Direct Answer
Under 14 CFR §119.69(a), every Part 135 certificate holder must staff three required management positions: a Director of Operations, a Chief Pilot, and a Director of Maintenance.
The qualifications for each are set in 14 CFR §119.71. The Director of Operations and Chief Pilot must hold the appropriate pilot certificate and have specified pilot-in-command or operational-control experience within the last 6 years; the Director of Maintenance must hold a mechanic certificate with airframe and powerplant ratings plus 3 years of qualifying maintenance experience within the last 6 years.
The only stated exception is a single-pilot operator. The FAA may approve a different number or categories of positions under §119.69(b), and may authorize an individual deviation from the experience requirements under §119.71(f). For the operator, the practical task is keeping a current qualification file for each person that proves the §119.71 standard on demand.
The Precise Regulatory Language
The requirement to have management personnel lives in 14 CFR §119.69, titled "Management personnel required for operations conducted under part 135 of this chapter." Subsection (a) states that each certificate holder must have sufficient qualified management and technical personnel to ensure the safety of its operations, and that — except for a certificate holder using only one pilot in its operations — the certificate holder must have qualified personnel serving in the following or equivalent positions:
14 CFR §119.69(a) — Required positions
- 1Director of Operations — the management official responsible for the conduct of flight operations.
- 2Chief Pilot — the management pilot responsible for crew standards and the conduct of flights.
- 3Director of Maintenance — the management official responsible for the airworthiness of the operator's aircraft.
The phrase "or equivalent positions" matters: the FAA recognizes that an operator may use a different title, but the function must be covered. And §119.69(b) allows the Administrator to approve a different number of positions, or different categories of management personnel, if the certificate holder shows it can conduct operations safely under the direction of fewer or different categories of management personnel. The Administrator weighs three factors: (1) the kind of operation involved; (2) the number and type of aircraft used; and (3) the area of operations.
Don't confuse §119.69 (Part 135) with §119.65 (Part 121)
14 CFR §119.65 lists the management positions required for Part 121 operations (which add a Director of Safety and other roles). §119.69 is the Part 135 section, and it names exactly three required positions. Likewise, §119.71 contains the qualifications for Part 135 management personnel; §119.67 contains the separate qualifications for Part 121. When you cite the rule, make sure you are in the §119.69/§119.71 pair for Part 135.
These positions are the human backbone of the certificate. They connect to the broader Part 135 record set — see what records a Part 135 operator must keep for the full index, and the FAA aviation compliance hub for the surrounding framework.
Why Required Management Personnel Are a Certificate-Level Issue
The management positions in §119.69 are not org-chart decoration. They are a condition of holding the certificate. The FAA accepts each named individual when it issues or amends the certificate, and the individuals are reflected in the certificate holder's management structure on file with its certificate-management office. If a required position goes vacant and is not filled with a qualified, FAA-accepted person, the certificate holder is — during that gap — operating without the management structure the rule requires.
This is why management personnel come up early in any Part 135 FAA surveillance audit. A principal operations inspector (POI) or principal maintenance inspector (PMI) will ask, in effect: who is your Director of Operations, your Chief Pilot, and your Director of Maintenance — and can you prove each one meets §119.71? An operator that answers with current certificates, a clean experience summary, and the FAA acceptance on file is in a completely different posture than one that has to reconstruct a qualification story after the question is asked.
What the three positions actually govern
The Director of Operations role is closely tied to the concept of operational control. The §119.71 experience standard for a DO is explicitly about experience in a position that "exercised operational control" over Part 121 or Part 135 operations. For the full distinction between the position and the legal obligation, see what operational control means in Part 135.
Qualifications by Role — The §119.71 Standard
14 CFR §119.71 sets the qualifications for each required position. The exact standard for the Director of Operations and Chief Pilot depends on whether the certificate holder conducts operations requiring an airline transport pilot (ATP) certificate or only a commercial pilot certificate. The core experience threshold across all three roles is consistent: 3 years of qualifying experience within the last 6 years. The subsection map below reflects the structure of §119.71 as published.
Director of Operations
14 CFR §119.71(a) (ATP operations) / §119.71(b) (commercial operations)Certificate required
Must hold the pilot certificate matching the operation — an ATP certificate for operations requiring an ATP PIC (§119.71(a)), or a commercial pilot certificate (with an instrument rating if the operations require it) for commercial-only operations (§119.71(b)).
Experience required
Either (1) at least 3 years of supervisory or managerial experience within the last 6 years in a position that exercised operational control over operations conducted under Part 121 or Part 135; or (2) for a person with no prior experience as a Director of Operations, at least 3 years of experience within the past 6 years as pilot in command of an aircraft operated under Part 121 or Part 135.
Chief Pilot
14 CFR §119.71(c) (ATP operations) / §119.71(d) (commercial operations)Certificate required
Must hold a current pilot certificate with the appropriate ratings to act as pilot in command in the operations conducted by the certificate holder — an ATP certificate for ATP operations (§119.71(c)) or a commercial pilot certificate with the required ratings for commercial-only operations (§119.71(d)).
Experience required
At least 3 years of experience within the past 6 years as pilot in command of an aircraft operated under Part 121 or Part 135. A person who has previously served as a Chief Pilot for a Part 121 or Part 135 certificate holder needs at least 3 years as PIC under Part 121 or 135 with no recency window (§119.71(c)(2)/(d)(2)). The Chief Pilot must be qualified to serve as PIC in at least one aircraft used in the operation.
Director of Maintenance
14 CFR §119.71(e)Certificate required
Must hold a mechanic certificate with both airframe and powerplant (A&P) ratings. This is the management-qualification standard — separate from the §43.7 / §43.9 question of who may sign a maintenance record return-to-service entry.
Experience required
Either (1) 3 years of experience within the past 6 years maintaining aircraft as a certificated mechanic, including, at the time of appointment, experience maintaining the same category and class of aircraft as used by the certificate holder; or (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.
The "ATP vs. commercial" fork drives the DO and Chief Pilot standard
Whether your operation requires an ATP-certificated PIC (for example, certain turbojet or scheduled operations) or only a commercial pilot certificate determines which §119.71 subsection applies to your Director of Operations and Chief Pilot. An operator that grows from commercial-only into ATP-required operations may need to re-confirm that its incumbent DO and Chief Pilot still meet the higher certificate standard. The Director of Maintenance standard in §119.71(e) does not change with that fork.
The Chief Pilot and Director of Maintenance roles sit directly on top of two of the most heavily audited Part 135 record sets — pilot records and maintenance records. For the records each role administers, see the Part 135 pilot records the FAA requires and the maintenance-entry standard in §43.9 maintenance record entries.
Can you prove your DO, Chief Pilot, and DOM meet §119.71 — today?
FileFlo classifies and indexes each management person's qualification package — pilot or mechanic certificate, medical, experience summary, and FAA acceptance — and tracks expirations so a vacancy or lapsed credential surfaces before an inspector finds it. Starter at $89/mo, Professional at $299/mo. 5-day free trial, no credit card required.
Deviations, Vacancies, and Personnel Changes
The rule contains two distinct flexibility mechanisms, and operators routinely confuse them.
Different number or categories of positions — §119.69(b)
This is about the structure of management. Under §119.69(b), the Administrator may approve a certificate holder operating with a different number of positions, or different categories of management personnel, if the operator shows it can conduct operations safely under the direction of fewer or different categories of management personnel — judged against the kind of operation, the number and type of aircraft, and the area of operations. A small operator might, for example, combine functions under one accepted individual. This is an approval of the management structure itself.
Individual experience deviation — §119.71(f)
This is about a specific person. Under §119.71(f), a certificate holder may request a deviation to employ a person who does not meet the applicable aeronautical experience, managerial experience, or supervisory experience requirements. The deviation is authorized at FAA headquarters by the Manager of the Air Transportation Division (AFS-200) or the Manager of the Aircraft Maintenance Division (AFS-300), as appropriate (§119.71(f)) — not the local POI/PMI — if the person has comparable experience and can effectively perform the functions associated with the position. The deviation is discretionary, fact-specific, and documented by the FAA — it is not something the operator grants itself.
Vacancies are the highest-risk scenario. When a Director of Operations, Chief Pilot, or Director of Maintenance leaves, the certificate holder must notify the FAA and provide the replacement's qualification records so the FAA can confirm the §119.71 requirements are met. Operators often have a short, FAA-coordinated window to fill a vacated required position with an interim or permanent qualified individual. Continuing to operate with an unfilled required position — or with an appointee whose qualifications have not been accepted — is a finding. The documentation discipline here is simple but unforgiving: the moment a person changes, the qualification file for the new person needs to be complete and retrievable.
Management personnel change — the documentation sequence
Confirm the candidate meets §119.71
Verify the correct certificate (ATP/commercial or A&P) and the 3-years-in-6 experience for the specific role and operation level
Assemble the qualification package
Pilot or mechanic certificate, current medical (where PIC duties apply), experience summary/resume, and any prior-equivalent documentation
Notify the FAA certificate-management office
Provide the new individual to the POI/PMI; request a §119.71(f) deviation if the person relies on comparable experience
Obtain FAA acceptance / OpSpecs reflection
Do not let the person serve as the required official until the FAA has accepted the appointment
File and index the package
Store the complete, dated qualification file so the §119.71 proof is retrievable on demand during surveillance
The same surveillance posture that applies to operational records applies here. For the broader inspection context — including how the FAA distinguishes a compliance action from an enforcement action — see how to prepare for a Part 135 FAA surveillance audit, and for the safety-program records arriving on the same regulatory horizon, see the Part 135 SMS 2027 deadline.
The Qualification Records That Prove §119.71
Meeting §119.71 is one thing; proving it on demand is another. For each required management person, the operator should maintain a documented, current qualification package. When an inspector says "show me that your Director of Operations meets §119.71," the answer should be a single retrievable folder — not a search through email and HR files. Below are the records that make up that package and how a document-intelligence layer keeps them audit-ready.
Pilot Certificate (DO & Chief Pilot)
14 CFR §119.71(a)–(d)What it proves
The Director of Operations and Chief Pilot must hold the pilot certificate matching the operation — ATP for ATP-required operations, or commercial (with instrument rating where required) for commercial-only operations. The certificate, with its ratings, is the threshold credential the FAA confirms.
How FileFlo tracks it
FileFlo classifies and indexes pilot certificates as a document class, tags them to the management role, and surfaces any rating mismatch against the operation level.
Mechanic Certificate with A&P Ratings (DOM)
14 CFR §119.71(e)What it proves
The Director of Maintenance must hold a mechanic certificate with both airframe and powerplant ratings. This is the management-qualification credential — distinct from §43.7/§43.9 return-to-service signing authority, which the DOM may also exercise but which is governed separately.
How FileFlo tracks it
FileFlo stores the A&P certificate, links it to the DOM role, and includes it in the management qualification binder for surveillance.
Medical Certificate (where PIC duties apply)
14 CFR Part 61 / §61.23What it proves
Where a management pilot — typically the Chief Pilot, who must be qualified to serve as PIC in at least one of the operator’s aircraft — actually acts as PIC, a current medical certificate of the appropriate class is required. The class and validity period depend on the operation and the pilot’s age.
How FileFlo tracks it
FileFlo tracks medical certificate class and expiration with proactive alerts, so a lapsing medical on a management pilot is flagged before it affects qualification.
Experience Summary / Resume
14 CFR §119.71 (3-years-in-6 standard)What it proves
A documented summary showing the §119.71 experience — for the DO, supervisory/managerial operational-control experience or PIC time within the last 6 years; for the Chief Pilot, PIC experience within the last 6 years; for the DOM, qualifying maintenance or repair-station experience within the last 6 years. This is the evidence the FAA evaluates against the rule.
How FileFlo tracks it
FileFlo indexes the experience summary alongside the certificate, creating a single management-person record that maps directly to the §119.71 standard.
FAA Acceptance / Management Structure on File
14 CFR §119.69 / OpSpecsWhat it proves
The record showing the FAA has accepted the individual in the required position — reflected in the certificate holder’s management structure on file with its certificate-management office. A person should not serve as the required official until this acceptance is in place.
How FileFlo tracks it
FileFlo stores the FAA acceptance documentation with the appointment date and ties it to the individual’s qualification package for a complete chain.
Deviation Authorization (if applicable)
14 CFR §119.71(f)What it proves
If a required management person relies on comparable experience rather than the literal §119.71 thresholds, the FAA-authorized deviation is the document that makes the appointment compliant. Without the deviation on file, an out-of-threshold appointee is unqualified on paper.
How FileFlo tracks it
FileFlo stores the §119.71(f) deviation authorization with the affected individual, so the comparable-experience basis is documented and retrievable.
Related guides: Part 135 pilot records · Part 145 repair station recordkeeping · Part 145 audit binder
FileFlo is the proof layer, not the operational or training system
FileFlo is a compliance document intelligence platform — it classifies, indexes, and tracks the qualification documents that prove your required management personnel meet §119.71, and it surfaces expirations and gaps. It is not a dispatch system, a flight operations management system (FOS), a training-management system, or a maintenance-tracking system, and it does not appoint or qualify personnel — the FAA does that. FileFlo keeps the documentary proof audit-ready alongside whatever operational and training systems you run.
Frequently Asked Questions
What management positions does 14 CFR Part 135 require?
Under 14 CFR §119.69(a), each Part 135 certificate holder must have qualified personnel serving in the following or equivalent positions: (1) Director of Operations, (2) Chief Pilot, and (3) Director of Maintenance. The only stated exception in the rule is a certificate holder using only one pilot in its operations. Separately, §119.69(b) lets the Administrator approve a different number or different categories of positions if the operator shows it can conduct operations safely with fewer or different management personnel, considering the kind of operation, the number and type of aircraft used, and the area of operations. These three are sometimes abbreviated DO, CP, and DOM (Director of Maintenance is also called the DOM or "DM").
What are the qualification requirements for a Part 135 Director of Operations?
The Director of Operations qualifications are in 14 CFR §119.71. The requirement depends on the certificate level: §119.71(a) applies when the certificate holder conducts any operation for which the pilot in command must hold an airline transport pilot (ATP) certificate, and §119.71(b) applies when the operations only require a commercial pilot certificate. In both cases the person must hold the corresponding pilot certificate and have either (1) at least 3 years of supervisory or managerial experience within the last 6 years in a position that exercised operational control over Part 121 or Part 135 operations, or (2) for a person with no prior Director of Operations experience, at least 3 years of experience within the past 6 years as pilot in command of an aircraft operated under Part 121 or Part 135.
What are the qualification requirements for a Part 135 Chief Pilot?
The Chief Pilot qualifications are in 14 CFR §119.71(c) and (d). Subsection (c) applies to operations requiring an ATP certificate; subsection (d) applies to operations requiring only a commercial pilot certificate. The Chief Pilot must hold the appropriate current pilot certificate with the ratings required to act as pilot in command in operations conducted by the certificate holder, and must have at least 3 years of experience within the past 6 years as pilot in command of an aircraft operated under Part 121 or Part 135. For a person who has previously served as a Chief Pilot for a Part 121 or Part 135 certificate holder, §119.71(c)(2)/(d)(2) drops the recency window entirely — the requirement becomes at least 3 years as PIC under Part 121 or 135, with no 6-year look-back. In practice the Chief Pilot must be qualified to serve as PIC in at least one of the operator’s aircraft.
What are the qualification requirements for a Part 135 Director of Maintenance?
The Director of Maintenance qualifications are in 14 CFR §119.71(e). The person must hold a mechanic certificate with both airframe and powerplant (A&P) ratings, and must have either (1) 3 years of experience within the past 6 years maintaining aircraft as a certificated mechanic, including experience maintaining the same category and class of aircraft as used by the certificate holder, or (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. Note this is the §119.71 management-qualification standard — it is separate from who may sign a return-to-service entry under §43.7 and §43.9.
Can the FAA waive or reduce the Part 135 management qualification requirements?
Yes, through a deviation. 14 CFR §119.71(f) allows a certificate holder to request a deviation to employ a person who does not meet the applicable aeronautical, managerial, or supervisory experience requirements. Under §119.71(f) the deviation authority sits at FAA headquarters — the Manager of the Air Transportation Division (AFS-200) or the Manager of the Aircraft Maintenance Division (AFS-300), as appropriate — who may authorize the deviation if the person has comparable experience and can effectively perform the functions associated with the position. The deviation is discretionary and fact-specific — it is documented and approved by the FAA, not self-certified by the operator. Separately, §119.69(b) addresses approval of a different number or categories of positions, which is distinct from a §119.71(f) individual-qualification deviation.
How does the FAA approve and track Part 135 management personnel changes?
Part 135 management personnel are reflected in the certificate holder’s Operations Specifications and approved by the certificate holder’s certificate-management office (the principal operations inspector and principal maintenance inspector). When a Director of Operations, Chief Pilot, or Director of Maintenance changes, the operator must notify the FAA and provide the new individual’s qualification records so the FAA can confirm the §119.71 experience and certificate requirements are met before the person serves. A vacancy that is not promptly filled with a qualified, FAA-accepted individual is a finding because the certificate holder is, during that gap, operating without the management structure §119.69 requires.
What qualification records should a Part 135 operator keep for its required management personnel?
For each required management person, the operator should maintain a documented qualification package: the individual’s pilot certificate (with ratings) or mechanic certificate with A&P ratings; a current medical certificate where the role requires acting as PIC; a resume or experience summary showing the §119.71 supervisory/PIC or maintenance experience within the last 6 years; the FAA acceptance or OpSpecs reflecting the appointment; and, if applicable, the §119.71(f) deviation authorization. Keeping these indexed and current means that when an FAA inspector asks "show me that your DO/CP/DOM meet §119.71," the answer is a single retrievable folder rather than an email scramble.
Is the Director of Operations the same as holding operational control?
No — they are related but distinct. Operational control, defined in 14 CFR 1.1 as the exercise of authority over initiating, conducting, or terminating a flight, rests with the certificate holder under §135.77. The Director of Operations is the management position §119.69 requires the certificate holder to staff to administer that responsibility. A qualified DO is part of how a certificate holder demonstrates it can exercise operational control, but the legal obligation sits with the certificate holder, and §119.71(a)–(b) specifically require DO experience in a role that "exercised operational control." See our operational-control explainer for the full distinction.
Keep your DO, Chief Pilot, and DOM qualification files audit-ready
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Reviewed by Chad Griffith, Founder, FileFlo — compliance document intelligence. June 9, 2026. Regulatory citations verified against the eCFR / Cornell LII (14 CFR §119.69 and §119.71) as of publication date. This article is educational and is not legal advice.