Direct Answer
If you want one airplane to fly paying passengers on demand, you have two real routes: get your own Part 135 certificate (a single-pilot, single-PIC, basic, or standard certificate), or place the aircraft on an aircraft management company’s existing Part 135 certificate so the company charters it for you. A Part 135 certificate is required at all because, under 14 CFR 119.1, carrying persons or property for compensation or hire makes you a commercial operator — and 14 CFR 119.21 requires that operator to hold a certificate and operations specifications.
The deciding factor between the routes is operational control — who exercises authority over initiating, conducting, or terminating the flight (14 CFR 1.1). On your own certificate, you hold it. On a management company’s certificate, the company holds it for charter flights. Keeping the aircraft purely Part 91 (no charter) avoids the certificate entirely — but then it earns no charter revenue, and the narrow Part 91 cost-sharing carve-outs in 14 CFR 91.501 are not a back-door to charter.
FileFlo does not pick the route, give legal or tax advice, or get you certified — those are jobs for an aviation attorney, a tax advisor, and your FAA office. What it does is keep the records both routes require — registration and airworthiness certificate, the lease or management agreement, operations specifications, pilot and maintenance records, and the truth-in-leasing paperwork — classified, current, and provable.
The Question Behind the Question
Almost everyone who asks “how do I charter my own plane?” is really asking one of two narrower questions: how do I make the airplane earn money? or how do I do it legally without becoming an airline? The frustrating part is that the FAA does not organize its answer the way an owner thinks about it. An owner thinks in terms of the asset — my plane, my trips, my revenue. The FAA thinks in terms of the operation — who is holding out transportation to the public, who is controlling the flight, and whether money is changing hands for carriage.
That reframing is the whole article. Once you see that the regulatory line runs through the operation and its control rather than through the airplane, the two routes — your own certificate, or a management company’s — stop looking like paperwork variants and start looking like genuinely different businesses. This guide walks the threshold test first (do you even need a certificate?), then the fork, then the one concept that decides the fork: operational control. For the deeper Part 91 versus Part 135 line, the companion guide on Part 91 vs. Part 135 and “compensation or hire” is the place to start.
First: Do You Even Need a Part 135 Certificate?
Before you choose a route, settle whether you are in Part 135 territory at all. The applicability rule is 14 CFR §119.1: it applies to “each person operating or intending to operate civil aircraft—(1) As an air carrier or commercial operator, or both, in air commerce.” The definition that does the heavy lifting is in 14 CFR §1.1, which defines a commercial operator as “a person who, for compensation or hire, engages in the carriage by aircraft in air commerce of persons or property, other than as an air carrier or foreign air carrier.” In plain English: the moment someone pays you to carry them or their cargo, you are presumptively in certificate territory.
The four-part common-carriage test (FAA doctrine, AC 120-12)
The FAA frames whether an operation is common carriage — the kind that needs a Part 121/135 certificate — through long-standing guidance in Advisory Circular 120-12A and a line of FAA legal interpretations, not a single CFR section. Under that doctrine, a common carrier is defined by four elements working together:
Holding out
A willingness to transport for anyone who wants the service — through advertising, a reputation for serving the public, or any other means.
Transport of persons or property
Moving people or cargo, as opposed to, say, aerial work like photography or survey.
From place to place
Point-to-point transportation, which is why same-point sightseeing is treated differently.
For compensation
Money or other value changing hands for the transportation.
These four elements are FAA guidance and doctrine drawn from AC 120-12A and FAA Chief Counsel interpretations — there is no CFR section literally titled “holding out.” The definitions (commercial operator, common carriage concepts) come from §1.1, the applicability from §119.1, and the doctrine that ties them together from AC 120-12A. Whether your operation meets the four elements is exactly the kind of question an aviation attorney exists to answer.
The narrow exemptions in §119.1(e)
§119.1(e) lists operations that do not require a Part 119/121/135 certificate. The list is specific and short: student instruction; certain nonstop commercial air tours and sightseeing flights flown within a 25-statute-mile radius under stated conditions; ferry or training flights; aerial work operations such as crop dusting, banner towing, aerial photography, and firefighting; certain parachute operations; emergency mail service; and a few others. The pattern is important: these are specialized non-transportation activities or tightly bounded local flights. Carrying paying passengers from one city to another for a fee is conspicuously absent — because that is the textbook on-demand operation that §119.21 routes into Part 135.
“But I’ll just split costs with my passengers”
Cost-sharing and reimbursement rules are some of the most misunderstood — and most aggressively enforced — corners of aviation. The Part 91 carve-outs in §91.501 (time-sharing, interchange, joint ownership, carriage of company officials within cost limits) apply only to large and turbojet-powered multiengine airplanes and come with strict conditions on what may be charged. They are not a general permission to carry the public for money in a light aircraft, and treating them as one is a fast path to an illegal-charter finding. See the FAA’s illegal-charter crackdown for how this goes wrong. Confirm any cost-sharing theory with an aviation attorney before the flight, not after.
If you have concluded you are carrying persons for compensation and none of the §119.1(e) exemptions fit, you need Part 135 authority — and the only question left is whose. That is the fork.
The Two Routes to a Chartered Airplane
Both routes put your aircraft on a Part 135 certificate and let it fly revenue charter. They differ in who holds the certificate — and therefore who holds operational control, who carries the compliance program, and who keeps the charter margin. Here is the side-by-side before we go deep on each.
Route A — Your own certificate
You apply for and hold your own Part 135 certificate (typically single-pilot or single-PIC for one airplane) and become the air carrier.
- You hold operational control of every flight.
- You keep the full charter margin.
- You run — and prove — the entire compliance program.
- Certification is a months-long project; you become an aviation business.
Route B — Management company’s certificate
You place the aircraft on an established aircraft management company’s Part 135 certificate; the company charters it for you.
- The company holds operational control of charter flights.
- You skip certification and inherit a running program.
- You pay management fees and/or share charter revenue.
- You must respect that they, not you, control the charter flight.
A third option deserves naming, even though it is the “do nothing commercial” answer: keep the aircraft purely Part 91 and never charter it. That avoids the certificate entirely and is the right call for many owners — but it earns no charter revenue, and it is not a workaround for carrying paying passengers. The comparison below assumes you genuinely want charter income.
Route A: Holding Your Own Part 135 Certificate
The legal basis is 14 CFR §119.21, which requires a person conducting on-demand operations to do so “in accordance with the applicable requirements of part 135” and to “be issued operations specifications for those operations in accordance with those requirements.” The good news for a one-airplane owner is that the FAA offers scaled certificate types — you do not have to build a regional-airline compliance department to charter a single airplane.
Single-pilot operator
Limited to using only one pilot for all Part 135 operations, named on the operations specifications. The lightest-weight certificate: a single-pilot operator is generally not required to develop full manuals or designate a director of operations, chief pilot, and director of maintenance — though it still must designate who is responsible for operational control and maintain a hazardous-materials training program. The natural fit for an owner-pilot chartering their own airplane.
Single-PIC (pilot-in-command) operator
Limited to one named pilot-in-command plus up to three named second-in-command pilots. A small step up from single-pilot when you need a backup PIC pool or fly an aircraft requiring two pilots, while staying far short of a full operation.
Basic operator
Limited to five aircraft and five pilots. The same regulatory backbone as a standard certificate but capped — a sensible ceiling if you expect to grow from one airplane to a small fleet.
Standard (full) operator
No pilot or aircraft caps, full management structure and manuals required. More than a single airplane usually needs, but the destination if the operation scales.
The full breakdown of those tiers — what each requires and which fits which operation — lives in the companion guide to Part 135 certificate types (single-pilot, single-PIC, basic, standard). And the certification process itself — the five phases, the formal application, the proving tests, and the timeline — is its own undertaking, walked step by step in how to get a Part 135 certificate and the certification application checklist.
Set expectations on time and cost — and verify both with your FSDO
Getting an original Part 135 certificate commonly takes many months and runs into the tens of thousands of dollars once you account for manuals or templates, a designated agent or consultant, proving-test flying, and the staff time to build the program — and figures published by certification consultants are ranges, not fixed prices (as of 2026). Neither the FAA nor any consultant guarantees a timeline; the calendar is driven by your FAA office’s workload and how clean your application is. Budget for it as a business launch, not a form.
The honest summary of Route A: you keep the charter margin and you answer to no management company, but you become an FAA-certificated air carrier with everything that entails — operations specifications, training and pilot records, a drug-and-alcohol program, a maintenance and inspection program, and recurring surveillance. The records burden is real and ongoing; it is exactly the burden FileFlo’s document layer is built to make provable, but the program itself is yours to run.
Whichever route you take, the records have to hold up
Own certificate or management company, the same documents decide whether the operation is provable: registration and airworthiness certificate, the lease or management agreement, operations specifications, pilot and training records, and maintenance status. FileFlo classifies all of it, tracks every expiration, and produces an audit binder on demand. Starter at $89/mo, Professional at $299/mo. 5-day free trial, no credit card required.
Route B: Putting the Aircraft on a Management Company’s Certificate
The far more common path for a single high-value aircraft is to engage an aircraft management company that already holds a Part 135 certificate. The company manages the aircraft on your behalf — arranging crew, coordinating maintenance, scheduling, insurance administration — and, when you want charter income, places the aircraft on its certificate and charters it to third parties. You skip the certification project entirely and plug into a program that is already built and surveilled.
But Route B is not “hands-off and keep the money.” The single most important thing to understand is what changes about control. When the aircraft flies a Part 135 charter, the management company — as the certificate holder — must hold operational control of that flight. You do not get to direct a charter trip the way you direct a personal Part 91 flight in your own airplane. The FAA’s deepest concern with management arrangements is precisely the case where an owner keeps de facto control while the certificate holder’s name is on the paperwork — a structure the FAA treats as illegal charter regardless of the contract’s label.
What to scrutinize before you sign a management agreement
Who holds operational control of charter flights — it must be the certificate holder, stated plainly and reflected in practice.
How charter revenue is split, what the management fee covers, and who bears which operating costs.
How the aircraft is placed on the OpSpecs, and what the truth-in-leasing requirements mean for the documents you sign.
What happens to your priority access when a paying charter wants your aircraft on a day you want it.
How maintenance decisions are made — and who has authority when the owner and the certificate holder disagree.
The management-versus-charter relationship — and the way operational control and truth-in-leasing rules shape it — is its own subject, covered in the companion guide on aircraft management company vs. charter. If a leaseback structure is on the table — you lease the aircraft to the operator who then charters it — read aircraft leaseback and Part 135 and the dry-lease vs. wet-lease distinction first, because which kind of lease you sign determines who is presumed to hold operational control.
The “flight department company” trap
A classic structuring mistake is forming a single-purpose company whose only asset and activity is owning and operating one aircraft to carry the parent business’s people — which the FAA can treat as carriage for compensation or hire requiring a Part 135 certificate, even though it feels “internal.” It is common enough to have a name. See the flight department company trap — and do not design your ownership entity without an aviation attorney.
The honest summary of Route B: you trade charter margin and control for speed and a turnkey compliance program. It is the right answer for most owners of a single turbine aircraft who want occasional charter offset without becoming an aviation operator — provided the agreement is clean on operational control and you genuinely let the certificate holder hold it.
The Concept That Decides Everything: Operational Control
Both routes ultimately turn on a single defined term. 14 CFR §1.1 defines operational control, with respect to a flight, as “the exercise of authority over initiating, conducting or terminating a flight.” That is the whole hinge. On a Part 135 charter, operational control must sit with the certificate holder — whether that is you (Route A) or the management company (Route B). The FAA’s sustained enforcement focus is on certificate holders who lend their authority to flights they do not actually control, and on owners who keep control while someone else’s certificate takes the legal weight.
Because this concept is where illegal-charter cases are won and lost, it has its own deep-dive — including the questions the FAA asks to determine who really held control on a given flight. Read what is operational control in Part 135 before you finalize either route, and what “holding out” means to understand the advertising-and-availability side of the common-carriage test.
Truth-in-leasing: the paper trail behind the control question
Whenever an aircraft changes hands operationally through a lease — common in both routes, and central to Route B — the truth-in-leasing rule attaches. The companion guide on truth-in-leasing and §91.23 lease records covers what the lease must say about who holds operational control, the written-agreement and notification mechanics, and why the document is a compliance record the FAA will actually read — not just a business contract. Getting the lease language right is how the control answer becomes provable rather than merely asserted.
The takeaway: do not choose a route on economics alone. Choose it on who can genuinely hold operational control of the charter flights — and then make sure the lease, the management agreement, and the operations specifications all say the same thing the operation actually does.
The Records Both Routes Require — and Where FileFlo Fits
Here is the part that does not change with the route. Whether the certificate is yours or a management company’s, the same categories of document have to exist, stay current, and be retrievable on demand — for the FAA, and increasingly for the charter customers and brokers who now vet operators before they book. FileFlo is the proof layer across all of it.
Aircraft registration & airworthiness certificate
§135.25(a) / §91.203 / §47.40Why it matters
The aircraft must be a registered U.S. civil aircraft with an effective registration and a current, displayed airworthiness certificate — the entry test for any Part 135 tail, and a document a charter customer can ask to see.
How FileFlo tracks it
FileFlo classifies both certificates against the tail and tracks the §47.40 seven-year registration renewal so neither lapses unnoticed.
The lease or management agreement
§135.25(b)–(c) / §91.23Why it matters
On either route, the agreement that gives the operator possession, control, and use of the aircraft is a compliance record — and under truth-in-leasing it must address operational control. The FAA reads the signed document, not a summary.
How FileFlo tracks it
FileFlo stores the executed agreement against the aircraft with its term and renewal dates tracked, so the document is current and produced the moment an inspector asks.
Operations specifications (the aircraft listing)
§119.49Why it matters
Whichever certificate the aircraft sits on, it must appear in that certificate’s operations specifications. Until the OpSpecs list the tail, it is not part of the authorized fleet.
How FileFlo tracks it
FileFlo version-tracks each OpSpecs revision so the current authorization — and its effective date — is always the one on file.
Pilot, training & qualification records
Part 135 Subparts E–GWhy it matters
The pilots flying the charter must be qualified, current, and trained for the operation — and that qualification has to be documented, whether the pilot is you (Route A) or a crew the management company assigns (Route B).
How FileFlo tracks it
FileFlo classifies and tracks the recurring currency and training documents per pilot, surfacing expirations before a flight is flown out of currency.
Maintenance & inspection status
§135.411 / §91.417 / §135.439Why it matters
The aircraft’s inspection status, AD compliance, life-limited parts, and overhaul times must be current and documented — the airworthiness backbone the certificate holder is accountable for on every revenue flight.
How FileFlo tracks it
FileFlo classifies each status document, indexes it to the tail, and tracks every clock — the proof layer for the maintenance program your provider executes.
Related decision-and-records reading: do I need a Part 135 certificate to charter my plane · Part 91 vs. Part 135 (compensation or hire) · certification: consultant vs. DIY · proving runs requirements · adding kinds of operations · adding an aircraft (conformity) · operations specifications explained · what records a Part 135 operator must keep
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FileFlo is the proof layer, not the decision-maker or the operator
FileFlo is a compliance document intelligence platform. It classifies, indexes, version-tracks, and surfaces expirations on the records either route generates — and it makes them retrievable for an FAA inspector or a charter customer in one place. It does not structure your entity, give legal or tax advice, decide who holds operational control, choose your certificate type, run your operation, or get you certified. Those belong to you, your aviation attorney, your tax advisor, and your FAA office.
Frequently Asked Questions
Can I put my plane on a 135 certificate?
Yes — there are two ways to do it. You can obtain your own Part 135 certificate (a single-pilot, single-PIC, basic, or standard certificate, depending on how you intend to operate), or you can place the aircraft on an existing Part 135 certificate held by an aircraft management company that charters it for you. Either route turns the aircraft into a Part 135 asset, but each carries the aircraft listing in operations specifications under 14 CFR 119.49 and runs on the recordkeeping that Part 135 requires. The threshold question — whether you need a Part 135 certificate at all — is set by 14 CFR 119.1: a certificate is required when you operate as a direct air carrier or commercial operator carrying persons or property for compensation or hire. Both the structure and the operational-control questions are fact-specific; confirm them with an aviation attorney.
Do I need my own Part 135 certificate to charter my plane?
Not necessarily. If you want to charter your own aircraft and hold operational control of those flights yourself, you generally need your own Part 135 certificate, because 14 CFR 119.21 requires a person conducting on-demand operations for compensation or hire to hold an Air Carrier or Operating Certificate and be issued operations specifications. But if you place the aircraft on an established management company's Part 135 certificate, that company holds the certificate and the operational control of the charter flights, and you do not need your own. The trade is control and economics: your own certificate means you run (and prove) the whole compliance program; the management route means someone else holds the authority — and you must respect that they, not you, control the charter flight. Which fits depends on facts an aviation attorney should weigh.
When does the FAA require a Part 135 certificate at all?
Under 14 CFR 119.1, this part applies to each person operating or intending to operate civil aircraft as an air carrier or commercial operator, or both, in air commerce. 14 CFR 1.1 defines a commercial operator as a person who, for compensation or hire, engages in the carriage by aircraft in air commerce of persons or property. So the trigger is compensation or hire plus carriage of persons or property — the moment money changes hands for the transportation. 14 CFR 119.1(e) lists narrow operations that do NOT require a Part 119/121/135 certificate (student instruction, certain nonstop sightseeing within a 25-statute-mile radius, ferry or training flights, aerial work such as crop dusting and banner towing, and a handful of others). Carrying paying passengers from place to place is not on that exemption list. Whether your specific arrangement crosses the line is a fact question for an aviation attorney.
What are the single-aircraft Part 135 certificate options?
The FAA describes four types of Part 135 operator certificate, and a one-airplane operation usually fits the smaller two. A single-pilot operator is limited to using only one pilot — named on the operations specifications — for all Part 135 operations. A single-pilot-in-command (single-PIC) operator is limited to one named PIC plus up to three named second-in-command pilots. A basic operator is limited to five aircraft and five pilots. A standard (full) operator has no such pilot/aircraft caps. The single-pilot and single-PIC certificates carry reduced administrative burden — for example, a single-pilot operator is generally not required to develop full manuals or designate a director of operations, chief pilot, and director of maintenance — but every type still requires operations specifications, an airworthy aircraft, and the records to prove it. Confirm the right certificate type with your FAA office and an aviation attorney.
What is an aircraft management company, and how does it differ from a charter operator?
An aircraft management company manages the aircraft on the owner's behalf — handling crewing, maintenance coordination, scheduling, and administration — and, when the owner wants the aircraft to earn charter revenue, places it on the management company's own Part 135 certificate so the company can charter it. The legal pivot is operational control: when the aircraft flies a Part 135 charter, the management company (the certificate holder) must hold operational control of that flight, defined in 14 CFR 1.1 as the exercise of authority over initiating, conducting, or terminating a flight. When you fly your own aircraft for your own Part 91 purposes, you hold operational control. Blurring that line — an owner directing a charter flight as if it were a personal trip — is a core FAA concern. The choice between your own certificate and a management-company certificate is fact-specific; an aviation attorney should help structure it.
Can I make money chartering my plane without a Part 135 certificate?
Generally no, if you mean carrying paying passengers on demand. Carrying persons or property for compensation or hire is what makes you a commercial operator under 14 CFR 1.1, and 14 CFR 119.21 then requires a Part 135 certificate and operations specifications for on-demand operations. There are narrow Part 91 carve-outs for certain large and turbojet-powered multiengine airplanes under 14 CFR 91.501 — time-sharing, interchange, and joint-ownership agreements, carriage of company officials with cost limits, and demonstration flights with no charge — but those are limited, condition-laden exceptions, not a general license to charter, and they do not turn a small piston single into a revenue charter. The honest answer is that real charter revenue almost always runs through a Part 135 certificate — yours or a management company's. Talk to an aviation attorney and a tax advisor before you assume an exception applies.
Which route keeps more of the charter money — my own certificate or a management company?
That is a business and tax question, not a compliance-document one, so treat any general answer with caution. Broadly: holding your own certificate means you keep the charter margin but you also carry the full cost and labor of running and proving a Part 135 program — manuals (for standard operators), training, drug and alcohol program, maintenance program, surveillance audits, and the records behind all of it. Going through a management company means the company takes a management fee and/or a share of charter revenue, but it carries the certificate, the compliance program, and the operational control. The break-even depends on how many hours you charter, your aircraft type, and your tolerance for running an aviation business. The tax treatment of charter income, depreciation, and the federal excise tax on transportation is genuinely complex — get a tax advisor and an aviation attorney before you choose.
Does FileFlo decide which route is right or get me a certificate?
No. FileFlo is a compliance document intelligence platform — it classifies, indexes, version-tracks, and surfaces expirations on the records that either route generates: the aircraft's registration and airworthiness certificate, the lease or management agreement, the operations specifications, pilot and training records, maintenance and inspection status, and the truth-in-leasing paperwork. It does not structure your entity, give legal or tax advice, decide who holds operational control, choose your certificate type, or get you certified by the FAA. Those belong to you, your aviation attorney, your tax advisor, and your FAA office. What FileFlo does is make the records half provable — so whichever path you take, the documents that keep the operation legal are organized, current, and retrievable the moment an inspector or a charter customer asks.
Pick your route with counsel. Prove your records with FileFlo.
Your own certificate or a management company’s — either way, the operation lives or dies on documents: registration and airworthiness certificate, the lease or management agreement, operations specifications, pilot and maintenance records, and the truth-in-leasing paperwork. FileFlo classifies all of it, tracks every expiration, and produces a one-click audit binder for the FAA or a charter customer. AI document classification. 600+ document types. Starter at $89/mo, Professional at $299/mo.
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Reviewed by Chad Griffith, Founder, FileFlo — compliance document intelligence. Last reviewed June 15, 2026. Regulatory citations verified against the Cornell Legal Information Institute (14 CFR §§1.1, 91.501, 119.1, 119.21, 119.49, 135.25) as of the publication date; the common-carriage four-element doctrine (holding out, transport, place to place, compensation) is drawn from FAA Advisory Circular 120-12A and FAA legal interpretations, which are guidance rather than a single CFR section. This article is general compliance-document information, not legal or tax advice. Whether you need a certificate, which route fits, and who holds operational control are fact-specific — consult an aviation attorney, and consult a tax advisor on charter income, depreciation, and federal excise tax.