How to Organize Aviation Compliance Documents: A Part 135 System
Last reviewed · By Chad Griffith
Organize aviation compliance documents by mapping every file to its governing 14 CFR citation, separating the records that must travel aboard the aircraft (the ARROW documents) from the records kept at your principal base under 14 CFR 135.63, and tracking each document against its regulatory expiration so nothing lapses before an FAA inspector asks for it.
Why organization decides whether you pass an audit
In an FAA Part 135 surveillance inspection or a Compliance Review, the most common finding is not that a record never existed — it is that a current record could not be produced: a medical certificate that lapsed, a six-month instrument proficiency check that slipped, or a load manifest that could not be found inside its 30-day window. Organization is therefore not housekeeping; it is the difference between producing a complete, current record set on demand and failing for a gap you did not know you had.
The organizing principle: map every document to its CFR citation
The strongest aviation compliance filing systems are organized by the regulation each document satisfies, not by document type or by date. When a pilot competency check is labeled to 14 CFR 135.293, a medical to the airman medical rule, and a maintenance entry to 14 CFR 43.9, you can answer an inspector’s request instantly and, just as importantly, see at a glance whether anything required is missing. Filing by regulation turns a pile of PDFs into a provable compliance picture.
Separate what flies with the aircraft from what stays at the base
Two distinct sets exist, and conflating them is a frequent cause of ramp-check findings:
- Aboard the aircraft (the ARROW documents): the Airworthiness certificate (14 CFR 91.203), the Registration certificate (14 CFR 91.203), a Radio station license if operating internationally, the Operating limitations / approved Flight Manual (14 CFR 91.9), Weight-and-balance data, plus the MEL and its letter of authorization if equipment is deferred (14 CFR 91.213), and for multiengine Part 135 the completed load manifest (14 CFR 135.63).
- At the principal base (14 CFR 135.63): the operating certificate, operations specifications, current aircraft list, individual pilot and flight-attendant records, training records, maintenance and airworthiness-directive records, and the drug and alcohol program (14 CFR Part 120).
The record categories to organize
A complete Part 135 documentation system has five buckets, each on its own retention clock:
- Crew & pilot records — certificates, medicals, flight time, and currency-check results (14 CFR 135.63; kept 12 months).
- Training records — proof of completed, certified training (14 CFR 135.323).
- Maintenance & airworthiness records — inspection signoffs, AD compliance, life-limited-part status (14 CFR 91.417, 43.9; status records transfer with the aircraft).
- Drug & alcohol program records — 14 CFR Part 120.
- Operational documents — certificate, OpSpecs, aircraft list, load manifests (14 CFR 135.63).
Track expirations, do not just store files
Storage is static; compliance is dynamic. Every category above contains dates — medicals, recurrent training, the six-month instrument proficiency check (14 CFR 135.297), annual inspections, AD next-due times, registration. A system that only files documents will still fail when one quietly expires. The organizing system must surface what is expiring before it lapses, which is why an “expiring soon” view at 90/60/30/7 days is the single highest-value feature of any aviation compliance filing method.
Paper, shared drives, and where FileFlo fits
Most operators start with a hangar filing cabinet or a shared drive of folders. Both store documents; neither knows which regulation a file satisfies or when it expires, so the organizing and expiration-tracking work falls on a person. FileFlo is the records-and-proof layer that automates exactly that: it reads each uploaded document, classifies it to its CFR citation, tracks the expiration against the regulatory interval with 90/60/30/7-day alerts, flags records missing from the expected set, and exports an inspector-ready audit binder on demand. To be clear about scope, FileFlo does not run your SMS, dispatch/FOS, or maintenance-tracking system — it organizes and proves the documents those systems generate. Starter $89/mo, Professional $299/mo, 5-day free trial (FileFlo is not SOC 2 certified).
Frequently Asked Questions
How should I organize Part 135 compliance documents?
Organize them by the regulation each document satisfies rather than by type or date. Map every file to its 14 CFR citation (for example, a competency check to 135.293, a maintenance entry to 43.9), separate the records that must travel aboard the aircraft (the ARROW documents) from the records kept at your principal base under 14 CFR 135.63, and track each document’s expiration against its regulatory interval so a lapse surfaces before an inspector finds it.
What documents must be aboard the aircraft versus at the base?
Aboard the aircraft: the ARROW documents — Airworthiness certificate and Registration (14 CFR 91.203), a Radio license if international, Operating limitations / approved Flight Manual (91.9), Weight-and-balance data, the MEL and its letter of authorization if equipment is deferred (91.213), and for multiengine Part 135 the completed load manifest (135.63). At the principal base: the operating certificate, OpSpecs, aircraft list, pilot and flight-attendant records, training records, maintenance and AD records, and the drug and alcohol program (Part 120), per 14 CFR 135.63.
What is the best way to file aviation records for an FAA audit?
File to the CFR citation and keep the set current and complete. Inspectors request the same records every time, so a system indexed to the rule lets you produce a complete package in minutes instead of assembling folders under pressure. The most common audit finding is a missing or expired required document, so the filing method must also track expirations, not just store files.
How do I track aviation document expirations?
Record the controlling date for every dated item — medicals, recurrent training, the six-month instrument proficiency check (14 CFR 135.297), annual inspections, AD next-due times, and registration — and surface anything approaching its limit, typically at 90, 60, 30, and 7 days out. The goal is to catch a lapse weeks before an inspector does, since an expired required document discovered during surveillance is an immediate finding.
Should aviation compliance records be paper or digital?
The FAA accepts either, but digital records are far easier to keep audit-ready because they can be classified, searched, date-tracked, and produced on demand. Paper and generic shared drives store documents but cannot tell you which regulation a file satisfies or when it expires — that interpretation falls on a person, which is where gaps appear. A document-intelligence layer adds that regulatory awareness on top of the storage you already use.
How does FileFlo organize compliance documents?
FileFlo reads each uploaded document, classifies it to its exact CFR citation, tracks the expiration against the regulatory interval with 90/60/30/7-day alerts, flags records missing from the expected set, and exports an inspector-ready audit binder. It is the records-and-proof layer — not the SMS, dispatch, or maintenance-tracking system — and works on the cloud storage you already use, with no migration. Starter $89/mo, Professional $299/mo, 5-day free trial.
Authoritative sources
- 14 CFR 135.63 — Recordkeeping requirements (Cornell LII)
- 14 CFR 91.203 — Civil aircraft: certifications required aboard (Cornell LII)
- 14 CFR 91.9 — Flight manual, marking, and placard requirements (Cornell LII)
- 14 CFR 91.213 — Inoperative instruments and equipment / MEL (Cornell LII)
- FAA Order 8900.1 — Flight Standards Information Management System (FSIMS)