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.
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.
The four components and what an inspector will look for
| Component | What you need | Evidence to have ready |
|---|---|---|
| Safety policy§§ 5.21–5.27 | Objectives 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§§ 5.51–5.55 | Identify 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§§ 5.71–5.75 | Monitor 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§§ 5.91–5.93 | SMS training for everyone with a role; communication about hazards, safety actions and changed procedures. | Training records; safety bulletins; read-and-acknowledge 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.
- 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
- 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.
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.
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.
Confidential reporting
Pilots and staff file hazard reports from the app, optionally confidential: only the safety officer sees who filed it.
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.
Audits and corrective action
Audit programme and checklists; findings with root cause, corrective and preventive actions and effectiveness checks; audit report PDFs.
Performance and reviews
Investigations, safety indicators with targets counted from your own data, and management reviews signed by the accountable executive.
Training and records
SMS training tracked per person; bulletins acknowledged through read & sign; every change recorded with who and when.
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.