NetJets and FAA Regulations: Part 91K, Part 135, and What They Mean for Owners

NetJets regulatory framework discussions have gotten complicated with all the “if I own a fraction of the aircraft why am I flying under Part 91K instead of just Part 91” debates, the regulatory implications for safety standards comparisons, and “what practical differences does the regulatory designation actually create for a NetJets owner versus someone using a charter service” conversations flying around. As someone who has spent years studying FAA regulatory frameworks and the specific ways that fractional ownership programs interact with the Federal Aviation Regulations, I learned everything there is to know about how NetJets fits within the FAR framework. Today, I will share it all with you.

But what regulatory category does NetJets actually operate under? In essence, NetJets operates primarily under FAR Part 91K — a subpart of Part 91 specifically created by the FAA in 2003 to address the unique characteristics of large fractional ownership programs — which is distinct from both standard Part 91 (private non-commercial operations) and Part 135 (commercial on-demand charter), with the regulatory requirements designed to reflect that fractional owners are using aircraft in which they hold genuine ownership interests rather than purchasing commercial transportation services. But it’s much more than a regulatory label. For owners evaluating fractional ownership versus charter, understanding which regulatory framework governs each type of operation determines the safety standards, operational requirements, and insurance structures that apply to every flight.

What Part 91K Requires

Part 91 Subpart K was created specifically because large fractional ownership programs like NetJets operate at a scale and with a complexity that standard Part 91 didn’t adequately address, but where the ownership structure distinguished them from commercial carriers. Part 91K requires fractional program managers to hold FAA management specifications, maintain specific training standards for pilots, operate approved maintenance programs, and provide owners with specific information about how the program operates. Don’t make my mistake of assuming Part 91K is simply a less rigorous version of Part 135 — at least if you’re comparing fractional ownership safety to charter, because Part 91K imposes specific requirements that go beyond basic Part 91 while being calibrated to the fractional ownership model rather than commercial air carrier operations.

Where Part 135 Enters the NetJets Picture

NetJets also holds Part 135 operating authority for its on-demand charter operations — flights where customers who don’t own a fractional share are purchasing commercial air transportation from NetJets. Charter customers are transported under Part 135 with its ATP certificate requirements for pilots, specific maintenance program requirements, and dispatch systems. That’s what makes NetJets’ dual regulatory structure endearing to aviation attorneys advising clients on fractional versus charter options — the same aircraft and the same pilot can operate under different regulatory frameworks depending on whether the passenger in the back holds a fractional ownership share or is a charter customer, and understanding which framework applies matters for insurance, liability, and regulatory compliance purposes.

Pilot Training Standards at NetJets

NetJets applies consistent high training standards across both Part 91K and Part 135 operations. The company’s training programs exceed regulatory minimums for both frameworks — simulator recurrency, emergency procedure training, and crew resource management programs reflect the operational demands of a large fleet serving demanding schedules rather than minimum compliance with the applicable subpart. First, you should understand that NetJets’ voluntary training investment above regulatory minimums is driven by operational and reputational considerations — at least if you’re evaluating how much the regulatory designation actually affects the quality of the flight operation you’ll experience as a passenger, because the training standards that NetJets actually applies are internally determined and tend to be more rigorous than the minimum requirements of either regulatory framework.

Safety Management and Third-Party Certification

NetJets maintains IS-BAO (International Standard for Business Aircraft Operations) certification — a voluntary third-party safety management standard that independently verifies that the company’s safety management system meets international best practices. IS-BAO certification requires demonstrated implementation of safety management processes that go beyond FAA minimum requirements for either Part 91K or Part 135 operations. The voluntary nature of IS-BAO certification is meaningful: it represents a business decision to invest in safety management infrastructure beyond what regulations require, which tells observers something about the company’s operational values that the regulatory designation alone doesn’t convey.