Direct Answer: What Does Part 135 Require for Training & Its Records?
Under 14 CFR §135.341, every Part 135 certificate holder (other than a single-pilot operator) must establish and maintain an FAA-approved training program with separate ground and flight curriculums covering initial, transition, upgrade, differences, and recurrent training. Separately, under §135.63(a)(4), the operator must keep an individual record for each pilot that documents the completion dates of each initial and recurrent training phase — retained for at least 12 months.
Two things an FAA inspector always checks together:
- The program (§135.341, §135.323) — is the approved curriculum current and matched to your OpSpecs and aircraft types?
- The records (§135.63(a)(4), §135.323(c)) — is every active crewmember current against it, with each completion certified by a named instructor or check pilot?
- The 12-month rule (§135.343) — no crewmember may serve unless they completed the appropriate training phase since the beginning of the 12th calendar month before that service.
The program tells you what must be taught. The per-pilot records prove who completed it and when. Passing a Part 135 surveillance audit means producing both, instantly, for any crewmember on the roster.
Training findings are administrative — and therefore entirely preventable
A recurrent phase that slipped past its 12-calendar-month window under §135.343 means the crewmember is not qualified to serve — full stop. Unlike an airworthiness issue that needs physical work on an aircraft, this is a calendar-and-paperwork failure. Civil penalties for Part 135 violations reach $75,000 per violation (14 CFR §13.301; violations on or after December 30, 2024) under 49 U.S.C. §46301.
The Program vs. The Records: Two Artifacts the FAA Audits Together
The single most common conceptual error operators make is conflating the training program with the training records. They are governed by different sections, they fail in different ways, and an FAA Principal Operations Inspector (POI) will ask for both during a Part 135 surveillance visit. Getting this distinction right is the foundation of a defensible training file.
The Approved Program
Governed by §135.341 and §135.323. It is the curriculum document the FAA has approved — the master description of what every crewmember must be taught, the ground and flight segments, the study materials, and the certification procedure. The certificate holder must furnish copies of the program and all changes to its assigned FAA representative.
How it fails an audit: the revision on file is stale and no longer matches current OpSpecs, a new aircraft type, or a regulatory change. The program existed — it just was not kept current under §135.323.
The Per-Pilot Records
Governed by §135.63(a)(4) and the certification rule in §135.323(c). These are the individual proofs that a named crewmember actually completed each phase — the completion dates for each initial and recurrent training phase, tied to a certifying instructor or check pilot.
How it fails an audit: a recurrent phase is past its 12-calendar-month window (§135.343), or a completion is recorded as a bare date with no certifier identified (§135.323(c)). The program was fine — the proof was incomplete.
This is the same program-versus-records split that runs through every Part 135 recordkeeping obligation — the manuals, the maintenance program, the drug-and-alcohol program. For the operator-wide picture of which records you must keep and for how long, see What records must a Part 135 operator keep. For the per-crewmember currency file (medicals, §135.293, §135.297, §135.299), see the FAA pilot-records guide.
The Curriculum Map: What §135.341 Requires the Program to Contain
Under 14 CFR §135.341, the program must provide ground and flight training curriculums covering five phases, plus current and appropriate study materials. Subpart H then builds out each segment in its own section. The cards below map the approved program to the controlling regulation for each piece.
1. Pilot Ground Training — §135.345
14 CFR §135.345 (Pilots: Initial, transition, and upgrade ground training) sets the classroom/CBT foundation. General subjects include the certificate holder's flight locating procedures; meteorology covering frontal systems, icing, fog, thunderstorms, and windshear; navigation and instrument approach procedures; and normal and emergency communication procedures.
For each aircraft type, the ground curriculum must cover performance characteristics; the major aircraft systems (flight controls, electrical, hydraulic); severe-weather recognition and escape; operating limitations; each normal and emergency procedure; and the approved Aircraft Flight Manual or equivalent. The record must show the phase (initial / transition / upgrade), the date, and the certifying instructor.
2. Pilot Flight Training (incl. Differences) — §135.347
14 CFR §135.347 (Pilots: Initial, transition, upgrade, and differences flight training) requires each pilot to receive flight and practice in each of the maneuvers and procedures in the approved training program curriculum. Training is conducted in flight, although certain maneuvers may be accomplished in an aircraft simulator or appropriate training device as allowed by Subpart H.
Where a simulator or training device is used, the pilot must complete the applicable maneuvers in the device and a flight check in the aircraft (or a check in the simulator/training device) to the level of proficiency of a PIC or SIC. Differences training is the trap most operators miss: when a pilot moves between variants of a type, the differences segment and its record must exist before the pilot serves on the variant.
3. Flight Attendant Ground Training — §135.349
If the operator employs flight attendants, the program must include flight attendant training. 14 CFR §135.349 (Flight attendants: Initial and transition ground training) covers general subjects — the authority of the pilot in command and passenger handling, including procedures for handling persons whose conduct might jeopardize safety — and aircraft-specific subjects such as a general description of the aircraft emphasizing characteristics bearing on ditching, evacuation, and in-flight emergencies; use of the public address system and crew communication (including emergency means); and proper use of electrical galley equipment and cabin heat/ventilation controls.
The Recurrent Cycle and the 12-Calendar-Month Rule
Initial training gets a crewmember qualified once. The recurrent cycle is what keeps them qualified — and it is where most training findings originate, because it repeats forever across the whole roster.
§135.343 — The Eligibility Rule
14 CFR §135.343 (Crewmember initial and recurrent training requirements) is the gate: no certificate holder may use a person, and no person may serve, as a crewmember unless that crewmember has completed the appropriate initial or recurrent training phase since the beginning of the 12th calendar month before that service. In practice this is the annual recurrent cycle. The single-pilot exception applies — an operator using only one pilot is not bound by this crewmember-training-phase requirement (but remains subject to Subpart G testing/checking).
"Since the beginning of the 12th calendar month before" is a calendar-month construction, not a rolling-day count — the same family of logic that governs the §135.293 / §135.297 / §135.299 checks. Track the calendar-month boundary, not the bare anniversary date.
§135.351 — What Recurrent Training Consists Of
14 CFR §135.351 (Recurrent training) requires the certificate holder to ensure each crewmember receives recurrent training and is adequately trained and currently proficient for the type aircraft and crewmember position involved. Recurrent ground training must include a quiz or other review of the crewmember's knowledge of the aircraft and position, plus instruction in the subjects from initial training.
For pilots, recurrent flight training covers the maneuvers and procedures of Subpart H — but §135.351 provides that satisfactory completion of the required check within the preceding 12 calendar months may be substituted for recurrent flight training. That substitution is why a pilot's §135.293 competency check and the recurrent training record are tightly coupled in the file, and why a missed check can cascade into a recurrent-training gap.
Build the alert buffer before the calendar-month boundary
Because §135.343 ties eligibility to serve to a calendar-month boundary, an operator that schedules recurrent training in the final days of the currency month carries real risk: a slip for weather, aircraft availability, or instructor scheduling can put a crewmember out of currency overnight. Best practice is a 90/60/30-day alert cadence targeting completion at least three weeks before the calendar-month boundary closes — the same discipline covered in the surveillance-audit prep guide.
The Training-Record Checklist: Every Artifact, Its CFR, and Its Proof
Use this as a build-from-scratch checklist for a new hire's training file and as a standing audit reference for the roster. Each row maps a required artifact to its controlling regulation, the interval or trigger, the retention floor, and the proof an inspector expects to see.
| Artifact | Governing CFR | Interval / Trigger | Retention | Proof Expected |
|---|---|---|---|---|
| Approved Training Program (curriculum document + revisions) | §135.341; §135.323 | Kept current; copies + all changes furnished to assigned FAA representative | Current approved revision on file at all times | Revision matches current OpSpecs and aircraft types |
| Initial Ground Training (pilots) | §135.345 | Before serving on type (initial / transition / upgrade) | Per §135.63(a)(4) — phase completion date, at least 12 months | Date + certifying instructor (§135.323(c)) |
| Initial / Transition / Upgrade / Differences Flight Training (pilots) | §135.347 | Before serving on type; differences when changing variant | Per §135.63(a)(4) — phase completion date, at least 12 months | Maneuvers/procedures + simulator vs. aircraft noted |
| Recurrent Ground & Flight Training (all crewmembers) | §135.351; §135.343 | Within preceding 12 calendar months (annual cycle) | Per §135.63(a)(4) — recurrent phase date, at least 12 months | Review/quiz of knowledge + maneuvers; check may substitute for flight portion |
| Crewmember Eligibility to Serve (training-phase currency) | §135.343 | Must have completed appropriate phase since start of 12th calendar month before service | Continuous — every active crewmember at all times | No service unless current; single-pilot exception applies |
| Flight Attendant Ground Training (if FAs employed) | §135.349 | Initial + transition per approved program | Crewmember record per approved program | PIC authority, passenger handling, emergency comms |
| Certification of Satisfactory Completion | §135.323(c) | At completion of each phase | Made part of the crewmember record | Certifying instructor/supervisor/check pilot identified with each entry |
| Per-Pilot Individual Record (training-phase dates + checks) | §135.63(a)(4) | Maintained current for each pilot | At least 12 months (records under (a)(4)/(a)(5)) | Includes completion dates for initial and recurrent training phases |
Data sourced from 14 CFR Part 135, Subparts B and H, as published on eCFR.gov and verified against Cornell LII. The 12-month figure is the §135.63 retention floor for records under (a)(4)/(a)(5); operators commonly retain longer on counsel's advice. Verify against current eCFR before relying for compliance determinations, and confirm your OpSpecs for any additional training authorizations.
The §135.323(c) certification linkage — the detail that fails quiet audits
14 CFR §135.323(c) requires that satisfactory completion of training be certified by the responsible flight instructor, supervisor, or check pilot, and that the certification be made a part of the crewmember's record. When the certification is entered in a computerized recordkeeping system, the certifying instructor, supervisor, or check pilot must be identified with that entry.
This is why a training record cannot just be a date in a spreadsheet cell. The regulation demands the completion be attributable to a named, authorized certifier. A digital record that captures the document, the phase, the date, and the certifier — and keeps them linked — is what satisfies §135.323(c). Loose PDFs and shared spreadsheets routinely break this linkage, and it is exactly the kind of gap an inspector finds on a careful records review.
How FileFlo Keeps the Training Program & Records Audit-Ready
Training compliance is a continuous stream of expiration events. An operator with 15 pilots generates at least 15 recurrent-training renewals per year under §135.343, on top of differences-training triggers when crews move between variants, flight-attendant recurrence if FAs are employed, and the standing obligation to keep the approved program current under §135.323. Every one is a date, a document, and a certifier that has to stay linked.
FileFlo is a compliance document intelligence platform that sits alongside the operational stack — it does not deliver the training, administer checks, run your training-management or flight-operations system, or replace your Director of Operations and approved training provider. It classifies the documents that prove training happened, tracks their currency on calendar-month logic, and produces the binder when the FAA asks.
Classifies training documents against the Subpart H taxonomy
Upload a §135.345 ground-training completion, a §135.347 flight-training/differences sign-off, a §135.351 recurrent record, or a flight-attendant training certificate — FileFlo classifies each against the correct CFR section automatically. No manual filing decisions and no §135.347 differences record misfiled under recurrent.
90/60/30-day recurrent alerts on calendar-month logic
FileFlo computes the §135.343 recurrent deadline using the calendar-month boundary, not rolling-day math, and fires alerts at 90, 60, and 30 days before the boundary — so a recurrent phase never slips past the 12th-calendar-month gate that would make a crewmember ineligible to serve.
Preserves the §135.323(c) certifier linkage
Because §135.323(c) requires the certifying instructor or check pilot to be identified with each completion entry, FileFlo keeps the document, phase, date, and certifier linked as one record — not a bare date that fails the certification requirement on a careful records review.
One-click training binder for a POI surveillance visit
When an FAA POI asks for training records, FileFlo assembles a complete, CFR-organized binder for any individual crewmember or the full roster — initial, recurrent, differences, and the certification entries — in under a minute, instead of an afternoon of pulling files.
Proof layer — not the training provider or the DOM
FileFlo keeps the evidence that your crewmembers completed the required training and that your approved program is the current revision. It does not conduct training, approve curricula, or replace the certificate holder's Director of Operations or training provider. Those parties stay accountable for the substance; FileFlo keeps the proof audit-ready.
See where your training records stand before your next POI visit
FileFlo's FAA Readiness Score evaluates your documentation posture against the key Part 135 record requirements — including training currency — with no signup required. Under 3 minutes.
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Aviation ClusterFrequently Asked Questions
What does an FAA-approved Part 135 training program have to include?
Under 14 CFR §135.341, each Part 135 certificate holder (other than one using only a single pilot) must establish and maintain an FAA-approved training program with separate ground and flight training curriculums covering initial training, transition training, upgrade training, differences training, and recurrent training, appropriate to each crewmember's assigned duties. The program must include current and appropriate study materials, and the certificate holder must furnish copies of the program and all changes to its assigned FAA representative. The pilot training building blocks are §135.345 (initial, transition, and upgrade ground training), §135.347 (initial, transition, upgrade, and differences flight training), and the §135.351 recurrent cycle; §135.349 covers flight attendant ground training.
How often must a Part 135 crewmember complete recurrent training?
Under 14 CFR §135.343, no certificate holder may use a person, and no person may serve, as a crewmember unless that crewmember has completed the appropriate initial or recurrent training phase since the beginning of the 12th calendar month before that service. In practice this is an annual (12-calendar-month) recurrent training cycle administered through the approved program under §135.351. Note that recurrent flight training requirements can, per §135.351, be satisfied by satisfactory completion of the required proficiency check within the preceding 12 calendar months. The single-pilot exception in §135.343 means an operator using only one pilot is not held to this crewmember-training-phase requirement.
What is the difference between the training program and the per-pilot training records?
They are two distinct compliance artifacts. The training program itself is the FAA-approved curriculum document (§135.341, §135.323) describing what every crewmember must be taught and how completion is certified. The per-pilot records are the individual proof that a named crewmember actually completed each phase — kept under 14 CFR §135.63(a)(4), which requires an individual record for each pilot including test/check results and the completion dates for each initial and recurrent training phase. An FAA inspector will ask to see both: the approved program (to confirm the curriculum is current and matches your OpSpecs) and the per-crewmember records (to confirm every active pilot is current against it).
Where in the regulations is the training-record retention period set?
14 CFR §135.63 requires the certificate holder to keep each record required by §135.63(a)(4) — which includes the dates of completion of initial and recurrent training phases for each pilot — for at least 12 months. That 12-month floor runs in practice for the duration of the crewmember's service and at least 12 months afterward. Because enforcement actions and incident investigations can reach back years, most Part 135 operators and their aviation counsel retain training records well beyond the regulatory minimum — commonly 3 to 5 years after a crewmember departs.
Who can certify that a crewmember completed Part 135 training?
Under 14 CFR §135.323(c), satisfactory completion of training is certified by the responsible flight instructor, supervisor, or check pilot, and that certification is made a part of the crewmember's record. When the certification is entered into a computerized recordkeeping system, the certifying instructor, supervisor, or check pilot must be identified with that entry. This is the regulatory reason a training record is not just a date — it must tie the completion to a named, authorized certifier, which is exactly the linkage that breaks down when records live in loose PDFs or a shared spreadsheet.
What does §135.323 require beyond the curriculum itself?
14 CFR §135.323 (Training program: general) requires the certificate holder to establish and implement an approved training program, provide adequate ground and flight training facilities and properly qualified ground instructors, and — critically for recordkeeping — provide and keep current for each aircraft type the appropriate training material, examinations, forms, instructions, and procedures. It also sets the certification-of-completion rule in §135.323(c). So §135.323 governs the infrastructure and currency of the program documents themselves, while §135.63(a)(4) governs the per-pilot completion records.
Does the training-program requirement apply to single-pilot Part 135 operators?
The formal approved-training-program requirement in §135.341 and the crewmember training-phase requirement in §135.343 each contain an exception for certificate holders who use only one pilot. A single-pilot operator is still subject to the testing and checking requirements of Subpart G — Crewmember Testing Requirements (for example the §135.293 competency test and, for IFR, the §135.297 instrument proficiency check) and must still keep the §135.63(a)(4) individual pilot record — but is not required to build the full multi-crewmember approved training program. Verify your specific OpSpecs, because authorizations can impose additional training obligations.
What are the most common Part 135 training-record findings in an FAA audit?
The recurring findings are: (1) a recurrent training phase completed outside the 12-calendar-month window under §135.343, leaving a crewmember unqualified to serve; (2) training records that record a date but not the certifying instructor or check pilot, failing the §135.323(c) certification linkage; (3) the approved program on file being an outdated revision that no longer matches current OpSpecs or aircraft types under §135.323; and (4) differences training (§135.347) missing when a pilot moves between variants of a type. All four are administrative, preventable failures — the category a document-intelligence layer is built to eliminate.
Stop tracking training currency in a spreadsheet
FileFlo classifies every §135.345, §135.347, and §135.351 training record against the correct CFR section, keeps the §135.323(c) certifier linkage intact, tracks the §135.343 recurrent window on proper calendar-month logic, and generates a POI-ready training binder in 60 seconds. Starter $89/month, Professional $299/month — 5-day free trial, no credit card required.
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