Written by a Director of Aviation Maintenance Operations · Updated July 2026
In April 2024 the FAA published its final SMS rule, extending 14 CFR Part 5 beyond the airlines to every Part 135 certificate holder and §91.147 air tour operators. Compliance lands roughly three years later — for most operators, May 2027. If you fly charter, cargo, medevac, or tours, this applies to you, including single-pilot certificates.
Part 5 asks for four functioning components, sized to your operation: a safety policy signed by an Accountable Executive who genuinely controls money and people; safety risk management — a documented way of finding hazards, sizing risks, and accepting them at the right level; safety assurance — audits, data, and an employee reporting system that prove your fixes work; and safety promotion — training and communication that keep the system alive. The 2024 rule also added §5.55(e): you must notify interfacing persons (contract maintenance, vendors) of hazards relevant to them — a requirement many older templates miss entirely.
You execute a declaration of compliance and submit your documentation to your FSDO. Your ASI will not grade your prose — they will ask to see the system breathe: a hazard that went through risk management end to end, the last employee report and what happened to it, training records, and an internal audit with closed findings. Big-operator frameworks scaled down get bounced; Part 5 explicitly permits (and inspectors expect) a system sized to a 1–10 aircraft operation.
Consultants ($10–25k): excellent for complex certificates; overkill for most small operators, and their calendar is filling as the deadline approaches. SMS software ($200+/month forever): the platform is not the requirement — the documented, functioning system is; plenty of accepted SMSs live in a binder and a spreadsheet. A complete kit (~$2k once): the 90% that is structurally identical for every small operator, professionally drafted, leaving you the 10% that must genuinely be yours.