Key Regulatory Dates
The FAA’s SMS final rule established a clear timeline for Part 135 compliance. Understanding these dates is essential for planning your implementation.
| Date | Milestone |
|---|
| April 26, 2024 | Final rule published in the Federal Register |
| May 28, 2024 | Rule becomes effective. New Part 135 applicants must include SMS in initial certification |
| May 28, 2025 | Existing Part 121 operators must update their SMS to meet revised Part 5 requirements |
| May 28, 2027 | Part 135 and Part 91.147 operators must submit Declaration of Compliance |
| Ongoing | Operators must maintain SMS as long as certificate is held |
The May 28, 2027, deadline is firm. The FAA has not indicated any plans for extensions. Operators who wait until late 2026 to begin implementation will face significant time pressure, particularly for the training and testing phases that require organizational buy-in and iterative refinement.
Why Start Now
Three years may seem like ample time, but SMS implementation involves organizational change, not just software deployment. Building effective hazard reporting requires earning employee trust. Developing meaningful risk assessments requires understanding your specific operational environment. Training personnel on new processes takes time to schedule around operational demands. And demonstrating that your SMS is actually functioning — not just documented — requires a track record of real-world use.
Operators who begin early gain several advantages. They accumulate safety data that demonstrates their SMS is operational. They identify and resolve implementation challenges while there is still time to course-correct. And they enter the Declaration of Compliance process with confidence rather than anxiety.
Recommended Implementation Phases
The FAA does not prescribe a specific implementation methodology, but industry experience and AC 120-92D guidance suggest a phased approach. The following timeline assumes a 30-36 month implementation for a typical Part 135 operation.
Phase 1: Gap Analysis (Months 1-2)
Assess your current safety practices against Part 5 requirements. Identify what you already do that aligns with SMS (you likely do more than you think) and what gaps exist. This phase produces a clear picture of the work ahead and helps prioritize resources.
PlaneConnection support: The Compliance module’s Part 5 element tracker lets you map your current state against every regulatory requirement, identifying gaps at a granular level.
Phase 2: Planning (Months 3-4)
Develop your implementation plan. Define your SMS scope, identify your accountable executive and key safety personnel, establish your implementation budget, and create a project timeline. This is also when you should select your SMS technology platform.
PlaneConnection support: Organization settings let you define your accountable executive, safety personnel, and organizational structure from day one.
Phase 3: Documentation (Months 5-8)
Write your safety policy, SMS manual, procedures, and forms. This includes your non-punitive reporting policy, risk assessment criteria, investigation procedures, training curriculum, and record retention policies. Documentation is required by Part 5 Subpart F, but the documents must describe processes you will actually use.
PlaneConnection support: The Documents module provides version-controlled storage for all SMS documentation. Policy settings capture your safety policy statement and organizational commitments.
Phase 4: Training (Months 9-12)
Train all personnel on the SMS — what it is, why it matters, and what their specific role is within it. The accountable executive, safety managers, investigators, and line personnel all need different levels of training. This phase often reveals gaps in your documentation when people ask questions your procedures do not answer.
Do not treat SMS training as a one-time event. Part 5 Subpart E requires ongoing competency, and initial training should be followed by recurrent refreshers. PlaneConnection’s Training module tracks completion across your organization.
Phase 5: Implementation (Months 13-20)
Launch your SMS processes. Begin accepting safety reports, conducting risk assessments, holding safety committee meetings, and tracking corrective actions. This is where the SMS transitions from documentation to operation. Expect an adjustment period as people learn new workflows.
PlaneConnection support: All core modules — Reports, Risks, Investigations, CPAs, Safety Committee — are active and processing real data, building the operational record you will need for your Declaration of Compliance.
Phase 6: Testing and Refinement (Months 21-28)
Conduct internal audits to verify that your SMS processes are working as intended. Identify weaknesses, refine procedures, and close gaps. Review your safety performance indicators to see if they are measuring what matters. This phase demonstrates the Safety Assurance pillar in action.
PlaneConnection support: The Compliance module tracks audit findings and corrective actions. Performance Indicators (SPIs) show trends over time, and SmartScore provides an overall safety health assessment.
Phase 7: Validation and Declaration (Months 29-36)
Conduct a final internal review to confirm all Part 5 requirements are met. Prepare your Declaration of Compliance, have the accountable executive review and sign it, and submit it to your FAA Certificate Management Office.
PlaneConnection support: The Part 5 compliance report can generate a comprehensive summary of your SMS status mapped to every regulatory requirement, supporting both your internal validation and the declaration itself.
After the Declaration
Submitting the Declaration of Compliance is not the finish line — it is the starting point of ongoing SMS maintenance. Part 5 requires continuous improvement, meaning your SMS must evolve as your operation changes, new hazards emerge, and lessons are learned.
The FAA will validate your SMS through routine surveillance. They will look for evidence that your processes are functioning, not just documented. A healthy SMS shows a steady flow of reports, active risk management, timely corrective actions, and regular safety committee engagement — exactly the kind of ongoing activity that PlaneConnection is designed to capture and demonstrate.
