Charter Broker vs. Direct Air Carrier

A direct air carrier holds an FAA Part 135 Air Carrier Certificate, which is the legal authority to operate aircraft for commercial air transportation on an on-demand, non-scheduled basis. The certificate is issued to a specific company and covers specific aircraft listed on the carrier's D085, the FAA's listing of aircraft approved to operate under a given certificate.
Operational control rests entirely with the direct air carrier. That means the carrier is accountable to the FAA for:

• Pilot training, qualification, and currency
• Aircraft maintenance programs and airworthiness
• Drug and alcohol testing programs
• Dispatch and flight release
• Crew scheduling and duty time compliance
• All operational decisions from departure to arrival

There are more than 2,500 FAA-certificated Part 135 operators in the United States. They range from single-aircraft operators to large managed fleets. The safety culture, maintenance standards, and operational depth vary considerably across that population, which is why third-party safety rating systems such as ARGUS and Wyvern exist.

A charter broker is an intermediary. The broker does not own aircraft, does not hold a Part 135 certificate, and does not exercise operational control over any flight. What the broker does is search the market of available Part 135 operators to find aircraft matching the client's route, date, category, and service requirements, then contract with the selected operator on the client's behalf.

The broker's value is access and expertise. A broker with a vetted operator network can source aircraft across a much wider pool than any single operator's fleet. On a given route on a given date, a broker may identify twelve aircraft options across six operators. A direct operator can only offer what is on their own certificate.
Brokers are not regulated by the FAA in the same way operators are. The FAA governs operators. The DOT has some jurisdiction over certain broker practices, but the industry-level standard for broker accountability is largely voluntary, governed by NBAA's Air Charter Broker Best Practices guidelines and by the vetting standards that individual brokers apply to their operator networks.

This is the question that matters most, and it deserves a direct answer.
Regardless of whether the client booked through a broker or directly with an operator, the Part 135 operator flying the aircraft bears legal accountability for the safety of the flight. The broker is not operationally responsible. The broker's accountability to the client is commercial: delivering the aircraft and service specified at the agreed price and terms.
The accountability gap that brokers are sometimes criticized for arises when they use opaque or unvetted operators. A broker who sources from the cheapest available operator without verifying safety credentials has introduced a gap between the client's expectation and the quality of the operation actually provided. 
A broker who works exclusively with ARGUS or Wyvern rated operators, verifies the Part 135 certificate, confirms the aircraft tail number on the D085, and discloses the operator identity to the client before booking has closed that accountability gap.

A direct air carrier holds an FAA Part 135 Air Carrier Certificate and bears full legal and operational accountability for every flight it operates. A charter broker does not own aircraft, does not hold a Part 135 certificate, and does not exercise operational control. The broker identifies available aircraft from the market, negotiates terms with a Part 135 operator, and arranges the trip on the client's behalf. Regardless of whether a client books through a broker or directly with an operator, the Part 135 operator flying the aircraft retains legal accountability for flight safety. The broker's accountability to the client is commercial: delivering the aircraft and service specified at the agreed terms.

Booking directly with an operator makes sense when you have an established relationship with a specific operator whose fleet, crew, and standards you know, and your routes consistently fall within their fleet capabilities and geographic base.

Working with a broker makes sense when you need aircraft access across varied routes and categories beyond what any single operator can supply, when you want independent sourcing across the market to avoid being limited to one operator's available inventory, or when you are booking in markets where you do not have existing operator relationships and need an intermediary with established vetting standards.

There are more than 2,500 FAA-certificated Part 135 operators in the United States. Safety culture, maintenance standards, and operational depth vary considerably across that population. Third-party safety rating systems including ARGUS International and Wyvern provide independent audits of operator safety management systems, crew training records, and maintenance programs. ARGUS Platinum and Wyvern Wingman represent the highest ratings available from each body. Clients booking through a broker should confirm the broker works exclusively with rated operators, verifies each aircraft tail number against the operator's FAA D085 list, and discloses the operating carrier before flight confirmation.

Hogani Jets is a charter broker. We are not a direct air carrier and do not own or operate aircraft. Every flight we arrange is operated by a properly licensed Part 135 direct air carrier. That legal structure is disclosed in our disclaimer and in every flight agreement.

Our sourcing process begins with all essential safety ratings as a minimum threshold for any operator we work with. We verify the specific aircraft tail number against the operator's D085 list for every booking. 

We disclose the operating carrier to our clients before they confirm, so there is no ambiguity about who is accountable for the operation.

Hogani Jets coordinates each charter through licensed Part 135 operators.

Contact Hogani Jets at charter@hoganijets.com or +1-855-660-0573.