Online Part 135 Training: How Operators Stay Compliant With FAA Requirements

Part 135 training is only 1 of 15 certification areas the FAA evaluates for Part 135 operators — yet a failure in training can cascade across nearly every other area, from your General Operations Manual to proving and validation tests. With the FAA’s updated certification process (effective January 24, 2024) placing new emphasis on applicant readiness and documentation quality, operators who treat training as a check-the-box exercise are the ones most likely to face delays, audit findings, or worse.

Part 135 training requirements sit at the center of every on-demand air carrier’s compliance framework. Under 14 CFR Part 135, operators offering flights to the public for compensation must maintain FAA-approved training programs that meet strict standards for pilot proficiency, operational control, aircraft maintenance knowledge, and safety management. This article is a practical compliance guide for operators and training managers who need to understand what the FAA requires, which components can be delivered online, and how to build audit-ready programs that hold up under scrutiny.

What Part 135 Training Requires — and Why It Matters

The regulatory scope of 14 CFR Part 135 is broad. Operators must satisfy 15 key certification areas — including training programs, drug and alcohol programs, management personnel qualifications, manuals, Minimum Equipment Lists (MEL), and proving and validation testing. Training touches nearly all of them. A deficient Part 135 training program doesn’t just create a training finding; it undermines the credibility of your General Operations Manual (GOM), raises questions during proving tests, and signals systemic weakness to FAA inspectors.

Part 135 compliance training is not a one-time event. Operators receive continuous FAA oversight through ongoing audits and operational inspections. Your training program must demonstrate that procedures for training and directing personnel are effective — not just that they exist on paper. The FAA evaluates whether your operation can consistently perform to the standards you’ve documented.

This creates a central question every operator and training manager must answer: which training components can your operation deliver online, and how do you structure a program that produces audit-ready documentation while still meeting every regulatory requirement? The sections below provide that mapping.

Part 135 Pilot Training Requirements at a Glance

Under Part 135 Subpart H, operators must develop and maintain an FAA-approved Part 135 operator training program that covers several mandatory categories. Your program must address each of the following:

• Initial training — for newly hired crewmembers before they serve in operations
• Transition training — when a crewmember moves to a new aircraft type
• Upgrade training — when a pilot advances from second-in-command to pilot-in-command
• Recurrent training — ongoing proficiency maintenance at FAA-approved intervals
• Differences training — for variations within the same aircraft type

Beyond these core categories, operators must maintain drug and alcohol testing programs under 14 CFR Part 120 and comply with pilot duty time and rest requirements under 14 CFR 135.261–135.273. Sterile cockpit protocols are enforced during critical phases of flight. Each of these areas demands documented training, and recurrent training for Part 135 pilots is where most operators spend the majority of their ongoing compliance effort.

Many Part 135 operators also set hiring minimums that exceed regulatory floors. Insurance requirements frequently push the minimum to 500 or more PIC hours for entry-level positions — an operator- and insurer-driven standard, not an FAA regulatory minimum — meaning the quality and rigor of your training program directly affects your ability to attract and retain qualified pilots.

Commercial vs. ATP: Which License Does Your Operation Require?

Not all Part 135 pilots need an Airline Transport Pilot (ATP) certificate. As a general rule, operators flying smaller aircraft typically require a commercial pilot certificate, while ATP is mandatory for larger or turbine-powered aircraft — though the specific requirement depends on aircraft type, weight, and crew configuration under the applicable FARs. Verify the requirements for your specific aircraft and operations with your FSDO.

The FAA mandates 1,500 total flight hours for full ATP qualification, including 500 hours cross-country, 100 hours night, 75 hours instrument, and 250 hours PIC. Restricted ATP (R-ATP) holders with FAA-accredited degrees may qualify at 1,000 hours. The financial stakes are significant: according to the Bureau of Labor Statistics Occupational Outlook for Airline and Commercial Pilots, airline pilots holding ATP certificates earn a median annual salary of $226,600, compared to $122,670 for commercial pilots. For many pilots, Part 135 operations represent a critical career-building stage on the path to ATP qualification.

Which Part 135 Training Components Can Be Completed Online?

This is the question most operators and training managers are trying to answer — and the one with the least consolidated guidance available. Here is a practical mapping of what can legally be delivered through FAA Part 135 online training platforms versus what must remain in-person or simulator-based.

Online-eligible components:

• Drug and alcohol awareness training (14 CFR Part 120)
• Fatigue management and rest requirement education
• Regulatory and procedural updates
• Initial and recurrent ground school knowledge components
• Crew resource management (CRM) knowledge modules
• Hazardous materials awareness training
• Security training ground components

In-person or simulator required:

• Proficiency checks under 14 CFR 135.299
• Flight training and line checks
• Emergency equipment drills requiring physical handling
• Simulator-based recurrent training where required by aircraft type

A critical distinction: Part 135 simulator requirements vary significantly by aircraft type and operation scope. Unlike Part 121, which mandates formal recurrent simulator training, some Part 135 operators may not need simulators at all — particularly those operating less complex aircraft in single-pilot configurations. Your operation’s specific requirements depend on fleet composition and crew setup.

Online training serves as the knowledge foundation that makes your proficiency checks more efficient. When pilots arrive for a 135.299 check having already completed ground school, CRM review, and regulatory updates through a structured e-learning curriculum, expensive aircraft and simulator time goes directly to the practical skill demonstration that demands it. Operators should verify specific interpretations with their FAA Flight Standards District Office (FSDO).

Online Training as Audit-Ready Documentation

One of the most underappreciated benefits of structured e-learning platforms is automatic training records management. When FAA auditors arrive, your operation needs complete, timestamped records of every training event — who completed what, when, and with what assessment results. Online platforms generate these records natively.

Contrast this with the paper-based or spreadsheet-driven tracking methods many smaller Part 135 operators still rely on. During Phase 4 of the certification process and through ongoing audits, the FAA evaluates your compliance documentation alongside your operational procedures. Platforms like CTS deliver knowledge-based modules with automatic completion tracking — explore available Part 135 training packages. Documentation quality is both a regulatory requirement and a competitive advantage.

How the January 2024 FAA Certification Process Changes Affect Part 135 Training Programs

On January 24, 2024, the FAA Flight Standards Service implemented an updated certification process designed to increase applicant readiness. This change applies across nine regulatory parts — 91K, 125, 133, 135, 137, 141, 142, 145, and 147 — signaling that the FAA is raising the bar for every category of air operator certification.

For Part 135 applicants, the practical implication is clear: your Part 135 training program must demonstrate a higher level of maturity before formal certification begins. Training curricula, documentation systems, and compliance workflows need to be substantially complete during the pre-application phase. The FAA’s five-phase certification process culminates in Phase 5 — administrative issuance of the certificate and operations specifications (OpSpecs) — but per FAA policy, the agency will not certificate an applicant until the certification project manager determines the applicant is fully capable of fulfilling responsibilities and will comply with 14 CFR.

This rewards operators who invest in structured, well-documented training platforms before they enter the certification pipeline. An online training system that can produce organized evidence of program design, curriculum alignment, and completion tracking gives your certification project manager exactly what the FAA is looking for: proof that your operation is ready — not just willing — to maintain compliance. Part 135 training program FAA approval depends on demonstrating this readiness.

Building an FAA-Approved Part 135 Training Curriculum

Developing a Part 135 training curriculum is not a creative exercise — it’s a compliance mapping exercise. Every training module must trace directly to your approved General Operations Manual (GOM) and General Maintenance Manual (GMM). If your GOM describes a procedure, your training program must teach it. If your operation changes a procedure, your curriculum must update accordingly.

Here’s a practical workflow for operators asking how to develop a Part 135 training curriculum:

• Map training modules to operational procedures — every GOM section should have a corresponding training component
• Structure initial vs. recurrent training cycles — define what new hires receive versus what returning crewmembers review, and at what intervals
• Integrate drug and alcohol program requirements under 14 CFR Part 120 into your training timeline
• Build proficiency check preparation into your ground school — NBAA provides resources for accomplishing 135.299 flight checks with local FSDOs
• Document everything — the FAA’s certification team evaluates compliance during Phase 4, and documentation is your primary evidence

Think of your Part 135 training curriculum as a living system, not a static document. Operational changes, fleet additions, regulatory updates, and audit findings all require curriculum revisions. Operators who treat their training program as compliance infrastructure — updated continuously and documented automatically — maintain a significant advantage over those who scramble to produce records when the FAA arrives.

Part 135 vs. Part 121 Training: Key Differences Operators Should Know

Operators and pilots frequently ask about the Part 135 vs Part 121 training differences in practical terms. Three distinctions matter most for training program design:

Simulator requirements: Part 121 (scheduled airlines) mandates formal recurrent simulator training. Part 135 (on-demand air carrier) requirements vary by aircraft type, complexity, and operation scope. Some Part 135 operators may not require simulators at all, depending on aircraft type and crew configuration.

Crew configuration: Part 135 includes single-pilot operations, which fundamentally changes the training scope. Single-pilot operators must address decision-making, workload management, and emergency procedures differently than multi-crew operations.

Program design flexibility: Part 121 training programs follow highly prescriptive structures. Part 135 operators have significantly more flexibility in how they design and deliver training — which is both an opportunity and a risk. More flexibility means more responsibility to demonstrate that your chosen approach meets the standard.

Both parts enforce sterile cockpit protocols. Both require ongoing compliance through recurrent training for Part 135 pilots and their Part 121 counterparts. Both demand that operators maintain comprehensive records. The difference is in how much latitude you have to structure the program — and Part 135 operators who use that latitude wisely build more efficient, targeted programs.

Frequently Asked Questions About Part 135 Training Requirements

What training is required for Part 135 operators?

Part 135 Subpart H mandates initial, transition, upgrade, recurrent, and differences training for all crewmembers. Operators must also maintain drug and alcohol programs under 14 CFR Part 120 and comply with duty time and rest requirements under 14 CFR 135.261–135.273.

Can Part 135 training be completed online?

Knowledge-based components — including drug and alcohol awareness, fatigue management, regulatory updates, and ground school — can be delivered through FAA Part 135 online training platforms. Proficiency checks under 14 CFR 135.299 and flight training must be completed in-person or in approved simulators. CTS offers online-eligible Part 135 training modules with built-in documentation.

How often do Part 135 pilots need recurrent training?

Recurrent training and proficiency checks are required at intervals specified in the operator’s FAA-approved training program. Instrument proficiency checks under 14 CFR 135.299 are a key recurring requirement that operators must schedule and document consistently.

How do Part 135 operators get FAA approval for their training program?

Part 135 training program FAA approval is part of the FAA’s five-phase certification process. Operators submit their training curriculum for evaluation during Phase 4, where the certification team verifies compliance with regulations and alignment with the operator’s GOM and operational procedures.

What is the difference between Part 121 and Part 135 training requirements?

Part 121 (scheduled airlines) mandates formal recurrent simulator training with prescriptive program structures. Part 135 (on-demand) Part 135 pilot training requirements vary by aircraft type, crew configuration, and operation scope, giving operators more flexibility in program design while requiring them to demonstrate compliance through documentation.

Staying Ahead of Part 135 Compliance With Online Training

Part 135 compliance training is a continuous obligation, not a milestone you pass once and forget. The January 24, 2024, FAA certification process changes signal a clear direction: the agency rewards operators who demonstrate readiness through structured, well-documented Part 135 training programs — and holds back those who don’t.

Online training platforms serve as compliance infrastructure. They deliver knowledge-based training at scale, generate audit-ready records automatically, and free your operation to allocate expensive simulator and aircraft time to the practical training that truly demands hands-on execution. For operators who build their Part 135 training requirements programs on this foundation, every audit becomes an opportunity to demonstrate competence rather than a scramble to produce paperwork.

For operators ready to build or upgrade their Part 135 training program, CTS offers FAA-aligned online training packages designed for exactly this purpose. Explore CTS’s FAR Part 135 training packages to streamline your operator compliance program — from recurrent ground school to drug and alcohol awareness — with built-in documentation that’s ready for your next FAA audit.