How to get a Part 135 certificate: the certification process from application to OpSpecs

A Part 135 Air Carrier or Commercial Operator certificate authorizes an individual or company to conduct on-demand air transportation for compensation. It is not a simple registration — it is a regulatory relationship with the FAA that requires demonstrating, before any passenger boards, that the organization has the management, training, operations, and maintenance systems in place to operate safely.

The FAA issues Part 135 certificates through a five-phase certification process. The minimum timeline is 90 days. The realistic timeline for a well-prepared applicant is 6-12 months. Operators who underestimate the preparation required frequently stall in Phases 2 or 3 and restart the clock.

Who needs a Part 135 certificate

Any person or entity conducting on-demand air transportation — carrying passengers or cargo for compensation or hire in an unscheduled operation — must hold a Part 135 certificate. This includes:

• Charter operators offering flights to the public
• Air ambulance operators (combined with appropriate medical certifications)
• Helicopter operators conducting tour, EMS, or utility work for hire
• On-demand cargo carriers (including freight and courier operations)

Operators of aircraft with 30 seats or fewer and a payload capacity of 7,500 lbs or less in unscheduled operations apply for Part 135. Larger aircraft in scheduled service apply for Part 121. Commuter operations (9 seats or fewer, scheduled) use Part 135 with additional commuter provisioning.

The five-phase FAA certification process

Phase 1 — Pre-application

The applicant contacts the FSDO (Flight Standards District Office) with jurisdiction over their proposed base of operations and schedules a pre-application meeting. At this meeting, the FSDO assigns a certification team and explains the process. The applicant presents a preliminary business plan and organizational structure.

Nothing is approved in Phase 1. It is a discovery phase. The FSDO wants to understand what operation is being proposed; the applicant gets a clear picture of what documentation is required. This meeting is the right time to ask every question, because the cost of assumptions is high later.

The most important outcome of Phase 1 is confirming FSDO workload. Some offices have backlogs of 12-18 months. Knowing this early determines whether the applicant should request expedited handling (for unusual circumstances) or plan around the queue.

Phase 2 — Formal application

The applicant submits FAA Form 8400-6 (Application for Operating Certificate) and begins the formal documentation process. The core documents required:

• General Operations Manual (GOM). The master operating manual for the certificate — describes the organization, management personnel, training programs, dispatch procedures, emergency procedures, and compliance with each applicable regulation. This is typically the most labor-intensive document to produce.
• Training program documentation. Initial and recurrent training syllabi for all flight and ground crew positions. The FSDO must approve the training program before any training begins.
• Operations Specifications (OpSpecs) application. The OpSpecs define the approved scope of the certificate — what aircraft, what routes, what kinds of operations, what weather minimums. The applicant proposes initial OpSpecs; the FSDO issues them after approval.
• Management personnel qualifications. The Director of Operations (DO), Director of Maintenance (DOM), and Chief Pilot must be named and their qualifications accepted by the FSDO. Unacceptable management qualifications are a Phase 2 stall point.
• Airworthiness documentation for each aircraft. Aircraft must be registered, airworthy, and on an acceptable maintenance program at the time of certification.

Phase 2 typically takes 3-6 months. The GOM is the most common bottleneck — operators underestimate how detailed it must be. A GOM that references regulations without explaining how the organization actually implements them will be returned for revision.

Phase 3 — Document compliance

The FSDO reviews all submitted documents and conducts a thorough compliance review. This is not a rubber stamp — the FSDO certification team reads the GOM and training program in detail, compares them against the applicable regulations, and issues a compliance findings report.

Common Phase 3 deficiencies:

• GOM does not adequately address all required subjects under 135.21
• Training program does not include all required subjects or maneuvers
• Proposed check airmen are not qualified or have not submitted the required paperwork
• Aircraft inspection program is not approved or does not cover the proposed fleet
• Drug and alcohol testing program (required under 49 CFR Part 40 and 14 CFR Part 120) is missing or incomplete
• Emergency response plan does not meet ASAP requirements

Each deficiency must be resolved before Phase 4 can begin. Operators who move quickly through Phase 2 often slow significantly in Phase 3 because the document quality was not sufficient. There is no shortcut here — the FSDO is protecting the traveling public, and they will find the gaps.

Phase 4 — Demonstration and inspection

With documents approved, the FSDO conducts physical demonstrations. This phase includes:

• Aircraft inspection. An FAA airworthiness inspector physically inspects each aircraft proposed for the certificate — not just the paperwork, but the actual metal.
• Facility inspection. The base of operations is inspected: maintenance facilities, crew rest areas, flight planning capabilities, recordkeeping systems.
• Management personnel interviews. The DO, DOM, and Chief Pilot are interviewed by the FSDO to verify they understand their regulatory responsibilities and the operator's operating procedures.
• Check airman demonstration flights. Proposed check airmen must demonstrate their check airman competency to an FAA inspector or designee before being approved.
• Crew training completion. All initial crew training must be completed and documented before certificate issuance. This includes the required simulator or aircraft training under the approved training program.

Phase 4 is where the theoretical meets the physical. Document deficiencies that made it through Phase 3 become visible here. An operator whose GOM says "we will brief passengers per 135.117" but whose crew cannot describe what that briefing includes will have that Phase 4 finding documented.

Phase 5 — Certification

If all Phase 4 items are satisfactory, the FSDO issues the Air Carrier or Commercial Operator certificate and the initial Operations Specifications. The certificate itself is a one-page document. The OpSpecs — which define the actual scope of the authorization — are the operative document.

The certificate has no expiration date, but it is not a one-time event. Ongoing certificate maintenance requires: annual FSDO surveillance, continued crew currency and training, aircraft airworthiness, drug and alcohol testing program compliance, and — for any changes to the operation (new aircraft, new routes, new management personnel) — OpSpecs amendments, which go through their own approval process.

Estimated timeline by phase

The management personnel requirement

The Director of Operations and the Chief Pilot positions are the most common certification blockers for new entrants. The DO must meet the qualifications in 135.37: at least 1,000 hours of flight time, including at least 500 hours in air transportation service, and any other requirements in the OpSpecs. The Chief Pilot must meet similar operational experience standards.

A startup operator who plans to be their own DO and Chief Pilot must meet these standards personally before the FSDO will accept their qualifications. Operators who do not yet have the required experience need to hire someone who does — which adds cost and organizational complexity before the first revenue flight.

After the certificate — what changes operationally

Operating under Part 135 means every flight is a regulated event. The certificate holder must issue a flight release before departure. Crew duty and rest must be tracked and documented. Every dispatch decision — CLEAR or UNABLE — is a record that the FAA can pull. Training currency, medical currency, and recurrent check currency must be maintained for every crew member used on every flight.

Operators who treat Part 135 compliance as a box checked at certification and then operate informally are the operators who face certificate action. The ongoing compliance burden is not onerous for a well-organized operation — but it is real, it is continuous, and it requires systems, not good intentions.