Why Part 135 Doesn't Actually Cover Your Charter Broker

The legal test that separates Part 91 from Part 135 is simple: any form of compensation, whether cash, a gift, or reimbursement for the cost of the flight, makes the flight commercial and subject to Part 135 rather than Part 91. This is why every private jet charter flight, regardless of the broker or operator involved, must be conducted under a Part 135 certificate.

Part 135's full name is Commuter and On-Demand Operations, and the distinction matters. On-demand charter, the kind Hogani Jets coordinates, means flights scheduled for a specific trip rather than a fixed, repeating route. Once an operator runs 5 or more round trips per week between the same two points on a published schedule, that service crosses into commuter operations, which layer in additional requirements closer to Part 121's scheduled-airline standards. Standard private jet charter stays on the on-demand side of Part 135 precisely because each trip is booked individually rather than sold as a recurring scheduled route.

Part 135 sets specific, numeric limits on how long a crew can fly and how much rest they must have beforehand, not a general fatigue guideline left to the operator's discretion.

Every Part 135 crewmember is also entitled to at least 36 consecutive hours of rest during any 7 consecutive days, and a rest period cannot be interrupted by a phone call, message, or standby responsibility to the operator. These are the specific rules a Part 135 operator is inspected against, not general best practices.

Part 135 sets requirements for pilot qualifications, aircraft maintenance schedules, operational procedures, and recurrent training specifically for on-demand commercial flights, a different risk and operating profile than either non-commercial Part 91 flying or the fixed, scheduled operations Part 121 covers. Part 135 operations are conducted under Instrument Flight Rules, and passengers are required to provide photo identification, unlike most Part 91 flights.

This is the single most important distinction for anyone booking a charter. The Part 135 certificate belongs to the direct air carrier, the company that owns or leases the aircraft and employs the pilots, not to the broker arranging the trip. 

Hogani Jets is an air charter broker and does not hold a Part 135 certificate; every flight coordinated through Hogani Jets is operated by a licensed Part 135 direct air carrier who retains full operational control of that flight. Ask any charter provider which specific operator, and which specific Part 135 certificate, is flying your trip.

Part 135 governs the operator; a separate DOT regulation, 14 CFR Part 295, governs air charter brokers directly. Part 295 requires brokers to disclose their broker status to clients, prohibits brokers from representing themselves as a direct air carrier, and sets specific requirements around how a broker advertises and arranges charter flights. 

Hogani Jets operates under Part 295 as a broker and coordinates every flight through a Part 135 operator; the two regulations apply to two different parties in the same transaction, and a client should understand which one applies to who they're actually speaking with.

Part 135 covers standard whole-aircraft charter, where a client books the entire aircraft. Some semi-private and per-seat charter services operate under a combination of Part 135 and Part 380, which governs public charter operations where individual seats, rather than a whole aircraft, are sold to separate passengers. Standard private jet charter, the kind Hogani Jets coordinates, operates under Part 135 alone.

Hogani Jets coordinates each charter through licensed Part 135 operators.

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

What is Part 135 in simple terms?

Part 135 is the FAA regulation covering on-demand commercial flights, meaning any flight where a passenger pays to be flown, including private jet charter and air taxi services. It is distinct from Part 91, which covers non-commercial flying, and Part 121, which covers scheduled airlines.

Is every private jet charter flight required to be Part 135?

Yes. Any flight where compensation changes hands for the trip is legally commercial and must be conducted under a Part 135 certificate, regardless of which broker arranged it.

Does Hogani Jets hold a Part 135 certificate?

No. Hogani Jets is an air charter broker and does not hold a Part 135 certificate. Every flight coordinated through Hogani Jets is operated by a licensed Part 135 direct air carrier who retains full operational control of the flight.

What regulation actually governs a charter broker like Hogani Jets?

DOT 14 CFR Part 295 governs air charter brokers directly, requiring clear disclosure of broker status and prohibiting a broker from representing itself as a direct air carrier. Part 135 governs the operator; Part 295 governs the broker.

How many hours can a private jet pilot fly in a day?

A two-pilot crew is limited to 10 hours of flight time in 24 hours; a one-pilot crew to 8 hours. Both require at least 10 consecutive hours of rest before the duty period, and every crewmember is entitled to at least 36 consecutive hours of rest during any 7 consecutive days.

What is the difference between on-demand and commuter Part 135 operations?

On-demand charter, the kind Hogani Jets coordinates, is booked trip by trip rather than on a fixed schedule. Once an operator runs 5 or more round trips a week between the same two points, it crosses into commuter operations, which carry additional requirements closer to Part 121's scheduled-airline standards.

What is the difference between Part 135 and Part 91?

Part 91 covers non-commercial flying where no compensation is exchanged; Part 135 covers commercial on-demand flights, including all private jet charter, where a passenger pays for the trip.

What is the difference between Part 135 and Part 121?

Part 121 governs scheduled commercial airlines operating fixed routes on a published schedule. Part 135 governs on-demand charter flights booked for a specific trip rather than sold as seats on a scheduled route.

Does every Part 135 pilot need an Airline Transport Pilot certificate?

Not always. An ATP certificate is required for the Pilot-in-Command on aircraft with 10 or more passenger seats or any turbojet-powered aircraft. Smaller piston or single-pilot turboprop operations may permit a Commercial Pilot Certificate with an instrument rating instead.

Who actually holds the Part 135 certificate on my charter flight?

The direct air carrier, the operator that owns or leases the aircraft and employs the pilots, holds the certificate, not the broker who arranged your trip. Always confirm which specific operator is flying your charter.

What is Part 380, and does it apply to my charter?

Part 380 governs public charter operations where individual seats are sold to separate passengers, relevant to some semi-private or per-seat charter services. Standard whole-aircraft private jet charter, which Hogani Jets coordinates, operates under Part 135 alone.

How do I confirm an operator's Part 135 certificate is valid?

Ask your broker for the operator's certificate number, which can be independently verified through public FAA resources. Hogani Jets confirms current, valid Part 135 certification as part of every booking.