Deadlines
The FAA Part 5 SMS deadline: 28 May 2027
Two dates matter in the expanded SMS rule. One has already passed. The other is the one you will be measured against.
The timeline
| Date | What was or is due |
|---|---|
| 26 April 2024 | Final rule published, extending 14 CFR Part 5 to Part 135, § 91.147 and certain Part 21 holders. |
| 28 May 2024 | Rule effective. |
| 28 November 2024 | SMS implementation plan due to the FAA for review — six months after the effective date. |
| Through 2025 | FAA review and approval of submitted implementation plans. |
| 28 May 2027 | SMS fully implemented and a Declaration of Compliance submitted — thirty-six months after the effective date. |
What "fully implemented" means
This is the part that catches people. The 2027 date is not a deadline to have a plan or to have a manual. It is the date by which the system described in your implementation plan must be operating, and by which you must attest to that in a Declaration of Compliance.
An SMS that was switched on the month before you file cannot demonstrate the thing Part 5 actually asks for: that hazards are being identified, that risk is being assessed and controlled, and that you are monitoring whether those controls work. Safety assurance is inherently retrospective. It needs a run of history behind it.
What happens if you miss it
Part 5 compliance is a condition of your certificate, not a best practice. Failing to implement an SMS by the compliance date exposes you to enforcement action and to certificate action. Practically, it also raises your profile with your local FSDO in a way most operators would prefer to avoid.
Note too that this cuts commercially. Charter brokers, corporate flight departments and insurers increasingly ask about SMS maturity during vendor selection, and the answer "we are working on it" is worth less every quarter between now and the deadline.
Has the deadline moved?
As of this writing, no. The 28 May 2027 compliance date stands as published. We will update this page if that changes, but planning on an extension that has not been announced is not a strategy.
Where to go next
See whether it fits your operation
Twenty minutes, no card. Tell us what certificate you hold and where your implementation plan stands, and we will show you the parts that apply to you.