The rule
14 CFR Part 5, the FAA's SMS regulation, was extended to Part 135 and Part 91.147 operators by a final rule published April 26, 2024 and effective May 28, 2024.
SMS Practice · Part 135 · Part 91.147
A Safety Management System
that's running,
not just written down.
A six-month program that takes Part 135 and Part 91.147 operators to a working SMS under 14 CFR Part 5, with the records to back your declaration of compliance due May 28, 2027.
Led by Captain Bob Wilson, former B-52 pilot and Part 135 captain.
The deadline
May 28, 2027.
The deadline
By May 28, 2027, you must have developed and implemented an SMS that meets Part 5 and submitted a declaration of compliance to the FAA.
The catch
The declaration states that your SMS is already built and running. It is the finish line, not the starting line. A program that exists only on paper can't honestly support it.
Implementation plans were due to the FAA by November 28, 2024. If you're not sure yours was filed and accepted, that's the first thing to check with your FAA principal inspector.
Applicability
Find your row.
Part 135 on-demand or commuter certificate holder
Is SMS required? Yes
Implement an SMS that meets Part 5 and submit your declaration of compliance by May 28, 2027.
Part 91.147 air tour letter of authorization holder
Is SMS required? Yes
Same rule, same date: May 28, 2027.
Single-pilot Part 135 operator
Is SMS required? Yes, with exceptions
If the single pilot is the only person responsible for the safe operation of the aircraft, the excepted sections in 14 CFR 5.9(e) apply. If you have other employees, you must meet all applicable Part 5 requirements.
Applying for a new Part 135 certificate or 91.147 letter
Is SMS required? Yes, as part of certification
New applicants must show an SMS in the certification process. Operators still in certification when the rule took effect have until May 28, 2027.
Part 141 pilot school with no Part 135 or 91.147 operation
Is SMS required? Not under Part 5
Voluntary. There is no May 2027 deadline. If your company also holds a Part 135 certificate or a 91.147 letter, the rule applies to that operation.
Part 145 repair station, FBO, or other operator not listed above
Is SMS required? Not under the 2024 rule
Voluntary.
Not sure where you fall? Ask your FAA principal inspector. Or ask us.
Day one
What you have the day we kick off.
A safety policy
Tailored to your operation, for your accountable executive to review, edit, and sign in the kickoff meeting.
A starter risk register
Opened and seeded from your own maintenance write-ups, crew debriefs, and near-misses, with common Part 135 hazards to react to.
Your first working tools
A hazard-report form and a corrective-action log, ready to use.
Before kickoff, a short intake collects your manuals, logs, and emergency plan, so day one starts with your documents, not a blank page.
Declaration day
What you have when you sign your declaration.
A signed safety policy, with a named accountable executive and SMS lead
A risk register built from your own hazards, with documented controls
Hazard reporting and monthly safety meetings that have been running for months
Internal audits, a corrective-action log, and proof of closure
Role-based training, with records
An evidence file indexed to the four components of Part 5
A mock inspection before the FAA looks
The plan
Six months. Five workstreams. Running in parallel.
Establish
- Month 1 — Assess, policy, roles
Identify & Control
- Month 1 — ongoing
- Month 2 — Hazards, risk register
- Month 3 — Controls designed
- Month 4 — ongoing
Promote
- Month 1 — ongoing
- Month 2 — Meetings begin
- Month 3 — Training
- Month 4 — Training
- Month 5 — ongoing
- Month 6 — ongoing
Assure
- Month 1 — ongoing
- Month 2 — ongoing
- Month 3 — Audit 1
- Month 4 — Corrective actions
- Month 5 — Audit 2
- Month 6 — ongoing
Verify & Hand Off
- Month 5 — ongoing
- Month 6 — Mock inspection, hand-off
Key milestones
- Month 1 — Policy signed at kickoff. Reporting live.
- Month 2 — First safety meeting.
- Month 3 — Risk register. Audit 1.
- Month 4 — Corrective actions closing.
- Month 5 — Training complete. Audit 2.
- Month 6 — Mock inspection. Hand-off.
To finish with margin before May 28, 2027, the six-month program should kick off by October 31, 2026, which means signing about a week earlier so intake is done first. Later starts run a shorter track with less time of proven operation. Earlier is better.
How it works
Built around how you actually fly.
- 01
Intake first.
A short intake before kickoff collects your manuals, logs, and emergency plan.
- 02
26 weeks.
Five workstreams run in parallel, so evidence starts building in week two.
- 03
Your people run it.
We coach and challenge. Your accountable executive makes the safety decisions.
- 04
Fixed rhythm.
A weekly working session and three leadership checkpoints.
- 05
Two audit cycles.
Then a mock inspection before you sign.
- 06
Nothing filed for you.
Your accountable executive signs the declaration once the records support it.
Before you decide
Ask us the same questions. We'd rather you did.
Who's behind it
Captain Bob Wilson
I flew the B-52 in the Air Force and worked as a Part 135 captain, so I know what operational discipline looks like when it's real. I've also spent a career in Fortune 200 systems engineering and technology leadership, where I learned that a process nobody uses is worse than no process at all.
Meet BobStart with a conversation about where you stand.
Which rule applies to you, what you already have in place, and how much runway you need.
Want to see where you stand first? Take the 15-question self-check
Or email bob@solutioneering.ai
Part 141-only flight schools are not covered by the May 2027 mandate. Solutioneering LLC is not affiliated with or endorsed by the FAA. This page is general information, not legal or regulatory advice, and does not guarantee any FAA outcome. Confirm your status with your FAA office. Rules and dates were checked in September 2026.