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Part 5 Declaration guide

Your SMS Declaration is due May 28, 2027.

What the FAA expects from a Part 135 operator, every element from §5.21 to §5.97, a working timeline back from the deadline, and the evidence an inspector asks for.

Key facts

Due
May 28, 2027
Applies to
Every Part 135 operator
Sent to
Your FSDO or CMO
FAA response
Acknowledges. It doesn't approve.

Preview · what's inside

What the Declaration is, and isn't

Part 5 now applies to every Part 135 operator, including single-pilot and small operators. By May 28, 2027 your Accountable Executive submits a Declaration of Compliance to your FSDO or CMO, stating that your SMS meets the rule.

The FAA acknowledges a Declaration. It doesn't approve or accept it. That puts the weight on your evidence: the FAA can ask for the data behind your SMS at any time, so the program has to be operating, not just written down.

The 15 elements, and the evidence for each

Grouped by the four SMS components plus documentation and records. The evidence column is what an inspector is likely to ask to see.

Safety policy§5.21–5.27

§5.21
Safety policy
A signed policy with safety objectives, a reporting commitment and conduct standards, communicated to staff.
§5.23
Safety accountability and authority
Who is accountable for what, and who may accept each level of risk.
§5.25
Required safety management personnel
The named Accountable Executive and the management personnel who run the SMS.
§5.27
Emergency response planning
An emergency response plan coordinated with the organizations you work with.

Safety risk management§5.51–5.57

§5.51
When SRM applies
Records showing SRM was run for new systems, changes and new procedures.
§5.53
System analysis and hazard identification
A hazard register built from your operation, not a template.
§5.55
Risk assessment and control
Each hazard rated, controlled and accepted by the right person.
§5.57
Hazard notification
Notices sent to interfacing persons about hazards they can address.

Safety assurance§5.71–5.75

§5.71
Performance monitoring and measurement
Reports, FRATs, audits and investigations, plus indicators measured against your objectives.
§5.73
Safety performance assessment
A management review with decisions recorded and signed.
§5.75
Continuous improvement
Corrective actions closed with proof that they worked.

Safety promotion§5.91–5.93

§5.91
Competencies and training
Training records per person, including management personnel.
§5.93
Safety communication
Bulletins and lessons learned, with who received and read them.

Documentation and records§5.95–5.97

§5.95
SMS documentation
The current, controlled SMS manual and policy documents.
§5.97
SMS records
Records kept for at least the required minimums, and retrievable on request.

A working timeline

Working back from May 28, 2027.

  1. Now

    Gap analysis

    Map what you have (binder, spreadsheet, another system) against every element. Decide who your AE and safety manager are.

  2. First 30 days

    Configured baseline

    Signed policy and objectives, an accountability register, a FRAT model, live confidential reporting and assigned training.

  3. Months 2–5

    Operating, with evidence

    Real reports and FRATs, hazards rated and controlled, indicators measured, corrective actions verified, and a first management review.

  4. Before May 28, 2027

    Declare

    Freeze a point-in-time readiness report. The Accountable Executive signs the Declaration and it goes to your FSDO or CMO.

  5. After you declare

    Stay ready

    Store the FAA's acknowledgement. The FAA can ask for supporting data at any time, so keep the program running and the evidence current.

Gaps we see most often

  • Configured, not operating: a reporting system with no reports doesn't count.
  • No management review in the last 12 months.
  • Management personnel missing their SMS training records.
  • Hazards on the register with no risk rating, control or owner.
  • Corrective actions closed without proof they worked.
  • A template manual that doesn't describe how your operation actually runs.

See where you stand today

The readiness check walks through each element and shows what moves an SMS from configured to operating.

Check your Part 5 readiness

The FAA acknowledges Declarations; it does not approve them. The readiness tracker is an indicator, not an FAA determination. This guide is a plain-language summary; 14 CFR Part 5 governs.

Part 5, operating

See an SMS that produces its own evidence.

In the demo, reports, FRATs, hazards and reviews link to each element, so the readiness view fills in as the program runs.

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