FlyWise SMS
The FAA SMS deadline is May 28, 2027.
If you operate under Part 135 or hold a § 91.147 Letter of Authorization, you must have a working Safety Management System in place — and submit a Declaration of Compliance to your FAA Certificate Management Office — by May 28, 2027. Here’s what that actually means, and how to get it done without spending $50,000 on a consultant.
Time Remaining Until Deadline
Who is required to comply?
The final rule affects three specific categories of operators.
Part 135 Commuter & On-Demand
Any person authorized to conduct operations under Part 135 before May 28, 2024 must develop and implement an SMS by May 28, 2027.
Commercial Air Tour Operators
Any person holding a Letter of Authorization under § 91.147 of this chapter before May 28, 2024 must have an SMS in place by the same deadline.
Some Production Certificate Holders
Certain Part 21 production certificate holders are also subject to the mandate. Check with your FAA CMO if you’re unsure.
What’s already happened — and what’s next.
The regulation has been rolling out on a fixed schedule. Here’s where we are today.
Final Rule Effective
The updated Part 5 rule went into effect. Operators already required to have an SMS (like Part 121 carriers) became subject to the new requirements.
Part 121 Carriers Deadline
Part 121 operators had one year to revise their existing SMS programs to meet the new definitions and requirements.
Part 135 & § 91.147 Are Preparing
Every Part 135 commuter/on-demand operator and § 91.147 air tour operator needs to be building their SMS now. The window to do this calmly is closing.
- Complete your company profile
- Generate your required SMS documents
- Deploy hazard reporting and FRAT to your pilots
- Begin your training and assurance processes
Full Compliance Required
All affected Part 135 and § 91.147 operators must have a fully implemented SMS and submit a signed Declaration of Compliance to their FAA Certificate Management Office.
- SMS must be developed and implemented
- Declaration of Compliance submitted to the FAA
- Signed by your Accountable Executive
What the FAA actually requires.
Part 5 requires four SMS components. FlyWise handles every one of them.
Safety Policy
Written commitment from leadership, signed by the Accountable Executive. Includes safety objectives, non-punitive reporting policy, and code of ethics.
✓ Generated by FlyWiseSafety Risk Management
A documented process to identify hazards, assess risk using a standard matrix, and apply controls before incidents happen.
✓ Hazard Reporting + FRATSafety Assurance
Measuring whether your SMS is working. Internal audits, drill tracking, trend monitoring, and continuous improvement.
✓ Internal Audit + Health CheckSafety Promotion
Training, communication, and a positive safety culture where employees feel safe reporting hazards.
✓ Training + NewslettersSMS Documentation
Documented policies, procedures, and records that prove your SMS meets Part 5.
✓ Procedures ManualDeclaration of Compliance
The formal document you submit to the FAA certifying your SMS is complete and in use.
✓ Generated by FlyWiseWhat happens if you miss the deadline?
Operating restrictions
The FAA can restrict your operating certificate or prevent you from accepting new business until your SMS is in place.
Enforcement action
Non-compliance with Part 5 is a regulatory violation and can trigger enforcement action, fines, or certificate suspension.
Scrambling at the last minute
The FAA is clear: building a working SMS takes months, not weeks. Waiting until 2027 means real operational disruption.
Get fully compliant in weeks, not months.
FlyWise is designed for Part 135 and § 91.147 operators who don’t have a dedicated safety department — and don’t want to pay consultant prices. Here’s what your first two weeks look like.
- Day 1: Create your company profile (about 20 minutes)
- Day 1: Generate your first SMS documents (minutes)
- Day 2: Build and deploy your Hazard Reporting form
- Day 3: Configure your FRAT for your operation
- Week 1: Add users, distribute documents, start training
- Week 2: Begin using your SMS — hazards, FRATs, and MOC tracking
The information on this page is drawn directly from the FAA’s Advisory Circular 120-92D, dated May 21, 2024, and from the text of 14 CFR Part 5. For complete regulatory language and implementation guidance, refer to the official documents.
📄 Read AC 120-92D →Don’t wait until 2027.
Start a free trial, or just call us. We’ll walk you through exactly what your operation needs — no pressure, no jargon.