As an aviation safety manager or accountable executive, ensuring compliance with the Federal Aviation Administration’s (FAA) Safety Management System (SMS) requirements under 14 CFR Part 5 is critical to maintaining operational safety and regulatory adherence.
A key component of this process is submitting a Declaration of Compliance (DOC) to the FAA, which formally affirms that your organization has developed and implemented an SMS that meets Part 5 standards.
This guide provides a comprehensive overview of the DOC requirements, actionable steps for submission, and best practices to streamline the process. Whether you’re a Part 135 operator, Part 91.147 air tour operator, or Part 21 certificate holder, this article will help you navigate the compliance landscape with confidence.
The Declaration of Compliance is a legal document submitted to the FAA to confirm that your aviation organization has developed and implemented an SMS in accordance with 14 CFR Part 5. This document serves as a formal commitment to safety standards, providing accountability and assurance to the FAA that your organization operates under a structured, proactive approach to safety management.
The DOC is not a one-size-fits-all statement but a tailored affirmation that reflects your organization’s adherence to the four pillars of SMS: Safety Policy, Safety Risk Management (SRM), Safety Assurance (SA), and Safety Promotion. It is typically signed by the accountable executive, underscoring their responsibility for the SMS’s performance.
Submitting a DOC is a regulatory requirement for certain aviation organizations, including:
The DOC signals to the FAA that your SMS is fully implemented and operational. Once submitted, the FAA’s Certificate Management Office (CMO) updates your organization’s status in its internal database, noting SMS compliance. Routine FAA surveillance then validates your SMS performance over time.
Beyond compliance, a robust SMS enhances safety performance, improves resource allocation, fosters a stronger safety culture, and aligns your organization with international standards, such as those outlined in the International Civil Aviation Organization (ICAO) Annex 19.
To prepare a compliant DOC, aviation safety managers and accountable executives must ensure their SMS meets the following Part 5 requirements:
Your organization must have a fully developed and operational SMS that aligns with the four components of Part 5:
The accountable executive is ultimately responsible for ensuring the SMS is implemented and performing across the organization. The DOC must be signed by this individual (or another senior management member with equivalent authority) to affirm compliance.
Your SMS must include documented processes for SRM, SA, and safety reporting. You should also maintain evidence of:
The FAA’s 2024 SMS Final Rule, effective May 28, 2024, sets specific implementation deadlines. For example:
Part 135 operators and Part 91.147 LOA holders: Must submit a DOC by May 28, 2027 (36 months from the effective date).
Part 21 certificate holders: Deadlines vary based on certification date, with some requiring implementation plans by December 27, 2024, and full SMS implementation by December 27, 2025.
Always verify your organization’s specific deadline based on its regulatory category.
Submitting a DOC is a straightforward but critical process. Follow these steps to ensure compliance:
Before drafting the DOC, ensure your SMS is fully implemented. This includes:
Leverage FAA resources, such as Advisory Circular (AC) 120-92D and Notice 8900.700, for guidance on SMS development.
The DOC should include:
Consult FAA Notice 8900.700 for a detailed list of required DOC content.
Conduct an internal review to ensure your SMS meets all Part 5 requirements. Verify that:
Consider engaging expert consultants, such as those from JDA Consulting, to validate your SMS and streamline compliance.
Submit the DOC to your local FAA Certificate Management Office (CMO) in a form and manner acceptable to the FAA. This typically involves:
Ensure submission aligns with your organization’s compliance deadline (e.g., May 28, 2027, for Part 135 operators).
After submission, the FAA will update your organization’s status in its database and conduct routine surveillance to validate SMS performance. Be prepared to:
To ensure a smooth compliance process, consider these best practices:
Smaller organizations may struggle with the resources needed for SMS implementation. Solution: Scale your SMS to match your organization’s size and complexity, as permitted by Part 5, and prioritize cost-effective tools like SMS Pro software. SMS Pro subscriptions include regulatory compliant templates and configurable processes that are less expensive than human resources and less error prone.
Navigating Part 5 requirements can be daunting. Solution: Consult FAA guidance materials (e.g., AC 120-92D) and consider external consultants for tailored support. SMS Pro tech support is less expensive than external consultants, and support fees are included in the subscription.
Demonstrating ongoing SMS performance can be challenging. Solution: Establish robust SA processes, including regular audits and corrective action tracking, to show continuous improvement. SMS Pro automates these documentation burdens.
Submitting a Declaration of Compliance for FAA Part 5 is a pivotal step in demonstrating your organization’s commitment to aviation safety. By developing a robust SMS, meeting Part 5 requirements, and following the submission process outlined above, you can achieve compliance and enhance your safety culture.
For additional support, explore FAA resources like Advisory Circular 120-92D and Notice 8900.700, or contact your local CMO. If you need expert assistance, organizations like JDA Consulting or SMS Pro's Aviation Safety Management Solutions can provide tailored guidance to streamline your SMS implementation.
Take the first step today—review your SMS, engage your team, and prepare your DOC to ensure compliance by your deadline. A proactive approach to SMS not only meets regulatory requirements but also positions your organization as a leader in aviation safety.
Contact the FAA SMS Program Office at 9-NATL-SMS-ProgramOffice@faa.gov or visit www.faa.gov for more information. Stay ahead of the curve and make safety your organization’s top priority.
If you need reputable software tools to manage Part 5 SMS compliance, SMS Pro can help.
Last updated June 2026.