How Long Does FAA Part 135 Certification Take? The Phases, the Clocks and What Changed in 2026
The honest answer to “how long does Part 135 certification take?” is: it depends — and most of what it depends on is within your control. The FAA does not run a stopwatch, but it does run a series of review gates. How quickly you pass through them is largely a function of how complete and compliant your documents are when you submit them. This guide walks the five phases, gives realistic ranges, and shows where Data Collection Tools and manuals fit.
The short answer
Typical range: roughly nine to eighteen months for a basic operation from a complete filing to certificate; longer for complex fleets, international, or special authorizations — and the wait for an FAA certification team after acceptance has no fixed limit.
The dominant variable: completing the DCTs correctly — by a wide margin the biggest source of delay in Design Assessment (weeks at best, often months).
The lever you control: reduce correction cycles by submitting mature, compliant documents the first time — and, since 2026, by filing the complete readiness package at the outset, because the FAA no longer puts an unready applicant in line.
Why there’s no fixed number
The FAA does not publish a guaranteed certification duration, and for good reason: the process is gated, not timed. Each phase ends when the FAA is satisfied that the applicant has met that phase’s requirements. A clean submission passes a gate; a deficient one gets returned for correction and re-review. The clock that matters is not a calendar — it is the number of times your materials cycle back for rework.
That is why two applicants starting on the same day can finish months apart. The one with a mature, internally consistent manual suite and well-prepared compliance documents passes gates cleanly. The one submitting drafts riddled with gaps spends the difference in correction cycles.
What changed in 2026: readiness first, then the line
The five-phase structure below is still how FAA Order 8900.1 describes certification, but the front of the process has been rebuilt. Under FAA Notice N 8900.766, Determine Applicant Readiness for Certification (effective January 26, 2026), an applicant must demonstrate readiness before the FAA places it on the national Applicant List. In practice the old Phase 1 and Phase 2 collapse into a single readiness filing, and an applicant that satisfies the checklist enters the process at document compliance with its manuals already on the table.
| Readiness tier | Required before placement on the Applicant List |
|---|---|
| Single Pilot or Single PIC | FAA Form 8400-6 (PASI); compliance statement sized and scoped to the intended operation; SMS documentation; list of proposed OpSpecs with procedures; category and class of aircraft; hazmat, flight-locating and deicing positions; the named pilot's résumé; sample records |
| Nine or Less, Basic or Full | Everything above, plus deviation or exemption requests, the General Operations Manual, the training manual, management résumés (DO, DOM, CP), pilot and medical certificates for the DO and CP, and an Approved Aircraft Inspection Program if required |
| Ten or More | Everything above, plus a Continuous Airworthiness Maintenance Program and a General Maintenance Manual |
The FAA's clocks then run as follows. The receiving office has 30 calendar days to decide whether the 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 sets no limit on the wait for a certification team and instructs its offices not to predict a start date. After the project starts, N 8900.775 (May 26, 2026) governs: the schedule of events is agreed at the outset, each correction letter must be answered within 15 days, and an applicant that fails to have personnel, aircraft or facilities in place when needed can be treated as withdrawn and must reapply with a complete new package.
Finally, since September 30, 2026, initial Part 135 applications are filed through the FAA's Aviation Integrated Safety (AIS) Services portal (formerly the AVS Hub) with login.gov sign-in, an organization profile with Administrator, Member and read-only Consultant roles, uploads of up to 500 MB per document, and machine-assisted review of documents for completeness. The content rules did not change; the package now meets a completeness check before an inspector reads it. For what a complete package contains and how to plan the business around these gates, see Can a Company Build Your Part 135 Certificate for You?.
The five phases of certification
FAA air carrier certification follows a standardized five-phase structure. Understanding what each phase demands is the first step to moving through it efficiently — keeping in mind that, under N 8900.766, the content of Phases 1 and 2 is now delivered in the readiness filing described above.
| Phase | What happens | What the applicant produces |
|---|---|---|
| 1. Pre-application | Initial contact with the FAA; the applicant signals intent and basic scope | Pre-application Statement of Intent (PASI) and initial information about the proposed operation |
| 2. Formal Application | The applicant submits the formal application package and meets with the certification team | Formal application, schedule of events, draft manual suite, requested OpSpecs, compliance documents |
| 3. Design Assessment | The FAA evaluates whether the written program and manuals satisfy the regulations | Compliant manuals and Data Collection Tool responses traceable to the manual suite |
| 4. Performance Assessment | The FAA observes whether the applicant can conduct operations as documented | Demonstration flights, inspections, and evidence the operation performs to its design |
| 5. Administrative & Certification | Final administrative steps; the certificate and OpSpecs are issued | Final document reconciliation; acceptance of the issued certificate and Operations Specifications |
Phase 1 — Pre-application
The applicant establishes contact with the FAA and submits a Pre-application Statement of Intent describing the proposed operation: type of operation, proposed aircraft, areas of operation, and key personnel. This phase sets the relationship and the framing. Time spent here getting the proposed scope right — and realistic — saves time later.
Phase 2 — Formal Application
The applicant submits the formal application package, including a schedule of events and the draft manual suite, and requests the specific OpSpecs the operation needs. This is where the depth of preparation starts to show. A thin or inconsistent manual suite submitted here guarantees friction in the assessment phases that follow.
Phase 3 — Design Assessment
The FAA evaluates whether the applicant’s written compliance system — the manuals and procedures — satisfies the regulations. This is where Data Collection Tools do much of their work: the FAA uses them to check, element by element, whether a complete and compliant procedure exists on paper. Strong DCT responses with paragraph-level citations to the manual suite are what carry an applicant through this gate.
In practice, the Data Collection Tools are by a considerable margin the single biggest source of delay in the Design Assessment phase. Getting a full set completed correctly — every answer cited to the right paragraph of a compliant manual, scoped to the applicant’s OpSpecs — takes weeks at best, and commonly several months. More applicants stall here than at any other point in certification, which is exactly why getting the DCTs done right, and done early, has an outsized effect on the overall timeline.
Phase 4 — Performance Assessment
Having confirmed the design on paper, the FAA evaluates whether the applicant can actually operate the way the manuals say. This includes demonstration flights and inspections. The question shifts from “is it written correctly?” to “does the operation perform to the written design?” — the performance half of the assessment.
Phase 5 — Administrative Functions and certification
With design and performance satisfied, the process moves to final administrative reconciliation and issuance of the air carrier certificate and the Operations Specifications. The OpSpecs issued here are the document that will govern the operator’s authorized scope from day one of operations.
Where DCTs and manuals fit
The two assessment phases — Design and Performance — are where most of the substantive compliance work lives, and they map directly onto the SAS framework operators encounter later in surveillance. Data Collection Tools are the instrument the FAA uses in both:
- In Design Assessment, DCTs check whether your manuals contain complete, compliant procedures for each element — answered with citations to where compliance is documented.
- In Performance Assessment, DCTs help confirm the operation performs to that documented design.
Because the same design-and-performance logic governs both certification and later surveillance, the discipline you build during certification pays dividends for the life of the certificate. For the mechanics of how those tools are structured and reviewed, see What are SAS DCTs? and Preparing for a SAS DCT Review. For how your authorized scope is defined and why it governs every answer, see OpSpecs Explained.
What actually drives the timeline
Some variables are outside an applicant’s control — FAA workload and scheduling among them. But the variables that most often determine duration are squarely within reach:
- Getting the DCTs completed correctly. By a wide margin the biggest single source of delay in Design Assessment. A full set of accurate, properly cited responses takes weeks at best and often several months — and incorrect or incomplete answers trigger the correction cycles that stretch a certification out.
- Manual completeness and compliance. Closely tied to the DCTs — a mature, regulation-compliant, internally consistent manual suite is what makes correct DCT answers possible and passes Design Assessment with minimal rework.
- Quality of compliance documents. DCT responses that cite the right paragraph of the current manual, and a clean compliance demonstration, keep the assessment phases moving.
- Realistic scope. Requesting authorizations the operation cannot yet support invites delay. Scope the OpSpec requests to what you can demonstrate.
- Correction cycles. Every returned submission adds a review round. Reducing the count of returns is the most reliable way to shorten the path.
- Internal consistency across the suite. The most common correction in a large package is not a missing document but a fact stated two ways — a device count, a notification time, a position title. Build every manual from one confirmed set of operator facts, and the package survives both an inspector's reading and the portal's completeness check.
- Staying current in the queue. DCTs are revised, Advisory Circulars are superseded and Notices expire while an applicant waits. A package that is complete at filing can be stale when the project starts. Re-check the DCT sets at least every 90 days and keep the manuals aligned to the current corpus.
- Spending in step with the schedule. The FAA expects people, aircraft and facilities to be in place when needed, and N 8900.775 makes the schedule of events the governing document. Staging the lease and the key hires to that schedule, rather than months ahead of it, is what keeps a long wait from consuming the startup capital.
The practical takeaway
You cannot make the FAA move faster, but you can give it less to send back. Applicants who invest in a complete, compliant manual suite and well-prepared Data Collection Tool responses before submission — rather than scrambling to fix deficiencies after a gate fails — consistently move through certification with fewer cycles and less elapsed time. The preparation is the timeline.
What “withdrawn” means under N 8900.775
FAA Notice N 8900.775 (effective May 26, 2026) governs what happens after a certification project has started if the application stalls. In plain terms:
- The schedule of events agreed at the start of the project is the governing document.
- Each correction letter must be answered within 15 calendar days.
- An applicant that fails to have required personnel, aircraft or facilities in place when the schedule calls for them can be treated as withdrawn.
- A withdrawn applicant must reapply with a complete new package — and forfeits its place in line.
That is why staging capital and hiring against the FAA’s gates, rather than months ahead of them, is part of timeline management. A long Applicant List wait that burns the lease and the key hires before a team is assigned is how otherwise-ready applicants get forced to restart.
SMS in the readiness package — and who builds it
Under N 8900.766, SMS documentation is part of the readiness package for every tier. New Part 135 applicants must develop and implement an SMS that meets 14 CFR Part 5 as a condition of certification (§ 5.9(b)). Existing certificate holders authorized before May 28, 2024 have until May 28, 2027 to implement Part 5 SMS and file a declaration of compliance (§ 5.9(a)).
Delta Bravo Aviation does not develop or sell SMS programs. For the SMS itself, Delta Bravo refers operators and applicants to vetted providers such as OmniSMS and AirTera. Delta Bravo’s Part 135 Certificate Builder builds the rest of the readiness package — manuals, OpSpecs list, compliance statement, applicant Element-Design DCTs and AIS Services filing — and integrates the SMS provider’s deliverables into that package once they are ready.
Realistic ranges by readiness tier
These are planning ranges, not promises. The FAA does not publish a guaranteed duration, and the Applicant List wait has no fixed limit:
| Readiness tier (N 8900.766) | Applicant-controlled build to a filed package | Planning range, complete filing to certificate |
|---|---|---|
| Single Pilot or Single PIC | Often 12–20 weeks when decisions come quickly | Roughly 9–14 months, longer if the Applicant List wait stretches |
| Nine or Less (Basic or Full) | Often 16–24 weeks | Roughly 12–18 months |
| Ten or More | Often 20–30+ weeks (CAMP/GMM depth) | Roughly 14–24 months, longer with complex fleets or international authorizations |
The dominant variable inside every tier is still DCT quality in Design Assessment. A clean Element-Design package that cites the current revision and the correct manual paragraphs passes; a package built on an older revision or vague citations cycles. For what a complete 2026 application contains and published Builder fees by tier, see Can a Company Build Your Part 135 Certificate for You? and Pricing.
Sources
- FAA Notice N 8900.766, Determine Applicant Readiness for Certification (effective January 26, 2026), ¶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).
- FAA Order 8900.1, Volume 2, Chapter 4 (Part 135 certification) and Volume 10, Chapter 12, Section 1 (Certification Services Oversight Process). Available on DRS.
- FAA Part 135 certification page — AIS Services transition beginning September 30, 2026, five-phase process and FAQs.
- 14 CFR Part 135 and 14 CFR § 5.9 (Part 5 SMS dates).
Frequently asked questions
What is the biggest single source of delay in Part 135 certification?
By a considerable margin, the biggest single source of delay is completing the Data Collection Tools (DCTs) correctly during the Design Assessment phase. A full set of accurate, properly cited DCT responses typically takes weeks at best and commonly several months to produce, and answers returned for correction add further review cycles. More applicants stall at the DCTs than at any other point in the certification process.
How long does FAA Part 135 certification take?
There is no fixed FAA timeline, and durations vary widely. Many single-pilot or basic Part 135 certifications take roughly nine to eighteen months from pre-application to certificate issuance; more complex operations with larger fleets, international authorizations, or special authorizations can take longer. The dominant variable is the quality and completeness of the applicant's submitted documents — manuals, OpSpecs requests, and compliance demonstrations. A well-prepared applicant moves through the FAA's review gates faster because there is less to send back.
What are the five phases of Part 135 certification?
The FAA air carrier certification process is organized into five phases: (1) Pre-application, where the applicant and FAA establish initial contact and the applicant submits a Pre-application Statement of Intent; (2) Formal Application, where the applicant submits the formal application package including the schedule of events and draft manuals; (3) Design Assessment, where the FAA evaluates whether the applicant's written program and manuals satisfy the regulations; (4) Performance Assessment, where the FAA observes whether the applicant can actually conduct operations as documented, including demonstration flights and inspections; and (5) Administrative Functions and certification, where the certificate and Operations Specifications are issued.
Where do Data Collection Tools fit in the certification process?
Data Collection Tools are central to the Design Assessment and Performance Assessment phases. During Design Assessment, the FAA uses DCTs to evaluate whether the applicant's manuals contain complete, compliant procedures for each element. During Performance Assessment, DCTs help evaluate whether the operation performs to the documented design. Answering the relevant DCTs accurately, with citations to the manual suite, is much of what moves an applicant through the two assessment phases.
What causes delays in Part 135 certification?
By a considerable margin, the single biggest source of delay is completing the Data Collection Tools (DCTs) correctly during the Design Assessment phase. Getting a full set of accurate, properly cited DCT responses done can take weeks at best and commonly several months, and incorrect answers trigger correction cycles that extend the process further. Other common causes include incomplete or non-compliant manuals, compliance documents that don't trace cleanly to the regulations, requests for authorizations the applicant cannot yet support, and FAA workload and scheduling. Applicants reduce delay most by getting the DCTs and the manual suite right before submission.
Can I speed up Part 135 certification?
An applicant cannot control FAA scheduling, but can control the quality of what it submits — and that is the largest lever on timeline. A complete, regulation-compliant manual suite, accurate Data Collection Tool responses with paragraph-level citations, and a clean compliance demonstration reduce the number of correction cycles, which is where most preventable delay accumulates. Engaging experienced compliance support before formal application, rather than after a gate fails, tends to shorten the overall path.
What is a Pre-application Statement of Intent (PASI)?
The Pre-application Statement of Intent is the document a prospective Part 135 applicant submits to the FAA to formally signal its intent to seek a certificate. It provides initial information about the proposed operation — the type of operation, proposed aircraft, areas of operation, and key personnel — and begins the certification relationship with the FAA office that will handle the application. It marks the start of the pre-application phase.
Does a consultant help with Part 135 certification?
Yes. Compliance consultants support applicants by developing or reviewing the manual suite, preparing Data Collection Tool responses, assembling compliance demonstrations, and helping package the application so it passes FAA review gates with fewer correction cycles. The applicant remains the certificate holder and the responsible party; the consultant supplies regulatory craft and documentation discipline. Delta Bravo Aviation's Part 135 Certificate Builder takes applicants from business plan to certificate as a fixed-fee partnership, and provides DCT completion and Manual Gap Suggested Edit Reports to certificate holders.
What does the FAA require before it places a Part 135 applicant on the Applicant List?
Under FAA Notice N 8900.766 (effective January 26, 2026), every applicant files a readiness package first: the Pre-application Statement of Intent, a compliance statement sized and scoped to the intended operation, Safety Management System documentation, a list of proposed Operations Specifications with procedures, the category and class of aircraft, and its hazmat, flight-locating and deicing positions. Nine-or-less basic and full applicants add the General Operations Manual, training manual, management résumés and DO/CP certificates and an AAIP if required; ten-or-more applicants add a CAMP and General Maintenance Manual. Only an accepted package earns a place on the Applicant List.
What are the FAA's clocks during Part 135 certification?
Thirty calendar days for the FAA's acceptance decision on the readiness package; 15 calendar days for the applicant to answer a return or, later, a correction letter — or the application is treated as withdrawn and the applicant loses its place; a status letter at least every 60 calendar days while the applicant waits on the Applicant List; and no fixed limit on the wait for a certification team.
Has the Part 135 application process moved to a new FAA system?
Yes. 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, with login.gov sign-in and machine-assisted document completeness review. Existing certificate holders continue to use the SAS External Portal for OpSpecs and surveillance activity, and N 8900.766 and Order 8900.1 still govern the content and the process.
Related reading
- Can a Company Build Your Part 135 Certificate for You? What a Complete 2026 Application Contains
- What are SAS DCTs? Element-Design (DA) and Element-Performance (PA) Explained
- Preparing for an FAA SAS DCT Review: What Part 135 Operators Should Expect
- OpSpecs Explained: How Operations Specifications Scope Your Certificate
- DCT vs. SOC: When the FAA Wants More Than Answered DCTs
- How to Get an FAA Part 145 Repair Station Certificate: The Ten-Step Roadmap
- Part 135 Certificate Builder service