ passenger-seat, or multiengine commuter passenger ops (§135.243(a)(1)) |
| First class | Commercial pilot privileges (operation requiring only a second-class medical) | End of the 12th month | End of the 12th month (no age split) | PIC under §135.243(b)/(c); required SIC under §135.245 |
| Second class | Commercial pilot privileges — §61.23(a)(2) | End of the 12th month | End of the 12th month (no age split) | Minimum class for most Part 135 PIC and SIC duty |
| First or second class | Private pilot privileges (operation requiring only a third-class medical) | End of the 60th month | End of the 24th month | Not sufficient for Part 135 flightcrew duty — personal flying only |
| Third class | Private, recreational, or student pilot privileges — §61.23(a)(3) | End of the 60th month | End of the 24th month | Never sufficient for Part 135 flightcrew duty |
Durations per the table at 14 CFR §61.23(d) as published on eCFR.gov; age brackets keyed to the pilot's age on the date of examination for the most recent medical certificate. Verify against the current eCFR before relying on this summary for a qualification determination.
Worked example: one exam, three horizons
A 47-year-old captain passes a first-class examination on June 10, 2026. For ATP PIC privileges — the operator's jet — the certificate is valid through December 31, 2026 (end of the 6th month after June). For commercial privileges — the operator's turboprop, or SIC duty — it runs through June 30, 2027 (end of the 12th month). For the captain's personal Part 91 flying on private privileges, it runs through June 30, 2028 (end of the 24th month, age 40 or older).
Had the same exam happened at age 39, the ATP window would run the full 12 months, through June 30, 2027 — and the private-privileges tail would stretch to the 60th month. The age bracket locks at the exam date and stays locked for the life of that certificate.
No grace month — and no printed date
The month-before/month-after provision of §135.301(a) applies to Part 135 tests and checks — the §135.293 recurrent and §135.297 IPC cycles described in our pilot-records guide — not to medical duration. When the calendar month ends, the privileges end.
And because the certificate shows the examination date rather than an expiration date, the deadline only exists in whatever system the operator uses to compute it. A transposed exam month, a missed age-40 bracket, or a class typo in the tracking sheet produces a confident, wrong answer that nothing on the paper contradicts.
Two more duration behaviors worth wiring into any tracking logic. First, the calendar-month convention means an exam early in the month buys almost a free month: a July 2 exam and a July 30 exam both expire at the same month-end. Second, the renewal exam resets the clock to the new examination month — so a captain who renews three weeks before the old certificate lapses starts the new 6- or 12-month count from the new exam month, not from the old expiration. Medical renewals do not stack or anchor the way check cycles anchored by §135.301(a) do.
Tracking medicals in a spreadsheet? FileFlo classifies each uploaded medical certificate, captures class and examination date, and computes calendar-month expirations per role — with 90/60/30-day alerts.
BasicMed Never Satisfies Part 135 — Even After the 2024 Expansion
BasicMed lets certain pilots fly without holding an FAA medical certificate, resting instead on a valid U.S. driver's license plus the requirements of 14 CFR Part 68 and §61.23(c)(3): a comprehensive medical examination by a State-licensed physician during the preceding 48 calendar months, a medical education course completed in the preceding 24 calendar months, and a part 67 medical certificate held at any point after July 14, 2006 — with the most recent medical not suspended or revoked, any Authorization for Special Issuance not withdrawn, and the most recent application not denied.
None of that reaches Part 135, and the chain is short. §61.23(c)(3) confines BasicMed to operations conducted under the conditions and limitations of §61.113(i) — a paragraph of the private pilot privileges section. A required Part 135 crewmember is exercising commercial or ATP privileges, and §61.23(a) attaches a second- or first-class medical to those privileges. There is no BasicMed row in that paragraph.
What §61.113(i) actually covers (current rule)
- Aircraft authorized to carry not more than 7 occupants, with not more than 6 passengers on board
- Maximum takeoff weight of not more than 12,500 pounds (and not a transport-category rotorcraft)
- At or below 18,000 feet MSL, not exceeding 250 knots indicated airspeed
- Within the United States, unless authorized by the country where the flight occurs
These are the enlarged limits reflecting the 2024 BasicMed expansion enacted in the FAA reauthorization legislation. The expansion grew the covered-aircraft envelope — it did not change which operations BasicMed covers.
Why it cannot reach a Part 135 flight
- Part 135 PICs exercise ATP or commercial privileges — §61.23(a)(1) and (a)(2) require first- or second-class medicals for those privileges
- BasicMed is limited by §61.23(c)(3) to operations under §61.113(i), which sits inside the private-pilot privileges section
- Fitting the airframe envelope changes nothing — a piston twin under 12,500 pounds with 5 passengers is still outside §61.113(i) the moment the flight is a Part 135 operation
- A pilot may personally fly Part 91 under BasicMed and still be unqualified for the operator's Part 135 roster until a part 67 first- or second-class medical is current
The hiring-desk failure mode looks like this: a resume arrives from a 5,000-hour pilot who has been flying a Bonanza under BasicMed for three years. Every logbook entry is legitimate, the driver's license is valid, the part 68 course certificate is current — and none of it satisfies the §135.63(a)(4)(v) record item, because the pilot holds no current part 67 medical certificate with a class and an effective date to record. The pre-hire workflow — alongside the PRD evaluation under Part 111 and the pre-employment drug-test record — has to include a fresh AME visit before the pilot touches a revenue leg.
One adjacent rule completes the picture: §61.53, the prohibition on operations during medical deficiency. Under §61.53(a), a pilot who holds a current medical certificate still may not act as PIC or as a required pilot flight crewmember while the pilot knows or has reason to know of a medical condition that would make the pilot unable to meet the requirements for the medical certificate necessary for the operation — or while taking medication or receiving treatment with the same effect. A current certificate on file is necessary, not sufficient; the self-grounding obligation runs continuously between exams. That is worth a line in the GOM and a briefing slot in recurrent ground training, because the operator's operational control responsibilities do not pause while a quietly disqualified pilot keeps flying on paper that looks current.
Hiring? Catch the BasicMed gap before the first revenue leg
FileFlo flags a crew file that is missing a current part 67 medical — class and effective date — the moment the file is assembled, so a BasicMed-only new hire never slips onto the schedule looking complete.
The Operator's Side: §135.63(a)(4)(v) and the Record That Proves It
Everything above is the pilot's qualification problem. Here is the certificate holder's recordkeeping problem. Under 14 CFR §135.63(a)(4), each certificate holder must keep an individual record of each pilot used in operations under the part, and the list of required contents includes, at romanette (v):
"The effective date and class of the medical certificate that the pilot holds."
— 14 CFR §135.63(a)(4)(v)
Two words in that romanette do the work. Effective date means the record must carry the examination date the computation runs from — not a hand-computed expiry someone typed in once. Class means the record must distinguish first from second, because the durations differ and because the class the operation requires can change with the aircraft assigned. The medical item sits inside a ten-item list that also covers the pilot's name, certificate and ratings, aeronautical experience, current duties and assignment date, test and check results, flight time detail, check pilot authorization, release-from-employment actions, and training completion dates — the full per-pilot file we map item-by-item in the Part 135 pilot records guide. A parallel record requirement covers flight attendants at §135.63(a)(5), and the check airmen and instructors on your certificate are pilots used in operations too.
Retention: under §135.63(b), the records required by (a)(4) and (a)(5) must be kept for at least 12 months. Read that as a floor, not a schedule — the record must stay current for as long as the pilot is used in operations, so the practical retention is the full employment period plus at least 12 months, and many operators keep separated-crew files for 3 to 5 years to defend enforcement actions that arrive late. When an inspector works a surveillance visit, the medical line in each pilot record is among the fastest items to check and the most embarrassing to fail — the inspector simply compares the recorded class and effective date against the duty the pilot has been flying and counts calendar months. Our surveillance-audit preparation guide covers how that visit unfolds end to end.
What a defensible medical-tracking record captures
| Field | Why It Is Load-Bearing | Failure Mode If Missing |
|---|---|---|
| Certificate class (first / second) | Required by §135.63(a)(4)(v); selects the duration row and the duty the pilot can fly | Second-class pilot scheduled onto an ATP-required operation |
| Examination date (the effective date) | The anchor every calendar-month computation runs from; the certificate shows no expiration | Expiry computed from an issuance or upload date instead of the exam month |
| Age bracket at examination (under 40 / 40+) | Locks the 12-vs-6-month first-class window for the life of that certificate | A 41-year-old captain tracked on the 12-month ATP window — 6 months of unqualified flying |
| Privileges required per assignment (ATP vs commercial) | One certificate carries different expirations for different tails and seats | Single expiry column silently blesses jet duty after the 6-month window closed |
| Computed expiration per privilege level | End of the last day of the relevant calendar month — the date alerts must key on | Mid-month anniversary-date alerts that fire after the real month-end deadline logic matters |
| Image of the certificate itself | The inspector verifies the record against the source document, not against your spreadsheet | A correct database row with no document behind it is an unproven claim at audit time |
Roster math makes the case for automation. A 12-pilot operator with, say, eight captains over 40 flying ATP-required equipment generates 16 first-class renewals a year from those eight alone, plus annual renewals for everyone else — on top of the §135.293, §135.297, and §135.299 check cycles, the drug and alcohol program records, and the training events in the approved program. Each medical renewal changes two fields (class can change at renewal too — pilots sometimes downgrade to second class deliberately) and recomputes up to two expiration horizons. The person responsible for keeping that straight is usually the Director of Operations wearing the required-management-personnel hat among several others — which is exactly why this category of finding shows up in surveillance results for honest, busy operators, not negligent ones. Operators heading into the SMS mandate will also find that a hazard register full of expired-qualification-document events is the first thing a safety assurance process flags.
How FileFlo Keeps Medical Certificates Provably Current
FileFlo is a compliance document intelligence platform — the proof layer for the records this post describes. It does not schedule AME appointments, decide medical qualification, run your safety program, or replace the Director of Operations. It makes sure that when anyone asks — a scheduler, a DO, or an FAA inspector — the medical certificate on file for every pilot is the current one, classified correctly, with an expiration computed the way §61.23(d) actually works.
Classification that knows a medical certificate when it sees one
Upload the certificate and FileFlo classifies it as an airman medical certificate and indexes it to the right pilot — alongside the pilot certificate, checks, and training records in the §135.63(a)(4) file. No misfiled medicals sitting in a training folder.
Calendar-month expiration logic, per privilege level
FileFlo tracks expirations to the end of the relevant calendar month — not a rolling 365 days from upload. A first-class exam in June for a captain over 40 shows ATP privileges through December 31 and commercial privileges through June 30 of next year, with 90/60/30-day alerts ahead of each.
One-click crew file for the surveillance visit
When the inspector asks for pilot records, FileFlo produces the per-crewmember file — medical class and effective date included — for one pilot or the whole roster, organized the way §135.63(a)(4) lists it. File-pulling afternoons become a sixty-second export.
Proof layer, honestly scoped
FileFlo proves the records exist, are current, and are organized — it does not conduct exams, host the medical application process, or integrate with FAA systems. The AME and the airman own the medical; the operator owns the record; FileFlo keeps the record audit-ready.
See where your medical tracking stands today
The free FAA Readiness Score checks your documentation posture against the key Part 135 record requirements — medicals, checks, training, and the rest of the §135.63 file. Under 3 minutes, no signup.
Run the FAA Readiness Score — FreePart 135 Crew Compliance: Related Guides
Part 135 Pilot Records: The Complete Per-Crewmember File
Crew RecordsEvery Record a Part 135 Operator Must Keep
RecordkeepingPart 135 Drug & Alcohol Program Records Checklist
Crew RecordsPilot Records Database (PRD): Part 111 Requirements
HiringHow to Prepare for a Part 135 FAA Surveillance Audit
Audit PrepFAA Part 135 SMS: The 2027 Deadline Explained
SMSFrequently Asked Questions
What class of medical certificate does a Part 135 pilot in command need?
It depends on the certificate the operation requires. Under 14 CFR §135.243(a)(1), passenger-carrying operations of turbojet airplanes, airplanes with 10 or more passenger seats (excluding crewmember seats), or multiengine airplanes in commuter operations require the PIC to hold an Airline Transport Pilot certificate — and under §61.23(a)(1), exercising ATP pilot-in-command privileges requires a first-class medical certificate. For Part 135 operations outside the ATP-required categories of §135.243(a) — which also include helicopters in scheduled interstate air transportation under (a)(2) and certain powered-lift operations under (a)(3) — §135.243(b) and (c) allow the PIC to fly on a commercial pilot certificate, and under §61.23(a)(2) exercising commercial pilot privileges requires at least a second-class medical certificate. A third-class medical is never sufficient for Part 135 flightcrew duty.
How long is a first-class medical certificate valid for Part 135 operations?
Under the duration table in 14 CFR §61.23(d), a first-class medical certificate supports ATP pilot-in-command privileges through the end of the last day of the 12th month after the month of the date of examination if the pilot was under age 40 on the examination date, or the 6th month if the pilot was age 40 or older. After the first-class window closes, the same certificate continues to support operations requiring only a second-class medical — commercial pilot privileges, which cover most Part 135 PIC and SIC duty — through the end of the 12th month after the month of examination, regardless of age. So a 45-year-old captain flying an operation that requires an ATP certificate must renew every 6 calendar months, while the same certificate would carry a commercial-privileges operation for 12 calendar months.
Can a Part 135 pilot fly on BasicMed instead of an FAA medical certificate?
No. BasicMed is confined by 14 CFR §61.23(c)(3) to operations conducted under the conditions and limitations of §61.113(i) — a private-pilot provision. Part 135 flightcrew members exercise commercial or ATP privileges, and §61.23(a) pairs those privileges with second-class and first-class medical certificates respectively. The 2024 BasicMed expansion enlarged the covered-aircraft envelope (up to 7 occupants, 6 passengers, and 12,500 pounds maximum takeoff weight) but did not extend BasicMed to Part 135 operations. A pilot may personally fly under BasicMed for their own Part 91 flying, but to serve as a required crewmember in Part 135 operations they must hold a current first- or second-class medical issued under 14 CFR Part 67.
What does 14 CFR §135.63(a)(4)(v) require the operator to record?
Under §135.63(a)(4), every Part 135 certificate holder must keep an individual record of each pilot used in operations under the part, and romanette (v) of that list requires the record to show the effective date and class of the medical certificate that the pilot holds. The medical item sits alongside the pilot's full name, certificate type and number with ratings, aeronautical experience, current duties and assignment date, test and check results, flight time detail, check pilot authorization, release-from-employment actions, and training completion dates. Under §135.63(b), the pilot records required by (a)(4) must be kept for at least 12 months — and because the record must stay current for as long as the pilot is used in operations, the practical retention is the full employment period plus at least 12 months.
When does an FAA medical certificate actually expire? There is no expiration date printed on it.
FAA medical certificates use calendar-month durations measured from the month of the examination date shown on the certificate — the certificate displays the examination date, and the holder or operator computes the expiration. Under §61.23(d), the certificate expires at the end of the last day of the 6th, 12th, 24th, or 60th month after the month of the date of examination, depending on the class, the privileges being exercised, and whether the pilot was under age 40 on the examination date. Example: a second-class medical issued after an exam on February 3, 2026 supports commercial pilot privileges through February 28, 2027 — the end of the 12th month after February 2026 — not just through February 3, 2027.
A pilot turns 40 in the middle of the medical certificate period. Does the duration shorten?
No. The duration table in §61.23(d) keys every interval to the pilot's age on the date of examination for the most recent medical certificate — not the pilot's age today. A pilot who was 39 on the examination date keeps the under-40 durations for that certificate even after turning 40 mid-period. The shorter age-40-or-older intervals first apply to the next certificate, issued after the next examination. For operator tracking, this means the age bracket must be captured per examination, not recalculated continuously.
Is there a grace month for medical certificates like the one for Part 135 checks?
No. The month-before/month-after provision in 14 CFR §135.301(a) applies to the tests and checks required by Part 135 — such as §135.293 recurrent checks and §135.297 instrument proficiency checks — not to medical certificate duration. A medical certificate expires at the end of the last day of its final calendar month under §61.23(d), full stop. A pilot whose second-class privileges lapsed on June 30 is not qualified for Part 135 duty on July 1, and there is no administrative cushion. The only flexibility in the system is that renewing early in the expiration month preserves more of the new period than renewing did under older anniversary-date schemes — the new period runs from the month of the new examination.
What happens if a pilot flies a Part 135 trip with a lapsed medical certificate?
Every flight after the lapse is an operation by an unqualified crewmember, and both the pilot and the certificate holder are exposed. Separately, 14 CFR §61.53(a) prohibits a medical certificate holder from acting as PIC or as a required pilot flight crewmember while the person knows or has reason to know of any medical condition that would make the person unable to meet the requirements for the medical certificate necessary for the pilot operation — so medical disqualification can ground a pilot even while the certificate is unexpired. On the operator side, civil penalties under 49 U.S.C. §46301 reach $75,000 per violation for operators other than individuals or small business concerns ($1,875 per violation for individuals and small business concerns) under the inflation-adjusted table at 14 CFR §13.301 for violations on or after December 30, 2024 — and a pattern of lapsed-medical operations is the kind of finding that escalates from civil penalty to certificate action.
Chad Griffith — Founder, FileFlo — compliance document intelligence. FileFlo classifies, indexes, and tracks the expiration of compliance documents for regulated operators, including 14 CFR Part 135 certificate holders.
This article reflects a compliance-document perspective on 14 CFR §§61.23, 61.53, 61.113, 135.63, 135.243, and 135.245 as published on eCFR.gov at the review date. It is not legal advice or aeromedical guidance — consult your AME, DO, or aviation counsel for determinations about a specific pilot or operation.
Stop computing medical expirations by hand
FileFlo classifies every medical certificate against the pilot file, captures class and examination date, computes calendar-month expirations per privilege level, and keeps the §135.63(a)(4) record inspector-ready. Starter $89/month, Professional $299/month — 5-day free trial, no credit card required.
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