14 CFR § 135.351
Recurrent training
See your compliance status for this section
3-minute free audit. CFR-cited gap report. No signup.
What does 14 CFR § 135.351 require?
14 CFR 135.351 is the recurrent crew training rule for Part 135 — every crewmember and dispatcher must go through the operator's FAA-approved recurrent training program every 12 calendar months. The training is two-part: ground training (regulations, weather, navigation, abnormal + emergency procedures, aircraft systems) and flight training (aircraft systems, abnormal/emergency operations, instrument procedures where applicable). The program itself is operator-specific — content + delivery methods + simulator/aircraft mix must be approved by the operator's Principal Operations Inspector (POI) under the operator's training program. §135.351 is distinct from §135.293: §135.351 is the training delivery (what's taught, by whom, and how), and §135.293 is the competency verification (testing that confirms the training stuck). Lapsed training currency under §135.351 is one of the most-cited Part 135 enforcement findings and frequently pairs with §135.293 testing violations in FAA Enforcement Decision Process (EDP) actions.
Regulation text (summary)
§135.351 requires each Part 135 certificate holder to ensure that each crewmember and aircraft dispatcher receives recurrent training as part of the operator's FAA-approved training program under Subpart H. Recurrent training consists of ground training (regulations, abnormal/emergency procedures, weather, navigation, aircraft systems) plus flight training (aircraft systems, abnormal/emergency operations, instrument procedures where applicable). Required every 12 calendar months. Pairs with §135.293 (initial and recurrent pilot testing) — §135.351 is the training delivery; §135.293 verifies competency stuck.
Read full regulation at eCFR.govWho must comply with 14 CFR § 135.351?
All FAA Part 135 certificate holders (air taxi, commuter, on-demand operators) with crewmember employees (pilots, flight attendants where applicable) and aircraft dispatcher employees. Approximately 2,000+ Part 135 certificate holders in the US are in scope. Single-pilot operators authorized under §135.3 remain subject to §135.351 recurrent training for the pilot in command — the single-pilot exemption that applies to §135.21 (manual requirement) does not exempt the operator from training program requirements for crew personnel. Recurrent training requirements scale with operator complexity: small on-demand operators may run streamlined programs covering 1-2 aircraft types, while multi-fleet commuters maintain extensive recurrent curricula per aircraft type + crew position.
What happens if you violate 14 CFR § 135.351?
FAA civil penalties: $1,500-$25,000 typical for §135.351 training-currency violations; higher for systemic findings or willful non-compliance. Recurrent training violations are among the most-cited Part 135 enforcement categories and frequently appear alongside §135.293 testing violations in FAA Enforcement Decision Process (EDP) actions — the two rules are operationally inseparable, since §135.351 delivers the training that §135.293 then tests. Common findings include: (1) crewmembers operating past the 12-calendar-month window without recurrent training completion, (2) training records that don't match the operator's FAA-approved training program (wrong subjects covered, wrong instructor authorization, wrong simulator level), (3) ground-training portions delivered online when the operator's program requires classroom delivery for specific subjects, and (4) flight-training portions delivered in a simulator level not authorized for that aircraft type. After-accident investigations always check training currency — a crewmember in an accident whose §135.351 recurrent had lapsed creates significant civil and potentially criminal exposure for both the crew and the operator. Repeated findings can trigger increased FAA surveillance frequency, mandatory corrective action plans, and in severe cases certificate suspension.
Penalty range
Annual citations
YoY penalty trend
How to comply (implementation checklist)
- 1Maintain the operator's FAA-approved training program documenting the full §135.351 recurrent curriculum: subject list, delivery methods (online vs classroom vs simulator vs aircraft), instructor authorization, frequency, and minimum hours per subject for each crew position + aircraft type.
- 2Track recurrent currency for every crewmember and dispatcher in a centralized training records system — last completion date, next-due date (end of 12th calendar month from completion), aircraft types covered, and any partial-completion gaps requiring follow-up.
- 3Schedule recurrent training 30-60 days before the end-of-month deadline to absorb instructor + simulator + crew-schedule friction; do not wait until the final week before lapse.
- 4Conduct ground training covering all subjects required by the operator's FAA-approved program — regulations, abnormal/emergency procedures, weather, navigation, aircraft systems, and operator-specific subjects (security, hazmat where applicable, MEL procedures, OpSpec-specific authorizations).
- 5Conduct flight training in the authorized setting per the operator's program — aircraft only, or aircraft + approved simulator/FTD per the aircraft type's authorized credit. Document instructor + setting + hours + subjects covered for each crewmember.
- 6Coordinate §135.351 recurrent training with §135.293 testing — most operators conduct the testing immediately following recurrent training in the same multi-day event under the same FAA-approved program. Records remain separate (training completion vs. testing results).
- 7Audit training records quarterly + before any scheduled FAA surveillance (§135.421 inspection, OpSpecs renewal, SVE) — verifying every crewmember has a current §135.351 recurrent + matching §135.293 testing record, with no end-of-month gaps.
Common misinterpretations
- Misinterpretation: '§135.351 and §135.293 are the same requirement.' Reality: They are separate rules with separate documentation requirements, though they're operationally coordinated. §135.351 is training DELIVERY — the operator's FAA-approved program specifies what subjects are taught, by whom, in what setting (ground/sim/aircraft), and on what cadence. §135.293 is competency VERIFICATION — a written/oral test plus an in-aircraft (or approved-sim) competency check that confirms the training stuck. Most operators run the §135.351 recurrent training and §135.293 testing in a coordinated multi-day event under the same FAA-approved program, but the records are separate: training completion under §135.351 vs. testing results under §135.293. FAA surveillance typically reviews both side-by-side.
- Misinterpretation: 'Online ground training is enough to satisfy the §135.351 ground portion.' Reality: §135.351 ground training delivery is governed by the operator's FAA-approved training program. Some subjects can be delivered online under modern training programs (e.g., regulation updates, weather refreshers, aircraft-systems review) when the program explicitly authorizes online delivery for those subjects — but the program must specify which subjects are eligible for online delivery and which require classroom or hands-on delivery. Online delivery of subjects that the operator's program lists as classroom-required is a finding even if the underlying content is correct. Operators with FAA-approved programs that don't authorize online delivery cannot use online courses to satisfy §135.351 ground training, regardless of how comprehensive the third-party online curriculum looks.
- Misinterpretation: 'Flight training must be conducted in the aircraft only.' Reality: §135.351 flight training may be conducted in part in an FAA-approved simulator depending on the operator's training program and the aircraft type. For aircraft with Level B/C/D FFS or appropriate FTD authorizations, significant portions of the flight training (abnormal/emergency operations, instrument procedures, system malfunctions) are typically conducted in the simulator — both because simulator training can safely cover scenarios that cannot be flown in the aircraft (engine failures, complex emergencies) and because operator training programs are FAA-approved to credit simulator hours. Aircraft-only flight training is required for aircraft types without an approved simulator. The split between simulator and aircraft training is specified in the operator's FAA-approved training program.
- Misinterpretation: '12 calendar months means 365 days.' Reality: §135.351 specifies 12 CALENDAR MONTHS, the standard FAA timekeeping convention. A crewmember who completed recurrent training on March 15, 2025 has until March 31, 2026 (end of the 12th calendar month from completion) to complete the next recurrent. Operating past March 31, 2026 without completion is a lapse. Most operators schedule recurrent at 30-60 days before the end-of-month deadline to absorb scheduling friction (instructor availability, simulator booking, crew schedules). The end-of-month convention applies identically to §135.293 testing currency.
Real enforcement examples
Anonymized from public FMCSA enforcement summaries. Penalty amounts reflect assessed and final settled values where disclosed.
Part 135 on-demand charter operator received a $19,500 FAA civil penalty in 2024 after a §135.421 surveillance inspection identified §135.351 recurrent training findings on three pilots: (1) one pilot had operated 8 days past the end-of-month deadline for §135.351 recurrent completion before training was scheduled, (2) one pilot's ground-training records showed online completion of two subjects (weather + abnormal procedures) that the operator's FAA-approved training program required to be classroom-delivered, and (3) one pilot's flight-training records showed simulator completion in a Level B FFS for an aircraft type the operator's program authorized only for Level C+ credit. The §135.351 findings paired with corresponding §135.293 testing-currency findings for two of the three pilots. Corrective action plan required full retraining for the three pilots under properly-authorized delivery methods, training-program audit, and updated end-of-month tracking procedures. Operator's surveillance frequency was increased for the following 12 months pending corrective-action close-out.
Source: FAA Enforcement Decision Process summaries, anonymized; consistent with FAA Compliance + Enforcement Program reporting in FAA Order 2150.3C
How FileFlo handles 14 CFR § 135.351
FileFlo's compliance rule-pack FAA-14CFR135.351 automatically checks every document you upload against this regulation. Auto-detects document type, parses key fields, sets renewal alerts, and surfaces this section in your audit binder if a gap is found.
Already evaluating? Start a 5-day free trial →
Frequently asked questions
What's the difference between §135.351 and §135.293?▾
§135.351 is recurrent TRAINING DELIVERY — the operator's FAA-approved program for what's taught, by whom, in what setting (ground/simulator/aircraft), and on what cadence (every 12 calendar months). §135.293 is recurrent TESTING — a written/oral knowledge test plus an in-aircraft (or approved-simulator) competency check that verifies the crewmember can actually perform what was trained. The two rules are operationally inseparable: §135.351 puts knowledge + skill into the crewmember; §135.293 confirms it stuck. Most Part 135 operators run them as a coordinated multi-day event under the same FAA-approved training program — recurrent training Monday-Wednesday, testing Thursday-Friday — but the records remain separate: training completion records under §135.351, testing results under §135.293. FAA surveillance reviews both side-by-side, and findings against one frequently pair with findings against the other in FAA Enforcement Decision Process (EDP) actions.
Can §135.351 ground training be delivered online?▾
It depends on the operator's FAA-approved training program. Some operators' programs explicitly authorize online delivery for specific subjects — typically regulation updates, weather refreshers, aircraft-systems review, and similar didactic content where the learning objective is recall + recognition rather than hands-on procedure execution. Other subjects (abnormal/emergency procedures, operator-specific OpSpec procedures, hazmat where applicable) are commonly classroom-required under operator programs because they involve discussion, scenario walk-throughs, or hands-on procedure execution. The decision is operator-by-operator: review your FAA-approved training program (typically OpSpec A005 or the operator's curriculum document) to confirm which subjects authorize online delivery. Operating online delivery for subjects the program lists as classroom-required is a §135.351 finding even if the underlying content is correct.
Can §135.351 flight training be done entirely in a simulator?▾
For aircraft with FAA-approved Level B/C/D Full Flight Simulator (FFS) or appropriate Flight Training Device (FTD) authorizations under the operator's training program, significant portions of §135.351 flight training are typically simulator-credited — abnormal/emergency operations, instrument procedures, system malfunctions, and scenarios that cannot be safely flown in the aircraft. For aircraft types without an approved simulator, flight training is conducted in the aircraft itself. The exact split between simulator and aircraft training is documented in the operator's FAA-approved training program for each aircraft type. Operating a simulator at a credit level the program doesn't authorize (e.g., using a Level B FFS for an aircraft type the program authorizes only for Level C+) is a finding even when the simulator session itself was well-conducted.
How often must §135.351 recurrent training be completed?▾
Every 12 calendar months. The 12-calendar-month convention is the standard FAA timekeeping rule: a crewmember who completed recurrent training on March 15, 2025 has until end-of-day March 31, 2026 (the end of the 12th calendar month from completion) to complete the next recurrent training. Operating past that end-of-month deadline without completion is a lapse and a §135.351 violation. Operators typically schedule recurrent at 30-60 days before the end-of-month deadline to absorb instructor + simulator + crew-schedule friction; waiting until the final week before lapse is operationally risky. The same end-of-month convention applies to §135.293 testing currency, and most operators run both within the same scheduled multi-day event under the same FAA-approved program.
Does §135.351 apply to dispatchers, not just pilots?▾
Yes. §135.351 applies to each CREWMEMBER and each aircraft DISPATCHER required to be trained under the operator's training program. Dispatcher recurrent training covers different subjects than crewmember training — typically focused on flight following, weather, regulatory updates, abnormal-operation coordination, and operator-specific dispatch procedures — but the 12-calendar-month cadence + FAA-approved-program requirement applies identically. Operators with dispatcher employees must maintain dispatcher training records on the same cadence as crewmember training records, and surveillance typically reviews dispatcher recurrent currency alongside crewmember currency. Smaller on-demand operators that do not employ formal dispatchers may have a simpler training-program structure, but flight followers or operations-control personnel performing dispatch-equivalent functions may still be subject to training under the operator's program.
What happens if a crewmember's §135.351 recurrent training lapses?▾
The crewmember is ineligible to act in their crew position under Part 135 until §135.351 recurrent training is completed under the operator's FAA-approved program. Operating after lapse is a violation by both the crewmember and the operator — and if §135.293 testing currency has also lapsed (the two often lapse together since they're typically scheduled together), both rules are cited. Civil penalties typically apply per crewmember per violation, with higher penalties for repeated or willful findings. After-accident investigations always check training + testing currency, and a crewmember in an accident whose §135.351 had lapsed creates significant exposure for the operator (civil penalty, certificate action, potential criminal exposure for willful non-compliance) and the crewmember (airman certificate action). The operational fix is straightforward: ground the crewmember, schedule the recurrent training (and §135.293 testing if also lapsed), document completion, and return the crewmember to service. The enforcement consequence is the bigger problem.
Related regulations
Sources + reviewer
Primary source: eCFR.gov — 14 CFR § 135.351
Reviewed by Chad Griffith (Founder + CEO, FileFlo) on