Part 135 drone delivery

Why delivery for compensation needs Part 135

Part 107 cannot carry a paid delivery business beyond visual line of sight. Under 14 CFR 107.205 the FAA will not waive the visual line of sight rule (107.31) or the moving vehicle rule (107.25) to allow the carriage of another person's property for compensation or hire. The FAA states that Part 135 certification is the only path for small drones to carry the property of another for compensation BVLOS.

The FAA says delivery operators must obtain a Part 135 certificate and airspace authorizations before they begin operations, and must also comply with state and local requirements, inform the local community, set up their hub and delivery infrastructure, and respond to public inquiries. An environmental assessment under the National Environmental Policy Act (NEPA) is required before the certificate is issued. The FAA does not choose hub locations: the operator does, in line with local land use and zoning rules.

The FAA issues four kinds of Part 135 certificate, based on the services you plan and where you will fly:

• Single-pilot operator: one pilot for all Part 135 operations
• Single Pilot in Command: one pilot in command and up to three second-in-command pilots, with limits on aircraft size and scope
• Basic operator: at most five pilots (including second in command) and five aircraft
• Standard operator: no limit on size or scope, but each type of operation must be separately authorized

The certification process: five phases, three gates

Drone applicants use the same Part 135 process as crewed operators, adapted with drone-specific focus items. Every item in a phase must be completed before passing the next gate.

From 30 September 2026 the FAA is moving Part 135 applications from its Safety Assurance System (SAS) to Aviation Integrated Safety (AIS) Services. Some FAA material may still refer to SAS while it is updated, so check the FAA's certification page for the current system before you start.

The FAA does not publish a standard timescale for drone certification. When you start, the FAA runs a resource check called the Certification Service Oversight Process, which decides whether your project begins or goes on a wait list. In its Part 108 proposal the FAA noted that the first drone Part 135 certifications took years, while more recent applicants were certificated much more quickly. Plan for exemptions and the environmental review to run alongside the phases below.

• Phase 1, pre-application: submit FAA Form 8400-6 (Pre-application Statement of Intent) to your local Flight Standards District Office. Expect to provide a concept of operations (purpose, scope, areas of operation and the aircraft's airworthiness, performance and capabilities), and evidence of an airworthiness certificate or a petition for exemption under 49 U.S.C. 44807. You and your key management personnel attend a pre-application meeting. This completes Gate 1.
• Phase 2, formal application: a formal application letter, schedule of events, compliance statement, manuals and training curricula where your scope requires them, management résumés, purchase or lease documents and proposed operations specifications. It ends with the formal application meeting and Gate 2.
• Phase 3, design assessment: the FAA reviews your manuals and documents in depth for regulatory compliance and safe operating practice.
• Phase 4, performance assessment: the FAA checks that your training and procedures work in practice, including an on-site facility inspection, validation testing of flight and maintenance procedures, and practical tests for pilots in command and check pilots. This completes Gate 3.
• Phase 5, administrative functions: the FAA issues the certificate and operations specifications.

Exemptions, manuals and management personnel

Many Part 135, 91 and 61 rules were written for crewed aircraft, so drone applicants petition for exemption from the ones they cannot meet (the FAA gives the example of carrying flight manuals on board). If your aircraft has no airworthiness certificate, you can petition for exemption under 49 U.S.C. 44807, which lets the FAA assess certain drones case by case on risk. Petitions are filed on the public docket under 14 CFR Part 11, and exemptions already issued to drone air carriers can be read on regulations.gov.

Before certification you must show you meet the reporting requirements in your exemption's conditions and limitations, such as an area of operations plan, ground risk assessment, communication services assessment and collision avoidance strategy. Validation testing may need its own relief, because an exemption issued for use with an air carrier certificate may not be valid until the certificate is issued. A drone under 55 pounds may need a Part 107 waiver (for example for BVLOS) to fly the tests. A heavier one may need a type certificate, a 44807 exemption or a special airworthiness certificate.

Under 14 CFR 119.69, a Part 135 certificate holder with more than one pilot needs a Director of Operations, Chief Pilot and Director of Maintenance (or approved equivalents), each qualified and familiar with the regulations, your operations specifications and your manual. The FAA can approve different or fewer positions for a particular operation, and drone applicants can submit deviation requests for proposed managers who do not meet the traditional requirements. If you intend to carry hazardous materials, the FAA expects an approved hazardous materials training program and an accepted manual, and your operations specifications will state whether you may carry them.

The FAA's guidance on 44807 petitions lists what a petition should contain, where relevant:

• Concept of operations and operations manual
• Emergency procedures and checklists
• Maintenance manual and training program
• Flight history (hours, cycles, accidents)
• A safety risk analysis, which the FAA requires for complex proposals including package delivery, Part 135 operations and BVLOS

Part 108 and drone delivery: where it stands

The FAA and the Transportation Security Administration (TSA) published a proposed rule, Normalizing Unmanned Aircraft Systems Beyond Visual Line of Sight Operations, in August 2025. It would create a new Part 108 with a package delivery route designed for drones, so operators would no longer need exemptions from Part 135, 91 and 61 rules. As proposed, smaller delivery operations could run under a permit (aircraft up to 55 pounds, up to 100 aircraft, lower population density areas, no hazardous materials), while larger or more complex delivery, including in denser areas, would need a Part 108 operating certificate with a safety management system and a training program.

The proposal would also state that Parts 119 and 135 do not apply to operations under Part 108, and the FAA said it expects existing Part 135 drone delivery operations to move to Part 108 within a reasonable time after the rule takes effect. The FAA reopened the comment period in January 2026.

As of October 2026 no final rule has been published in the Federal Register, so Part 135 remains the route for paid drone delivery. Check the Federal Register for the current position before you plan around Part 108, and expect the details of any final rule to differ from the proposal.

What a consultant does, and what to ask before hiring

A consultant helps you shape the concept of operations, plan the exemption petitions, write the manuals, training curricula and compliance statement, prepare your management team for FAA meetings and inspections, and respond to FAA questions through each phase. They cannot issue a certificate or exemption or promise a date: the FAA decides. Operators can compare vetted consultants on DOC, where regulator experience is shown as verified only where it has been evidenced.

• Which phases of a Part 135 certification have you supported, and was it for a drone operator?
• Have you drafted 44807 petitions and petitions for exemption from Part 135, 91 or 61 rules?
• Will you write our manuals and training curricula, or review drafts we write?
• How will you prepare our management personnel and pilots for the meetings, inspections and practical tests?
• How would our plan change if Part 108 becomes final during the project?

Common mistakes

Delays usually come from sequencing and gaps in the paperwork. Watch for these:

• Assuming a Part 107 BVLOS waiver can cover paid delivery (107.205 rules this out)
• Arriving at pre-application without a clear concept of operations or an airworthiness route for the aircraft
• Filing exemption petitions late, when the FAA must issue them before it can issue the certificate
• Forgetting that validation testing may need separate relief
• Naming managers who do not meet 119.69 without asking for a deviation or approval
• Leaving the environmental review, local approvals and community engagement until the end