The checklist, mapped to the rule that already requires it
Each program sends its own request. The groups below are the ones both programs review, with the FAA rule that requires the same record.
| Area | Records to stage | Rule |
|---|---|---|
| Pilots | Certificates and ratings, medicals, checks, training and the check pilot authorizations | 14 CFR 135.63(a)(4) |
| Aircraft and maintenance | Inspection status, the maintenance records and the program the aircraft are on | 14 CFR 91.417, 91.409 |
| Manuals | The operations and maintenance manuals at their current revision | 14 CFR 135.21 |
| Safety management system | The SMS manual, hazard reports, risk assessments and the corrective actions that closed prior findings | 14 CFR Part 5 |
| Management personnel | Records that the Director of Operations, Chief Pilot and Director of Maintenance hold the qualifications for their roles | 14 CFR 119.69, 119.71 |
| Insurance | The certificate of insurance in force | Program request |
What each program says it reviews
Wyvern. Wyvern's PASS report checks each pilot's certification, type rating, flight time, current medical and training records.
ARGUS. ARGUS expanded its Gold audit standard in October 2025 to cover training programs, personnel qualifications, and recordkeeping and documentation systems, alongside safety management, operational control and maintenance.
Both programs set their own criteria and change them; the current request from the program is the list to work from.
The FAA side of the same records
The pilot record under 135.63(a)(4) holds the certificate and ratings, the medical, and the date and result of each required test and check. The aircraft's maintenance records are kept under 91.417, and the annual inspection is due every 12 calendar months under 91.409. The manual is kept current under 135.21. The safety management system is required by Part 5. The management positions and their qualifications are set by 119.69 and 119.71.
An operator that keeps those records current for the FAA has most of an ARGUS or Wyvern request already answered.
Worked example: one request, three aircraft
Illustration, not an operator
A Part 135 operator with three aircraft and six pilots receives an audit request. Working it line by line:
- Pilots. Six pilot records under 135.63(a)(4). Five are complete. One pilot's most recent line check form is not in the file, so the record shows no 135.299 date. Pull the form from the check airman and file it before sending anything.
- Aircraft. For each tail, the last annual inspection entry (91.409) and the maintenance records (91.417). All three annuals fall within the last 12 calendar months.
- Manuals. The general operations manual on file is one revision behind the copy in the aircraft. File the current revision so the one produced is the one in force (135.21).
- SMS. The SMS manual, the hazard reports for the year and the corrective action that closed last cycle's finding.
- Management. The qualification records for the Director of Operations, Chief Pilot and Director of Maintenance (119.71).
Two fixes before sending: the missing line check form and the manual revision. Everything else answers its line as it stands.
Where FileFlo does the work
Most compliance tools track a date someone typed in and send a notice. FileFlo does the work behind the date: it reads each record, finds the date, checks it against the rule, files it where the rule wants it and works out what is due next, for every pilot, every aircraft and every recurring item. The certificate's documents are filed and shown as on file, and each aircraft's annual is watched on its 12-calendar-month cycle. When the auditor asks, the records are ready as of one date, tagged to the Wyvern Wingman clauses and the ARGUS audit categories. You approve what goes out, and your Director of Operations makes the operational decision.
Sources
Checked
- PASS reports, Wyvern. What a PASS report checks
- ARGUS enhances and expands Gold audit standard (October 13, 2025), AIN
- 14 CFR 135.63, recordkeeping requirements, eCFR
- 14 CFR 91.409 and 91.417, inspections and maintenance records, eCFR
- 14 CFR 135.21, manual requirements, eCFR
- 14 CFR 119.69 and 119.71, management personnel, eCFR
- 14 CFR Part 5, safety management systems, eCFR
Questions
Is an ARGUS or Wyvern audit an FAA requirement?
No. ARGUS and Wyvern are private audit and rating programs that operators choose to join, and charter brokers and clients use their ratings when they vet an operator. The FAA's own requirements are in 14 CFR Parts 119 and 135, and Part 5 for the safety management system.
What records do ARGUS and Wyvern auditors review?
Both programs review the pilots, the aircraft and their maintenance, the operator's manuals and procedures, the safety management system and the management team. Wyvern's PASS report checks each pilot's certification, type rating, flight time, current medical and training records. ARGUS's Gold standard, expanded in October 2025, covers training programs, personnel qualifications and recordkeeping and documentation systems.
How should an operator prepare the documents?
Start from the program's request, map each line to the record that answers it, and bring every pilot, aircraft and manual record current before the auditor opens the request. Most of those records are ones Part 135 already requires the operator to keep.
Does an ARGUS or Wyvern rating satisfy the FAA's SMS rule?
They are separate. Part 5 requires a Part 135 certificate holder to have a safety management system the FAA accepts through its own oversight. A well-documented SMS serves both the rule and the audit.