Part 135 · October 31, 2026 · 6 min read · By BizJetDocs

Part 135 certification: the five phases and the documents you need at each one

The FAA's five-phase, three-gate Part 135 certification process, the formal application package, and how single-pilot and basic operators differ.

Short answer: the FAA certifies a Part 135 operator through five phases separated by three gates: preapplication, formal application, design assessment, performance assessment, and administrative functions (AC 120-49B, paragraph 8.1). The documents do most of the work. At formal application you hand over the application letter, schedule of events, compliance statement, manuals, training curricula, management qualifications and aircraft documents, and the FAA spends the next two phases checking that the documents are right and that your people do what they say. Single-pilot and basic operators follow the same process with fewer documents.

Phase 1: Preapplication

AC 120-49B, paragraph 8.2, says this phase starts when a prospective applicant first asks about a certificate. Applicants should sign up for the FAA's Safety Assurance System (SAS) External Portal (para 8.2.1) and then submit FAA Form 8400-6, Preapplication Statement of Intent (PASI), to the responsible Flight Standards office, through the portal if they have access (para 8.2.2).

When the FAA accepts the PASI, the office manager initiates the Certification Services Oversight Process, which the AC describes as how the FAA determines whether it has the resources to conduct the certification and continued oversight, and whether the project "will be assigned to begin, or if the applicant will be placed onto a wait list" (para 8.2.3). The applicant and key management personnel then attend a preapplication meeting with the Certification Project Team. Completing this phase completes Gate 1.

Documents: the PASI. For a single-pilot applicant, FAA Order 8900.1, Volume 2, Chapter 4, Section 6, paragraph 2-460A, says the PASI must state that the operation will use one pilot or only one pilot in command, and a single-PIC applicant attaches a statement identifying the regulations from which deviations will be requested.

Phase 2: Formal application

14 CFR 119.35 requires an application "in a form and manner prescribed by the Administrator." AC 120-49B, paragraph 8.3, lists what must be submitted:

1. Formal application letter
2. Schedule of Events
3. Compliance statement
4. Company manuals (General Operations Manual and General Maintenance Manual), if required by the classification or scope of operation
5. Training curricula, if required
6. Management qualification attachments, such as résumés
7. Documents of purchase, contracts or leases
8. SAS Element Design Data Collection Tools scoped to the proposed operation, if applicable
9. Flight attendant materials, if applicable

The phase ends with the formal application meeting, which completes Gate 2.

The application letter. AC 120-49B, Appendix A, paragraph A.4, says it must contain the applicant's full official name, be signed by the owner, all partners or an authorized officer, give the physical address of the intended primary operating location (and the mailing address if different), name the agent for service, confirm the key management personnel, and note any anticipated requests for deviation from management qualification requirements, with the deviation itself requested in a separate letter.

The compliance statement. AC 120-49B, paragraph 7.16, says it lists all 14 CFR parts 5, 91, 119 and 135 regulations applicable to the proposed operation, by section and paragraph, with a reference to the manual or document showing compliance and, if useful, a short narrative. Applicants not required to have a manual must describe compliance in narrative form. The AC calls it "a living document" and a master index to the manual system, and a copy of the final version goes into the certification report.

Management personnel. Under 14 CFR 119.69(a), a Part 135 certificate holder must have qualified people serving as Director of Operations, Chief Pilot and Director of Maintenance, or equivalent positions, except a certificate holder using only one pilot. Section 119.69(e) requires their duties, names and business addresses in the manual.

Manuals. Under 14 CFR 135.21(a), each certificate holder other than one using only one pilot must prepare and keep current a manual acceptable to the Administrator, with deviations possible for a limited operation.

SMS. 14 CFR 5.9(b) requires any person applying for Part 135 authorization to develop and implement an SMS meeting Part 5, so the safety management system is part of the package. See SMS for small Part 135 operators.

Phase 3: Design assessment

AC 120-49B, paragraph 8.4: "the applicant's manuals and other documents are reviewed in depth to ensure compliance with applicable regulations and conformity to safe operating practices." This is where weak documents cost time. Every cross-reference in the compliance statement gets followed to a manual page, and inspectors work from the SAS Data Collection Tools for each element.

Phase 4: Performance assessment

Paragraph 8.5: the team validates "through observation and testing" that the procedures and training programs work, observing required training, flight checks, and proving and validation tests. Completing this phase completes Gate 3.

Phase 5: Administrative functions

Paragraph 8.6: the FAA issues the certificate and operations specifications. The AC is explicit that the FAA "will not, under any circumstances, certificate an applicant until the certification project manager (CPM) determines that the applicant is fully capable" of meeting its responsibilities.

Single-pilot, single-PIC and basic operators

8900.1, Volume 2, Chapter 4, Section 6, paragraph 2-458, says these applicants follow the same procedures, and certification "may take less time since fewer documents, facilities, and other items require Federal Aviation Administration (FAA) evaluation." A single-PIC operator may be issued an OpSpec authorizing deviations from §§ 119.69(a), 135.21(a) and 135.341(a) (para 2-460).

To qualify as a basic Part 135 operator under paragraph 2-461, the operation must use no more than five pilots including seconds in command, no more than five aircraft, no more than three aircraft types, no aircraft type certificated for more than nine passenger seats, no Category II or III operations, and no operations outside the United States, Canada, Mexico and the Caribbean (including the Bahamas). Basic operators still need management personnel, manuals and training curricula adapted to the smaller operation.

Checklist

• Decide the operating rule and kind of operation (AC 120-49B, Chapter 2) and whether you fit single-pilot, single-PIC or basic.
• Set up SAS External Portal access.
• Submit the PASI.
• Identify the Director of Operations, Chief Pilot and Director of Maintenance, with résumés against 119.71.
• Build the compliance statement as you write the manuals, not after.
• Prepare the General Operations Manual, maintenance manual and training curricula your classification requires.
• Prepare the SMS, hazmat program, drug and alcohol program and any other programs your OpSpecs will need.
• Assemble aircraft purchase or lease documents.
• Propose a realistic schedule of events.

What you submit and who submits it

The applicant submits the PASI and the formal application package to its Flight Standards office, signed as AC 120-49B, Appendix A, describes. A consultant can help prepare it, but the application is the applicant's, and its key management personnel attend the meetings.

We prepare the documents: PASI, application letter, schedule of events, the rule-by-rule compliance statement, the General Operations Manual, training program and the supporting programs, with instructions for each submission. You review, sign and submit. Certification decisions and timelines are the FAA's alone.

Frequently asked questions

How long does Part 135 certification take?

It depends on the FAA's resources and your documents. AC 120-49B notes the FAA may place an accepted applicant on a wait list before the project begins.

Does a single-pilot operator need a manual?

Section 135.21(a) exempts a certificate holder that uses only one pilot from the manual requirement. The compliance statement must then describe compliance in narrative form.

What is the compliance statement used for after certification?

AC 120-49B calls it a master index to the manual system, and the final version goes into the certification report kept by the Flight Standards office.

Have it prepared

The PASI is $375, the formal application letter with compliance statement $1,800, the schedule of events $350, the rule-by-rule compliance statement $1,175 and the General Operations Manual from $2,200. Packages: Single-Pilot from $5,400, Basic Operator from $8,950, Full Operator from $14,950. See the format below.

Sources

Primary sources, as retrieved when this article was last updated. Check the current text before you rely on it.

• AC 120-49B, Parts 121 and 135 Certification (10/7/2024)
• FAA Order 8900.1, Volume 2, Chapter 4, Section 6, Single-Pilot, Single PIC and Basic Part 135 Operations (CHG 933)
• FAA Order 8900.1, Volume 2, Chapter 4, Section 1, Phase 1, Preapplication (CHG 920)
• 14 CFR 119.35, Certificate application requirements for all operators
• 14 CFR 119.69, Management personnel required for operations conducted under part 135
• 14 CFR 119.71, Management personnel: qualifications for operations conducted under part 135
• 14 CFR 135.21, Manual requirements
• 14 CFR Part 5, Safety Management Systems

Informational only. Not legal advice, not FAA guidance and not a promise of FAA approval or of any FAA timeline. The operator submits its own application; only the FAA approves, accepts or issues an authorization.