RBAC 135 (Brazil's equivalent of FAR Part 135) has twelve subparts with content, one reserved subpart and seven appendices. Whoever runs an air taxi company does not need to know the text by heart. They need to know where each obligation lives, who in the company answers for it and what evidence to show when ANAC asks.
This guide is that map, built on Amendment No. 15 of RBAC 135 (issued on July 9, 2025, in force since January 9, 2026) and Amendment No. 10 of RBAC 119 (in force since November 1, 2024). Each block gives the section number and, when there is one, the blog article that goes deeper into the topic.
Who RBAC 135 applies to
135.1(a)(1) sets the scope: operations of anyone applying for or holding an air operator certificate (COA) under RBAC 119 that uses airplanes with a maximum certified configuration of up to 19 passenger seats and a maximum payload capacity of up to 3,400 kg (7,500 lb), or helicopters. The same cut is in 119.21(a): above it, the airplane goes to RBAC 121; helicopters stay in 135.
135.1 also reaches anyone providing services to the certificate holder, including maintenance, and every person on board. And 135.7 closes a door many people imagine is open: the rules of 135 also apply to anyone who engages in an operation governed by it without the required certificate and operations specifications. Real control over the aircraft does not always match the registry, and that is covered in de facto operator × de jure operator.
Before 135 comes 119: certificate and operations specifications
Under 119.5(a)(1), the operator obtains the COA and the operations specifications (EO) before it starts carrying anyone. 119.5(c) prohibits air transport without them, operating contrary to the EO and advertising an unauthorized operation.
135 says how to operate; the EO say what, where and with which aircraft. 119.49(c) lists the minimum content for the non-scheduled 135 operator: kinds and areas of operation, each authorized aircraft (type, marks and serial number), authorized deviations and the authorization or prohibition for dangerous goods, among other items. An aircraft not on the list does not operate. The detail is in the article on operations specifications.
Three points of 119 that weigh on anyone opening a company:
- 119.35(b) and (c): the application carries an Initial Statement of Compliance that goes through every section of RBAC 91 and 135, with the means of compliance for each, and must be filed at least 120 days before the intended start of operations.
- 119.69(a): five management positions: Director or Manager of Operations, Chief Pilot, Director or Manager of Maintenance, Director or Manager of Safety and Accountable Manager. 119.71 sets the qualifications, and 119.69(e)(3) requires notifying ANAC within 10 days of any change or vacancy.
- 119.71(g): the Accountable Manager is the single person with final authority over operations, who decides on resources and is accountable for safety performance.
For small operations, ANAC created the Simple Operator category, which changes the size of the requirement without changing the list of documents. It is covered in Simple Operator in air taxi.
How RBAC 135 is organized
| Subpart | Subject |
|---|---|
| A | General: applicability, manual, aircraft, SMS |
| B | Flight operations and records |
| C | Aircraft and equipment |
| D | VFR and IFR limitations |
| E | Flight crewmember requirements |
| F | Flight time and rest |
| G | Crewmember testing |
| H | Training |
| I | Airplane performance |
| J | Maintenance |
| K | Dangerous goods |
| M | SMS |
135.61 defines the relationship with general aviation: Subpart B sets rules in addition to those of RBAC 91. 135 does not replace 91; it stacks on top of it.
Subparts B, C, D and I are the ones dispatch consults every day: flight locating (135.79), MEL (135.179), minimums and fuel (Subpart D), performance by airplane category (Subpart I). One example of how one of these sections weighs on a decision is the runway factoring of 135.385, discussed in stabilized approach and go-around.
The company general manual is where everything converges
Under 135.21, the holder submits the company general manual, and each revision of it, for ANAC's prior acceptance. 135.23 lists 41 items of content: from the people who exercise operational control (135.77) to weight and balance, recording of mechanical irregularities, flight locating, SOPs and the method for filing maintenance records.
Almost every requirement in 135 ends in "establish, in the company general manual, the procedures". When the written procedure and the real routine drift apart, that is where the audit finds the difference.
Crew: qualification, testing and training
Who may fly (Subpart E). 135.242 requires a valid license and rating, a valid CMA (medical certificate) and a link to the holder through an employment contract. 135.243 sets the captain's experience: for VFR, at least a commercial pilot with 500 hours, 100 of them cross-country and 25 at night; for IFR, 1,200 hours, with 500 cross-country, 100 at night and 75 on instruments, 50 of those in actual flight. When carrying passengers in a turbojet, in an airplane with 10 or more seats or in a multiengine airplane in scheduled operations, the captain needs an airline transport pilot license. Recent experience follows RBAC 61.21 (135.247).
Testing (Subpart G). The deadlines that most often break a roster: knowledge and proficiency every 12 calendar months (135.293), IFR proficiency every 6 months for the captain who flies on instruments (135.297) and a line check every 12 months (135.299).
Training (Subpart H). 135.341 requires an approved program for pilots and, where there are any, flight attendants, with initial, transition, upgrade, differences and recurrent curricula. Recurrent training is annual (135.351), and CRM has initial training and recurrent training every 24 months (135.330). 135.323(b) counts recurrent training completed in the month before or after the due month as done in the due month. Amendment 15 allowed ANAC to authorize deviations from 135.341 when size and complexity keep safety at an acceptable level. A deviation is an express authorization, not a presumption.
Duty and rest (Subpart F). 135.263 has no numbers of its own: it refers to Law No. 13.475/2017 and its regulations. The limits and where the roster breaks are in duty and rostering in air taxi.
Maintenance and airworthiness
135.413(a) makes the holder primarily responsible for airworthiness, even when maintenance is contracted. The path depends on size, under 135.411(a):
- up to 9 seats: RBAC 43 and RBAC 91, plus a set of 135 sections, including 135.421, which calls for the manufacturer's program or one approved by ANAC;
- 10 seats or more: a maintenance program, under sections 135.413, 135.415, 135.417 and 135.423 to 135.443.
135.417, the monthly summary report of flight interruptions and in-flight propeller feathering, due within the first 10 business days of the following month, appears in both lists. On the ramp, 135.71 prohibits starting a flight without checking that the required inspections were done, and 135.179 only allows takeoff with inoperative equipment if there is an approved MEL and an ANAC letter authorizing its use. What this changes in maintenance tracking is in RBAC 91 × 135: what changes in the CTM.
Records and documents
135.63(a) lists what stays at the principal business office, available to ANAC: COA, authorization to operate the service, EO, an up-to-date list of aircraft and an individual record for each pilot, with license, experience, CMA, checks, duty, flight hours and training. Retention periods: aircraft list, 6 months; crewmember records, 5 years; load manifest and fuel and oil consumption, 90 days after the flight. In non-scheduled operations, each transport contract is kept for at least one year after performance (135.64).
On board, 135.65 requires the crew and aircraft logbook: the captain records each flight and each irregularity and, before flying, checks the status of earlier ones. In maintenance, 135.439(a)(2) requires total times, life-limited parts, status of inspections and airworthiness directives and major alterations and repairs, records that are kept permanently and go with the aircraft when it is sold (135.439(b)(3)).
New in Amendment 15, 135.51 requires the holder to send ANAC, periodically, operational information per flight leg and SMS data and indicators. Format, deadlines and frequency are left to an ANAC normative act.
SMS: Subpart M
135.29 requires an SMS (SGSO) built on the structure of Subpart M, proportional to the size of the organization and the complexity of its operations. 135.703 defines four components and twelve elements: safety policy and objectives, risk management, safety assurance and safety promotion.
What the manager must have named and documented is in 135.705: the policy signed by the accountable manager, with a reporting policy and a statement of unacceptable behavior; the director or manager of safety, with direct access to the accountable manager; the emergency response plan; and the MGSO (SMS manual), which is part of the company general manual. 135.707 calls for hazard identification through reactive and proactive methods. Amendment 15 added 135.29(f), which allows ANAC to authorize deviations for operations of smaller size and complexity. How to keep the cycle running is in SMS in practice.
RBAC 135 and RBAC 91: what changes
RBAC 91 (Amendment 08) applies to the operation of any civil aircraft in Brazil (91.1(a)), and 91.1(e) notes that air carriers additionally comply with the specific regulations. The difference is one of layers: on top of 91, 135 adds certification, an accepted manual, approved training, periodic checks, a maintenance regime, records with retention periods and SMS.
Two rules help separate one from the other. Under 119.1(b) and 119.5(c)(3), a COA holder may conduct general aviation under RBAC 91, but only for its own benefit: ferry flights, crew training, carrying employees. And 135.131, as worded by Amendment 15, prohibits simulating abnormal or emergency procedures or IMC conditions in an air transport service operation. Emergency practice belongs on the training flight.
Where Alis fits in
The Alis air taxi module brings together in one database records that 135 requires in different places:
- Electronic logbook (eDB), a system accepted by ANAC, with a warning of the operator's signature deadline after the captain signs, and a TLB, where the discrepancy receives corrective action and can be flagged as an MEL item or as grounding the aircraft.
- CTM with components, limits and airworthiness directives, counted down with every flight logged.
- A crewmember-impeded warning in scheduling and on the flight: expired CMA or rating, expired training (such as CRM), 30-day hour limit, rest between duty periods and night recent experience. With the block turned on by the company, saving requires a release.
- SMS with reports and risk matrix, policy, emergency response plan, MGSO, inspections, change management, indicators, training and communication, plus the tab with the eight process documents (MGO, MGM, MGSO, PTO, PTM, MAP, FAI and EO), each with its current revision and status at ANAC.
- Flight Kit with weight, fuel and FRAT, and the RIODSO spreadsheet, built from the logbook, the crew and the SMS.
The air taxi page summarizes the module, and the article on Simple Operator shows how the requirement changes with size.
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This article is for informational purposes. The requirements cited are those of RBAC 135 (Amendment No. 15, issued on July 9, 2025 and in force since January 9, 2026), RBAC 119 (Amendment No. 10, in force since November 1, 2024) and RBAC 91 (Amendment No. 08, issued on October 2, 2026), according to the text published by ANAC and read on the publication date. The text does not replace consulting the regulations, your company's operations specifications or the guidance of the technical and operational managers.