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Passenger ID checks at the FBO: REAL ID for Part 135 operators

By Apparent Logic, LLC · Updated October 5, 2026
Legal sources last checked September 2026 · How we review sources

General information, not legal advice. Laws and permit conditions vary; ask your lawyer or regulator what applies. Check ID is a tool for your staff, not a guarantee of compliance or a legal defense. No system can catch every fake ID. Staff must inspect the document and its holder and make the final decision.

For Part 135 charter operators, flight crews and FBO staff. TSA’s June 2, 2025 REAL ID FAQ for aircraft operators says that on Part 135 flights under the Twelve-Five Standard Security Program, “crew are responsible for validating passenger ID”.

At a glance

  • TSA’s acceptable-ID list includes passports and state Enhanced licenses as well as REAL ID-compliant cards (TSA).
  • NATA and NBAA reported in early 2026 that TSA ConfirmID was not then available for Twelve-Five flights (NATA, NBAA).
  • NBAA states that “REAL ID requirements do not apply to Part 91 flights” (NBAA, Feb. 2, 2026).

What the law says

Who validates passenger ID

In its June 2, 2025 REAL ID FAQs for aircraft and airport operators, TSA says REAL ID requirements have been enforced for all passengers boarding commercial aircraft in the U.S. since May 7, 2025. On Part 135 flights under the Twelve-Five Standard Security Program (TFSSP), “crew are responsible for validating passenger ID, to ensure an acceptable ID is presented” (FAQ 21). TSA also says that “REAL ID requirements apply to all commercial aviation operations, including charters” (FAQ 11). The FAQs note that their references to program requirements “may not be relevant to your security program.”

Which flights are in the twelve-five program

Under 49 CFR § 1544.101(d), the twelve-five program applies to scheduled or charter operations in aircraft with a maximum certificated takeoff weight of more than 12,500 pounds that are not under a full, partial or full all-cargo program. Whether an aircraft is above that line depends on its maximum certificated takeoff weight, not its size class. FAQ 21’s statement about crew refers only to flights under this program.

Which IDs TSA lists

FAQ 21 points operators to TSA’s list of acceptable identification, the same list used at TSA checkpoints. It includes REAL ID-compliant and Enhanced state licenses and ID cards, U.S. and foreign passports, U.S. passport cards and DHS trusted traveler cards, among others, and TSA says it is “subject to change without notice.” TSA’s operator FAQs say a temporary driver’s license is not acceptable (FAQs 10 and 20). TSA’s acceptable-ID page says it currently accepts expired ID of the listed types up to two years after expiration.

TSA ConfirmID and charter flights

Since February 1, 2026, a traveler without an acceptable ID at a TSA checkpoint can pay a $45 fee through Pay.gov to have TSA attempt to verify their identity, and TSA says there is no guarantee it can. NATA reported on January 27, 2026: “At this time, the service is not available for operations under the Twelve-Five Standard Security Program or the DCA Access Standard Security Program.” NBAA reported on February 2, 2026 that it was “not currently available” for those flights. As of September 2026 we found no later statement from TSA, NATA or NBAA on this.

What it means at the counter

This guide can’t summarize your own security program: aircraft operator security programs are Sensitive Security Information under 49 CFR § 1520.5(b)(1). Whether your program accepts everything on TSA’s list, including mobile IDs, is a question for your program and your TSA Principal Security Specialist.

On the card, 6 CFR § 37.17(n) requires a REAL ID card to bear a DHS-approved security marking on its face. State Enhanced licenses, which TSA also accepts, may not carry it: TSA’s REAL ID FAQs say “most EDLs do not contain the star marking and this is acceptable.” For REAL ID outside aviation, see our REAL ID guide.

Where Check ID fits

Check ID is a tool that helps staff check IDs. On iPhone and iPad, it reads the barcode on US and Canadian driver’s licenses and ID cards and compares the birth and expiry dates with your rules. Staff see a clear result, such as Verified, Underage or Expired ID, and make the call. Verified means only that the dates meet your rules. On iPhone, it also reads the chip in many ePassports and accepts Apple Wallet IDs where the issuing state offers them. From version 3.0, it shows a license’s REAL ID indicator as encoded, when the card encodes it.

A scan record never keeps the name, date of birth, address, ID number or a picture of the ID, on any plan. Free and Pro scan history covers the last 7 days, on your device or in your own iCloud. Check ID for Teams keeps scan records for two years by default, including the device and, when known, which staff member ran each scan. Its reports show an internal staff ID, not a name.

Check ID can’t tell whether a card is genuine: a well-made fake can carry a valid barcode. Whether it fits your security program is a question for your program, your TSA Principal Security Specialist or your lawyer.

Frequently asked questions

Who checks passenger ID on a Part 135 charter flight?

On Part 135 flights under the Twelve-Five Standard Security Program, TSA’s June 2, 2025 operator FAQ says “crew are responsible for validating passenger ID, to ensure an acceptable ID is presented”.

Do REAL ID requirements apply to fractional flights under Part 91 Subpart K?

TSA’s operator FAQ does not address fractional programs. NBAA states that “REAL ID requirements do not apply to Part 91 flights.” How a particular flight is treated is a question for your program manager or your lawyer.

Does Check ID tell me whether an ID is REAL ID compliant?

Not by itself. From version 3.0, Check ID shows the REAL ID indicator as a license barcode encodes it, when the card encodes it. Earlier versions don’t. The minimum barcode data elements in 6 CFR § 37.19 don’t include it, so a valid card may not carry it. It isn’t proof that a card is genuine or REAL ID-compliant, and Apple Wallet IDs don’t report it.

Is Check ID TSA-approved?

No. Check ID is not affiliated with, endorsed by, or approved by TSA or any government agency. It does not detect fake IDs, and using it is not a certification of compliance with 49 CFR Part 1544 or your security program.

Sources

Read the ID, then make the call.

Check ID reads the ID and shows your staff a clear result. They decide.

Download on the App Store Check ID for Teams How verification works

Free to download · iPhone and iPad · iOS 18 or later