Helicopters · November 1, 2026 · 5 min read · By BizJetDocs

The May 28, 2027 SMS deadline for helicopter Part 135 operators

Helicopter Part 135 and 91.147 LOA holders must have a Part 5 SMS and file a declaration of compliance by May 28, 2027. What it covers and what to do now.

Short answer: if you hold a Part 135 certificate that covers helicopters, or a Letter of Authorization under § 91.147, you must have a Safety Management System (SMS) that meets 14 CFR Part 5 and you must send the FAA a declaration of compliance, both by May 28, 2027 (§ 5.9(a)). The rule does not treat helicopters differently. What changes for a helicopter operation is the content: your SMS has to describe the hazards of the flying you actually do.

What the rule requires

Section 5.9(a) applies to any person authorized to conduct operations under Part 135, or who held a § 91.147 Letter of Authorization issued before May 28, 2024. Two things are due by May 28, 2027:

1. An SMS that meets Part 5, developed and implemented (§ 5.9(a)(1)). Writing a manual is not enough. The SMS has to be running in the company.
2. A declaration of compliance with Part 5, submitted to the FAA in a form and manner the Administrator accepts (§ 5.9(a)(2)).

The dates are different if you are not yet certificated. Under § 5.9(b), a person applying for Part 135 authority or a § 91.147 Letter of Authorization, or with that application pending, on or after May 28, 2024, must develop and implement the SMS as part of getting authorized. For a new applicant the SMS is part of the certification package, not a 2027 task.

Who this reaches in a helicopter operation

Section 5.1 sets the scope: certificate holders and applicants authorized for Part 135 operations (§ 5.1(b)) and holders and applicants of a § 91.147 Letter of Authorization (§ 5.1(c)). In practice that includes:

• On-demand charter and corporate helicopter operators under Part 135.
• Helicopter air ambulance operators that hold Part 135 authority.
• Air tour operators that fly under a § 91.147 Letter of Authorization.
• Small operators with one helicopter and one pilot, with the limited relief described below.

Once you are required to have an SMS you must maintain it for as long as you hold the authority (§ 5.9(c)), and you must make the information that shows it meets Part 5 available to the FAA on request (§ 5.9(d)).

What a Part 5 SMS contains

Section 5.5(a) requires an SMS that is "appropriate to the size, scope, and complexity" of your organization and that includes four components at a minimum:

• Safety policy (§ 5.21), including the emergency response plan that § 5.27 requires where emergency procedures are necessary.
• Safety risk management (§§ 5.51 to 5.55): finding hazards, assessing the risk and putting controls in place.
• Safety assurance (§§ 5.71 to 5.75): measuring safety performance, assessing it and improving continuously.
• Safety promotion (§§ 5.91 to 5.93): training for the people with SMS duties and communication across the organization.

You also have to keep SMS documentation, meaning your safety policy and your SMS processes and procedures (§ 5.95), and SMS records (§ 5.97). Records of safety assurance outputs are kept at least 5 years, training records for as long as the person is employed, and communication records at least 24 consecutive calendar months.

What a helicopter operator should put in it

Part 5 is performance-based, so the hazards you list are yours. A helicopter SMS usually has to deal with the flying the company really does: low-altitude and off-airport landings, flight in marginal visibility, night operations, external loads or hoist work where they apply, and the pressure to complete a mission for a customer or patient. A hazard register copied from an airline will miss most of this, and the person reviewing it will see that quickly.

The accountable executive (§ 5.25) needs to understand the SMS well enough to own it. For a small helicopter company that is often the owner. Name the person, write down what they decide, and make sure the safety policy you publish to employees says the same thing as the manual.

Single-pilot relief

An organization with a single pilot who is the sole individual performing every function needed to operate the aircraft is excused from some provisions, listed in § 5.9(e): §§ 5.21(a)(4), 5.21(a)(5), 5.21(c), 5.23(a)(2), 5.23(a)(3), 5.23(b), 5.25(b)(3), 5.25(c), 5.27(a), 5.27(b), 5.71(a)(7), 5.93 and 5.97(d). Everything else in Part 5 still applies. An owner who also hires a second pilot or a chief pilot is no longer in that group.

What to do now

• Confirm which paragraph applies to you. An existing certificate holder follows § 5.9(a). An applicant follows § 5.9(b). Check the dates on your authority before you plan.
• Scope the SMS to your operation. Build it from the flying you do, and keep it consistent with your operations manual and training program.
• Run it before you declare it. The rule asks you to implement the SMS, so give it time to produce real records, such as hazard reports and training entries, before you file.
• Plan the declaration. It is a formal submission to the FAA, so have your accountable executive review it against the SMS well before the date.
• Keep it current. Section 5.9(c) requires you to maintain the SMS for as long as you hold the authority.

What you submit and who submits it

Existing Part 135 and § 91.147 holders submit the declaration of compliance to the FAA themselves, in the form and manner the FAA accepts. Applicants include the SMS in their certification package. The SMS itself stays in your company: it is shown to the FAA on request under § 5.9(d), not mailed in as a manual.

We prepare the SMS manual and implementation plan sized to a helicopter operation, the emergency response plan, the Part 5 compliance cross-reference and the declaration of compliance, with instructions for submitting. A specialist reviews each document before release. You review, sign and submit; we do not file or certify anything for you.

Frequently asked questions

Does the deadline apply to a Part 135 operator with one helicopter?

Yes. Part 5 applies to every Part 135 certificate holder. A single pilot who performs all the functions is excused only from the provisions listed in § 5.9(e).

Is a § 91.147 air tour operator covered?

Yes. Section 5.1(c) applies Part 5 to holders of a § 91.147 Letter of Authorization, and § 5.9(a) sets the same May 28, 2027 date for those issued before May 28, 2024.

Does the FAA approve my SMS before the deadline?

Existing operators submit a declaration of compliance. The rule does not describe a separate approval step for that submission, and the FAA checks the SMS through its own oversight.

Have it prepared

The SMS manual and implementation plan is $1,875 and the emergency response plan is $850. See the format below.

Sources

Primary sources, as retrieved when this article was last updated. Check the current text before you rely on it.

• 14 CFR 5.9, Requirements for commuter and on-demand operations or passenger-carrying flights for compensation or hire
• 14 CFR Part 5, Safety Management Systems
• AC 120-92D, Safety Management Systems for Aviation Service Providers (5/21/2024)

Informational only. Not legal advice, not FAA guidance and not a promise of FAA approval or of any FAA timeline. The operator submits its own application; only the FAA approves, accepts or issues an authorization.