Part 5 safety management systems

Part 135 SMS is due May 28, 2027.

The FAA's expanded SMS rule now covers every Part 135 operator and every § 91.147 air tour operator. By the deadline you need a working SMS and a signed declaration of compliance, and the FAA will inspect all four parts of it within two years.

Our free brief sets out what's required, what inspectors will ask for, how long to keep records, and what makes the electronic signatures behind it acceptable under AC 120-78B.

14 CFR Part 5Part 135 · § 91.147AC 120-78BReadiness checklist
May 28, 2024Part 5 amendments in effect. New Part 135 and air tour applicants build an SMS as part of certification.
May 28, 2027Existing operators: SMS implemented and a declaration of compliance sent to the FAA (§ 5.9(a)).
Within 24 months afterFAA surveillance of all four SMS components, then periodically based on risk.
What's due

Two things by the deadline

An SMS that is running

Not just a manual. The FAA expects to see the processes in use: hazards reported and assessed, risks accepted at the right level, audits done and findings closed, and management reviewing safety performance. You keep it running for as long as you hold the certificate or LOA.

A declaration of compliance

A signed letter to your responsible Flight Standards office with your name, certificate number (air tour: Operator Designator Code), address and a statement that your SMS meets Part 5, signed by the accountable executive or another senior manager. Part 135 operators don't submit an implementation plan, and there's no separate approval step: the FAA checks through surveillance.

In the SMS Voluntary Program? Your acknowledgment letter stays valid until you submit a declaration or until May 28, 2027, whichever comes first. You still need to submit the declaration.
The rule

The four components and what an inspector will look for

ComponentWhat you needEvidence to have ready
Safety policy§§ 5.21–5.27Objectives and commitment, a safety reporting policy, unacceptable behavior, an emergency response plan and a code of ethics; an accountable executive, named SMS managers, and who may accept each level of risk.Signed safety policy communicated to staff; emergency response plan; SMS roles.
Safety risk management§§ 5.51–5.55Identify hazards in new systems, changes and procedures; assess risk; put controls in place and confirm the risk is acceptable with them.Risk register; management-of-change records; FRATs with approvals.
Safety assurance§§ 5.71–5.75Monitor operations; audit processes and systems; evaluate the SMS; investigate incidents and non-compliance; run a confidential employee reporting system; review performance and fix what's found.Audits, findings and corrective actions; investigations; hazard reports; indicators; signed management reviews.
Safety promotion§§ 5.91–5.93SMS training for everyone with a role; communication about hazards, safety actions and changed procedures.Training records; safety bulletins; read-and-acknowledge records.
Records (§ 5.97): safety assurance outputs at least 5 years · risk management outputs as long as the control is relevant · training records while the person is employed · safety communications at least 24 months. Part 5 sets no audit frequency: you define it in your SMS and then follow it.
Signatures and records

Electronic signatures that hold up

An SMS runs on signatures: the accountable executive signs the policy and management reviews, managers accept risk, approvers sign off high-risk FRATs, and staff acknowledge procedure changes. If they live in software, the FAA's AC 120-78B is what the system is measured against. For required records, a Part 135 operator's system is accepted through OpSpec A025.

AC 120-78B · the signature
  • Unique to the signer, who is identified and authenticated
  • Under the signer's sole control: their own login
  • Made with intent to sign
  • Can't be denied later, and signed content can't change without a new signature
AC 120-78B · the records system
  • Safeguards against uncontrolled access
  • Records stay unaltered and protected from corruption
  • Backups equal to the primary records
  • Records provided to the FAA or NTSB on request

More on how sign-offs work in MRO Tracker: electronic signatures and audit trail.

How MRO Tracker helps

Your SMS, in the same system as your flights and maintenance

The Safety (SMS) module is built around Part 5. Its dashboard checks each requirement against your live records and shows what's in place, what's due and what's late.

§§ 5.21–5.27

Safety policy

Policy revisions signed by the accountable executive and published through read & sign, so you can see who has read them. Emergency response plan on file.

§ 5.71(a)(7)

Confidential reporting

Pilots and staff file hazard reports from the app, optionally confidential: only the safety officer sees who filed it.

§§ 5.51–5.55

Risk register and FRATs

Hazards, risks and controls with owners and due dates, accepted at the level you set. Management of change. FRATs on every release, with high scores routed to your approver.

§§ 5.71–5.75

Audits and corrective action

Audit programme and checklists; findings with root cause, corrective and preventive actions and effectiveness checks; audit report PDFs.

§§ 5.71–5.75

Performance and reviews

Investigations, safety indicators with targets counted from your own data, and management reviews signed by the accountable executive.

§§ 5.91–5.97

Training and records

SMS training tracked per person; bulletins acknowledged through read & sign; every change recorded with who and when.

See the SMS module, screen by screen (PDF) →

Get ready for May 2027 with one system.

See the SMS module and the signature trail in a 30-minute demo, or download the brief to share with your accountable executive.

Sources: 14 CFR Part 5 (eCFR); FAA Notices N 8900.700 and N 8900.737; FAA AC 120-78B; FAA AC 120-92D. A summary as of October 2026, not legal advice.