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FAQs
Quick answers on the Part 135 SMS deadline, single-pilot operators, record retention and more.
Part 135 SMS Frequently Asked Questions
Answers to the questions small and single-pilot Part 135 operators ask most about the Part 5 SMS requirements.
May 28, 2027. Part 135 operators certificated before May 28, 2024 must implement a Part 5 SMS and file a declaration of compliance by that date.
Source: 14 CFR §5.9
Yes. Part 5 now applies across Part 135 regardless of fleet size. Your SMS can be simple and sized to your operation, but it must include every Part 5 component.
Source: 14 CFR §5.1
Not automatically. The voluntary program was based on earlier standards. Your SMSVP letter remains valid only until you file your Part 5 declaration or May 28, 2027, whichever comes first. Review your SMS against the current rule before you declare.
Source: FAA Notice N 8900.737
No. There is no approval step for existing Part 135 operators. You declare compliance, and the FAA evaluates your SMS during routine surveillance.
No implementation plan submission is required for existing Part 135 operators under the current rule. You only file the declaration of compliance.
The one person with final authority over operations and resources who is ultimately responsible for the SMS. In many small operators, this is the owner or Director of Operations.
Source: 14 CFR §5.25
Yes. eSMS lets employees report anonymously or with their name kept confidential. Part 5 requires a confidential employee reporting system so people can report without fear of reprisal.
Source: 14 CFR §5.71
| Record | Keep for |
|---|---|
| Safety Risk Management outputs | As long as the control remains relevant |
| Safety Assurance outputs | At least 5 years |
| SMS training records | As long as the person is employed |
| Safety communications | At least 24 months |
Source: 14 CFR §5.97
No. The manual documents your SMS, but the FAA expects the system to be running: reports filed, risks assessed, actions tracked, audits done and records kept. Learn how eSMS runs it for you.
Our partner Air Carrier Compliance Group writes Part 5 SMS manuals for Part 135 operators that match the eSMS platform. More about SMS manuals.
Start with our free SMS Compliance Checklist. It covers every Part 5 requirement in plain English.
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Our partner Air Carrier Compliance Group writes Part 5 SMS manuals that match eSMS. About SMS manuals →
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Work through every Part 5 requirement with the free SMS Compliance Checklist.