A standard Part 91 flight department is not required by the FAA to have a Safety Management System — the SMS rule in 14 CFR Part 5 applies (under §5.1) to Part 121, Part 135, §91.147 air-tour LOA holders, and certain Part 21 holders, not to typical Part 91 operations. Operators that want an FAA-recognized SMS anyway can join the FAA SMS Voluntary Program (SMSVP), build an SMS that meets the Part 5 standard, and file a Declaration of Compliance with their Flight Standards office. Most Part 91 departments adopt a voluntary SMS not because they must, but because insurers, owners, customers, and audit programs (IS-BAO, ARGUS, Wyvern) increasingly expect one — and because it gives a head start if they ever enter the Part 5 mandate.
If you searched "part 91 sms requirements", "is sms required for part 91", or "sms voluntary program faa", you have probably hit a lot of pages that blur the line between the FAA's mandate (Part 121/135/§91.147) and the FAA's voluntary program(everyone else who wants in). This guide keeps that line sharp: it explains what the SMSVP actually is, why so many Part 91 flight departments opt in even though they are outside the rule, and — because the program is only as real as its evidence — exactly what records a voluntary SMS depends on. If you want what the mandate requires for the operators it does cover, start with the FAA Part 135 SMS 2027 deadline.
First, the Honest Part: Part 91 Is Not in the Mandate
Before anyone sells you an SMS, get the regulatory picture straight. The FAA SMS rule is 14 CFR Part 5, and its scope is defined in §5.1.
Who 14 CFR Part 5 actually applies to (§5.1)
Per §5.1, the SMS rule applies to: Part 121 air carriers; Part 135 certificate holders; holders of a §91.147 Letter of Authorization (air-tour operators); and certain Part 21 type/production certificate holders. A standard Part 91 corporate or private flight department is not on that list, so the FAA does not require it to have an SMS. Under §5.9, operators already authorized when the rule took effect must develop and implement an SMS no later than May 28, 2027 — but that deadline applies to the Part 135 and §91.147 holders in scope, not to ordinary Part 91 operations.
There are two narrow Part 91 exceptions worth naming because they cause most of the confusion. The FAA expanded eligibility for its voluntary program to include Part 91 Living History Flight Experience (LHFE) operations and Part 91K fractional ownership operations. Those are specific categories — they do not make every Part 91 flight department subject to an SMS rule. For the typical business or private operator flying under Part 91, an SMS remains optional. As NBAA puts it in its practical guide for operators, "Part 91, 141, 142 and 145 organizations can also use this framework to develop an SMS, even without a regulatory mandate."
The line that moves: if your operation changes
The moment a flight department adds a Part 135 certificate or operates under a §91.147 LOA, it crosses into the Part 5 mandate and the May 28, 2027 timeline becomes a real obligation, including a formal Declaration of Compliance. That is the single most common reason a Part 91 department decides to stand up a voluntary SMS early — to be ready before the rule applies, not scrambling after. If that is your situation, read the Part 135 SMS requirements and the Declaration of Compliance guide.
What the FAA SMS Voluntary Program (SMSVP) Is
The SMSVP is the FAA's path for operators and air agencies that are not required to have an SMS but want to build one and have the FAA recognize it. Here is the plain-English version.
It is genuinely voluntary
The FAA does not compel a Part 91 flight department to join, and joining does not turn a voluntary obligation into a mandatory one. You opt in. The program grew out of the FAA's earlier SMS pilot programs and guidance — Advisory Circular 120-92 and FAA Order 8000.369 — which established how a voluntary SMS is developed and recognized.
Who is eligible
Historically the SMSVP covered Part 125, Part 133, Part 137, Part 141, Part 142, Part 145, and Part 147 organizations. The FAA expanded eligibility to add Part 91 LHFE operations and Part 91K fractional ownership operations. Eligibility for those other categories was unchanged by the 2024 Part 5 amendments.
You build a Part 5–standard SMS
A participant develops and implements an SMS built on the same four components the rule expects — safety policy, safety risk management, safety assurance, and safety promotion — scaled to the size and complexity of the operation. The FAA and NBAA both emphasize that an SMS is meant to be scalable, so a small department is not expected to run an airline-sized program.
You document it with a Declaration of Compliance
Once the SMS meets the Part 5 standard, the organization submits a Declaration of Compliance — a document stating it has developed and implemented a conforming SMS — to its responsible FAA Flight Standards office. Existing SMSVP participants that had an FAA-recognized SMS were directed to revise it to the new Part 5 standard and file by May 28, 2025.
SMSVP vs IS-BAO — they are complementary, not rivals
The SMSVP is an FAA program (recognition via a Declaration of Compliance to Flight Standards). IS-BAO, run by IBAC, is a private, ICAO-recognized, stagedregistration (Stage 1 → 2 → 3) built specifically for business aviation and verified by an accredited third-party auditor. Many Part 91 departments pursue IS-BAO for its international recognition and clear maturity path; some engage the FAA's voluntary program as well. Both build the same four SMS components and rely on the same records. For the staged structure, see IS-BAO Stage 1, 2 & 3 explained and the ARGUS vs Wyvern vs IS-BAO comparison.
A voluntary SMS is only as real as its records
Whether you join the SMSVP, pursue IS-BAO, or simply want a safety program your insurer and board respect, the program rests on evidence you can produce on demand. FileFlo's free FAA readiness score takes about 3 minutes and surfaces the document gaps most likely to undermine a voluntary SMS. No signup required.
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Why Part 91 Departments Adopt a Voluntary SMS Anyway
If it is not required, why do it? Because the parties a flight department answers to increasingly expect a documented safety program — and because the program delivers real risk reduction. These are the drivers we see most often.
Insurance & underwriters
Aviation insurers increasingly look favorably on a documented, active safety program. A real SMS — with hazard reporting and risk assessment you can evidence — is a tangible underwriting story, not just a binder.
Owners, boards & risk committees
Principals and corporate risk committees want demonstrable safety governance over the aircraft they fund. A voluntary SMS gives leadership a structured, auditable answer to "how do we manage flight-department risk?"
Customers & audit programs
IS-BAO, ARGUS, and Wyvern all exercise an SMS, and international customers often ask whether you run one. A voluntary SMS is the foundation those registrations and ratings are built on.
Regulatory readiness
If you ever add a Part 135 certificate or a §91.147 LOA, you move inside the Part 5 mandate. A mature voluntary SMS is a major head start on the formal requirement and the Declaration of Compliance.
The original purpose: fewer surprises
Underneath the external drivers is the point of an SMS: a repeatable way to surface hazards and manage risk before they become incidents. That is the benefit that compounds whether or not anyone is asking.
The honest caution: an SMS is a commitment, not a binder
A voluntary SMS only delivers value if hazard reporting, risk assessment, safety meetings, and recordkeeping actually happen on a recurring basis. A "documented but dormant" SMS — a manual on a shelf with no live reports behind it — helps no one and will not survive an IS-BAO audit or an insurer's scrutiny. The good news is that the FAA and NBAA both stress that an SMS is meant to be scalable, so a small department can run a right-sized program. The deciding question is not "can we write the manual?" but "will we sustain the records?"
The Four SMS Components — Voluntary or Not, They Are the Same
Whether your SMS is mandated (Part 135) or voluntary (Part 91 via the SMSVP or IS-BAO), it is built on the same four pillars the FAA defines in 14 CFR Part 5. The difference is scale, not structure.
Safety policy
Management commitment, defined safety accountabilities, an accountable executive, and a non-punitive reporting policy. This is where leadership ownership of the program lives.
Safety risk management
A repeatable process to identify hazards, analyze and assess risk, and apply controls — documented in hazard reports and risk assessments you can later prove you acted on.
Safety assurance
Monitoring, internal audits, and performance measurement to confirm controls are working and to catch new hazards — with corrective-action tracking that closes the loop.
Safety promotion
Training, communication, and a safety culture so the program is something people actually do, not a manual on a shelf. Records show who was trained and when.
Each of these pillars produces records. Safety policy produces your manual and accountability documents. Risk management produces hazard reports and risk assessments. Safety assurance produces audit findings and corrective-action logs. Safety promotion produces training records and meeting minutes. That is the bridge from "we have an SMS" to "we can prove our SMS is alive" — and it is where most voluntary programs quietly fall down.
The Records a Voluntary SMS Actually Depends On
Here is the part the "should you adopt an SMS?" articles skip: a voluntary SMS generates and depends on the same evidence as a mandated one, and the records are the part that either holds up or falls apart. An SMS is only as credible as your ability to produce its evidence on demand — for an insurer, an IS-BAO auditor, your board, or (if you ever enter the mandate) the FAA.
SMS manual & safety policy
The SMS manual, safety policy statement, accountable-executive designation, and defined safety accountabilities — the documentary backbone of the program.
Hazard reports & risk assessments
Submitted hazard reports, risk analyses, and the controls applied — proof the risk-management process is actually running, not theoretical.
Safety assurance & audits
Internal audit findings, safety-performance monitoring, and corrective-action tracking that closes the loop on identified issues.
Safety promotion & training
Records showing personnel were trained on the SMS, plus safety meeting and safety-committee minutes that evidence the safety culture.
Pilot training & currency
The underlying operational records the SMS oversees — initial and recurrent training, checkrides, and currency for every crewmember.
Maintenance & airworthiness
Aircraft inspection status, airworthiness, and maintenance records that feed the SMS and any audit of the operation.
The single biggest reason a voluntary SMS underwhelms is not a bad manual — it is records that are scattered across drives, inboxes, and binders, so no one can prove the program is live when it counts. The discipline of keeping SMS evidence current, complete, and retrievable is what turns a paper program into a real one. That same retrievability is what an IS-BAO auditor checks, what an insurer wants to see, and what the FAA expects if your operation ever enters the mandate. For the broader Part 91 records picture, see Part 91 corporate flight department records; for the audit-prep mechanics that overlap heavily, see the ARGUS & Wyvern audit document checklist and how to prepare for an ARGUS audit.
How FileFlo Helps: The Records Layer Behind a Voluntary SMS
FileFlo holds and proves the records — it does not run your SMS
FileFlo is a compliance document intelligence platform. It classifies your SMS records, version-controls them, tracks expirations, and assembles an organized evidence binder on demand. It does not write your safety policy, run your safety meetings, make safety decisions, conduct an audit, grant or guarantee an IS-BAO, ARGUS, or Wyvern rating, or provide legal advice. The SMSVP is an FAA program and IS-BAO, ARGUS, and Wyvern are independent programs and registered trademarks of their respective owners; FileFlo is not affiliated with or endorsed by any of them. You own and run the SMS. FileFlo makes the records behind it instantly provable.
The honest positioning is simple: a voluntary SMS is your safety program and your decision, and FileFlo does not change that. What it removes is the recurring labor of keeping SMS evidence current and producing it on demand — the exact bucket where voluntary programs go dormant. When your SMS manual, hazard reports, risk assessments, training records, and the pilot-currency and maintenance records the SMS oversees are classified, version-controlled, and retrievable in seconds, the program stays alive between audits instead of being reconstructed before each one.
Classifies every record your SMS depends on
SMS manual, hazard reports, risk assessments, audit findings, training records, pilot currency, and maintenance records are filed by type — so the evidence behind your safety program is organized, not scattered across drives and inboxes.
Tracks expirations so nothing lapses silently
Pilot currency, recurrent training, and inspection cycles carry expiry dates. FileFlo flags upcoming gaps 90, 60, and 30 days out — before a lapsed record undermines the very SMS that is supposed to catch it.
Assembles an organized evidence binder on demand
When an insurer, an IS-BAO auditor, your board, or the FAA asks for documentation, FileFlo produces a complete, organized binder in seconds instead of staff hours spent assembling it across systems.
One records home — voluntary today, mandated tomorrow
Because a voluntary SMS exercises the same Part 5 components and records the mandate expects, FileFlo holds them once. If your operation ever adds a Part 135 certificate or §91.147 LOA, the evidence is already in order.
Starter Plan
$89/mo
Up to 100 documents/month · 3 users
For smaller Part 91 departments organizing the records behind a voluntary SMS.
Professional Plan
$299/mo
Unlimited documents + users · audit trail · employee auto-detection
For multi-aircraft departments running an IS-BAO Stage 2/3 program or preparing for Part 135.
FileFlo pricing is a fixed published rate (5-day free trial on both plans). It is separate from, and additional to, any SMS consultant, IS-BAO auditor, or registration cost — and it targets the records/proof bucket, not the safety program itself.
Frequently Asked Questions
Is SMS required for a Part 91 flight department?
No. The FAA's Safety Management System rule lives in 14 CFR Part 5, and under §5.1 it applies to Part 121 air carriers, Part 135 certificate holders, holders of a §91.147 Letter of Authorization (air-tour operators), and certain Part 21 certificate holders. A standard Part 91 corporate or private flight department is not on that list, so the FAA does not require it to have an SMS. The exceptions are narrow: Part 91 Living History Flight Experience (LHFE) operations and Part 91K fractional ownership operations are eligible for the FAA's voluntary program, and any Part 91 department can choose to build an SMS on its own. But choosing to is the key phrase — for the typical Part 91 flight department, an SMS is voluntary, not mandated.
What is the FAA SMS Voluntary Program (SMSVP)?
The SMS Voluntary Program (SMSVP) is the FAA's framework for operators and air agencies that are not required to have an SMS but want to implement one and have the FAA recognize it. It grew out of the FAA's earlier SMS pilot programs and guidance (Advisory Circular 120-92 and FAA Order 8000.369) and lets eligible organizations — historically Part 125, Part 133, Part 137, Part 141, Part 142, Part 145, and Part 147, plus Part 91 LHFE and Part 91K — voluntarily develop, implement, and document an SMS. Participants build an SMS that meets the Part 5 standard and submit a Declaration of Compliance to their responsible FAA Flight Standards office. It is genuinely opt-in: the FAA does not compel a Part 91 flight department to join, and joining does not convert a voluntary obligation into a mandatory one.
Why would a Part 91 flight department voluntarily adopt an SMS?
Because the people who matter to a flight department increasingly expect one, and because it works. The most common drivers are: insurance and underwriters that look favorably on a documented safety program; boards, owners, and risk committees that want demonstrable safety governance; customers, charter brokers, and audit programs (IS-BAO, ARGUS, Wyvern) that ask whether you run an SMS; and regulatory readiness — if your operation ever adds a Part 135 certificate or a §91.147 LOA, you would then be inside the Part 5 mandate, and a mature voluntary SMS is a large head start. Underneath all of that is the original purpose: a structured way to find and fix hazards before they become incidents. NBAA notes that Part 91, 141, 142, and 145 organizations can use the Part 5 framework to develop an SMS even without a regulatory mandate.
What is the difference between SMSVP and IS-BAO for a Part 91 department?
They are complementary, not competing. The SMSVP is an FAA program — your SMS is recognized by the FAA via a Declaration of Compliance to a Flight Standards office. IS-BAO (the International Standard for Business Aircraft Operations, run by IBAC) is a private, ICAO-recognized, staged registration (Stage 1, 2, 3) built specifically for business aviation and verified by an accredited third-party auditor. Many Part 91 flight departments pursue IS-BAO because it is widely recognized by international customers and audit programs and because its staged structure gives a clear maturity path; some also engage the FAA's voluntary program. Both build the same four SMS components — safety policy, safety risk management, safety assurance, and safety promotion — and both rely on the same underlying records. Neither is FAA-mandated for a standard Part 91 operation.
Does a voluntary SMS satisfy the Part 5 SMS rule?
For a standard Part 91 flight department there is no Part 5 obligation to satisfy in the first place, so the question is usually moot. Where it matters is if your operation is, or becomes, a Part 135 certificate holder or a §91.147 LOA holder — then Part 5 applies and you must develop and implement an SMS that meets the rule and submit a Declaration of Compliance no later than May 28, 2027 for operators authorized before the rule. A voluntary SMS you built earlier does not automatically check that box, but because it exercises the same Part 5 components it gives you a substantial head start; you would still need to confirm it meets the current Part 5 standard and file the Declaration of Compliance with the FAA. In short: a voluntary SMS is a head start on Part 5, not an automatic substitute for the formal compliance step when the mandate actually applies to you.
What records does a voluntary Part 91 SMS require?
A voluntary SMS generates and depends on the same evidence as a mandated one — and the records are the part that either holds up or falls apart. You need your SMS manual and safety policy, your hazard reports and risk assessments, safety meeting minutes and safety committee records, internal audit and safety-assurance findings with corrective actions, training records showing personnel understand the SMS, and the underlying operational records the SMS oversees: pilot training and currency, aircraft maintenance and airworthiness, and personnel qualifications. The SMS is only as credible as your ability to produce these on demand — for an insurer, an IS-BAO auditor, your board, or (if you ever enter the mandate) the FAA. The recordkeeping discipline, not the binder on the shelf, is what makes the program real.
Is a voluntary SMS worth it for a small flight department?
It depends on your drivers, and it is a real decision rather than a formality, since for a Part 91 department it is not legally required. The case for it is strongest when an insurer, an owner or board, or a customer/audit program is asking for demonstrable safety governance, or when you anticipate adding a Part 135 certificate or a §91.147 LOA and want a head start on the Part 5 mandate. The honest caution is that an SMS is an ongoing commitment, not a one-time project: it only delivers value if hazard reporting, risk assessment, and recordkeeping actually happen on a recurring basis. A small department can absolutely run a right-sized, scalable SMS — the FAA and NBAA both emphasize scalability — but a documented-but-dormant SMS helps no one. Decide based on who is asking and whether you will sustain it.
How does FileFlo help with a voluntary Part 91 SMS?
FileFlo is the records and proof layer behind a voluntary SMS — not the SMS itself, not a consultant, and not an auditor. A voluntary SMS lives or dies on whether its evidence is current, complete, and retrievable, and that is exactly the bucket FileFlo targets. It classifies and version-controls your SMS manual, hazard reports, risk assessments, training records, and the pilot-currency and maintenance records the SMS oversees; it tracks expirations so currency and recurrent items do not lapse silently; and it assembles an organized evidence binder on demand for an insurer, an IS-BAO auditor, your board, or the FAA. FileFlo does not write your safety policy, run your safety meetings, make safety decisions, grant any rating, or provide legal advice. You own and run the SMS; FileFlo makes the records behind it instantly provable.
Run the SMS. Let FileFlo prove it.
A voluntary SMS is your safety program — FileFlo handles the records bucket it rests on. It classifies every document your SMS depends on, surfaces expiring pilot, training, and maintenance records before they become gaps, and assembles a complete, organized evidence binder in seconds for an insurer, an IS-BAO auditor, your board, or the FAA. Starter at $89/mo · Professional at $299/mo · 5-day free trial.
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Written by Chad Griffith, Founder, FileFlo — compliance document intelligence. This article explains a voluntary FAA program from a compliance-document perspective. The SMS Voluntary Program (SMSVP) is an FAA program; IS-BAO (IBAC), ARGUS (ARG/US), and Wyvern are independent, voluntary third-party programs and registered trademarks of their respective owners. FileFlo is not affiliated with, endorsed by, or a substitute for any of them, is not an auditor or a consultant, does not run your safety management system, and does not grant or guarantee any rating. Cited regulatory facts reflect 14 CFR Part 5 (including §5.1 and §5.9) as published, and program details reflect FAA and industry material as of 2026 and can change. This is not legal, financial, or safety-program advice. Always confirm your specific obligations and current program requirements with your assigned FSDO and the relevant program.