Part 135 Training Program Approval: OpSpec A031 Guide

Getting Your Part 135 Training Program Approved: OpSpec A031 and the Revisions That Slow You Down

You contracted with a respected training provider, submitted your curriculum revisions, and expected a straightforward approval. Instead, you received a letter from your POI requesting a regulatory crosswalk, version-control documentation, and clarification on how your operator-specific procedures integrate into the provider’s courseware. Your revision is stalled, and you are not sure what went wrong. Why does OpSpec A031 not approve your part 135 training program when the provider is already FAA-qualified?

The answer is foundational and widely misunderstood. A part 135 training program approval is earned not by purchasing vendor courseware or contracting with a qualified provider, but by demonstrating operator-controlled governance — a traceable curriculum, proper revision management, and clear regulatory crosswalks. The FAA must review and approve your complete curriculum, training devices, instructors, checking system, records, and controls. This article explains what the part 135 training program approval process actually requires, what OpSpec A031 authorizes (and what it does not), and the specific revision-submission mistakes that cause the longest delays.

What FAA Approval of a Part 135 Training Program Actually Means

An FAA approved training program under Part 135 is not a purchased product. It is a certificate-holder-specific system that the FAA has reviewed and found compliant with 14 CFR Part 135 Subpart H (§§ 135.321 through 135.343). The approval is tied to your specific operation — your aircraft make and model, your procedures, your instructors, your checking system, and your records controls. Another operator’s approved curriculum, even for the same aircraft type, does not satisfy your obligation.

Understanding how to get FAA approval for a part 135 training program starts with recognizing the two-stage structure. Under § 135.325, part 135 training program approval involves two stages: initial approval and final approval. Initial approval allows you to begin training under the proposed program. Final approval follows the FAA’s evaluation of how the program performs in practice. These are distinct steps, not formalities.

A third-party provider’s existing approval does not automatically extend to your program. If you contract with a provider that holds approvals for other certificate holders, those approvals belong to those operators. You must still demonstrate that your curriculum, instructors, devices, checking events, and records meet FAA training program requirements for your operation. The provider’s materials may support your application, but they do not replace it.

This distinction matters because it shapes every revision, every A031 application, and every interaction with your principal operations inspector. Your program is yours to own, defend, and maintain.

What OpSpec A031 Authorizes — and What It Does Not

OpSpec A031 is an authorization and control document. It permits you, as a part 135 certificate holder, to use an outside training provider or other approved training arrangement for specific courses, aircraft types, or training events. It is not a blanket approval of your training program. It authorizes a specific arrangement within your broader approved program — think of it as an opspec a031 contract training authorization, not a vendor purchase order.

When applying for or revising A031, the FAA expects you to demonstrate:

Which courses are provided internally and which are contracted to the outside provider.
Which organization supplies instructors, evaluators, simulators, training devices, and courseware.
How operator-specific procedures, aircraft differences, manuals, emergency procedures, and company policies are incorporated into the provider’s training.
How you perform standardization, surveillance, audits, corrective action, and records control over the contracted training.
How revisions to the provider, device, curriculum, or operational scope will be submitted to the FAA.

Contracting training out does not transfer regulatory responsibility. The certificate holder retains full certificate holder training responsibility — for curriculum accuracy, instructor qualification, records integrity, and contract training provider oversight. One industry provider references a 60-day window for submitting written audit findings to the POI after initial contract training begins. Operators should verify whether this timeline applies to their specific authorization, but the principle is clear: approval is the start of ongoing compliance, not the finish line.

Part 135 Training Program Revision Process: Common Delay Triggers

If your part 135 training program revision process has stalled, the cause is likely one of the following. These are the most common triggers that generate additional questions from the principal operations inspector and extend your approval timeline.

Adding an aircraft make or model without updating all curricula and checking events. A new type affects initial, transition, differences, and recurrent training. Partial updates create gaps the POI must question.
Changing a simulator, training device, instructor, evaluator, or contract provider. Each change alters the approved training arrangement and may require updates to A031, instructor qualifications, device authorizations, and course content.
Revising procedures without updating lesson plans, knowledge assessments, scenarios, and checking standards. A procedure change in your operations manual that is not reflected in the training curriculum creates a traceability gap.
Introducing electronic courseware without demonstrating version control, learner tracking, testing integrity, and records retention. Digital delivery requires the same governance rigor as classroom training — and the documentation to prove it.
Submitting a revised manual without a detailed revision summary and part 135 training program regulatory crosswalk. The POI should not have to search for what changed. Identify every affected paragraph, course, lesson, and checking event.
Failing to distinguish FAA-required subjects from operator-specific or optional material. Your curriculum must clearly identify which elements satisfy regulatory requirements and which are supplemental.
Omitting differences training after changes to avionics, aircraft configuration, or procedures. Differences training is not optional when operational changes affect crewmember knowledge or proficiency.
Changing a provider without updating A031, source-of-training documentation, standardization and surveillance evidence, and oversight procedures. A new provider is a new arrangement — not a substitution.
Using a provider’s generic curriculum without demonstrating integration into the certificate holder’s approved program. Generic courseware is a starting point, not a finished product. You must show how it maps to your manuals, procedures, and operations specifications.
Making multiple uncoordinated revisions while the POI is still reviewing an earlier training program revision submission. This is one of the most cited practical causes of extended approval timelines. Coordinate your submissions so each package is complete and does not conflict with a pending review.

Before submitting any revision, evaluate it across five areas: curriculum, manuals, instructors, devices, and records. A concise but traceable curriculum is more defensible than an incomplete one that invites more questions. A practical submission should also explicitly identify what has not changed — this reduces the POI’s review burden and prevents unnecessary follow-up.

What the POI Needs to See in Your Submission

Here are the elements of a defensible part 135 training program approval submission. Use this as a checklist before contacting your POI:

Detailed revision summary identifying every affected paragraph, course, lesson, device, instructor qualification, checking event, manual reference, and record.
Regulatory crosswalk mapping each curriculum element to its applicable CFR section under the part 135 training program requirements 14 CFR framework. The final curriculum should be mapped against your specific regulatory profile rather than copied from another certificate holder.
Clear identification of what has not changed — as important as documenting what has.
Configuration control showing version history and effective dates for all affected documents and courseware.
Evidence of alignment — that any proposed provider, courseware, instructors, and devices match your FAA approved part 135 training curriculum and operations specifications.
Crewmember training requirements coverage, including initial, transition, upgrade, recurrent, requalification, and differences training as applicable.
Hazardous materials training — if applicable, a statement of how training under § 135.501 is addressed. A hazardous materials training approval requires its own separate FAA approval before implementation. This is a parallel track, not a subset of the general program.

Assemble these elements before your first conversation with the POI. A complete, well-organized package signals that your part 135 training program is governed, not improvised.

How E-Learning Supports — or Undermines — Your Part 135 Training Program Approval

Digital delivery, LMS platforms, and blended training are increasingly common in Part 135 programs. The compliance issue is not whether training is online — it is whether the method produces the required knowledge, skills, proficiency, documentation, and FAA-acceptable oversight. Three broad delivery modes characterize most approved programs: computer-based or instructor-led ground training, device or simulator training, and aircraft or operational training. E-learning fits within the first mode, but its value depends on the controls behind it.

An e-learning platform supporting part 135 e-learning compliance requirements must demonstrate:

Curriculum mapping: Every lesson linked to the applicable regulation, manual paragraph, company procedure, and checking objective.
Version control: Obsolete lessons locked, effective dates documented, revision history preserved, and FAA approval status recorded.
Learner authentication: Individual accounts and controls that prevent proxy completion.
Knowledge-check recording: Questions, attempts, scores, remediation steps, and completion status captured and stored.
Instructor involvement: A documented process for learner questions, performance deficiencies, and required instructor-led elements.
Records retention: Completion records, test results, instructor identity, course version, dates, and corrective actions maintained in accordance with part 135 LMS records retention FAA expectations.
Auditability: The operator and FAA can reconstruct what each crewmember completed and which course version was in force at the time.

E-learning is particularly effective for systems knowledge, regulations, company procedures, human factors, hazmat, security, and pre-simulator preparation. It does not replace required practical training, flight training, proficiency checks, or competency demonstrations. Online training may satisfy some knowledge objectives, but it does not by itself satisfy flight, simulator, practical, proficiency-check, or competency requirements.

See how CTS’s Part 135 Training platform addresses version control, curriculum mapping, and records retention requirements.

Misconceptions That Cost You Part 135 Training Program Approval Cycles

These are the most damaging misconceptions about part 135 training program approval. Each one costs operators time, resubmissions, and credibility with the FAA.

“A031 approves the entire training program.” OpSpec A031 authorizes a specified training arrangement. It does not eliminate the need for approval of the operator’s complete program and revisions.
“An FAA-approved provider makes the operator’s curriculum approved.” The operator’s FAA approved training program must still be reviewed in the context of its aircraft, manuals, procedures, operation, and responsibilities.
“The vendor is responsible for compliance after contracting.” The certificate holder retains responsibility for the training program and oversight of contracted activities.
“Once approved, a program can be changed without FAA involvement.” Material revisions generally require submission, review, and approval before use. Recurrent training requirements and program changes are not exempt from this principle.
“The shortest curriculum is the easiest to approve.” An incomplete curriculum creates more questions and revision cycles. A concise but traceable curriculum is more defensible.

Building a Revision-Resilient Part 135 Training Program

Part 135 training program approval is not a one-time event. It is the beginning of an ongoing lifecycle that demands operator ownership, regulatory traceability, version control, and coordinated revision management. The distinction between vendor content and operator governance is not academic — it determines whether your next revision moves forward or triggers another round of resubmissions.

Reported FAA certification-process changes for 2026 may allow prepared part 135 certificate applicants to advance directly to later phases when they satisfy readiness criteria and the responsible FAA office has capacity. This does not reduce the depth of training-program review required. If anything, it raises the documentation standard: operators who reach the training-review stage faster must arrive with a complete, defensible package. The operator — not the vendor — owns the approved training system.

A well-structured part 135 training program is achievable. It requires a governance-ready e-learning platform, disciplined revision management, and a records infrastructure that supports auditability as a daily function rather than a scramble before the next POI review. Building these controls into your operations from the start transforms part 135 training program approval from a recurring obstacle into a managed process.

Download the Part 135 training revision-readiness checklist or explore CTS’s Part 135 Training packages to see how a governance-ready e-learning platform supports your approval process from initial submission through ongoing compliance.