Part 135 Pilot Training Records Requirements: What to Keep and How Long

Last reviewed June 16, 2026 · By Chad Griffith

Under 14 CFR 135.63, a Part 135 certificate holder must keep each pilot and flight attendant individual record for at least 12 months, and 14 CFR 135.323(c) requires every training and check certification to be made a part of the crewmember's record. Records must be detailed enough to prove qualifications and flight-time compliance.

How long must Part 135 operators keep pilot training records?

Part 135 operators must keep each pilot and flight attendant individual record for at least 12 months. 14 CFR 135.63(b) states that records required by paragraphs (a)(4) and (a)(5) must be retained for at least 12 calendar months, while completed load manifests for multiengine aircraft are kept for at least 30 days under 135.63(d) and certain aircraft maintenance records for at least 6 months under 135.63(b).

The 12-month minimum is a floor, not a recommended ceiling. Because FAA inspectors and auditors routinely look back across multiple recurrent cycles, many operators retain pilot training and qualification records for the duration of employment plus several years. Recurrent intervals span 6 to 12 months (see below), so a strict 12-month purge can leave you unable to demonstrate a continuous compliance trail. The safest practice is to keep the current record plus the immediately preceding cycle so no expiration window has an undocumented gap.

What must each pilot training record contain? (14 CFR 135.63(a)(4))

14 CFR 135.63(a)(4) requires the certificate holder to maintain an individual record for each pilot that is detailed enough to determine the pilot's qualifications and flight-time compliance. Required contents include the pilot's full name; the pilot's aeronautical experience in sufficient detail to determine qualifications; the pilot's current duties and the date of assignment to those duties; the pilot's flight time in sufficient detail to determine compliance with the applicable flight-time limitations; the airman certificate and ratings held and the medical certificate's class and effective date.

The record must also capture the date and result of each initial and recurrent competency test, proficiency check, and route check, the date the pilot completed (or successfully completed) the initial phase and each recurrent phase of training, and, where applicable, the pilot's check airman authorization status and any action taken to disqualify a pilot for cause. For flight attendants, 135.63(a)(5) requires an individual record in sufficient detail to determine compliance with the applicable duty-period and rest provisions of 14 CFR 135.273, retained for the same 12-month minimum.

Training certifications become part of the crewmember's record (135.323)

14 CFR 135.323 governs the certificate holder's training program, and subsection (c) ties training directly to recordkeeping: when an instructor, supervisor, or check pilot certifies that a crewmember has satisfactorily completed required training or a required check, that certification "shall be made a part of the crewmember's record." In other words, training is not complete for compliance purposes until the certification is captured in the individual file.

135.323(c) also expressly permits computerized recordkeeping systems, provided the certifying instructor, supervisor, or check pilot is identified with the entry. This matters for digital compliance: an electronic training record is acceptable to the FAA, but only if each completion or check entry is attributable to the person who signed it off. The broader approved-training-program structure lives in 14 CFR 135.341 through 135.351, and under 135.341(a) every certificate holder except one that uses only one pilot must establish and maintain an FAA-approved pilot training program.

Pilot testing and check intervals that drive your records

The recurrent intervals are what make pilot records perishable, and each generates a dated entry you must be able to produce on demand. Under 14 CFR 135.293, no person may serve as a pilot unless, since the beginning of the 12th calendar month before that service, the pilot has passed the written or oral test in 135.293(a) and the competency check in 135.293(b). Under 14 CFR 135.297, a pilot in command may not fly under IFR unless an instrument proficiency check was passed since the beginning of the 6th calendar month before that service. Under 14 CFR 135.299, a pilot in command may not serve unless a line check (routes and airports) was passed since the beginning of the 12th calendar month before that service.

Practically, that means the typical Part 135 PIC carries at minimum a 12-month competency check, a 6-month instrument proficiency check, and a 12-month line check running on different clocks. Miss any one window and the pilot is ineligible to serve in that capacity until requalified, even if the other items are current. The records function is therefore an expiration-tracking problem first and a filing problem second.

Where Part 135 operators lose points on a records audit

The most common findings are not missing training; they are missing or untraceable proof of training. Inspectors flag records that lack the date and result of a specific check, entries that cannot be attributed to the certifying check pilot as 135.323(c) requires, expiration windows that lapsed between recurrent cycles, and flight-time detail too thin to verify 135.293 currency. Because the IPC runs on a 6-month clock while competency and line checks run on 12-month clocks, a single pilot can have three different next-due dates, and a spreadsheet maintained by hand routinely drifts out of sync.

This proof-and-expiration problem is exactly what document-intelligence tooling addresses. FileFlo classifies each uploaded compliance document to its specific CFR citation (for example, tagging a completed competency check to 14 CFR 135.293), reads the relevant dates, and tracks expirations with 90/60/30/7-day alerts so no recurrent window closes silently. It flags missing records against the set a Part 135 pilot file should contain and exports an inspector-ready audit binder on demand. FileFlo is the records and proof layer; it is not your learning-management system, flight-operations system, or maintenance-tracking system, and it does not deliver training or run your Safety Management System.

Building an audit-ready pilot training records system

A defensible Part 135 pilot-records system has four properties. First, completeness: every item 135.63(a)(4) lists is present for every active pilot, plus the 135.323(c) training certifications. Second, attribution: each check or completion entry identifies the certifying instructor or check pilot, which 135.323(c) requires even for computerized systems. Third, currency tracking: each perishable item (the 12-month competency check and line check, the 6-month IPC) has a visible next-due date and an alert before it expires. Fourth, retrievability: you can produce a complete, organized file per pilot within minutes when an inspector asks.

Operators meet these requirements with a mix of an FAA-approved training program (135.341), disciplined recordkeeping, and a tracking layer over the documents themselves. Whether you build that layer in software or maintain it manually, the test is the same one the FAA applies: can you prove, for any pilot on any date, that every required test, check, and training phase was current and the certification was on file? FileFlo automates the classification, expiration tracking, and audit-binder export side of that test so the underlying records stay continuously demonstrable rather than reconstructed under audit pressure.

Digital vs. paper pilot training records: what the FAA accepts

The FAA accepts electronic pilot training records. 14 CFR 135.323(c) expressly allows a certificate holder to use a computerized recordkeeping system, with the single condition that the certifying instructor, supervisor, or check pilot is identified with each entry. There is no regulatory requirement that the original be paper, so a properly attributed digital file satisfies the same 135.63 retention and content rules as a paper one.

The practical advantage of digital records is not storage; it is currency and retrieval. A digital system can compute each pilot's next-due dates across the 6- and 12-month check intervals, surface them before they lapse, and assemble a per-pilot binder for an inspector instantly, none of which a filing cabinet can do. The risks to manage are attribution (preserving who signed off each entry, per 135.323(c)), retention integrity over the 12-month minimum, and access control. A system that classifies each document to its CFR citation and timestamps its expiration directly addresses the failure modes that turn a routine records review into a finding.

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