The FAA SMS Declaration of Compliance

What it is

The Declaration of Compliance is the statement you submit to the FAA confirming that your safety management system meets the requirements of 14 CFR Part 5 and is implemented. For Part 135 and § 91.147 operators it is due no later than 28 May 2027.

It is the culmination of the process, not a step within it. You develop the SMS, you implement it, you operate it, and then you declare. Filing before the system is genuinely running inverts that order, and it is an attestation — so getting it wrong is not a paperwork problem.

The question behind the question

An implementation plan describes a system you intend to run. A Declaration asserts that the system exists and functions. The practical test is simple: if an inspector asked you to show how a specific hazard was identified, assessed, controlled and verified, could you?

For most small operators the honest answer, before they put a system in place, is that some of it lives in email, some in a spreadsheet, some in a filing cabinet, and some only in the chief pilot's memory. That is the gap the Declaration exposes.

Evidence that should exist by the time you file

Safety policy (§ 5.21–5.27)

• A safety policy, approved and signed by the accountable executive, with a date.
• A named accountable executive and a documented designation.
• Defined safety accountabilities for management and staff.
• An emergency response plan, current and distributed.
• Evidence the policy reached your people — and, ideally, that they acknowledged it.

Safety risk management (§ 5.51–5.55)

• A hazard reporting process your people demonstrably use, including a confidential route.
• A body of actual reports across a meaningful period — not three filed the week before you declared.
• Risk assessments using a defined methodology; the FAA 5×5 matrix is the conventional choice.
• Recorded risk controls with an owner, and residual risk scored after the control was applied.

Safety assurance (§ 5.71–5.75)

• Evidence you monitored whether controls actually worked — this is the element most often missing.
• Safety performance monitoring against something you defined in advance.
• A record of hazards closed, and on what basis.

Safety promotion (§ 5.91–5.97)

• Safety communication that went out, with dates.
• Evidence of receipt where it matters — acknowledgment tracking rather than "we emailed everyone".

Producing it on demand

When you are preparing to declare — or responding to an inspector afterwards — you need to get the record out of the system and into a form you can hand over. Safety reports and their assessments export to PDF over any date range here, with reporter names and tail numbers redacted by default so you can share evidence without compromising the confidentiality that made people report in the first place.