The New SMS Rule: One Year Later
May 28, 2025, marks one year since the Federal Aviation Administration (FAA) published significant updates to Title 14, Code of Federal Regulations (14 CFR) part 5 and Advisory Circular (AC) 120–92D. These revisions, long anticipated and widely discussed, expanded the requirement for Safety Management Systems (SMS) beyond 14 CFR part 121 air carriers to include 14 CFR part 135 commuter and on‑demand operators, 14 CFR part 91.147 air tour operators, and specific 14 CFR part 21 design and production approval holders. Now, as we reflect on this milestone, it’s an ideal time to assess the impacts, evaluate new resources, and clarify essential next steps.
Expanded SMS Scope: What’s Changed?
The updated rule was designed to align more closely with international standards, particularly the International Civil Aviation Organization’s (ICAO) Annex 19 to the Convention on International Civil Aviation, and foster a proactive approach to aviation safety across a broader spectrum of the aviation industry. Previously, mandatory SMS compliance primarily applied to larger air carriers under 14 CFR part 121. The expansion brings smaller, often resource‑limited operators as well as aircraft and component manufacturers, into the fold.
AC 120–92D accompanied these regulatory changes to provide comprehensive, practical tools and scalable guidance to support organizations of various sizes in implementing their SMS. The revised AC’s notable enhancements include user‑friendly templates, tailored worksheets for risk assessments, and clear recommendations for integrating SMS components within existing operational frameworks.
Early Impacts: Safety Enhancements Taking Shape
One year into the expanded SMS requirement, comprehensive data from newly regulated sectors—such as part 135 operators, part 91.147 air tour operators, and part 21 manufacturers—remains limited; however, insights from legacy part 121 air carriers, who have operated under mandatory SMS requirements since 2015, offer a strong indication of what newer adopters might expect.
Part 121 air carrier experience consistently shows SMS enhances hazard identification, strengthens proactive risk mitigation, and increases frontline employee engagement—leading to more frequent and higher‑quality hazard reporting. These improvements have helped foster greater transparency and more proactive safety cultures.
Although outcomes from newly covered sectors will take time to assess, SMS’s demonstrated success in part 121 operations provides a solid foundation for high expectations. These precedents suggest that, as operators and manufacturers apply AC 120–92D’s non‑regulatory guidance to structure risk‑management processes, they are well positioned to achieve similar gains in safety performance and support broader industrywide SMS adoption.
New Tools, Guides, and Industry Insights
Over the past year, regulators and industry stakeholders have introduced a range of new resources to support organizations navigating SMS implementation under the expanded rule.
· FAA SMS Portal: The FAA has enhanced its public‑facing SMS portal with updated checklists, implementation tools, and guidance tailored to the needs of parts 135, 91.147, and 21 organizations.
· Updated Software Capabilities: Many SMS software platforms have been refined to better align with the revised regulatory requirements, offering features assisting with code‑of‑ethics documentation, operational interface assessments, and streamlined compliance tracking.
· Improved SMS Tools and Templates: Many operators have access to refined software platforms and practical templates that align with the latest regulatory guidance, supporting tasks such as Safety Risk Management (SRM), operational interface analysis, and documentation tracking.
· Operator‑shared Best Practices: Lessons learned from early adopters—shared through webinars, conferences, and safety forums—emphasize the value of employee engagement, targeted safety training, and integrating SMS principles into daily operations.
· Voluntary Guidance for Part 91 Operators: Although part 91 business aircraft operators are not required to implement SMS under the new rule, the National Business Aviation Association (NBAA) continues to encourage proactive safety practices. Resources such as Five Simple Steps to a Safer Small Flight Operation offer clear, actionable advice for fostering a safety culture, using flight risk assessments effectively, and building scalable safety processes in smaller operations.
Together, these tools and shared experiences reflect a growing collaborative effort to help organizations of all sizes navigate SMS implementation and enhance their overall safety performance.
One Year In: Critical Implementation Milestones
The anniversary also highlights critical compliance milestones. Organizations now find themselves halfway or one-third through their implementation timelines:
Part 135 and Part 91.147
o These operators have until May 28, 2027 (approximately 24 months from this writing), to implement their SMS fully and submit a declaration of compliance.
Part 21 Manufacturers
o Those holding production certificates issued on or before May 28, 2024, had until November 28, 2024, to submit implementation plans, and must achieve full SMS implementation by May 28, 2027.
o Those applying after May 28, 2024, must fully implement SMS within 36 months after submitting their implementation plan.
Part 121 Operators and Accepted Voluntary SMS Program Participants with Existing SMS Programs Approved before May 28, 2024
o These must update their SMS according to the new rule by May 28, 2025.
Considering the timelines, all organizations should urgently assess their current compliance status and accelerate their implementation activities accordingly—waiting too long increases the risk of regulatory non‑compliance and could lead to safety gaps.
Immediate Next Steps for Affected Organizations
If your organization falls under the newly expanded SMS requirements, here are recommended next steps for affected organizations to ensure timely compliance and effective implementation.
Perform a Gap Analysis: Assess your current practices against the updated AC 120–92D to identify what remains to be accomplished.
Clarify Roles and Responsibilities: Define clear accountability structures to ensure visible commitment from senior leadership.
Employee Engagement: Prioritize frontline staff involvement in hazard reporting and safety training programs to cultivate a proactive safety culture.
Leverage Industry Resources: Use FAA‑provided templates, operator‑shared insights, and software tools tailored to support SMS implementation.
Enhance Documentation and Reporting: Initiate robust documentation of safety management activities to demonstrate regulatory compliance and provide data for continuous improvement.
Who Should Act Now?
Part 135 Commuter and On‑demand Operators: Often resource‑limited, these operators should leverage available guides and templates immediately.
Part 91.147 Air Tour Operators: These organizations must urgently address SMS components such as hazard reporting and SRM, areas typically less formalized previously.
Part 21 Design and Production Approval Holders: Focus on integrating SMS seamlessly within existing quality management frameworks to meet longer‑term compliance deadlines efficiently.
Looking Ahead: Continuing the Safety Journey
The first anniversary of the updated part 5 and AC 120–92D highlights a significant milestone—but it’s only one step in an ongoing journey. The aviation industry must continue to collaborate, sharing insights and best practices to drive innovation and improve safety. Early indicators are positive, suggesting the potential for long‑term enhancements to aviation safety culture and reduced operational risks.
Operators and manufacturers should use this anniversary as a catalyst to accelerate their SMS integration. Through industry collaboration, thoughtful implementation, and continued refinement, SMS promises to become an increasingly powerful tool for enhancing safety across the aviation sector.
For more SMS insights and best practices, explore our SMS Quick Takes blog series.
Do you have questions or concerns about SMS? Share them with us!
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