Aircraft Records Retention Requirements (14 CFR): How Long to Keep Every Record

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Chad Griffith, Founder & CEO

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Last reviewed · By Chad Griffith

Aircraft records fall into two retention buckets under 14 CFR. Records of routine maintenance, preventive maintenance, alterations, and required inspections must be kept until that work is repeated or superseded, or for 1 year after it is performed, whichever comes first (14 CFR 91.417(b)(1); 135.439(b)(1) for Part 135). The second bucket -- the aircraft's permanent status records -- must be kept and transferred with the aircraft when it is sold (14 CFR 91.417(b)(2); 135.439(b)(3)): total time in service of the airframe, each engine, propeller, and rotor; the current status of life-limited parts; the time since last overhaul of every item overhauled on a time basis; the current inspection status; the current status of applicable airworthiness directives (AD number, revision date, method of compliance, and next-due time/date if recurring); and copies of the FAA Form 337 for each major alteration. Overhaul and rebuild documentation lives in this permanent bucket -- it is the evidence behind the life-limited-part and time-since-overhaul status, so it stays with the aircraft for its service life. Part 135 operators carry additional retention windows: completed load manifests for at least 30 days (14 CFR 135.63(d)); crewmember and dispatcher records for at least 12 months and the aircraft equipment list for at least 6 months (14 CFR 135.63(b)); and drug and alcohol testing records per 14 CFR Part 120 and 49 CFR 40.333 -- verified positives, refusals, SAP reports, and follow-up tests for 5 years, EBT calibration records for 2 years, and negative/low results for 1 year. Bottom line: maintenance work records can be retired after 1 year or supersession, but life-limited-part, overhaul, inspection, and AD status records must follow the aircraft permanently.

The two retention rules: superseded-or-1-year vs. transferred with the aircraft

Federal aviation recordkeeping is built on a single, often-misread distinction. 14 CFR 91.417 -- the controlling rule for general-aviation aircraft, mirrored for commuter and on-demand operators by 14 CFR 135.439 -- sorts every record into one of two retention categories with very different lifespans.

The practical trap: operators apply the 1-year rule to everything and discard records that legally must follow the aircraft -- or they keep mountains of superseded work entries while the actual status records (life-limited part times, AD compliance) are incomplete. The two buckets answer different questions: "what was done" (work records, short) versus "what is the aircraft's current airworthiness status" (status records, permanent).

Maintenance and alteration records: what each entry must contain (14 CFR 43.9)

Retention is only half the obligation -- the record itself has to be complete. 14 CFR 43.9 governs the content, form, and disposition of every maintenance, preventive maintenance, rebuilding, and alteration record. Each entry must include:

14 CFR 43.9 does not itself set a retention period -- that comes from 91.417(b) (or 135.439(b) for Part 135). Major repairs and major alterations carry the added requirement of an FAA Form 337 prepared under 43.9(d) and Appendix B to Part 43; the operator's copy of that 337 is one of the permanent status records (91.417(a)(2)(vi)) that transfers with the aircraft. Inspection entries (annual, 100-hour, progressive) are made under 14 CFR 43.11 and retained on the same 91.417(b)(1) schedule -- until superseded by the next inspection or 1 year.

Life-limited parts, overhaul and rebuild records: the permanent pedigree (14 CFR 91.417(a)(2))

These are the records that must be retained and transferred with the aircraft on sale (14 CFR 91.417(b)(2); 135.439(b)(3)). 14 CFR 91.417(a)(2) lists them verbatim:

Overhaul and rebuild documentation belongs to this permanent bucket. An overhaul or rebuild record is the underlying evidence for items (ii) and (iii) -- it substantiates the current life-limited-part status and the time-since-overhaul figure -- so it is retained for the service life of the part or aircraft, not discarded after a year. When the part is removed or scrapped, its life history still has to reconcile against the airframe records a buyer or inspector reviews. Losing these records does not just create a paperwork gap; it can ground an otherwise airworthy aircraft until the status is reconstructed.

Airworthiness directive (AD) records and AD compliance status (14 CFR 91.417(a)(2)(v))

AD compliance is recorded twice. The act of complying is a maintenance entry under 43.9 (retained until superseded or 1 year). But the current status of every applicable AD is a permanent status record under 14 CFR 91.417(a)(2)(v): for each AD, the record must show the method of compliance, the AD number and revision date, and -- for recurring ADs -- the time and date the next action is due. This status record transfers with the aircraft (91.417(b)(2)). Most operators maintain a running AD compliance record (an "AD status sheet" or equivalent) precisely because the individual maintenance entries can be superseded while the status summary must persist. A missing or stale AD status record is one of the most common general-aviation and Part 135 inspection findings, because a recurring AD that is overdue makes the aircraft unairworthy regardless of how well the rest of the file is kept.

Part 135 operator records: crew, dispatch, and the 30-day load manifest (14 CFR 135.63)

Commuter and on-demand (Part 135) certificate holders carry recordkeeping duties beyond the maintenance file, set out in 14 CFR 135.63. The certificate holder must keep, at its principal business office, the operating certificate and operations specifications, a current aircraft equipment list, and individual records for each crewmember and aircraft dispatcher. Retention windows differ by record:

These are floors, not ceilings -- many operators retain crew and training records far longer to support enforcement defense, insurance, and personnel actions. But 30 days is the minimum the FAA will hold you to for a load manifest, and 12 months for crew records.

Drug and alcohol testing records: 1 to 5 years (14 CFR Part 120 / 49 CFR 40.333)

Part 135 operators (and other DOT-regulated aviation employers) run a drug and alcohol testing program under 14 CFR Part 120, which incorporates the testing procedures of 49 CFR Part 40. Record retention is set by 49 CFR 40.333 and tiered by record type:

14 CFR 120.219 also requires that, in addition to the records mandated by 49 CFR Part 40, employers maintain their testing records in a secure location with controlled access. Because these records contain protected medical and personnel information, retention has to be paired with access control -- a point inspectors and auditors check alongside the dates.

Aircraft records retention at a glance (record type, period, CFR cite)

Record typeMinimum retention periodCFR citation
Maintenance, preventive maintenance & alteration work recordsUntil the work is repeated or superseded, or 1 year after performed14 CFR 91.417(b)(1); 135.439(b)(1)
Required inspections (100-hour, annual, progressive)Until superseded by the next inspection, or 1 year14 CFR 91.417(b)(1); 43.11
Total time in service (airframe, engine, propeller, rotor)Retained & transferred with the aircraft on sale14 CFR 91.417(a)(2)(i), (b)(2)
Current status of life-limited partsRetained & transferred with the aircraft on sale14 CFR 91.417(a)(2)(ii), (b)(2)
Time since last overhaul (time-limited items) & overhaul/rebuild recordsRetained & transferred with the aircraft on sale14 CFR 91.417(a)(2)(iii), (b)(2)
Current inspection statusRetained & transferred with the aircraft on sale14 CFR 91.417(a)(2)(iv), (b)(2)
Current status of airworthiness directives (AD)Retained & transferred with the aircraft on sale14 CFR 91.417(a)(2)(v), (b)(2)
Major alteration records (FAA Form 337)Retained & transferred with the aircraft on sale14 CFR 91.417(a)(2)(vi), 43.9(d)
Aircraft equipment/record list (Part 135)At least 6 months14 CFR 135.63(b) (a)(3)
Crewmember & dispatcher records (Part 135)At least 12 months14 CFR 135.63(b) (a)(4)-(a)(5)
Completed load manifest (Part 135)At least 30 days14 CFR 135.63(d)
Drug/alcohol: verified positives, refusals, SAP & follow-up tests5 years14 CFR Part 120; 49 CFR 40.333(b)
Drug/alcohol: previous-employer testing information3 years49 CFR 40.333(a)(3)
Drug/alcohol: EBT calibration/maintenance records2 years49 CFR 40.333(a)(2)
Drug/alcohol: negative & low (<0.02) results1 year49 CFR 40.333(a)(1)

Periods above are regulatory minimums. Operators frequently retain longer to support enforcement defense, resale, and insurance -- but never shorter.

How FileFlo tracks aircraft records retention and proves it to an inspector

The retention rules are simple to state and hard to operate, because the dates live across logbooks, AD status sheets, training files, and manifest binders -- and the penalty for a gap is an unairworthy aircraft or a finding, not a fine you can pay later. FileFlo is the records and proof layer for that problem. It is not your maintenance-tracking program, your dispatch/FOS system, or your safety management system -- it reads the documents you already generate and keeps the evidence audit-ready.

FileFlo is $89/mo (Starter) or $299/mo (Professional) with a 5-day free trial. It keeps the retention windows and the proof straight; you keep flying.

Frequently Asked Questions

How long do you have to keep aircraft maintenance records?

Records of maintenance, preventive maintenance, alterations, and required inspections must be kept until that work is repeated or superseded by other work, or for 1 year after the work is performed -- whichever occurs first (14 CFR 91.417(b)(1); 14 CFR 135.439(b)(1) for Part 135 operators). However, the aircraft's status records -- total time in service, current life-limited-part status, time since last overhaul, current inspection status, current AD status, and major-alteration (Form 337) records -- are not on the 1-year clock. They must be retained and transferred with the aircraft when it is sold (14 CFR 91.417(b)(2)), effectively for the life of the aircraft.

Which aircraft records must be transferred with the aircraft when it is sold?

Six categories under 14 CFR 91.417(a)(2) must be retained and transferred with the aircraft at the time of sale (14 CFR 91.417(b)(2); Part 135: 135.439(b)(3)): (1) total time in service of the airframe, each engine, propeller, and rotor; (2) current status of life-limited parts; (3) time since last overhaul of all time-limited items; (4) current inspection status; (5) current status of applicable airworthiness directives, including AD number, revision date, method of compliance, and next-due date for recurring ADs; and (6) copies of FAA Form 337 for each major alteration. Overhaul and rebuild records back up items (2) and (3) and stay with the aircraft as well.

How long must I keep overhaul and rebuild records?

Overhaul and rebuild documentation is part of the aircraft's permanent status records, not the 1-year maintenance-record bucket. It is the underlying evidence for the current status of life-limited parts and the time since last overhaul -- both of which 14 CFR 91.417(a)(2)(ii)-(iii) require to be retained and transferred with the aircraft on sale (91.417(b)(2)). Keep these records for the service life of the part or aircraft; do not discard them after a year.

How long must a Part 135 operator keep load manifests?

At least 30 days. Under 14 CFR 135.63(d), the certificate holder must keep copies of completed load manifests for at least 30 days at its principal operations base, or at another location it uses that is approved by the Administrator. The load manifest must be prepared before each takeoff. Many operators retain manifests longer, but 30 days is the regulatory minimum.

How long must Part 135 crewmember and training records be kept?

At least 12 months. 14 CFR 135.63(b) requires the certificate holder to keep each crewmember and aircraft dispatcher record described in 135.63(a)(4) and (a)(5) -- qualification, training, currency, and flight/duty-time records -- for at least 12 months. The aircraft equipment/record list under 135.63(a)(3) must be kept for at least 6 months. These are minimums; operators often retain personnel and training records considerably longer.

How long must aviation drug and alcohol testing records be kept?

Retention is tiered by record type under 14 CFR Part 120 and 49 CFR 40.333. Keep for 5 years: verified positive drug tests, alcohol results of 0.02 or greater, refusals to test, Substance Abuse Professional (SAP) reports, and follow-up testing records. Keep for 3 years: testing information received from an employee's previous employers. Keep for 2 years: evidential breath testing device (EBT) calibration and maintenance records. Keep for 1 year: negative and cancelled drug results and alcohol results below 0.02. Records must be stored in a secure, access-controlled location (14 CFR 120.219).

Does 14 CFR 43.9 set a retention period for maintenance records?

No. 14 CFR 43.9 sets what each maintenance, preventive maintenance, rebuilding, and alteration record entry must contain -- a description of the work, the completion date, and the signature, certificate number, and kind of certificate held by the person approving the return to service. The retention period for those records comes from 14 CFR 91.417(b) (general aviation) or 14 CFR 135.439(b) (Part 135): until superseded or 1 year for work records, and permanently/transferred with the aircraft for the 91.417(a)(2) status records. Major repairs and alterations additionally require an FAA Form 337 under 43.9(d) and Appendix B to Part 43.

Can FileFlo track aircraft records retention windows automatically?

Yes. FileFlo classifies each aircraft document to its CFR citation, then tracks the applicable retention window -- the until-superseded-or-1-year clock on 91.417(a)(1) work records, the permanent "transfers with the aircraft" status on 91.417(a)(2) records, the 30-day load-manifest minimum under 135.63(d), and the 1/2/3/5-year drug-and-alcohol tiers under 49 CFR 40.333. It flags missing or expiring records before an inspection and exports an inspector-ready audit binder organized by CFR cite. FileFlo is the records and proof layer; it does not replace your maintenance-tracking, dispatch, or safety management systems.

Authoritative sources

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