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Aircraft Broker Course

Charter Operator Due Diligence for Brokers

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Charter broker due diligence is the work a broker does before booking an operator: checking that the company may legally fly the trip, in that aircraft, and that it holds the authority it claims. A broker never holds operational control, but it chooses who flies the client.

This guide sets out the checks step by step, using FAA tools and the regulations, then the voluntary safety audits. It covers US practice, with a short note on the UK and EU. It is a summary, not legal advice. Read the current rules and speak to an aviation attorney before relying on it.

Key points

  • Start with the FAA's own Part 135 Operators and Aircraft List. It shows which operators are certificated for charter and which aircraft each may use, searchable by operator name or N-number.
  • The certificate is not enough on its own. The specific aircraft must be authorized for that operator, and no one may operate in violation of its operations specifications (14 CFR 119.5(l)).
  • Operational control is "the exercise of authority over initiating, conducting or terminating a flight" (14 CFR 1.1). The Part 135 certificate holder is responsible for it (14 CFR 135.77). Any document that shifts it to the client is an FAA red flag.
  • ARGUS, WYVERN and IS-BAO are voluntary, private audit programs. They look at different things and do not replace FAA authority.
  • Ask for the operator's insurance evidence and read the limits. US air taxi operators must file a certificate of insurance with the Department of Transportation (14 CFR 205.4).

Why the checks fall on the broker

A US air charter broker may only arrange flights operated by a carrier that holds the right economic authority from the Department of Transportation and safety authority from the FAA (14 CFR 295.20). Selling a flight the broker has reason to know "cannot be legally performed" is listed as an unfair and deceptive practice (14 CFR 295.50(b)). The disclosures that follow from this, including naming the carrier in operational control, are set out in what Part 295 requires a charter broker to disclose. Broker versus operator is covered in what a private jet broker is. This page covers the step before: confirming the operator you will name is authorized and covered.

Step 1: Confirm the operator holds a Part 135 certificate

On-demand charter in the US is flown under 14 CFR Part 135. "No person may operate as a direct air carrier or as a commercial operator without, or in violation of, an appropriate certificate and appropriate operations specifications" (14 CFR 119.5(g)). The same section adds that no person may advertise or offer to perform such an operation unless the FAA has authorized it (14 CFR 119.5(k)).

The FAA publishes two lookup tools. As of 17 October 2026:

  • Part 135 Operators and Aircraft List. A spreadsheet the FAA says is for verifying "whether an operator is certificated for charter and which aircraft are authorized for charter." It is searchable by operator name or registration number and, per the FAA page, updated weekly. The file lists operator name, aircraft model, registration and serial number.
  • AVInfo Air Operator Search. Searches by operator name or "doing business as" name across Parts 91, 121, 125, 129, 133, 135 and 137, with an option to show aircraft. The FAA says it is working on merging the two tools.

If an operator or aircraft is not listed, the FAA's instruction is to contact the local Flight Standards District Office (FSDO) to verify charter status.

Then ask the operator directly. The FAA's consumer guidance says to "ask to see the Operator's Air Carrier or Operating Certificate," and to find another operator if one refuses. NBAA gives the same advice: ask for a copy of the certificate, or at least the air carrier number, and treat a refusal as a sign of possible illegal charter. Match the legal name and any trading names on the certificate to the name on the quote.

Step 2: Confirm the specific aircraft is authorized

A valid certificate does not cover every aircraft the operator can reach. An on-demand operator's operations specifications set out the kind and area of operations and the category and class of aircraft authorized, and list aircraft by type, registration and serial number where 14 CFR 119.49(c) requires it. No one may operate in violation of those operations specifications (14 CFR 119.5(l)), or in an area they do not authorize (14 CFR 119.5(j)).

In practice, a broker can:

  • Search the tail number on the FAA Part 135 list and confirm it sits under the same operator that quoted it.
  • Look the tail number up on the FAA Aircraft Registry, which the FAA's consumer guidance links to.
  • Check the aircraft size and route against the operator's authority. NBAA notes a Part 135 carrier flies an illegal charter if it uses a larger aircraft than authorized, or flies outside its authorized areas.

If the tail changes after booking, run the check again on the new aircraft.

Step 3: Pin down who has operational control

Operational control, with respect to a flight, "means the exercise of authority over initiating, conducting or terminating a flight" (14 CFR 1.1). Under Part 135, "each certificate holder is responsible for operational control" and must list in its manual the name and title of each person it authorizes to exercise it (14 CFR 135.77).

The FAA lists as a red flag any case where "the company provides the aircraft and at least one crewmember, yet attempts to transfer operational control to a consumer via any document." The FAA's own Safe Air Charter page asks the passenger: "Am I liable for the flight (do I have operational control)?" NBAA describes "illegal dry leases or excessive timeshare agreements" that exceed the limits in 14 CFR 91.501 as common forms of illegal charter.

So read the paperwork the operator sends. If a client is asked to sign a lease for the aircraft and a separate agreement for the crew, or anything that names the client as the party in operational control, stop and ask why. The carrier you name to the client under Part 295 should be the certificate holder that holds operational control on that flight.

Step 4: Watch for illegal charter red flags

Warning signs from the FAA's consumer page (updated 8 January 2026) and NBAA's 2019 guidance:

  • An attempt to transfer operational control to the customer by document (FAA).
  • No Federal Excise Tax charged. The FAA says "legitimate operators have to charge this" (FAA; NBAA).
  • A price far below other quotes. "If the price is too good to be true, it probably is" (FAA).
  • No safety briefing or passenger briefing cards (FAA).
  • Evasive answers to questions (FAA).
  • Passengers coached on what to say if an FAA inspector meets the aircraft (FAA; NBAA).
  • Separate bills for the aircraft and for the pilots on one flight (NBAA).
  • A refusal to show the certificate or give the air carrier number (FAA; NBAA).

NBAA warns that insurers may refuse a claim if they believe a flight was really for hire. Suspected illegal charter in the US can be reported on the hotline the FAA publishes, 1-888-SKY-FLT1 (1-888-759-3581), or through the FAA Hotline and local FSDOs.

Step 5: Check third-party safety audits and ratings

Several private companies audit operators against their own standards. No FAA rule we read requires any of them. They are a second layer after the legal checks, never a substitute. Each is described from its own website, with no ranking.

ProgramRun byWhat it looks at (vendor's description)How a broker checks it
ARGUS ratings (Gold, Gold Certified, Platinum, Platinum Elite)SGS ARGUS InternationalGold uses a remote audit of SMS and maintenance practices. Gold Certified adds an on-site audit. Platinum is a two-day on-site audit of training, maintenance, procedures and organizational controls, and requires a mature safety management system. Platinum Elite adds continuous monitoring.ARGUS operator registry and CHEQ, its database of ARGUS-rated operators. TripCHEQ checks crew, aircraft and operating certificate for a specific flight.
WYVERN Wingman and Wingman PROWYVERNThe Wingman audit evaluates flight operations, safety management systems, training and maintenance. An operator moves to Wingman PRO when WYVERN assesses its safety culture and finds its SMS fully effective.WYVERN's public member directories for Wingman and Wingman PRO operators.
IS-BAO (Stages 1 to 3)International Business Aviation Council (IBAC)An industry standard built around a safety management system. Stage 1 confirms the SMS is in place, Stage 2 that risks are managed, Stage 3 that safety management is integrated into the business.IBAC's IS-BAO page does not describe a public registry. Ask the operator for evidence of its registration and current stage.

Check that the rating belongs to the certificate holder flying the trip, not an affiliate, and that it is current. IS-BAO covers business aircraft operations generally, so registration alone does not show charter authority.

Step 6: Ask for insurance evidence

Air taxi operators registered under 14 CFR Part 298 must maintain insurance under Part 205 and keep a current certificate of insurance on file with DOT (14 CFR 298.3(a)(3)). Certificates are filed on OST Form 6410 for US air carriers including air taxi operators (14 CFR 205.4(a)), and an aircraft may not be listed in the FAA operations specifications or flown unless liability cover is in force (14 CFR 205.4(b)).

The regulatory minimum is low. For US air taxi operators carrying passengers, Part 205 sets passenger liability at $75,000 per passenger and $75,000 times 75 percent of the installed passenger seats per aircraft per occurrence, plus third-party cover (14 CFR 205.5(c)). Operators may carry more, so read the actual certificate. Check:

  • The named insured matches the certificate holder on the FAA list.
  • The quoted aircraft is covered, by tail number or by type.
  • The policy period covers the trip dates.
  • The liability limits, both per passenger and per occurrence.
  • Any geographic or use limits that would exclude the route or the type of flight.

Your own liability insurance is separate, with its own Part 295 disclosure duty.

Outside the United States

In the UK, any UK-established company that wants to operate an aircraft for commercial air transport must first obtain an Air Operator Certificate (AOC) and Operating Licence from the Civil Aviation Authority, and the CAA publishes a downloadable list of UK aeroplane and helicopter AOC holders. In the EU, Part-ORO requires an operator to obtain an AOC from its competent authority before starting commercial air transport (ORO.AOC.100). The country-level rules for brokers are on aircraft broker licence: UK and Europe, GCC and Canada.

Charter broker due diligence checklist

A list to work through for each new operator, and again when the aircraft changes:

  1. Find the operator on the FAA Part 135 Operators and Aircraft List or AVInfo Air Operator Search. If it is missing, call the local FSDO.
  2. Ask for the Air Carrier or Operating Certificate and the air carrier number. Match the legal and trading names to the quote.
  3. Find the quoted tail number under that operator on the FAA list, and look it up on the FAA Aircraft Registry.
  4. Confirm the aircraft size and the route sit inside what the operator is authorized to fly.
  5. Read the client paperwork. Confirm the certificate holder, not the client, holds operational control.
  6. Confirm the quote includes Federal Excise Tax where it applies, and that the aircraft and crew are on one contract with one carrier.
  7. If the operator cites ARGUS, WYVERN or IS-BAO, check it in the vendor's directory or ask for current evidence.
  8. Get the insurance certificate. Check the named insured, aircraft, dates, limits and exclusions.
  9. Record what you checked, where, and when.
  10. Make your Part 295 disclosures, naming the carrier in operational control.
  11. Re-check if the tail, the operator or the route changes before departure.

Operator vetting is one part of air charter broker training. Terms are defined in the glossary.

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Frequently asked questions

How do I verify a charter operator in the US?

Search the FAA's Part 135 Operators and Aircraft List by operator name or N-number, ask for the Air Carrier Certificate, and confirm the quoted aircraft is listed under that operator. If either is missing, the FAA says to contact the local FSDO.

Who has operational control on a chartered flight?

The Part 135 certificate holder. Operational control means authority over initiating, conducting or terminating a flight (14 CFR 1.1), and each certificate holder is responsible for it (14 CFR 135.77). A broker never holds it, and a document shifting it to the client is an FAA red flag.

Is an ARGUS or WYVERN rating required to fly charter?

No FAA rule we read requires one. ARGUS, WYVERN and IS-BAO are private, voluntary audit programs. They do not replace the FAA certificate and operations specifications that make a charter legal.

What are the signs of an illegal charter?

The FAA and NBAA list: paperwork that moves operational control to the customer, no Federal Excise Tax, a price far below the market, no safety briefing, evasive answers, coaching passengers on what to tell inspectors, separate bills for aircraft and pilots, and refusal to show the certificate.

Sources

Every source below was checked on 17 October 2026.

About this guide. Aircraft Broker Course is published by the International Aircraft Broker Institute (IABI), which sells aircraft broker training. Where a page mentions an IABI course, that is our own product. No course can promise a job, an income or a license. This is general information, not legal, tax or financial advice. How this site works.