Part 135 Recordkeeping Requirements: Every Record the FAA Expects

Last reviewed May 7, 2026 · By Chad Griffith

Under 14 CFR Part 135, an air carrier must keep five categories of records audit-ready: (1) pilot and crewmember records (14 CFR 135.63) covering certificates, medicals, flight time, and the results of recurrent testing, instrument proficiency checks, and line checks (14 CFR 135.293, 135.297, 135.299); (2) training records certifying crewmember proficiency (14 CFR 135.323); (3) aircraft maintenance and airworthiness records (14 CFR 91.417 and 43.9 for aircraft with 9 or fewer seats, or 135.439 for 10 or more seats) plus the onboard maintenance log (14 CFR 135.65); (4) a drug and alcohol testing program with records under 14 CFR Part 120; and (5) operational documents including the operating certificate, operations specifications, current aircraft list, and load manifests (14 CFR 135.63). Retention periods vary: pilot and crewmember records are kept at least 12 calendar months, aircraft records at least 6 months, load manifests at least 30 days, and maintenance records until the work is repeated or superseded or for at least 1 year, with airworthiness status records transferred with the aircraft at sale.

The five record categories every Part 135 operator must keep

FAA Part 135 recordkeeping is not a single list in one section. The requirements are spread across Part 135 (operations and crew), Part 91 and Part 43 (maintenance), and Part 120 (drug and alcohol). For most on-demand and commuter operators, the obligation breaks into five buckets that a Principal Operations Inspector (POI) or Principal Maintenance Inspector (PMI) will expect to see produced on demand:

• Crew and pilot records — certificates, ratings, medicals, flight time, and currency-check results (14 CFR 135.63).
• Training records — proof each crewmember completed and was certified proficient in required training (14 CFR 135.323).
• Maintenance and airworthiness records — inspection signoffs, AD compliance, life-limited-part status, and the onboard maintenance log (14 CFR 91.417, 43.9, 135.65, and 135.439).
• Drug and alcohol program records — testing of safety-sensitive employees under an FAA-approved program (14 CFR Part 120).
• Operational and certificate documents — the air carrier certificate, operations specifications (OpSpecs), current aircraft list, and completed load manifests (14 CFR 135.63).

Each category has its own retention clock. Missing or expired records in any one bucket is the most common finding in a Part 135 surveillance inspection or certificate renewal.

Pilot and crewmember records (14 CFR 135.63)

Section 14 CFR 135.63, titled "Recordkeeping requirements," requires the certificate holder to keep, at its principal business office, an individual record for each pilot that includes the pilot's name; type and number of certificates and ratings; aeronautical experience sufficient to determine qualification; the pilot's current duties and the date assigned; the date and result of the latest competency and instrument proficiency checks and line checks; flight time so it can be determined the pilot meets currency rules; the status of the pilot's medical certificate; any check pilot authorization; and the dates and results of training and any disciplinary action. A comparable record showing compliance with applicable training requirements must be kept for each flight attendant.

• What it covers: certificates, ratings, medical status, flight time, and the dates and results of recurrent testing.
• Retention: pilot and flight-attendant records must be kept for at least 12 calendar months; the aircraft list and related aircraft records for at least 6 months.
• Where: at the certificate holder's principal business office (or an FAA-approved alternate).

The currency-check results referenced here are generated by three separate recurring requirements covered in the next section.

Pilot testing, proficiency, and line checks (14 CFR 135.293, 135.297, 135.299, 135.323)

The dated check results that live inside each pilot file under 135.63 come from four sections, each on its own clock:

• 14 CFR 135.293 — Initial and recurrent pilot testing requirements: each pilot must pass a written or oral knowledge test and a competency check; recurrent testing is required within the preceding 12 calendar months.
• 14 CFR 135.297 — Pilot in command: Instrument proficiency check requirements: a PIC may not serve under IFR unless an instrument proficiency check was passed within the preceding 6 calendar months.
• 14 CFR 135.299 — Pilot in command: Line checks: Routes and airports: a PIC must pass a line check over a route segment with takeoffs and landings at representative airports within the preceding 12 calendar months.
• 14 CFR 135.323 — Training program: General: the instructor, supervisor, or check airman must certify each crewmember's proficiency and knowledge, and "that certification shall be made a part of the crewmember's record." If kept in a computerized system, the certifying person must be identified with the entry.

Because these intervals differ (6 vs. 12 calendar months) and are measured from the beginning of the calendar month, tracking them by hand is where most operators drift out of currency without realizing it.

Maintenance and airworthiness records (14 CFR 91.417, 43.9, 135.65, 135.439)

Maintenance recordkeeping depends on the aircraft's certificated seating configuration, per 14 CFR 135.411 ("Applicability"):

• Aircraft with 9 or fewer passenger seats are maintained under Parts 91 and 43 (plus 135.415, 135.417, 135.421, and 135.422). The owner/operator's records under 14 CFR 91.417 ("Maintenance records") include maintenance and inspection signoffs, total time in service, life-limited-part status, time since last overhaul, current inspection status, and airworthiness-directive (AD) compliance. Each maintenance entry must meet 14 CFR 43.9 ("Content, form, and disposition of maintenance, preventive maintenance, rebuilding, and alteration records").
• Aircraft with 10 or more passenger seats are maintained under a continuous maintenance program (135.415, 135.417, and 135.423 through 135.443), with recordkeeping under 14 CFR 135.439 ("Maintenance recording requirements").
• Onboard log: 14 CFR 135.65 ("Reporting mechanical irregularities") requires an aircraft maintenance log carried in the aircraft; the PIC enters mechanical irregularities and reviews the status of prior entries before each flight.

Maintenance retention (91.417): work records (91.417(a)(1)) are kept until the work is repeated or superseded, or for 1 year after the work is performed; status records (91.417(a)(2)) — total time, AD compliance, life-limited parts, major alterations — are retained and transferred with the aircraft when it is sold. Note: FileFlo tracks and proves these records; it is not a maintenance-tracking or airworthiness system of record.

Drug & alcohol, OpSpecs, and load manifests (14 CFR Part 120, 135.63)

Two more obligations round out the record set:

• Drug and alcohol testing — 14 CFR Part 120 ("Drug and Alcohol Testing Program"): Part 135 certificate holders must implement an FAA-approved program testing employees who perform safety-sensitive functions (including flight crew, flight attendants, dispatchers, maintenance, ground security, and aviation screeners), and must retain testing and program records as Part 120 specifies. This is administered consistent with the certificate holder's Antidrug and Alcohol Misuse Prevention Program described in its operations specifications.
• Operations specifications and certificate documents — 14 CFR 135.63: the operating certificate, current OpSpecs, and a current list of aircraft (with type, registration, and the kinds of operations authorized) must be maintained at the principal business office.
• Load manifests — 14 CFR 135.63(c)–(d): for multiengine aircraft, the certificate holder prepares a load manifest in duplicate before each takeoff (passenger/crew count and positions, total weight, maximum allowable takeoff weight, CG limits and actual CG, and registration or flight number). The PIC carries a copy to the destination, and the certificate holder keeps completed load manifests for at least 30 days.

Retention periods at a glance

Different records have different mandatory retention clocks under Part 135 and the maintenance rules. The shortest clocks are the ones operators most often miss:

• Load manifests: at least 30 days (14 CFR 135.63).
• Aircraft list / aircraft records: at least 6 months (14 CFR 135.63).
• Pilot and flight-attendant records: at least 12 calendar months (14 CFR 135.63).
• Maintenance work records: until the work is repeated or superseded, or 1 year after it is performed (14 CFR 91.417(a)(1)).
• Airworthiness status records (total time, AD compliance, life-limited parts, major alterations): retained and transferred with the aircraft at sale (14 CFR 91.417(a)(2)).
• Drug & alcohol program records: per the retention schedule in 14 CFR Part 120 (varies by record type, from 1 to 5 years).

Note that the 12-calendar-month and 6-calendar-month testing intervals (135.293, 135.297) are currency windows, not record-retention windows — the underlying check results stay in the pilot file under 135.63.

How Part 135 operators keep these records audit-ready

The hard part of Part 135 recordkeeping is not knowing the rules — it is keeping every record current, complete, and instantly producible across crew, training, maintenance, and drug-and-alcohol files when an inspector or auditor asks. Operators commonly fail surveillance not because a record never existed, but because a medical lapsed, a 6-month instrument proficiency check slipped, or a load manifest could not be located inside the 30-day window.

FileFlo is the records and proof layer for this. It classifies every uploaded compliance document to its governing CFR citation, tracks expirations with 90/60/30/7-day alerts (so a 6-month IPC or a lapsing medical surfaces before it becomes a finding), flags records that are missing from the expected set, and exports an inspector-ready audit binder organized by requirement. To be clear about scope: FileFlo proves and organizes the records — it is not the Safety Management System (SMS), the dispatch/FOS, or the maintenance-tracking system of record. It sits alongside those systems and turns the documents they generate into demonstrable, audit-ready compliance.

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