Part 135 recurrent training requirements: what 135.293 checks and how often

The Part 135 recurrent training requirement is stricter than most pilots coming from Part 91 expect. A biennial flight review is not sufficient. The currency window is shorter, the check is more comprehensive, and the consequence of a lapsed crew member is an immediate dispatch restriction — not a grace period.

The 12-calendar-month rule

Under 14 CFR 135.293, no certificate holder may use a pilot as a flight crewmember, and no pilot may serve as a flight crewmember, unless that pilot has passed a required check within the preceding 12 calendar months. The check must be administered by an FAA-designated check airman authorized under the certificate holder's training program.

"12 calendar months" means the check is valid through the last day of the same month one year later. A check passed in June 2025 is valid through June 30, 2026. The common mistake is confusing "12 months from the date" with "through the end of the calendar month" — the calendar month convention gives a small buffer at the end of each cycle.

What 135.293 checks

The proficiency check under 135.293 must include the maneuvers and procedures required for the pilot's certificate and ratings as appropriate to the category, class, and type of aircraft being flown. The check airman follows the Airman Certification Standards (ACS) or the applicable Practical Test Standards (PTS) for the operation.

For a typical single-engine or multiengine piston Part 135 operation, the check covers:

• Preflight procedures and systems knowledge
• Engine failure procedures (including engine-out operations for multiengine)
• Instrument approaches — multiple types, including non-precision and precision where applicable
• Missed approach procedures
• Holding patterns
• Emergency procedures — abnormal and emergency checklists
• Night operations considerations (where applicable)
• Short-field and soft-field operations (aircraft-specific)

For turbine operations and aircraft requiring a type rating, the check is more extensive and includes high-altitude considerations, pressurization emergencies, and the full range of systems abnormalities.

135.293 vs 135.297 — understanding the interaction

The Part 135 currency landscape has two separate checkpoints that are commonly confused:

• 135.293 — the annual proficiency check. Satisfies the recurrent training requirement. Administered by a check airman. Covers aircraft-specific maneuvers and procedures.
• 135.297 — instrument currency. Requires 6 instrument approaches, holding, and intercepting/tracking in the preceding 6 calendar months. Can be satisfied by flying, or reset by a 135.297 proficiency check.

A 135.293 check that includes instrument approaches does not automatically satisfy 135.297 unless the approaches are logged and the check is documented as a 135.297 currency event. Check airmen typically note this distinction explicitly in the training record — it must be clear that 135.297 currency was established, not just that the check was passed.

Conversely, a 135.297 currency flight — six approaches flown in actual or simulated IMC — does not satisfy 135.293. The annual check cannot be replaced by currency flying alone.

Who can give the check

Under 135.293, the check must be administered by:

• An FAA inspector
• A check airman designated by the certificate holder and approved in the OpSpecs
• An FAA-designated pilot examiner (DPE), where authorized

A regular CFII cannot give a Part 135 proficiency check — they are not authorized under the certificate holder's training program. The DO or training manager must confirm that the check airman performing a given check is currently authorized in the OpSpecs. Authorization can be removed by the FAA, by the certificate holder, or by the check airman's own currency lapsing.

What happens when a check lapses

If a crew member's 135.293 check expires, they cannot be used as a flight crewmember until the check is completed. There is no grace period, no retroactive cure, and no "fly one trip and then get the check" option. The lapse means grounded from Part 135 operations effective the day after expiry.

For a small operation with limited reserve crew depth, a lapsed check on a key pilot is an operational emergency. The failure mode is almost always scheduling: a check airman was unavailable, a training appointment was postponed, or the approaching expiry was not flagged early enough to arrange a flight.

The practical fix is a 60-day advance alert in the crew records system — enough lead time to schedule a check without emergency pressure, and enough buffer that a single scheduling failure can be recovered before the actual expiry.

Simulator vs. aircraft

The 135.293 proficiency check may be conducted in an aircraft, a flight simulator (FSTD), or a flight training device (FTD) — provided the simulator or device is qualified for the maneuvers being tested and is approved in the certificate holder's training program and OpSpecs.

For most single-engine and light multiengine operations, simulator availability is limited and checks are typically conducted in the actual aircraft. For turbine operations, Level C or D full-flight simulators are common and are generally preferred — they allow unusual attitudes, engine failures at V1, and other maneuvers that carry real risk in the aircraft itself.

The GOM and training program requirements

The certificate holder's General Operations Manual (GOM) must describe the training program, including the check schedule, the check airman roster, the approved simulators or aircraft, and the procedures for tracking and documenting currency. An FSDO audit that finds crew members current but without documentation is treated nearly the same as an FSDO audit that finds crew members who missed their check — the record is the proof.

Part 135 currency tracking is one of the items the pre-dispatch compliance gate checks before releasing a flight. A 135.293 check expiry — like a medical expiry or an instrument currency lapse — triggers an UNABLE, with the citation and the expiry date, before the quote is issued rather than after the flight departs.