Does the FAA require a Part 135 accountable manager?

Not under that name. Accountable Manager is the ICAO and EASA term. The FAA equivalent is the accountable executive required by 14 CFR 5.25 for organisations that must have an SMS, and separately 14 CFR 119.69 requires a Part 135 certificate holder to have a Director of Operations, Chief Pilot and Director of Maintenance. Operators using the phrase are usually referring to one of those two things.

Who can be the accountable executive under 14 CFR part 5?

Under 5.25(a) it must be someone who, irrespective of other functions, is the final authority over operations conducted under the certificate, controls the financial resources and the human resources required for those operations, and retains ultimate responsibility for their safety performance. In practice that is the owner, president or accountable head of the business — not a contractor.

Can an accountable executive be outsourced or hired fractionally?

No, and this is worth being blunt about. The designation in 5.25(a) turns on control of the operation's financial and human resources, which an external part-time appointee does not have. What can be engaged fractionally is the management personnel the accountable executive designates under 5.25(c) to build and run the SMS on their behalf.

When does a Part 135 operator have to comply with the SMS rule?

The FAA published the final rule on 26 April 2024. Operators certificated before 28 May 2024 have 36 months to develop and implement their SMS, a deadline of 28 May 2027. Applicants already in the initial certification phase before that date work to the same deadline, and applications submitted on or after 28 May 2024 must have an SMS upon certification.

What is the difference between an accountable manager and a director of operations?

They answer to different rules and different scopes. The accountable executive under part 5 owns safety accountability for the organisation as a whole and signs the safety policy. The Director of Operations under 119.69 owns operational control of the flying — dispatch, release, crew standards, and the relationship with the responsible Flight Standards office. One operator commonly has both, and they are not the same person.

Who builds the SMS if the accountable executive cannot be outsourced?

The management personnel designated under 5.25(c): the people who coordinate SMS implementation and integration, facilitate hazard identification and risk analysis, monitor the effectiveness of risk controls, run safety promotion and report to the accountable executive on performance. That role is routinely filled fractionally or on an interim basis, particularly for the build phase.

We hold an EASA AOC as well. Does one person cover both roles?

Often yes in substance, but the two frameworks document it differently, and the paperwork is where multi-registry operators come unstuck. A leader who has held an EASA Accountable Manager post and worked inside a part 5 SMS can map one onto the other; someone who has only ever worked one side tends to assume the frameworks line up more neatly than they do.

Role guide

The Part 135 accountable manager, and what the FAA actually requires

This is one of the few pages on this site that starts by correcting the search term. "Accountable manager" is the ICAO and EASA title; the FAA rule that now applies to Part 135 says "accountable executive", and the distinction changes which parts of the job you can hire out.

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The title you searched for is not the title in the rule

If you operate under an EASA, UK CAA, Transport Canada or other ICAO-aligned framework, Accountable Manager is a defined post: the person with corporate authority for ensuring the operation is financed and carried out to the required standard. The term is embedded in those regulations and in the language of anyone who has worked inside them.

The FAA does not use it. Under 14 CFR part 5, the SMS rule, the equivalent post is the accountable executive — and under 14 CFR 119.69 the named Part 135 management positions are Director of Operations, Chief Pilot and Director of Maintenance. There is no FAA position called Accountable Manager for a Part 135 certificate holder.

This matters practically, not pedantically. Operators searching for a Part 135 accountable manager are usually asking one of two very different questions: who has to sign for safety at the top of this organisation, or who is going to build and run the SMS that the signature attests to. The first is largely not outsourceable. The second very much is, and it is where most of the demand actually sits.

What 14 CFR part 5 actually requires

The FAA published the SMS final rule on 26 April 2024, extending part 5 beyond Part 121 to Part 135 certificate holders, 91.147 air tour operators with a letter of authorisation, and certain Part 21 certificate holders. It is the largest structural change to Part 135 oversight in years, and it has a date attached.

Under 5.25(a), an organisation required to have an SMS must identify an accountable executive who — irrespective of any other function they hold — is the final authority over operations conducted under the certificate, controls the financial resources for those operations, controls the human resources for them, and retains ultimate responsibility for their safety performance. Under 5.25(b) that person must ensure the SMS is properly implemented and performing, develop and sign the safety policy, communicate it through the organisation, review it to keep it relevant, and regularly review safety performance and direct action where it falls short.

Read the four criteria in 5.25(a) together and the conclusion is unavoidable: this is the owner, the president or the accountable head of the business. Someone engaged part-time from outside does not control the financial and human resources of the operation, so they cannot satisfy the designation however capable they are. The accountable executive is the one aviation leadership role that genuinely cannot be engaged fractionally — and anyone offering to be your accountable executive on a retainer is telling you they have not read 5.25.

Operators certificated before 28 May 2024 — 36 months to develop and implement an SMS — a deadline of 28 May 2027, per the FAA's published implementation timeline.
New applications submitted on or after 28 May 2024 — SMS required upon certification, alongside everything else in the certification process.
Applicants already in the initial certification phase before 28 May 2024 — The same 28 May 2027 date as existing certificate holders.
Part 91K and other voluntary participants — Fractional-ownership programmes are eligible for the FAA's voluntary SMS programme rather than mandated under this rule — a growing route to a part 5 conformant system.

What you can engage fractionally — and it is most of the work

Section 5.25(c) is the part operators tend to skip, and it is the one that answers the hiring question. The accountable executive must designate sufficient management personnel who, on their behalf, coordinate the implementation, maintenance and integration of the SMS across the organisation; facilitate hazard identification and safety risk analysis; monitor the effectiveness of safety risk controls; ensure safety promotion; and report regularly to the accountable executive on how the SMS is performing and where it needs to improve.

That is a job description, and nothing in it requires the person to control the company's finances or headcount. It is the safety manager function — the work of actually building a part 5 conformant system: the safety policy the accountable executive signs, the hazard reporting process, the risk register, the safety assurance programme, the performance measures, the training and promotion. For most Part 135 operators it is a substantial project followed by a modest ongoing load, which is the exact profile a fractional engagement fits.

The same is true of the three named management positions. A Director of Operations, Chief Pilot or Director of Maintenance can be engaged fractionally or on an interim basis, because 119.69 asks for qualified personnel serving in the positions — unlike 119.65 for Part 121, it does not carry the full-time wording. So the honest division is this: your accountable executive is your own senior leader and always will be. Nearly everything that makes their signature defensible can be brought in.

The May 2027 problem is a resourcing problem

Every Part 135 certificate holder that existed before 28 May 2024 is working to the same deadline, which means the demand for people who can build a part 5 SMS is concentrated into the same window. That is a straightforward supply problem, and it gets worse the closer the date comes.

The operators who will find this comfortable are the ones treating it as a project with an owner rather than a document to be procured. An SMS that exists as a binder does not survive contact with a safety assurance review; what part 5 asks for is a system that is implemented and performing, with the accountable executive regularly reviewing safety performance and directing action when it is substandard. Building that takes someone who has done it, working inside the operation, for a period measured in months.

Very few Part 135 operators need that person permanently. Almost all of them need that person now. That gap — a serious, time-boxed leadership job that does not justify a permanent executive hire — is what fractional and interim engagement was built for.

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Flight Level Partners is the curated directory of fractional and interim aviation leaders. Every listing states the certifications, frameworks and operations behind it — so you can vet fast without trading away rigor.

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Frequently asked questions

Does the FAA require a Part 135 accountable manager?: Not under that name. Accountable Manager is the ICAO and EASA term. The FAA equivalent is the accountable executive required by 14 CFR 5.25 for organisations that must have an SMS, and separately 14 CFR 119.69 requires a Part 135 certificate holder to have a Director of Operations, Chief Pilot and Director of Maintenance. Operators using the phrase are usually referring to one of those two things.
Who can be the accountable executive under 14 CFR part 5?: Under 5.25(a) it must be someone who, irrespective of other functions, is the final authority over operations conducted under the certificate, controls the financial resources and the human resources required for those operations, and retains ultimate responsibility for their safety performance. In practice that is the owner, president or accountable head of the business — not a contractor.
Can an accountable executive be outsourced or hired fractionally?: No, and this is worth being blunt about. The designation in 5.25(a) turns on control of the operation's financial and human resources, which an external part-time appointee does not have. What can be engaged fractionally is the management personnel the accountable executive designates under 5.25(c) to build and run the SMS on their behalf.
When does a Part 135 operator have to comply with the SMS rule?: The FAA published the final rule on 26 April 2024. Operators certificated before 28 May 2024 have 36 months to develop and implement their SMS, a deadline of 28 May 2027. Applicants already in the initial certification phase before that date work to the same deadline, and applications submitted on or after 28 May 2024 must have an SMS upon certification.
What is the difference between an accountable manager and a director of operations?: They answer to different rules and different scopes. The accountable executive under part 5 owns safety accountability for the organisation as a whole and signs the safety policy. The Director of Operations under 119.69 owns operational control of the flying — dispatch, release, crew standards, and the relationship with the responsible Flight Standards office. One operator commonly has both, and they are not the same person.
Who builds the SMS if the accountable executive cannot be outsourced?: The management personnel designated under 5.25(c): the people who coordinate SMS implementation and integration, facilitate hazard identification and risk analysis, monitor the effectiveness of risk controls, run safety promotion and report to the accountable executive on performance. That role is routinely filled fractionally or on an interim basis, particularly for the build phase.
We hold an EASA AOC as well. Does one person cover both roles?: Often yes in substance, but the two frameworks document it differently, and the paperwork is where multi-registry operators come unstuck. A leader who has held an EASA Accountable Manager post and worked inside a part 5 SMS can map one onto the other; someone who has only ever worked one side tends to assume the frameworks line up more neatly than they do.