Rules guide for charter operators

Part 135 Crew Scheduling: Flight Time, Duty & Rest Rules

The flight time, duty and rest limits in Part 135, Subpart F, in plain language with the regulation behind each one, and how CrewBench can help you check them before you confirm crew.

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Part 135 flight time, duty and rest limits

Which rules apply depends on the operation (§135.261). §135.267 covers one- and two-pilot crews, and §135.269 three- and four-pilot crews, in any operation that is not a scheduled passenger-carrying operation, which includes most on-demand charter. Scheduled passenger-carrying operations follow §135.265, as do other operators who elect it through an operations specification amendment; operations conducted solely within Alaska follow §§135.267 and 135.269 unless the operator makes that election. Flight attendants follow §135.273, and helicopter emergency medical evacuation service (HEMES) has additional limits in §135.271, which this summary does not cover.

One- and two-pilot crews, unscheduled operations — §135.267

LimitWhat it coversRule
8 hoursFlight time for a one-pilot crew in any 24 consecutive hours, including any other commercial flying by the crewmember§135.267(b)(1)
10 hoursFlight time for a two-pilot crew in any 24 consecutive hours, including any other commercial flying by the crewmember§135.267(b)(2)
10 hoursConsecutive rest that each assignment under §135.267(b) must provide during the 24 hours before its planned completion time§135.267(d)
14 hoursAlternative to the 24-hour limits above: flight time may exceed them if it falls within a regularly assigned duty period of no more than 14 hours that is immediately preceded and followed by at least 10 consecutive hours of rest, with duty and rest periods totalling 24 hours. Flight time in that duty period, including other commercial flying, is still limited to 8 hours (one pilot) or 10 hours (two pilots).§135.267(c)
11 / 12 / 16 hoursRest required before the next flight assignment when a daily flight time limit was exceeded because of circumstances beyond the control of the certificate holder or crewmember (such as weather): by up to 30 minutes / by more than 30 and up to 60 minutes / by more than 60 minutes§135.267(e)
500 / 800 / 1,400Total flight time in all commercial flying per calendar quarter / per two consecutive calendar quarters / per calendar year§135.267(a)
13 × 24 hoursRest periods of at least 24 consecutive hours each that the certificate holder must provide to each flight crewmember in every calendar quarter§135.267(f)

Three- and four-pilot crews, unscheduled operations — §135.269

LimitWhat it coversRule
10 hoursConsecutive rest immediately before the assignment§135.269(b)(1)
8 hoursFlight deck duty in any 24 consecutive hours§135.269(b)(2)
18 / 20 hoursDuty in any 24 consecutive hours, three-pilot / four-pilot crew§135.269(b)(3)
12 / 16 hoursTime aloft during those maximum duty hours, three-pilot / four-pilot crew§135.269(b)(4)
12 hoursRest after the assignment is completed§135.269(b)(6)
16 hoursRest before the next duty period when the daily flight deck duty limit was exceeded by more than 60 minutes because of circumstances beyond the control of the certificate holder or crewmember§135.269(c)
500 / 800 / 1,400Total flight time in all commercial flying per calendar quarter / per two consecutive calendar quarters / per calendar year§135.269(a)
13 × 24 hoursRest periods of at least 24 consecutive hours each that the certificate holder must provide to each flight crewmember in every calendar quarter§135.269(d)

The assignment must also provide adequate sleeping facilities on the aircraft for the relief pilot, and the crew must meet the composition and qualification requirements in §135.269(b)(7) and (b)(8).

Scheduled operations — §135.265

LimitWhat it coversRule
1,200 / 120 / 34Total flight time in all commercial flying per calendar year / per calendar month / in any 7 consecutive days§135.265(a)(1)–(3)
8 hoursFlight time in any 24 consecutive hours, one-pilot crew§135.265(a)(4)
8 hoursFlight time between required rest periods, two-pilot crew§135.265(a)(5)
9 / 10 / 11 hoursScheduled consecutive rest required during the 24 hours before the scheduled completion of any flight segment, for less than 8 / 8 to less than 9 / 9 or more hours of scheduled flight time§135.265(b)
8 / 8 / 9 hoursMinimum reduced rest in place of 9 / 10 / 11 hours, allowed only if the crewmember is then given a rest of at least 10 / 11 / 12 hours beginning no later than 24 hours after the reduced rest began§135.265(c)
24 hoursConsecutive hours free of all further duty during any 7 consecutive days, for crewmembers engaged in scheduled air transportation§135.265(d)

Flight attendants — §135.273

LimitWhat it coversRule
14 hoursLongest scheduled duty period, unless additional flight attendants are assigned as in the next row§135.273(b)(1)
16 / 18 / 20 hoursLongest scheduled duty period with at least 1 / 2 / 3 flight attendants beyond the minimum complement. 20 hours only if the duty period includes a flight that lands or takes off outside the 48 contiguous states and the District of Columbia.§135.273(b)(4)–(6)
9 hoursScheduled rest after a duty period of 14 hours or less; may be 8 hours if a rest of at least 10 hours is scheduled to begin no later than 24 hours after the reduced rest began§135.273(b)(2)–(3)
12 hoursScheduled rest after a duty period of more than 14 hours; may be 10 hours if a rest of at least 14 hours is scheduled to begin no later than 24 hours after the reduced rest began, and then no duty period over 14 hours in the 24 hours after the reduced rest began§135.273(b)(7)–(9)
24 hoursConsecutive hours free of all further duty during any 7 consecutive calendar days§135.273(b)(13)

Instead of these limits, a certificate holder may apply the flight crewmember limits of Subpart F to flight attendants under written procedures approved by the FAA and referenced in its operations specifications (§135.273(c)).

Where charter schedules usually go wrong

  1. Other commercial flying counts. The 8- and 10-hour limits apply to the assigned flight time when added to any other commercial flying by the crewmember (§135.267(b) and (c)), and the quarterly and annual totals count all commercial flying (§135.267(a)). A freelance pilot who flew for another operator earlier in the day brings those hours with them, so ask, and keep a record.
  2. Rest is measured back from the planned completion. For assignments under §135.267(b), the 10 consecutive hours of rest must fall within the 24 hours before the assignment’s planned completion time (§135.267(d)). If an added leg or a later return moves the planned completion, that 24-hour window moves too, so check the pilot again.
  3. Positioning is not rest. Transportation that is not local in character, which the certificate holder requires of a crewmember and provides, to the airport where they will serve as a crewmember or from the airport where they were relieved back to their home station, is not part of a rest period (§135.263(c); for flight attendants, §135.273(b)(12)).
  4. No duty during required rest. A certificate holder may not assign a flight crewmember any duty with the certificate holder during a required rest period (§135.263(b)).
  5. The quarterly rest periods are easy to lose track of. Each flight crewmember must be given at least 13 rest periods of at least 24 consecutive hours in every calendar quarter (§135.267(f), §135.269(d)). They rarely matter for a single trip, but they do across a busy season.
  6. Keep the pilot records. Each pilot’s individual record must include flight time in sufficient detail to determine compliance with the Part 135 flight time limitations, and these pilot records must be kept for at least 12 months (§135.63(a)(4)(vii) and (b)).

This is a plain-language summary to help with planning, not legal advice and not an FAA interpretation. Your operations specifications and approved programs, the current regulation text on eCFR, and your FAA principal operations inspector take precedence.

The problem

Legal on paper, until the bench gets involved

The rules are clear. Applying them across a mix of rostered and freelance pilots is where it gets hard.

⏱️
Outside flying you can’t see

Freelance pilots fly for several operators. Their commercial flying elsewhere counts toward the limits, and a text saying “I’m fine” is not something you can check later.

🔁
Trips change after crew is set

An added leg or a later return moves the planned completion time, and with it the 10-hour rest window in §135.267(d). The check has to run again, not just at booking.

📂
“We called around” is hard to reconstruct

When a pilot questions the seniority order or you need to show how a trip was staffed, memory and phone logs don’t hold up. A timestamped record does.

The solution

How CrewBench helps

CrewBench supports your process with staffing, qualification checks, an FTL check and a record of how each trip was staffed. It does not replace your operations specifications, approved programs or your own compliance review.

FTL check when you confirm a pilot
On the Scale plan, confirming a pilot checks the trip against key §135.267 limits for two-pilot crews, including flight time, minimum rest and quarterly rest periods, and re-checks when legs change. It does not yet cover one-pilot, three- or four-pilot, scheduled-operation or flight attendant limits, and it is only as complete as the flight hours recorded.
Outside hours for bench pilots
Record the hours a freelance pilot reports flying for other operators, and the FTL check counts them, because the limits include all commercial flying.
Qualification filtering
Only pilots with the right type rating and role are notified, and lapsed medicals or ratings are flagged before you confirm anyone.
A timestamped record of how each trip was staffed
Who was offered the trip, in what order, when they answered and who was confirmed, logged automatically. This is an operational record, separate from the pilot records §135.63 requires. Shield adds a compliance certificate per trip.

How Shino Aviation staffs a 20-aircraft, five-type fleet

Shino runs Part 135 charter and Part 91 private trips from one bench roster. One staffing call once took its CEO two hours of phone calls. Now he usually has a pilot confirmed within 10 to 15 minutes.

Read the Shino Aviation case study
“The filtering is what I kept coming back to. I don’t need to remember who’s current on what anymore. I just filter by type, and the list is right there.”
Neer O. CEO, Shino Aviation

FAQ

Common questions about Part 135 crew scheduling

What are the Part 135 flight time limits for charter pilots? +
For one- and two-pilot crews in unscheduled operations, §135.267(b) limits flight time to 8 hours (one pilot) or 10 hours (two pilots) in any 24 consecutive hours, including any other commercial flying. §135.267(c) allows an alternative based on a regularly assigned duty period of no more than 14 hours with at least 10 consecutive hours of rest immediately before and after it. Total flight time in all commercial flying is also limited to 500 hours per calendar quarter, 800 hours in two consecutive calendar quarters and 1,400 hours per calendar year (§135.267(a)).
How much rest does a Part 135 pilot need? +
For one- and two-pilot crews in unscheduled operations, it depends on how the assignment is made. Under §135.267(b), each assignment must provide at least 10 consecutive hours of rest during the 24 hours before its planned completion time (§135.267(d)). Under the §135.267(c) alternative, the duty period of no more than 14 hours must be immediately preceded and followed by at least 10 consecutive hours of rest. The certificate holder must also provide each flight crewmember at least 13 rest periods of at least 24 consecutive hours in each calendar quarter (§135.267(f)). Three- and four-pilot crews (§135.269) and scheduled operations (§135.265) have their own rest requirements.
Does Part 117 apply to Part 135 operations? +
No. Part 117 applies to flightcrew members and certificate holders conducting passenger operations under Part 121, and to certain Part 91 operations directed by Part 121 certificate holders (§117.1). Part 135 operations follow the flight time, duty and rest requirements in Part 135, Subpart F (§§135.261–135.273).
Do a freelance pilot’s hours with other operators count? +
Yes. Under §135.267(b), the daily limit applies to the assigned flight time when added to any other commercial flying by that pilot, and the quarterly and annual totals in §135.267(a) count all commercial flying. In CrewBench you can record a bench pilot’s outside hours so the FTL check includes them.
Does CrewBench replace our operations specifications or compliance program? +
No. CrewBench helps you staff trips with qualified crew, check key limits and keep a record of how each trip was staffed. Your operations specifications, approved programs and the current regulations still govern, and the operator remains responsible for compliance.

Check the limits before you confirm crew

Notify qualified pilots, check key limits on the Scale plan and keep a record of how each trip was staffed. Start free, no card needed.