Home / SMS Deadline
The Part 135 SMS Deadline: May 28, 2027
Every Part 135 operator certificated before May 28, 2024 must develop and implement a Safety Management System that meets 14 CFR Part 5, and submit a declaration of compliance to the FAA, no later than May 28, 2027. Here is what the rule says, who it covers, and how to plan your remaining months.
What Changed in 2024
For years, only Part 121 airlines were required to have an SMS. Part 135 operators could join a voluntary program. On April 26, 2024, the FAA published a final rule that extended Part 5 to Part 135 operators and §91.147 commercial air tour operators. The rule took effect May 28, 2024, and gave existing operators 36 months to comply.
Source: 14 CFR §5.9; FAA Notice N 8900.737
Who Has to Comply
| Operator | What's required | When |
|---|---|---|
| Part 135 operators certificated before May 28, 2024 | Implement a Part 5 SMS and file a declaration of compliance | By May 28, 2027 |
| §91.147 air tour operators with an LOA issued before May 28, 2024 | Implement a Part 5 SMS and file a declaration of compliance | By May 28, 2027 |
| New Part 135 applicants (applied on or after May 28, 2024) | SMS is reviewed as part of certification | Before certification |
| Operators in the SMS Voluntary Program (SMSVP) | Still must meet Part 5; the SMSVP letter ends at declaration or May 28, 2027 | By May 28, 2027 |
Size is not an exemption. A single-aircraft operator falls under the same rule as a large fleet. The SMS can be scaled to fit a small operation, but every Part 5 element must be there.
Source: 14 CFR §5.1, §5.9
"Implement" Means More Than "Write"
The rule says develop and implement. That means your SMS must be running, not just documented. Before you sign the declaration, you should be able to show:
- Employees are reporting hazards, and you are acting on the reports.
- Hazards are assessed for risk, and controls are in place.
- Safety performance is monitored, with audits and corrective actions tracked to closure.
- Your people have been trained on their SMS duties.
- Records are being kept as Part 5 requires.
There is no FAA approval or acceptance step before you declare. The FAA checks your SMS during routine surveillance after you file. That's where the gap between "paper SMS" and "working SMS" shows up.
A Realistic Timeline From Today
With about seven months left, a small operator can still get there, but not by waiting. A practical plan:
- YOU ARE HERENow – December 2026
Run a gap analysis with our free SMS checklist. Name your accountable executive and safety lead. Get your SMS manual written or updated.
- YOU ARE HEREJanuary – February 2027
Go live on an electronic SMS. Train every employee on hazard reporting and their safety duties.
- YOU ARE HEREMarch – April 2027
Let the system run. Process real reports, complete risk assessments, run your first internal audit and track corrective actions.
- YOU ARE HEREMay 2027
Review your records against Part 5 and file your declaration of compliance before May 28.
How We Help You Meet the Deadline
eSMS gives you a working SMS on day one: hazard reporting, risk assessment, corrective actions, audits and records in one place. Our partner ACCG provides the SMS manual that matches it. You get the documentation and the evidence the FAA will ask for.