Can a Company Build Your Part 135 Certificate for You? What a Complete 2026 Application Contains, What It Costs — and Why the Business Plan Comes First

A Part 135 air carrier certificate is not a document you obtain. It is a business you design and then prove to the FAA, on paper first and in the air second. In 2026 the FAA rewrote the sequence: the complete package is due before you are even placed in line, the clocks are short, and the application is filed through a new portal that reads documents with machine assistance. The applicants who move through cleanly are the ones who treat the certificate as the output of a business plan — and who have a partner planning the money, the people and the paper against the FAA's gates at the same time.

What changed in 2026, in order

Three FAA actions reshaped how a new Part 135 certificate is built this year. They stack, and an applicant planning a build needs all three in view.

1. N 8900.766 — the readiness checklist (January 26, 2026)

FAA Notice N 8900.766, Determine Applicant Readiness for Certification, requires an applicant to demonstrate that it is ready before the FAA places it on the national Applicant List. The practical effect is that the old Phase 1 (pre-application) and Phase 2 (formal application) collapse: an applicant that satisfies the checklist enters the process at document compliance, with its manuals already on the table. The Notice's Appendix A, Table A-4 sets three cumulative tiers for Part 135:

Two consequences follow. First, the Statement of Compliance is no longer a late-phase document; it is part of the first filing for every tier. Second, an applicant that is “returned” and does not respond within 15 days is withdrawn — and a withdrawn applicant forfeits its place in line.

2. N 8900.775 — incomplete and insufficient applications (May 26, 2026)

N 8900.775 adds the disposition rules for applications that stall after acceptance. The schedule of events is agreed at the outset; failing to meet a schedule date or a correction timeframe can cause the application to be considered withdrawn; and the Notice names the circumstances — not providing personnel, not having aircraft or equipment, not having facilities when they are needed. An applicant that cannot meet a requirement must notify the FAA within 15 calendar days. An applicant withdrawn after the project starts must reapply with a complete new package.

3. AIS Services — the new filing channel (September 30, 2026)

Beginning September 30, 2026, initial Part 135 air carrier and operator certificate applications are filed through the FAA's Aviation Integrated Safety (AIS) Services portal (formerly the AVS Hub) rather than the legacy SAS External Portal. Access is through login.gov; the applicant creates an organization profile and invites its people as Administrators, Members or read-only Consultants; documents are uploaded as PDF, Word or Excel files of up to 500 MB each; and the portal advertises machine-assisted review of documents “for compliance and application completeness.” The content rules did not change — N 8900.766 still governs what is filed and Order 8900.1 still governs the certification project — but the package now meets a completeness check before a human inspector reads it, which rewards clean, well-indexed, cross-referenced documents.

What a complete package contains

Behind the checklist tiers sits the real work: a manual suite and a set of filings that have to agree with each other to the device count and the phone number. For a standard nine-or-less turbine applicant, the package Delta Bravo Aviation builds contains:

• The compliance statement, built to the N 8900.766 checklist and cross-referenced to the manual section that satisfies each applicable regulation.
• The General Operations Manual (§§ 135.21, 135.23) — operational control, flight locating, weather and airport minimums, fueling, deicing, passenger handling, hazmat recognition, records, emergency procedures, and every program the OpSpecs call for.
• The training program manual with its forms, or the deviation or exemption requests that replace it for basic and single-PIC classifications.
• The maintenance program: the manufacturer's program or an Approved Aircraft Inspection Program for nine-or-less aircraft; a CAMP and General Maintenance Manual — with Chief Inspector, RII and CASS structures — where aircraft are type-certificated for ten or more seats or where CAMP is elected under § 135.411(b).
• Not included: the Safety Management System. Part 5 requires every applicant to have an SMS, but Delta Bravo Aviation does not develop SMS programs. We refer applicants to vetted SMS providers we recommend, such as OmniSMS and AirTera.
• The supporting volumes as scoped: hazmat will-carry or will-not-carry manual, emergency response plan, minimum equipment list, electronic flight bag and electronic records program for OpSpecs A025 and A061, weight-and-balance program, deicing program, destination airport analysis, international operations manual, RVSM, EFVS, CAT II and SIC professional-development programs where sought.
• The proposed Operations Specifications — the A, B, C, D, E and H paragraphs the operation needs, each with the data the FAA will need to issue it — and the deviation requests (OpSpec A005) for management positions or qualifications under §§ 119.69 and 119.71.
• The registrations the FAA will not issue OpSpecs without: DOT air taxi registration (OST Form 4507, at least 30 days before operations) and Part 205 liability insurance; drug and alcohol program registration under Part 120; the Pilot Records Database responsible person under Part 111; TSA and CBP programs where weight, seats or international operations trigger them.
• The applicant-completed Element-Design DCTs the certification team will use, answered to the manual section and audited before the FAA sees them.

The failure mode in packages of this size is not a missing document. It is a fact stated differently in two places — four EFB devices in the GOM and five in the EFB program manual, an overdue-aircraft notification time of 30 minutes in one volume and 60 in another. Inspectors find these, and under a machine-assisted completeness review they will be found faster. Delta Bravo's builds run from a single operator ground-truth register: every cross-manual fact — fleet and seat configurations, device counts, named position holders, systems of record, OpSpecs held, retention periods, company minimums — is confirmed by the Director of Operations before any manual text is drafted, and a suite-wide consistency check gates every edit.

Why the DCTs matter twice — and why the Builder includes them

Of everything in the package, the Element-Design Data Collection Tools deserve their own paragraph. They are the FAA's instrument of Design Assessment: for each element of the operation — training, hazmat, operational control, maintenance, records — the DCT asks whether a complete, compliant procedure exists and where in the manuals it lives. Under the 2026 readiness process the applicant answers them, question by question, citing its own manual sections, before the certification team reviews the design. Done well, they shorten the design assessment to a verification exercise; done badly, they are by a wide margin the largest single source of delay in a Part 135 certification, generating correction letters on 15-day clocks.

They matter a second time after issuance. The same DCT bank, in its Element-Performance form, is how Principal Inspectors oversee the certificate in surveillance for as long as it is held, and the Element-Design answers accepted at certification are the baseline every later review is read against. An operator that leaves certification with a complete, cited, current DCT package enters every surveillance cycle already prepared; one that treated the DCTs as a one-time hurdle rebuilds them under pressure when the inspector calls.

That is why the requisite DCT completion is included in the Builder fee, not sold alongside it. Delta Bravo answers every applicable Element-Design DCT for the applicant's peer group and scope — for a nine-or-less turbine operator that is typically well over a thousand questions — cites each to the manual section, runs a blind inspector-style counsel review over the whole package, and re-checks the set against the FAA's current DCT revisions every 90 days while the applicant waits in the queue. There is no per-question charge inside a Builder; the published $20-per-question rate applies to standalone DCT engagements for certificate holders. At issuance the operator holds its surveillance baseline, and the first-year compliance partner option keeps it current as the operation grows.

Why the business plan has to come first

Every paragraph of OpSpecs an applicant requests carries weight: manual content, training curricula, equipment, personnel qualifications, and a set of Data Collection Tool questions the FAA will ask about it. Requesting authority the business will not use in its first year — international areas, CAT II, an aircraft type that is not yet under contract — adds months of design assessment for authority that earns nothing. Requesting too little means returning for OpSpec amendments, which under § 119.51 require at least 15 days' notice for most changes and 90 days for changes in the kind of operation or the introduction of an aircraft type not previously proven in air carrier service, each with its own compliance demonstration.

That is why Delta Bravo Aviation's Builder begins with the business, not the paperwork. Working sessions with the owners settle what will be flown, for whom, where, and at what scale at 12, 24 and 36 months. From that plan the certificate is derived: the peer group and classification, the OpSpec set for day one and the amendment schedule for the growth that follows, the maintenance regime, the management structure, and the manual suite that supports all of it. The output is a signed Operator Definition that fixes the scope of the build — and a growth plan that already knows which amendments come next and when.

Planning the money against the FAA's gates

The second half of the partnership is financial structuring. A Part 135 applicant's carrying cost before its first revenue flight is substantial: a leased light jet, commercial insurance, a hangar, and a Director of Operations, Chief Pilot and Director of Maintenance who must be named and qualified — and in most cases on the payroll — before the FAA will proceed. For a nine-or-less jet applicant that cost commonly runs well into six figures a month; for a ten-or-more applicant with a Chief Inspector, flight attendants and a larger crew pool, more. Every month spent waiting in the FAA's line fully staffed is that cost paid with nothing in return.

Delta Bravo plans the spend against the gates where the regulations allow it. The management team must exist on paper — with résumés in the readiness package — before the Applicant List, but the FAA's own guidance expects personnel, aircraft and facilities to be in place when needed, and N 8900.775 makes the schedule of events the governing document. The Builder therefore sequences: entity and ownership structure first, with the applicant's counsel and CPA (the citizenship requirement of § 119.33 and the ownership and management disclosures the FAA reviews are decided here); the key hires and the aircraft lease staged to the schedule of events; proving or validation tests planned at least 30 days ahead with crews, aircraft and routes nailed down; and DOT registration and insurance timed to the OpSpecs issuance date, since the FAA will not issue OpSpecs with an effective date before the liability coverage is in force. Where a cost cannot be deferred, it is at least known — the Operator Definition carries a capital-and-hiring timeline the owners can finance against.

Keeping the certificate ready while you wait

The FAA does not limit the wait for a certification team, and instructs its offices not to speculate about when a project will begin. During that wait the regulatory ground moves: Data Collection Tools are revised, Advisory Circulars are superseded, Notices like N 8900.766 and N 8900.775 expire and are replaced or folded into Order 8900.1, and the applicant's own plan shifts as aircraft and people come and go. A package that was complete at filing can be stale when the project starts — and stale is what generates correction letters on a 15-day clock.

The Builder treats the queue as part of the engagement. Delta Bravo maintains a regulatory library — the full 14 CFR, every current Advisory Circular, all twenty volumes of Order 8900.1, the current Notices and the complete SAS DCT bank — refreshed weekly against the FAA's own sources, and re-checks the applicant's DCT sets against it every 90 days. A change in the applicant's plan re-opens the ground-truth register, and every manual location that states the changed fact is updated together. When the certification project starts, the package the FAA opens is current.

The six phases of a Builder engagement

1. Define the operator and the business plan. Scope, peer group, classification, OpSpec set, maintenance regime, management structure, facilities, the 12/24/36-month growth plan and the capital-and-hiring timeline. Outcome: a signed Operator Definition.
2. Build the manual suite and the application. Every manual written from a blank page to the regulation, the Order and the DCT questions, from one ground-truth register; the compliance statement; proposed OpSpecs; registrations. Outcome: the complete document set for owner review.
3. DCT completion — answer the FAA's questions before it asks. Every applicable Element-Design DCT for the peer group answered to the manual section (included in the fee), then a blind inspector-style audit of the whole package and closure of every gap. Outcome: a clean audit and a complete, cited DCT package that becomes the surveillance baseline.
4. File and get in line. The readiness package filed through AIS Services; any return answered inside 15 days; the Applicant List letter in hand; six months of queue upkeep. Outcome: an accepted, current application.
5. Carry it through the FAA project. Manager interview preparation, the formal application and schedule of events, design-assessment responses, the proving or validation test plan and flights, on-site support through the performance assessment, review of the certificate and OpSpecs before signature, and a day-one compliance checklist. Outcome: the air carrier certificate and Operations Specifications.
6. Operate and grow. Optionally, the first-year compliance partner: manual and roster updates, quarterly internal audits, SAS surveillance support, and the OpSpec amendments the growth plan calls for, filed on the § 119.51 lead times.

Build or buy? The comparison every applicant asks about

Because a Part 135 certificate cannot be sold or transferred, "buying a certificate" means buying the company that holds one — its history, its OpSpecs, its training program and any open surveillance findings. Brokered listings for operating Part 135 companies commonly run from several hundred thousand dollars to several million, and the purchase does not end the FAA's involvement: a change of ownership triggers a management-qualification review under § 119.71, a look at the operator's compliance history, and usually a round of OpSpec amendments to fit the buyer's actual plan — each with its own notice period and compliance demonstration.

Buying can be the right answer for a buyer who needs exactly the authorizations the seller already holds and who values a short runway above everything else. Building produces a certificate scoped to your own 12/24/36-month plan, at a cost that is fixed before work starts and a fraction of the acquisition price, with manuals your team actually wrote their procedures into rather than inherited. The honest comparison is not "months versus years"; since the FAA's 2026 changes, a complete, readiness-tiered build enters the queue faster and comes out of the certification project with fewer corrections than the typical acquired certificate needs to be re-scoped.

What the owners provide

The fee covers Delta Bravo's work; the business's own startup costs stay with the owners: forming the entity with their own attorney; leasing and fitting out the base; hiring the management team and crews on the agreed schedule; acquiring or leasing the aircraft on exclusive-use terms; insurance and DOT registration fees; drug and alcohol consortium fees; and prompt decisions — the Builder's 12-to-24-week pace to filing assumes replies within five business days of a request.

The practical takeaway

In 2026 a Part 135 certificate is won or lost in the first filing. The FAA now asks for the complete, scoped, internally consistent package before it will put an applicant in line, reads it with machine assistance, and runs 15-day clocks from there. The applicant that arrives with a certificate derived from a real business plan, a package built from one set of facts, its DCTs already answered and audited, and its spending staged to the FAA's schedule passes those gates with the fewest correction cycles — and starts operating with the capital it would otherwise have spent waiting.

What the Builder does not include

The Part 135 Certificate Builder builds the readiness package, manuals, applicant Element-Design DCTs, OpSpecs list, compliance statement and AIS Services filing, and carries the project through FAA acceptance, start and issuance. It does not develop or sell an SMS program. New applicants need a Part 5-compliant SMS under 14 CFR § 5.9(b); Delta Bravo refers that work to vetted providers such as OmniSMS and AirTera and integrates their deliverables into the readiness package. Aircraft acquisition, insurance, economic authority and TSA security program work remain the applicant’s (or their other advisors’) responsibility.

Sources

• FAA Notice N 8900.766, Determine Applicant Readiness for Certification (effective January 26, 2026; cancels January 26, 2027), ¶6, ¶7 and Appendix A, Table A-4.
• FAA Notice N 8900.775, Disposition of Incomplete or Insufficient Air Operator and Air Agency Certification Applications (effective May 26, 2026), ¶7 and Appendix B.
• FAA Order 8900.1, Volume 10, Chapter 12, Section 1 (Certification Services Oversight Process): ¶10-12-1-5 and ¶10-12-1-9 — 30-day acceptance decision, Applicant List, 60-day status letters.
• FAA Order 8900.1, Volume 2, Chapter 4 (Part 135 certification) and Volume 3, Chapter 29, Section 4 (proving and validation tests).
• FAA, Aviation Integrated Safety (AIS) Services and the Part 135 certification transition FAQs (faa.gov, September–October 2026).
• 14 CFR §§ 5.1, 5.9; 119.33, 119.51, 119.69, 119.71; 135.21, 135.23, 135.25, 135.411, 135.419, 135.427; 14 CFR Parts 111, 120, 205 and 298.

Frequently asked questions

Can a company build a Part 135 certificate for me?

Yes. A certification firm such as Delta Bravo Aviation can plan, write and manage the entire Part 135 application on your behalf — the N 8900.766 readiness package, the General Operations Manual and training program, the compliance statement, the proposed Operations Specifications, every applicant SAS Data Collection Tool, and the FAA meetings and proving tests — for a fixed fee set by readiness tier. The certificate itself is always issued to your company: the FAA requires your own Director of Operations, Chief Pilot and Director of Maintenance to qualify under 14 CFR § 119.71, and your aircraft, facilities and personnel must be in place when the certification project begins. A reputable firm builds the certificate around your business plan rather than selling you a template.

How much does it cost to get a Part 135 certificate in 2026?

The FAA does not charge a fee for the certificate itself. The cost is the build and the business behind it. Delta Bravo Aviation's Part 135 Certificate Builder is a fixed fee of $45,000 to $65,000 for a Single-Pilot or Single PIC operation, $85,000 to $140,000 for a Nine-or-Less operation, and $150,000 to $240,000 for a Ten-or-More operation with CAMP and GMM, with all applicant DCTs included. Beyond the consulting fee, applicants should budget for the aircraft (owned or dry-leased), the required management personnel from the start of the certification project, insurance, training and a 12-to-24-month capital runway, because the FAA's Applicant List wait has no fixed length.

Can I buy an existing Part 135 certificate instead of building one?

Certificates are not transferable, so what is actually bought is the company that holds one, with its history, its OpSpecs and any surveillance findings. Listings for operating Part 135 companies commonly run from several hundred thousand dollars into the millions, and the FAA still requires a change-of-ownership review, new management qualification and often OpSpec amendments before the new owner can operate as intended. Buying can be faster for a buyer who needs the exact authorizations the seller holds; building produces a certificate scoped to your business plan at a lower and more predictable cost. The primer's build-versus-buy section walks through the comparison.

What does a new Part 135 applicant have to submit before the FAA will put it in line?

Under FAA Notice N 8900.766 (effective January 26, 2026), the applicant files a readiness package before it is placed on the national Applicant List. Every applicant files the Pre-application Statement of Intent (FAA Form 8400-6), a compliance statement sized and scoped to the intended operation, documentation of its Safety Management System, a list of proposed Operations Specifications with the procedures behind them, the category and class of aircraft, and its hazmat, flight-locating and deicing positions. Nine-or-less basic and full applicants add deviation or exemption requests, the General Operations Manual, the training manual, management résumés and pilot and medical certificates for the Director of Operations and Chief Pilot, and an Approved Aircraft Inspection Program if required. Ten-or-more applicants add a Continuous Airworthiness Maintenance Program and a General Maintenance Manual. Since September 30, 2026, initial applications are filed through the FAA's AIS Services portal.

What are the FAA's clocks once a Part 135 application is filed?

The receiving office has 30 calendar days to decide whether the readiness package is accepted. If it is returned, the applicant has 15 calendar days to respond or the application is withdrawn, and a withdrawn applicant forfeits its place in line. Once accepted, the applicant receives an Applicant List letter and a status letter at least every 60 calendar days while it waits; the FAA does not set a limit on the wait and instructs its offices not to predict a start date. After the certification project starts, each FAA correction letter must be answered within 15 calendar days, and under N 8900.775 a missed schedule-of-events date or a failure to have personnel, aircraft or facilities in place when needed can also cause the application to be treated as withdrawn.

Which SAS peer group will my Part 135 certificate fall into?

The FAA sorts Part 135 certificates into peer groups by configuration: 135B for operators of aircraft type-certificated for 10 or more passenger seats, 135C for nine-or-less operations including turbojets and multi-pilot aircraft, 135D for single-pilot operators, and 135E for helicopter air ambulance. The peer group decides which Data Collection Tools the FAA uses, which readiness tier applies, and much of the manual content. Single PIC (OpSpec A039) operators are grouped with single-pilot operators for process purposes.

Does a Part 135 applicant need a Safety Management System?

Yes. 14 CFR Part 5 applies to every Part 135 certificate holder, and N 8900.766 requires SMS documentation in the readiness package of every tier. The only carve-out, in § 5.9(e), is for a single-pilot operator in which the pilot is the sole individual performing all necessary functions; even then the SMS documentation and recordkeeping requirements still apply.

How long does it take to build a Part 135 certificate?

The applicant controls the first stretch: with decisions and information supplied promptly, Delta Bravo Aviation's Part 135 Certificate Builder takes a nine-or-less applicant from a signed Operator Definition to a filed readiness package in roughly 12 to 20 weeks, and a ten-or-more applicant with CAMP and GMM in roughly 16 to 24 weeks. The FAA then sets the pace: a 30-day acceptance decision, an Applicant List wait of no fixed length, and a certification project whose duration depends on the quality of the package and the applicant's readiness for proving tests. Applicants should plan capital for 12 to 24 months from signing to certificate, with a reserve for a longer queue.

Related reading

• How Long Does FAA Part 135 Certification Take? The Phases, the Clocks and What Changed in 2026
• DCT vs. SOC: When the FAA Wants More Than Answered DCTs
• OpSpecs Explained: How Operations Specifications Scope Your Certificate
• What are SAS DCTs? Element-Design (DA) and Element-Performance (PA) Explained
• How to Get an FAA Part 145 Repair Station Certificate: The Ten-Step Roadmap
• Part 135 Certificate Builder — the service
• Part 135 Certificate Builder — tiers, options and payment schedule