Direct Answer
A Part 135 single-pilot operator — an operator whose operations use only one pilot — is excepted from four notable obligations: the general operations manual (§135.21(a)), the approved pilot training program (§135.341(a)), the three required management positions (§119.69(a)), and — for a 9-or-fewer-seat aircraft — the continuous airworthiness maintenance program (§135.411(a)(1)).
What it does not scale back: the Subpart G testing and checks (the §135.293 written/oral test and competency check on a 12-calendar-month cycle, the §135.297 instrument proficiency check on a 6-calendar-month cycle for IFR PICs, and the §135.299 line check), and the core recordkeeping requirement in §135.63, including the individual pilot record.
In short: the single-pilot exception removes the obligation to build certain programs and structures. It does not remove the obligation to be qualified, current, and airworthy — or to keep the records that prove it.
There Is No Single "Single-Pilot Operator" Definition
The first thing to understand is structural. The regulations do not contain one master definition of "single-pilot operator" that switches a tidy set of rules on and off. Instead, the relief is distributed: each rule that grants it carves out the operator that uses only one pilot in its own operative language. §135.21(a) phrases it as a certificate holder "other than one who uses only one pilot in the certificate holder's operations." §135.341(a) phrases it as "other than one who uses only one pilot." §119.69(a) phrases it as "Except for a certificate holder using only one pilot in its operations." The trigger is the same idea — one pilot — but you have to read each rule.
Where you do see the crisp labels "single pilot operator" and "single pilot in command operator" is in FAA Operations Specifications practice — paragraph A040 and A039, respectively, in FAA guidance. Those are an FAA authorization/Operations Specifications convention rather than a Code of Federal Regulations definition, so this article keeps the load-bearing claims pinned to the operative regulatory text and treats the OpSpec letter designations as the practical labels they are. (For the broader role OpSpecs play, see our explainer on Operations Specifications.)
"One pilot" and "9 seats" are two different tests
The management and manual exceptions turn on how many pilots the operator uses. The maintenance-program split in §135.411 turns on how many passenger seats the aircraft is type-certificated for (nine or fewer vs. ten or more), excluding any pilot seat. A single-pilot operator almost always flies a small, 9-or-fewer-seat aircraft, so the two tests usually point the same direction — but they are independent. Do not assume "single pilot" automatically means "parts 91/43 maintenance"; confirm the aircraft's type-certificated seating.
With that framing in place, the rest of this guide splits the question cleanly in two: what the single-pilot exception genuinely scales back, and what survives untouched. For the full Part 135 record set that surrounds all of this, start with what records a Part 135 operator must keep.
What the Single-Pilot Exception Scales Back
Four meaningful obligations are lifted. Each is tied to a precise rule, and each removes a document-building or staffing burden — not the underlying duty to operate safely and legally.
1. The general operations manual — §135.21(a)
Section 135.21(a) requires each certificate holder, "other than one who uses only one pilot in the certificate holder's operations," to prepare and keep current a manual setting out procedures and policies acceptable to the Administrator. The single-pilot operator is excepted from building and maintaining that manual. The operator still runs on its Operations Specifications and still complies with applicable operating rules — it simply is not required to maintain the full multi-pilot manual.
2. The approved pilot training program — §135.341(a)
Section 135.341(a) requires each certificate holder "other than one who uses only one pilot" to establish and maintain an approved pilot training program appropriate to its operations. The single-pilot operator is excepted from maintaining that approved program document. Crucially, the rule itself frames the program as the vehicle for ensuring pilots meet "the applicable knowledge and practical testing requirements of §§135.293 through 135.301" — which means the testing requirements themselves live elsewhere and are not waived by this exception (more on that below).
3. The three required management positions — §119.69(a)
Section 119.69(a) requires each Part 135 certificate holder to have qualified personnel serving as Director of Operations, Chief Pilot, and Director of Maintenance — "Except for a certificate holder using only one pilot in its operations." A true single-pilot operator is therefore excepted from staffing those three accepted management individuals. The functions do not vanish — the operator still holds operational control under §135.77 — but the FAA does not require three separate management appointees for a one-pilot operation. For the full picture of those positions, see our guide to Part 135 required management personnel.
4. CAMP for small aircraft — §135.411(a)(1)
Section 135.411(a) sets two maintenance paths by aircraft size. Aircraft type-certificated for a passenger seating configuration of nine seats or less (excluding any pilot seat) "shall be maintained under parts 91 and 43 of this chapter and §§135.415, 135.417, 135.421 and 135.422" — the lighter path. Aircraft of ten seats or more "shall be maintained under a maintenance program in §§135.415, 135.417, 135.423 through 135.443" — the continuous airworthiness maintenance program (CAMP). A single-pilot operator typically flies a 9-or-fewer-seat aircraft and so avoids the CAMP, instead maintaining under parts 91/43 plus the §135.421 manufacturer's-program requirement. This is a seat-count rule, not a pilot-count rule.
A separate, limited deviation also exists for training
Beyond the single-pilot carve-out, §135.341(a) gives the Administrator authority to authorize a deviation from the training-program section if the limited size and scope of the operation allows it — but the rule expressly states that this deviation authority "does not extend to the training provided under §135.336." That is a discretionary, FAA-granted deviation, distinct from the automatic single-pilot exception, and not something the operator self-certifies.
On the maintenance side, the parts 91/43 path is not a free pass either. Under §135.421(a), an operator of a 9-or-fewer-seat aircraft must comply with the manufacturer's recommended maintenance programs, or a program approved by the Administrator, for each engine, propeller, rotor, and item of emergency equipment required by the chapter. And the part 91 inspection rules still bite — see the §91.409 annual and 100-hour inspection requirements and the broader part 91 aircraft records requirements.
Fewer programs to build — but the records still have to be perfect
A single-pilot operator carries a lean compliance stack: the pilot's qualification file, the aircraft's airworthiness and inspection records, and the Operations Specifications. FileFlo classifies and indexes each document, ties it to the governing rule, and tracks expirations so a lapsing medical or an overdue competency check surfaces before an inspector does. Starter at $89/mo, Professional at $299/mo. 5-day free trial, no credit card required.
What Still Applies — Testing, Checks, and Records
This is the half operators most often get wrong. The relief above is real, but it is narrow. The competency framework that proves a pilot is fit to fly, and the recordkeeping framework that proves it to the FAA, are not waived for a single-pilot operator.
The Subpart G testing and checks survive
The §135.341(a) exception removes the obligation to maintain an approved training program. It does not remove the pilot-qualification requirements those programs exist to satisfy. Those requirements sit in Subpart G of Part 135, and they apply by their own terms to the pilot:
Subpart G — still required for a single pilot
- §135.293Written or oral test and a competency check — since the beginning of the 12th calendar month before that service. The competency check covers the pilot's knowledge and skill in the category, class, and type of aircraft flown.
- §135.297Instrument proficiency check for a PIC operating under IFR — since the beginning of the 6th calendar month before that service, administered by the Administrator or an authorized check pilot.
- §135.299Pilot-in-command line check — a flight check over routes and into airports, since the beginning of the 12th calendar month before that service, given by an approved check pilot or by the Administrator.
Note the authority language carefully: §135.297 and §135.299 allow the check to be administered by the Administrator or an authorized/approved check pilot — not only an FAA inspector. The frequency language is just as precise: §135.293 and §135.299 run on a 12-calendar-month cycle, while the §135.297 IPC runs on a 6-calendar-month cycle. These intervals are "since the beginning of the Nth calendar month before service" — a currency window, not a record-retention period. For more on who may serve as a check airman, see our guide to Part 135 check airman and flight instructor records.
The trap: "no training program" misread as "no testing"
A single-pilot operator that reads §135.341(a) as relief from all training and checking is exposed. The exception is to the approved program document. The pilot must still be tested and checked under Subpart G and must still hold a valid medical and the correct certificate and ratings under §135.243 and Part 61. If the competency check or IPC lapses, the pilot is not legal to fly the operation — single-pilot status changes nothing about that.
The §135.63 recordkeeping requirement survives
Section 135.63(a) requires the certificate holder to keep at its principal business office (or another approved place), and make available to the Administrator, the records below. None of this is waived for a single-pilot operator — the operator simply is the pilot whose record must exist:
§135.63(a) — records that still apply
On the operations side, §135.63 also addresses the load manifest: for a multiengine aircraft, the pilot in command must carry a completed load manifest in the aircraft, and the certificate holder must keep copies of completed load manifests for at least 30 days. For a single-pilot operator running a multiengine aircraft, that 30-day retention obligation applies just as it would to anyone else. For how the operator's own records relate to the pilot's personal logbook, see pilot logbook vs. operator records under §61.51.
And the surveillance reality does not soften for a small operator. A principal operations inspector can ask a single-pilot certificate holder for the same proof — current medical, current checks, airworthy aircraft, current OpSpecs — as a larger one. See how to prepare for a Part 135 FAA surveillance audit and, for the safety-program obligation arriving on the same horizon for all Part 135 operators, the Part 135 SMS 2027 deadline.
Single-Pilot vs. Single-Pilot-in-Command: A040 and A039
Operators frequently use "single-pilot operator" loosely to mean any small charter outfit. In FAA Operations Specifications practice, there are actually two distinct authorizations, and the difference matters for whether the "uses only one pilot" exceptions apply. These are described here as FAA guidance/OpSpec conventions, not CFR-defined terms.
Single-Pilot Operator
OpSpec A040 (FAA practice)
In FAA guidance, this authorization limits the certificate holder to a single, specifically named pilot for all Part 135 operations. Because the operator genuinely "uses only one pilot," it sits squarely within the operative language of §135.21(a), §135.341(a), and §119.69(a) — the manual, training-program, and management-personnel exceptions.
Single-Pilot-in-Command Operator
OpSpec A039 (FAA practice)
In FAA guidance, this authorization limits the certificate holder to one named pilot in command plus a small, specified number of second-in-command pilots. Because more than one pilot is involved, an A039 operator may fall outside the "uses only one pilot" language that drives several exceptions — so the relief that applies to a true single-pilot operator should not be assumed.
Confirm your authorization before relying on any exception
The OpSpec A039/A040 labels are an FAA authorization convention; the legal exceptions are written in terms of "using only one pilot." If your operation has grown to include SIC pilots, or you are unsure which authorization you hold, confirm it with your principal operations inspector. Misreading an A039 operation as a true single-pilot operation — and skipping a manual or training program you actually owe — is a self-inflicted finding.
The IFR fork also interacts with pilot qualifications. A single PIC who flies under IFR carries the §135.297 instrument-proficiency-check currency in addition to the §135.293 competency check, and the certificate and rating thresholds in §135.243 (which sets out the categories of operation requiring an airline transport pilot certificate) still govern who may serve as PIC at all. For the medical side, see Part 135 medical certificate requirements and tracking.
The Single-Pilot Operator's Lean Record Set — and How to Keep It Audit-Ready
The practical upside of single-pilot status is a smaller stack of documents. The practical risk is that, with no team and no full manual, the records get scattered across a logbook, an email account, a maintenance shop, and a filing cabinet. When an inspector asks for them, "scattered" reads as "non-compliant." Below is the record set that still applies and how a document-intelligence layer keeps it retrievable.
Pilot Certificate & Ratings
14 CFR §135.243 / §135.63(a)(4)What it proves
The certificate and ratings the pilot holds, appropriate to the category, class, and type of aircraft and the kind of operation. §135.243 sets when an ATP certificate is required; the pilot record under §135.63(a)(4) must capture the certificate and ratings.
How FileFlo tracks it
FileFlo classifies the certificate as a document class, indexes its ratings, and keeps it in the pilot's qualification file tied to §135.243.
Medical Certificate
14 CFR §135.63(a)(4) / Part 61What it proves
The effective date and class of the pilot's medical certificate must be recorded, and the medical must be valid for the operation flown. For a single-pilot operator, a lapsed medical grounds the entire operation.
How FileFlo tracks it
FileFlo tracks medical class and expiration with proactive alerts, so a lapsing medical is flagged well before it affects the operation.
Competency Test & Check Records
14 CFR §§135.293, 135.297, 135.299What it proves
The dates and results of the §135.293 written/oral test and competency check (12 cal-month cycle), the §135.297 instrument proficiency check (6 cal-month cycle for IFR PICs), and the §135.299 line check (12 cal-month cycle). §135.63(a)(4) requires these results in the pilot record.
How FileFlo tracks it
FileFlo indexes each test and check result by date and tracks the currency window, surfacing an approaching or expired check before it grounds the pilot.
Flight-Time Records
14 CFR §135.63(a)(4)What it proves
Flight time sufficient to show that the pilot complies with the applicable flight-time limitations. The operator's record — not just the pilot's personal logbook — must support this.
How FileFlo tracks it
FileFlo stores flight-time records alongside the qualification file so the compliance picture is in one place. (FileFlo records the documents; it does not compute or enforce duty/rest limits.)
Aircraft Airworthiness & Inspection Records
14 CFR Part 91/43 + §§135.421, 135.422What it proves
For a 9-or-fewer-seat aircraft, the maintenance, preventive-maintenance, inspection, and return-to-service records required under parts 91 and 43 and §§135.415, 135.417, 135.421, and 135.422 — including the §91.409 annual/100-hour inspections and the §135.421 manufacturer's-program compliance.
How FileFlo tracks it
FileFlo classifies and indexes airworthiness and inspection documents, ties them to the governing rule, and tracks inspection due dates. (FileFlo is not a maintenance-tracking system; it keeps the documentary proof.)
Operations Specifications
14 CFR §135.63(a)(2) / Part 119What it proves
The current, FAA-issued Operations Specifications — including the authorization (A040 or A039 in FAA practice) that defines the single-pilot or single-PIC arrangement. The operator must keep them current and available.
How FileFlo tracks it
FileFlo stores the current OpSpecs as a controlled document and flags when a superseded version is still on file.
Related guides: Part 135 pilot records · Part 135 drug & alcohol program records · §43.9 maintenance record entries · Airworthiness Directive compliance records · Part 135 required management personnel
FileFlo is the proof layer, not the operation
FileFlo is a compliance document intelligence platform — it classifies, indexes, and tracks the documents that prove a single-pilot operator is qualified, current, and airworthy, and it surfaces expirations and gaps. It does not fly the aircraft, run a dispatch or flight-release system, administer the §135.293/§135.297/§135.299 checks, run a safety (SMS) program, or maintain the aircraft. The FAA, your check airman, and your mechanic do those jobs. FileFlo keeps the documentary proof audit-ready alongside whatever operational systems you run.
Frequently Asked Questions
What is a single-pilot operator under Part 135?
A single-pilot operator is a Part 135 certificate holder whose operations use only one pilot. The regulations do not collapse this into one tidy defined term — instead, several rules carve out the operator that "uses only one pilot in the certificate holder's operations" (14 CFR §135.21(a)) or "using only one pilot in its operations" (§119.69(a)). In FAA practice, the certificate-management office distinguishes a true single-pilot operator (one named pilot, reflected on Operations Specification A040 in FAA guidance) from a single-pilot-in-command operator (one named PIC plus a limited number of second-in-command pilots, reflected on OpSpec A039). Those OpSpec letter designations are an FAA guidance/Operations Specifications convention, not a CFR-defined term — so this article anchors the requirements on the operative regulatory language rather than the OpSpec labels.
What does the single-pilot exception actually scale back?
Four things, each tied to a specific rule. (1) The general operations manual — §135.21(a) requires each certificate holder "other than one who uses only one pilot in the certificate holder's operations" to prepare and keep a manual. (2) The approved pilot training program — §135.341(a) requires a program for each certificate holder "other than one who uses only one pilot." (3) The three required management positions — §119.69(a) requires a Director of Operations, Chief Pilot, and Director of Maintenance "Except for a certificate holder using only one pilot in its operations." (4) The continuous airworthiness maintenance program (CAMP) — under §135.411(a), only aircraft type-certificated for 10 seats or more must be maintained under the CAMP in §§135.415, 135.417, 135.423 through 135.443; a single-pilot operator typically flies a 9-or-fewer-seat aircraft, which is maintained under parts 91 and 43 instead (§135.411(a)(1)). Note that the 9-vs-10-seat line in §135.411 is about aircraft size, not pilot count — it commonly coincides with single-pilot operations but is a separate test.
Do single-pilot operators still have to pass the Subpart G testing and checks?
Yes. The training-PROGRAM relief in §135.341(a) does not relieve the pilot from the underlying competency requirements in Subpart G. A single pilot must still pass, since the beginning of the 12th calendar month before service, a written or oral test and a competency check under §135.293, and — for a pilot in command flying under IFR — an instrument proficiency check since the beginning of the 6th calendar month before service under §135.297, plus the line check under §135.299 (12 calendar months). The exception removes the obligation to build and maintain an FAA-approved training PROGRAM document; it does not remove the requirement to actually be tested and checked and to keep the records proving it.
What records must a single-pilot operator still keep?
The core Part 135 recordkeeping requirement in §135.63 still applies. §135.63(a) requires the certificate holder to keep, and make available to the Administrator, its operating certificate, its operations specifications, a current inventory of aircraft, and an individual record for each pilot. The pilot record under §135.63(a)(4) must include the pilot's certificate and ratings, aeronautical experience, present duties and assignment date, effective date and class of medical certificate, the results and dates of competency tests / proficiency checks / route checks, flight time sufficient to show compliance with flight-time limitations, and training-completion dates. For a single-pilot operator that record is effectively the operator's own file, but it still has to exist and be retrievable.
Does the single-pilot exception remove the requirement for a manual entirely?
§135.21(a) excepts the single-pilot operator from the requirement to prepare and keep the general operations manual described in that section. It does not erase every document obligation. The operator still operates under its Operations Specifications, still must comply with applicable maintenance and inspection rules, and still must keep the §135.63 records. In practice, a single-pilot operator runs on its OpSpecs plus the records the rules require — it just is not obligated to build the full manual that a multi-pilot operator must maintain. The OpSpecs themselves are an FAA-issued, controlled document the operator must keep current.
How is a single-pilot operator different from a single-pilot-in-command operator?
This distinction comes from FAA Operations Specifications practice, not from a single CFR definition. In FAA guidance, a single-pilot operator authorization (OpSpec A040) limits the certificate holder to one specifically named pilot for all Part 135 operations. A single-pilot-in-command operator authorization (OpSpec A039) limits the certificate holder to one named pilot in command plus a small, specified number of second-in-command pilots. The two arrangements receive different OpSpec authorizations and therefore differ in how many people the operator may use. Because A039 introduces additional pilots, an A039 operator can fall outside the "uses only one pilot" language that drives several of the exceptions — so an operator should confirm with its principal operations inspector exactly which authorization it holds before relying on any single-pilot relief.
Does a single-pilot operator need a Director of Operations, Chief Pilot, or Director of Maintenance?
Under §119.69(a), the requirement to staff a Director of Operations, Chief Pilot, and Director of Maintenance applies to each certificate holder "Except for a certificate holder using only one pilot in its operations." So a true single-pilot operator is excepted from the three named management positions. That does not mean the functions disappear — the operator still bears operational control under §135.77 and still must ensure the aircraft is airworthy and the pilot is qualified. It means the FAA does not require three separate accepted management individuals for an operation that runs on one pilot. An operator relying on this should confirm its management structure with its certificate-management office, because §119.69(b) also lets the FAA approve a different number or categories of positions.
How does FileFlo help a single-pilot operator stay audit-ready?
FileFlo is the compliance document layer. For a single-pilot operator, the records that matter — the pilot's certificate and ratings, current medical, the §135.293 competency-test and §135.297 IPC results, the §135.299 line check, flight-time records, the airworthiness and inspection records for the aircraft, and the Operations Specifications — are exactly the documents the FAA asks for in surveillance. FileFlo classifies and indexes each one, ties it to the governing rule, and tracks expirations so a lapsing medical, an out-of-date competency check, or an overdue inspection surfaces before an inspector finds it. FileFlo does not fly the aircraft, run a dispatch or flight-release system, administer the checks, or maintain the aircraft — it keeps the documentary proof retrievable.
Run a single-pilot certificate? Keep the lean record set perfect.
FileFlo classifies and indexes the documents that prove a single-pilot operator is compliant — pilot certificate and ratings, medical, §135.293/§135.297/§135.299 check results, flight-time records, aircraft airworthiness and inspection records, and current OpSpecs — against the governing CFR section, with expiration alerts and a one-click POI 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 11, 2026. Regulatory citations verified against the eCFR / Cornell LII (14 CFR §§135.21, 135.341, 119.69, 135.411, 135.421, 135.63, 135.293, 135.297, 135.299, 135.243, 91.409) as of publication date. OpSpec A039/A040 designations reflect FAA Operations Specifications practice, not CFR-defined terms. This article is educational and is not legal or airworthiness advice.