Part 135 Scheduled Operations Flight Time and Rest: The §135.265 Scheme — and How It Differs From the Unscheduled Rules

First Question: Are You Even on the §135.265 Scheme?

Part 135 Subpart F — Crewmember Flight Time and Duty Period Limitations and Rest Requirements — is not one rule but a family of schemes, and §135.261 is the routing table that decides which one applies to your operation. Getting this wrong means proving compliance against the wrong rule — a documentation problem before it is anything else.

• §135.263 — the general rules that apply to all operations under the subpart: no duty assignments during a required rest period, and the rule that time spent in non-local transportation the operator requires and provides is not part of a rest period. These sit underneath whichever scheme governs you.
• §135.265 — the subject of this guide. Under §135.261(b), it applies to scheduled passenger-carrying operations, except those conducted solely within the State of Alaska. It uses calendar-based limits — annual, monthly, and 7-day flight time, plus scheduled rest keyed to scheduled flight time.
• §135.267 and §135.269 — under §135.261(c), these apply to any operation that is not a scheduled passenger-carrying operation, and to any operation conducted solely within Alaska, unless the operator elects §135.265. §135.267 is the unscheduled one- and two-pilot rule covered in the unscheduled duty/rest records guide; §135.269 is the unscheduled three- and four-pilot rule.
• §135.271 — special flight time limits and rest requirements for helicopter hospital emergency medical evacuation service (HEMES). Air ambulance duty/rest sits in its own scheme — see the HEMS records guide.

Scheduling crews within these limits is an exercise of operational control — the authority over initiating, conducting, or terminating a flight, as defined in 14 CFR §1.1 — which is why duty/rest findings often appear alongside operational control findings in enforcement actions: both trace back to who decided a pilot could fly a segment, and on what recorded basis.

Every §135.265 Limit — and the Record That Proves It

The table maps each provision of §135.265 (plus the §135.63 recordkeeping anchor) to the limit, the measurement window, and the document an FAA inspector would ask for to verify compliance. The right-hand column is the part most operators have never formalized — and the part that decides how a records review goes.

Data sourced from 14 CFR Part 135, Subpart F and §135.63 as published on eCFR.gov. Verify against the current eCFR before relying on this table for compliance determinations — and note that an unscheduled operator, or one running three- and four-pilot crews or HEMES operations, follows a different scheme.

Reading the Limits: Calendar Caps, the 7-Day Window, and the Daily 8-Hour Rule

The Rest Rules: the 9/10/11 Tiers and the 24-Hour Weekly Relief

§135.265(b) ties required scheduled rest to scheduled flight time. Except as the paragraph (c) reductions allow, no certificate holder may schedule a crewmember for flight time during the 24 consecutive hours preceding the scheduled completion of any flight segment without a scheduled rest period during that 24 hours of at least the tier below. The anchor is the scheduled completion of the segment — look back 24 hours from when the segment is scheduled to finish, and within that window the schedule must contain the required consecutive rest block.

Then there is the weekly floor. Under §135.265(d), each certificate holder must relieve each flight crewmember engaged in scheduled air transportation from all further duty for at least 24 consecutive hours during any 7 consecutive days. This is one full day off inside every rolling 7-day window — and because the window is rolling, it can be silently violated by a busy stretch even when each individual schedule looks fine. Only a week-level view of the roster reveals a pilot who has gone eight or nine days without a qualifying 24-hour relief.

The (d) relief is a clean example of why duty/rest compliance is a documentation discipline: the operator needs a per-pilot relief calendar that marks each qualifying 24-consecutive-hour period — a record nothing in the cockpit produces automatically, and one that the broader Part 135 records system has to generate and retain deliberately. The same week-level discipline produces exactly the fatigue-relevant scheduling data a Safety Management System expects an operator to surface as the May 28, 2027 SMS deadline approaches.

The §135.265(c) Reduction: Rest Deferred, Not Recovered

Paragraph (c) is the provision operators most often misread as a way to simply run shorter rest. It is not. §135.265(c) allows the scheduled rest of paragraph (b) to be reduced only if it is paid back with a longer compensating rest period that begins soon after. There are three pairings, and each one trades a reduction now for a larger rest block within 24 hours:

Read the pairings carefully: an 8-hour reduced period can be compensated by either a 10-hour or an 11-hour makeup block (the two are distinct provisions for distinct schedule shapes), and a 9-hour reduced period requires a full 12-hour makeup. In every case the makeup rest must begin within 24 hours of the moment the reduced rest started — not merely occur sometime later. The reduction is rest deferred and repaid at a premium, not rest skipped.

The records implication is direct. An operator relying on §135.265(c) must be able to produce both halves of the pairing and the timing that links them: the reduced rest block, the compensating block, and proof the makeup began inside the 24-hour window. If the schedule only shows the short rest, the reduction was never lawful — which is why a reduction memo cross-referenced to the published schedule is the defensible artifact. This is also where single-pilot operators have to be especially disciplined: there is no second crewmember whose records corroborate the timeline.

The Proving Records: §135.63(a)(4)(vii) and the 12-Month Window

Everything above is the scheduling half. The compliance half lives in 14 CFR §135.63. Each certificate holder must keep, at its principal business office or at other places approved by the Administrator, and make available for inspection by the Administrator, an individual record for each pilot used in Part 135 operations. Item (vii) of the §135.63(a)(4) list is the duty/rest anchor: the pilot’s flight time in sufficient detail to determine compliance with the flight time limitations of this part.

The phrase in sufficient detail to determine compliance is a functional standard, not a format. A folder of schedules fails it not because the data is missing but because no one can compute a rolling 7-day total, a calendar-month total, or a weekly relief count from it on demand. In practice, a records set sufficient for §135.265 means:

• Per-segment flight time entries (block out/in) tied to each pilot, each aircraft, and each trip — the atomic data for every limit computation
• Running totals on the §135.265 windows: calendar year, calendar month, and rolling 7 consecutive days, per pilot
• The published schedule itself, showing scheduled flight time per segment and the scheduled rest block in the 24 hours preceding each segment’s scheduled completion
• A weekly relief calendar demonstrating the 24 consecutive hours off in any 7 consecutive days under §135.265(d)
• Outside-flying declarations covering all other commercial flying, on a recurring cadence, signed by the pilot
• Reduction-and-makeup memos for every §135.265(c) event: the reduced block, the 10/11/12-hour compensating block, and proof the makeup began within 24 hours
• Both pilots’ Part 135 qualification records where the operation relies on a qualified two-pilot crew under §135.265(a)(5)

Retention is explicit: under §135.63(b), each record required by paragraph (a)(4) must be kept for at least 12 months. That rolling 12-month window is what a Principal Operations Inspector samples during routine surveillance — typically by picking a busy stretch and asking the operator to walk a specific pilot’s specific segment backward: show me this segment’s block times, the schedule that built it, the scheduled rest behind it, and the 7-day and monthly totals it fed. Operators who can answer from one organized system in minutes set the tone for the entire visit.

Remember also that the flight-time record is only item (vii) of the items in the individual pilot record — the same file that must hold certificates, medical class and effective date, competency and route check results, and training completions. The full file architecture is covered in the Part 135 pilot records guide, and the adjacent program records — drug and alcohol testing, PRD evaluations, medical certificate tracking, and check airman authorizations — ride along in the same inspection.

How FileFlo Fits: the Proof Layer for Scheduled Duty/Rest Documentation

Honest scoping first: FileFlo does not build crew schedules, compute rest legality, or replace your scheduling and flight operations software. The scheduling decision — whether this pilot can legally fly this segment — belongs to your Director of Operations and the systems that run the operation. FileFlo is the compliance document intelligence layer underneath: it makes sure the records that prove those decisions were legal are classified, organized, retained, and producible the day the FAA asks.

Related reading across the broader Part 135 records system: required management personnel, the General Operations Manual, training program recordkeeping, pilot logbook vs operator records, and how long to keep each aviation record.

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