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The SMS Declaration of Compliance: A Guide for Part 135 Operators
The declaration of compliance is your company's formal statement to the FAA that your SMS meets every requirement of 14 CFR Part 5. Existing Part 135 operators must submit it by May 28, 2027. It's the finish line, not the starting line — so the SMS must already be working when you sign it.
Source: 14 CFR §5.9
What the Declaration Is
It's a written statement, submitted to your responsible Flight Standards office, that you have developed and implemented an SMS meeting Part 5. The FAA does not approve or accept your SMS beforehand. Instead, inspectors review it during routine surveillance after you file.
Who Files It
- Part 135 operators certificated before May 28, 2024.
- §91.147 air tour operators with an LOA issued before May 28, 2024.
- Operators in the old SMS Voluntary Program. Your SMSVP letter stays valid only until you file your declaration or May 28, 2027, whichever comes first.
New Part 135 applicants don't file a separate declaration on this timeline; their SMS is reviewed during certification.
Source: 14 CFR §5.9; FAA Notice N 8900.737
What Happens After You File
The FAA will look for evidence that your SMS is functioning: hazard reports, risk assessments, corrective actions, audit results, training records and safety communications. Operators who declared early have already received FAA requests for this kind of evidence. A system that only exists on paper will show its gaps quickly.
Before You Sign: Five Questions to Ask
- Do we have a signed safety policy, a code of ethics and a named accountable executive?
- Have hazards actually been reported, assessed and controlled — with records to prove it?
- Have we run at least one internal audit and tracked its findings to closure?
- Has every employee completed SMS training for their role?
- Are our records organized and kept for the periods Part 5 requires?
If any answer is "no," work through our free SMS Compliance Checklist first.
How eSMS and ACCG Help
eSMS
eSMS keeps every report, assessment, audit and corrective action on record, so you can answer an FAA request in minutes. See eSMS →
ACCG
ACCG reviews your SMS against Part 5 before you file and can help prepare the declaration. Visit ACCG →