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Aviation Compliance — Master Records Retention Pillar

Aviation Records Retention Schedule: How Long to Keep Every FAA/DOT Record

There is no single retention clock. This is the master matrix — every FAA and DOT compliance record mapped to its exact CFR citation and minimum retention period, from a 30-day load manifest to the life of the aircraft. The hub every deep-dive in our aviation library links back to.

Chad Griffith, Founder & CEOReviewed: June 11, 202614 min read

This is a compliance-document perspective, not legal or airworthiness advice. Retention periods are regulatory minimums; your OpSpecs, CHDO guidance, or SMS policy may require longer. Verify every period against the current published eCFR — it is the authoritative current text — and against your specific operation.

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Direct Answer — How Long Do You Keep Aviation Compliance Records?

There is no single aviation retention period — each record type has its own clock, ranging from 30 days to the life of the aircraft. The seven controlling clocks:

  1. Routine maintenance entries — until the work is repeated or superseded, or 1 year after performed (14 CFR §91.417(b)(1)).
  2. Permanent aircraft status records — total time, life-limited parts, AD status, inspection status, Form 337 copies — kept for the life of the aircraft and transferred with it on sale (§91.417(b)(2); CAMP analogue §135.439(b)).
  3. Part 135 crew records — at least 12 months; the aircraft list at least 6 months; load manifests at least 30 days (§135.63(b)–(d)).
  4. Repair station records — at least 2 years from return to service (§145.219(c)).
  5. Drug & alcohol records — 5 / 3 / 2 / 1-year tiers (49 CFR §40.333).
  6. SMS records — safety assurance min 5 years, communications min 24 months, training while employed, SRM while the control is relevant (14 CFR §5.97).
  7. PRD historical records — at least 5 years after reporting (§111.255(e)).

Source: eCFR 14 CFR §§91.417, 135.63, 135.439, 145.219, 5.97, 111.255; 49 CFR §§40.333, 172.704, 830.10. All periods are minimums unless OpSpecs require longer. After a reportable accident/incident, §830.10 imposes an absolute preservation hold.

The single most expensive recordkeeping mistake in aviation is assuming one retention rule covers everything. A maintenance entry you were free to discard after a year is the same physical event that produced an aircraft-status record you must keep for the life of the aircraft. A drug test result might be a 1-year record or a 5-year record depending only on whether it was negative. And a record you would otherwise be allowed to shred becomes a mandatory preservation item the moment it relates to a reportable event under 49 CFR §830.10.

This page is the master reference that the rest of our aviation library links back to. Each row in the matrix below names the governing CFR section, the minimum retention period, and a note on the trap that catches operators. For the record-by-record obligations behind each row, follow the deep-dive links — start with What Records Must a Part 135 Operator Keep and Part 91 Aircraft Records Requirements.

30 days
Shortest schedule — completed load manifests at the principal operations base
14 CFR §135.63(c)–(d)
Life
Longest schedule — aircraft status records (total time, ADs, Form 337) transfer with the aircraft on sale
14 CFR §91.417(b)(2)
$75,000
Max civil penalty per violation (other than an individual/small business) for violations on or after Dec 30, 2024
14 CFR §13.301 (49 U.S.C. 46301)

A retention floor is not a filing strategy

Every period below is a minimum. Two things routinely turn a compliant operator into a non-compliant one anyway: discarding a record exactly at the floor when it still transfers with the aircraft, and keeping a record that exists but cannot be retrieved on demand. The FAA evaluates the record it can see — an archived box in a hangar you cannot produce during a surveillance visit is, for enforcement purposes, a missing record.

The Master Aviation Retention Matrix

Every required record mapped to the governing CFR cite and its minimum retention period. Click a category filter to isolate a section. Retention-tier color coding: amber = short (≤1 yr), blue = mid (1–3 yr), purple = long (≥5 yr or event-tied), orange = life of aircraft.

CategoryRecordCFR CiteRetention (minimum)
Maintenance
Maintenance, preventive maintenance, alteration, and required-inspection entries (work description, date, signature & certificate number of person approving return to service)
The "routine" maintenance clock. §91.417 does not apply to CAMP-maintained aircraft — see §91.401(b); those use §135.439 or §91.1411.
§91.417(a)(1), (b)(1)
Until repeated or superseded, or 1 year after work performed
Short (≤1 yr)
Maintenance
Total time in service of the airframe, each engine, each propeller, and each rotor
Permanent status record under §91.417(b)(2).
§91.417(a)(2)(i), (b)(2)
Life of aircraft — transferred with the aircraft on sale
Life of aircraft
Maintenance
Current status of life-limited parts
Engines, propellers, rotors, and appliances with published life limits.
§91.417(a)(2)(ii), (b)(2)
Life of aircraft — transferred with the aircraft on sale
Life of aircraft
Maintenance
Time since last overhaul of items required to be overhauled on a specified time basis
Under §135.439 the last complete overhaul record is kept until superseded by work of equivalent scope and detail.
§91.417(a)(2)(iii), (b)(2)
Life of aircraft — transferred with the aircraft on sale
Life of aircraft
Maintenance
Current inspection status of the aircraft (time since the last required inspection)
The 12-calendar-month annual interval (§91.409(a)) is an inspection deadline, NOT a retention period — do not confuse the two.
§91.417(a)(2)(iv), (b)(2)
Life of aircraft — transferred with the aircraft on sale
Life of aircraft
Maintenance
Current status of applicable airworthiness directives (AD number, method of compliance, recurring-AD next-due)
A purchased tail with an undocumented AD history is a constructive non-compliance finding.
§91.417(a)(2)(v), (b)(2)
Life of aircraft — transferred with the aircraft on sale
Life of aircraft
Maintenance
Copies of the forms prescribed by §43.9(d) for each major alteration (FAA Form 337, per part 43 appendix B)
Major-repair Form 337 records fall under §91.417(a)(1) — the until-repeated-or-superseded / 1-year rule.
§91.417(a)(2)(vi), (b)(2)
Life of aircraft — transferred with the aircraft on sale
Life of aircraft
Maintenance
Maintenance/alteration record ENTRY content (description, date, name, signature, certificate number & kind)
§43.9 governs maintenance entries; §43.9(c) excludes persons performing inspections — inspection entries are made under §43.11.
§43.9(a)
Per the §91.417 / §135.439 clock for the record it lives in
Short (≤1 yr)
Maintenance
Inspection record ENTRY content (type/extent, date, aircraft total time, return-to-service certification statement)
Separate section from §43.9 — inspection entries, not maintenance entries.
§43.11(a)
Per the §91.417 / §135.439 clock for the record it lives in
Short (≤1 yr)
Part 135 Ops
Individual pilot record (certificate type, aeronautical experience, duties, medical status, competency/check results, training completion)
In practice kept for duration of employment — feeds Part 111 PRD reporting and must be produced on FAA request.
§135.63(a)(4), (b)
At least 12 months
Mid (1–3 yr)
Part 135 Ops
Individual flight attendant record (where flight attendants are required)
Same 12-month floor as pilot records under §135.63(b).
§135.63(a)(5), (b)
At least 12 months
Mid (1–3 yr)
Part 135 Ops
Current list of aircraft used or available for use, and the operations each is equipped for
A shorter floor than crew records — §135.63(b) sets 6 months for the (a)(3) list specifically.
§135.63(a)(3), (b)
At least 6 months
Mid (1–3 yr)
Part 135 Ops
Completed load manifest (multiengine aircraft) — weight, CG, crew, origin/destination
PIC carries a copy to the destination; the operator keeps copies for 30 days.
§135.63(c)–(d)
At least 30 days at the principal operations base
Short (≤1 yr)
Part 135 Ops
Airworthiness release or maintenance-log entry before return to service (aircraft on a §135.411(a)(2) maintenance program)
Four-part certification; aircraft with 9 or fewer seats return to service under part 43 (§43.5/§43.9) instead.
§135.443
Until repeated/superseded or 1 year (the §135.439(a)(1) record)
Short (≤1 yr)
Part 135 Ops
CAMP maintenance records — release-supporting records (a)(1) and aircraft status records (a)(2)
The CAMP analogue to §91.417; applies to aircraft type certificated for 10+ seats on a continuous airworthiness program.
§135.439(a), (b)
(a)(1): until repeated/superseded or 1 year · (a)(2): life of aircraft (transfer on sale)
Life of aircraft
Drug & Alcohol
Alcohol results ≥ 0.02; verified positive drug results; refusals; SAP reports; follow-up tests & schedules
Incorporated for aviation through 14 CFR Part 120. The evidentiary backbone of any enforcement action.
49 CFR §40.333(a)(1)
5 years
Long (≥5 yr / event-tied)
Drug & Alcohol
Information obtained from previous employers under §40.25 (prior D&A test history)
The only 3-year tier — frequently misfiled with the 5-year positive results.
49 CFR §40.333(a)(2)
3 years
Mid (1–3 yr)
Drug & Alcohol
Inspection, maintenance, and calibration of evidential breath testing devices (EBTs)
Equipment records — distinct from the test-result tiers.
49 CFR §40.333(a)(3)
2 years
Mid (1–3 yr)
Drug & Alcohol
Negative and cancelled drug test results; alcohol results below 0.02
The shortest D&A tier — but pre-employment negatives still gate the start of safety-sensitive duty.
49 CFR §40.333(a)(4)
1 year
Short (≤1 yr)
PRD (Part 111)
Historical records reported to the Pilot Records Database
A reporting-and-retention hybrid: report the record, then retain it for 5 years after reporting.
§111.255(e)
At least 5 years after reporting those records
Long (≥5 yr / event-tied)
PRD (Part 111)
Drug and alcohol testing events reported to the PRD (verifications, results, refusals)
This is a REPORTING deadline, not a retention period — the underlying record is still retained per §40.333.
§111.220
Reporting window: within 30 days of the occurrence
Short (≤1 yr)
SMS (Part 5)
Safety risk management records (hazard logs, risk assessments, risk-control documentation)
No fixed number — tied to the lifecycle of the risk control itself.
§5.97(a)
As long as the control remains relevant to the operation
Long (≥5 yr / event-tied)
SMS (Part 5)
Safety assurance records (audits, performance monitoring, assessment outputs, corrective actions)
Supports trend analysis and ASAP/FOQA correlation across audit cycles.
§5.97(b)
Minimum 5 years
Long (≥5 yr / event-tied)
SMS (Part 5)
SMS training records
Employment-tied, like the §172.704 hazmat training analogue.
§5.97(c)
As long as the individual is employed by the person
Long (≥5 yr / event-tied)
SMS (Part 5)
Safety communication records (§5.93 safety communication)
Applies to ALL Part 135 holders; SMS + declaration of compliance due May 28, 2027 (no fleet-size threshold).
§5.97(d)
Minimum 24 consecutive calendar months
Mid (1–3 yr)
Repair Station
Repair station records of work performed and the maintenance release for each article returned to service
Independent of the owner/operator clock — the same work creates a station record and an owner entry.
§145.219(c)
At least 2 years from the date the article was approved for return to service
Mid (1–3 yr)
Hazmat
Hazmat employee training records (inclusive of the preceding 3 years of training)
Recurrent training is required at least every 3 years (§172.704(c)) — the 3 years is the interval, not the retention.
49 CFR §172.704(d)
Duration of employment as a hazmat employee + 90 days thereafter
Long (≥5 yr / event-tied)
Registration
Certificate of Aircraft Registration (validity / renewal cycle)
This is a certificate validity period, not a document-retention rule — but the expiration is a hard operational deadline.
§47.40
Expires 7 years after the last day of the month in which it is issued (renewable)
Long (≥5 yr / event-tied)
Accident/Incident
Preservation of wreckage, cargo, mail, and ALL records (incl. flight/maintenance/voice recordings) after a reportable event
An absolute hold that overrides normal schedules. Immediate notice: §830.5; written report: §830.15.
49 CFR §830.10(a)
Until the NTSB takes custody or a release is granted (§831.12(b))
Long (≥5 yr / event-tied)
OSHA (if applicable)
OSHA 300 Log, 300-A annual summary, and 301 incident reports (ground/maintenance personnel)
Applies to covered ground operations (MRO, FBO, line-service employers), not the flight operation itself.
29 CFR §1904.33(a)
5 years following the end of the calendar year the records cover
Long (≥5 yr / event-tied)

Retention periods are regulatory minimums. Your OpSpecs, CHDO guidance, or SMS policy may impose longer requirements, and a reportable accident/incident triggers an absolute preservation hold under 49 CFR §830.10. Always verify against the current published eCFR.

The Seven Clocks, Explained

Why each clock exists, what it covers, and the deep-dive that walks through the records inside it.

1. The routine maintenance clock — until repeated/superseded or 1 year

Under 14 CFR §91.417(b)(1), the records of maintenance, preventive maintenance, alterations, and the 100-hour, annual, progressive, and other required or approved inspections must be retained until the work is repeated or superseded by other work, or for 1 year after the work is performed — whichever the operator reaches. The logic is that once you have re-done a task, the prior record of that task is no longer the controlling evidence of airworthiness. This clock does not apply to aircraft maintained under a continuous airworthiness maintenance program, because §91.401(b) exempts CAMP-maintained aircraft from §§91.405, 91.409, 91.411, 91.417, and 91.419 — those aircraft use §135.439 (CAMP recordkeeping) or §91.1411 for fractional programs.

Deep dives: §43.9 maintenance entry requirements, §91.409 annual/100-hour inspections, and FAA Form 337 major repair/alteration records.

2. The life-of-aircraft clock — records that transfer on sale

The §91.417(a)(2) status records — total time in service of the airframe, each engine, propeller, and rotor (a)(2)(i); current status of life-limited parts (a)(2)(ii); time since last overhaul of items overhauled on a time basis (a)(2)(iii); current inspection status (a)(2)(iv); current status of applicable airworthiness directives (a)(2)(v); and copies of the forms prescribed by §43.9(d) for each major alteration (a)(2)(vi) — must, under §91.417(b)(2), be retained and transferred with the aircraft when it is sold. These are the records that establish the airworthiness lineage of the airframe across owners. An operator who buys a tail without a complete AD and life-limited-parts history inherits the gap.

Deep dives: AD compliance records, life-limited parts records, engine & propeller overhaul time tracking, and weight & balance records.

3. The Part 135 operations clock — 30 days, 6 months, 12 months

Even inside one section the floors differ. Under §135.63(b), the current aircraft list (§135.63(a)(3)) is kept for at least 6 months, while each individual pilot record (§135.63(a)(4)) and flight attendant record (§135.63(a)(5)) is kept for at least 12 months. Completed load manifests are kept for at least 30 days at the principal operations base (§135.63(c)–(d)). Because crew records feed Pilot Records Database reporting under Part 111 and must be produced on FAA request, most operators keep them for the duration of employment regardless of the 12-month floor.

Deep dives: Part 135 pilot records, training program recordkeeping, flight time / duty / rest records, and pilot logbook vs. operator records (§61.51).

4. The drug & alcohol clock — 5 / 3 / 2 / 1 years

DOT testing records under 49 CFR §40.333 (incorporated for aviation through 14 CFR Part 120) split into four tiers. Five years: alcohol results of 0.02 or greater, verified positive drug results, refusals, SAP reports, and follow-up tests and schedules (§40.333(a)(1)). Three years: previous-employer information obtained under §40.25 (§40.333(a)(2)). Two years: inspection, maintenance, and calibration of evidential breath testing devices (§40.333(a)(3)). One year: negative and cancelled drug results and alcohol results below 0.02 (§40.333(a)(4)). The single most common filing error is letting a negative result (1 year) get co-mingled with positives (5 years), or filing the §40.25 previous-employer record on the 5-year shelf when it is a 3-year record.

Deep dive: Part 135 drug & alcohol program records checklist.

5. The SMS clock — 24 months, 5 years, while-employed, while-relevant

The 2024 SMS final rule (14 CFR Part 5) made SMS retention a regulation rather than a practice. Under §5.97: safety risk management records are kept as long as the control remains relevant to the operation (a); safety assurance records are kept a minimum of 5 years (b); training records are kept as long as the individual is employed (c); and safety communication records are kept a minimum of 24 consecutive calendar months (d). The rule applies to ALL Part 135 certificate holders regardless of fleet size, with a single compliance date of May 28, 2027 — there is no aircraft-count threshold.

Deep dive: FAA Part 135 SMS 2027 deadline.

6. The repair station clock — at least 2 years from return to service

A certificated repair station must retain its §145.219 records for at least 2 years from the date the article was approved for return to service (§145.219(c)), and must make them available to the FAA and NTSB. This clock runs independently of the owner/operator clock: the same engine overhaul produces a station record kept under §145.219(c) and an owner record kept under §91.417 or §135.439. An operator relying on a station to hold the only copy of a critical maintenance record is exposed when the station's 2-year window closes before the operator's life-of-aircraft obligation does.

Deep dives: Part 145 repair station recordkeeping and the Part 145 audit binder.

7. The PRD & accident-hold clocks — 5 years after reporting, and the absolute hold

Two clocks behave unlike the others. Under 14 CFR §111.255(e), an operator must maintain the historical records it reports to the Pilot Records Database for at least 5 years after reporting them — a retention clock that starts at the moment of reporting, not the moment the record is created (and note §111.220 requires drug/alcohol events to be reported within 30 days). The second is not a retention period at all: under 49 CFR §830.10(a), after a reportable accident or incident the operator must preserve all records — including flight, maintenance, and voice recordings — pertaining to the operation and maintenance of the aircraft and to the airmen, until the NTSB takes custody or grants a release under §831.12(b). This is an absolute hold that overrides every other schedule on this page.

Related: service difficulty reports (SDRs) and required management personnel who own the response.

Six Retention Traps That Catch Compliant Operators

These are the failure patterns where an operator who genuinely complied still ends up with a finding. None of them are about doing the work wrong — they are about the records.

Confusing an inspection interval with a retention period

The 12-calendar-month annual inspection deadline in §91.409(a) and the 24-calendar-month intervals for the §91.411/§91.413 altimeter, static, and transponder tests are deadlines for doing the work — not retention periods for the records. The inspection-status record itself is a §91.417(a)(2)(iv) life-of-aircraft record. Discarding it because "the inspection was more than a year ago" destroys a permanent record.

RVSM / altimeter / transponder inspection records

Shredding a maintenance entry that also feeds a life-of-aircraft record

The same work order that creates a 1-year §91.417(b)(1) entry also updates total time in service, AD status, and life-limited-parts status — all life-of-aircraft records under §91.417(b)(2). The 1-year clock applies to the work entry, not to the status it produced. Operators who purge "old maintenance paperwork" at the 1-year mark sometimes destroy the only documentation of a status record.

Part 91 aircraft records requirements

Filing a negative drug result on the 5-year shelf (or a positive on the 1-year shelf)

Under §40.333, the retention tier is determined entirely by the result. Negatives and sub-0.02 alcohol results are 1-year records; positives, refusals, and SAP reports are 5-year records; previous-employer §40.25 information is a 3-year record. A filing system organized by date rather than by result type guarantees mis-retention.

Drug & alcohol program records checklist

Assuming the repair station is keeping your records

A Part 145 station keeps its records for at least 2 years (§145.219(c)). The owner/operator obligation under §91.417 or §135.439 can run for the life of the aircraft. If you do not capture your own copy of the maintenance release and supporting records, the station can lawfully discard them long before your obligation ends.

Part 145 repair station recordkeeping

Treating SMS records as informal once 2027 passes

Before the 2024 rule, many operators handled hazard logs and safety communications informally. After May 28, 2027, §5.97 makes safety assurance records a 5-year obligation and safety communications a 24-month obligation. The same email that was once disposable is now a retention item.

FAA Part 135 SMS 2027 deadline

Letting a reportable event lapse the preservation hold

After a §830.5 reportable accident or incident, §830.10 requires preservation of all related records — including recordings — until the NTSB releases them. Normal retention schedules are suspended. An operator who continues a routine purge cycle during an open investigation can destroy evidence it was legally required to preserve.

Flight locating & flight release records

Retention by Operation Type

The matrix above is universal, but which clocks apply depends on how you operate. Jump to the deep-dive for your certificate or operation.

How FileFlo Keeps Every Clock On Time

FileFlo is a compliance document intelligence platform — a read-only proof layer that holds the records behind every row in the matrix above and tracks each one against its own retention clock. It classifies 600+ document types against the governing CFR cite, flags approaching expirations, and produces an inspector-format binder on demand. It does not run your SMS, dispatch flights, provide your safety program, or perform maintenance tracking — those stay in your existing systems. FileFlo keeps the documents that prove them, and makes sure the right clock is applied to each one.

Classifies each record to its governing CFR cite

Upload a maintenance release, a check-airman record, a §43.9 entry, or a D&A chain-of-custody and FileFlo classifies it against the correct section — so a negative drug result lands on the 1-year clock and a Form 337 lands on the life-of-aircraft clock automatically.

Tracks every retention clock, not just expirations

FileFlo distinguishes a record that can be retired at its floor from one that transfers with the aircraft on sale — and surfaces the difference before a purge cycle destroys a permanent record.

Inspector-format audit binder on demand

When a CHDO inspector or repair-station auditor requests records, FileFlo assembles a binder organized by CFR section with each document's retention status visible — no all-hands scramble through a hangar archive.

Preservation-hold awareness

Because §830.10 suspends normal schedules after a reportable event, FileFlo lets you flag records under an investigation hold so they are never auto-retired while the NTSB matter is open. It is the proof layer — not the investigation system itself.

See which of your records are on the wrong clock — in 5 minutes

The FAA readiness score tool benchmarks your operation against the record categories in this matrix and surfaces the gaps before your CHDO does. Free, no signup required. FileFlo Professional ($299/mo, no credit card, 5-day free trial) then keeps every record on the correct retention clock year-round.

Check FAA Readiness Score — Free

Related Records & CFR Deep Dives

Frequently Asked Questions

Is there one master retention period for all aviation compliance records?

No. There is no single FAA-wide retention clock — each record type is governed by its own regulation, and the periods range from 30 days to the entire life of the aircraft. The mistake operators make is assuming one rule (often "keep everything 12 months" or "keep everything for the life of the aircraft") applies everywhere. In reality you are managing at least seven different clocks: maintenance entries (until repeated or superseded, or 1 year, under 14 CFR §91.417(b)(1)); permanent aircraft status records that transfer with the aircraft on sale (§91.417(b)(2)); Part 135 crew records (at least 12 months under §135.63(b)); repair station records (at least 2 years under §145.219(c)); drug and alcohol records (1 to 5 years under 49 CFR §40.333); SMS records (24 months to 5 years to life-of-control under 14 CFR §5.97); and Pilot Records Database historical records (at least 5 years after reporting under §111.255). This page maps each one to its exact citation.

How long must aircraft maintenance records be kept under §91.417?

Under 14 CFR §91.417(b)(1), the records described in §91.417(a)(1) — records of maintenance, preventive maintenance, alteration, and the 100-hour, annual, progressive, and other required or approved inspections, including the description of work, date of completion, and signature and certificate number of the person approving return to service — must be retained until the work is repeated or superseded by other work, or for 1 year after the work is performed. Separately, §91.417(b)(2) requires the §91.417(a)(2) status records — total time in service of the airframe, each engine, propeller, and rotor (a)(2)(i); current status of life-limited parts (a)(2)(ii); time since last overhaul of items overhauled on a time basis (a)(2)(iii); current inspection status (a)(2)(iv); current status of applicable airworthiness directives (a)(2)(v); and copies of the forms prescribed by §43.9(d) for each major alteration (a)(2)(vi) — to be retained and transferred with the aircraft at the time it is sold. So routine entries roll off after a year, but the permanent status records follow the aircraft for its entire life. Note §91.417 does not apply to aircraft maintained under a CAMP — see §91.401(b).

How long do drug and alcohol testing records have to be kept?

Federal DOT testing records under 49 CFR §40.333 follow a four-tier schedule. Five years (§40.333(a)(1)): records of alcohol test results showing a concentration of 0.02 or greater, verified positive drug test results, documentation of refusals, SAP reports, and all follow-up tests and follow-up test schedules. Three years (§40.333(a)(2)): information obtained from previous employers under §40.25 concerning a driver or employee drug and alcohol test history. Two years (§40.333(a)(3)): records related to the inspection, maintenance, and calibration of evidential breath testing devices (EBTs). One year (§40.333(a)(4)): negative and cancelled drug test results and alcohol test results with a concentration of less than 0.02. For aviation, these are incorporated through 14 CFR Part 120. Separately, under 14 CFR §111.220 a Part 135 operator must REPORT certain drug and alcohol testing events to the Pilot Records Database within 30 days of the occurrence — reporting is a distinct obligation from retention.

How long must SMS records be kept under the 2024 Part 5 rule?

Retention is set by 14 CFR §5.97, not by guidance. Safety risk management records (§5.97(a)) are retained for as long as the control remains relevant to the operation. Safety assurance records (§5.97(b)) — audits, performance monitoring, and assessment outputs — are retained for a minimum of 5 years. Training records (§5.97(c)) are retained for as long as the individual is employed by the person. Safety communication records (§5.97(d)) are retained for a minimum of 24 consecutive calendar months. The 2024 SMS final rule applies to ALL Part 135 certificate holders regardless of fleet size, with a single compliance date of May 28, 2027 — there is no aircraft-count threshold.

Do Part 135 crew records and load manifests have different retention periods?

Yes — even within §135.63 the periods differ. Under §135.63(b), the certificate holder must keep the current aircraft list required by §135.63(a)(3) for at least 6 months, and must keep each individual pilot record (§135.63(a)(4)) and each flight attendant record (§135.63(a)(5)) for at least 12 months. Completed load manifests are kept for at least 30 days at the principal operations base. These are minimums; in practice operators retain crew records for the duration of employment because the records feed Pilot Records Database reporting under 14 CFR Part 111 and must be produced for FAA inspection on short notice.

How long must a certificated repair station keep its records?

Under 14 CFR §145.219(c), a certificated repair station must retain the records required by §145.219 for at least 2 years from the date the article was approved for return to service. The repair station must also make those records available for inspection by the FAA and the National Transportation Safety Board, and must provide a copy of the maintenance release to the owner or operator of the article. The 2-year repair-station clock is independent of the owner or operator clock — the same physical work generates a record the station keeps under §145.219(c) and a corresponding entry the owner keeps under §91.417 or §135.439.

What records must be preserved after an accident or incident?

Under 49 CFR §830.10(a), the operator of an aircraft involved in an accident or incident for which notification must be given is responsible for preserving, to the extent possible, any aircraft wreckage, cargo, and mail aboard, and all records — including all recording mediums of flight, maintenance, and voice recorders — pertaining to the operation and maintenance of the aircraft and to the airmen, until the NTSB takes custody or a release is granted under 49 CFR §831.12(b). This is an absolute preservation hold that overrides normal retention schedules: records you would otherwise be allowed to discard must be preserved if they relate to a reportable event. Immediate notification of accidents and listed serious incidents is required under §830.5, and a written report on the prescribed Board form is due under §830.15.

What happens if I cannot produce a record an inspector asks for?

A missing record presents the same enforcement exposure as a failure to comply, because the record is the only evidence the FAA can evaluate — an inspector cannot observe a maintenance event or a proficiency check that happened months ago. Civil penalties under 14 CFR §13.301 reach a maximum of $75,000 per violation for a person other than an individual or small business concern, and $1,875 for an individual or small business concern, for violations occurring on or after December 30, 2024 (implementing 49 U.S.C. 46301). Because retention periods are minimums and several records transfer with the aircraft on sale, the practical standard most operators adopt is to retain documents past the regulatory floor and to keep them retrievable on demand rather than merely archived.

Chad Griffith

Founder, FileFlo — compliance document intelligence

This article is a compliance-document perspective, not legal or airworthiness advice. Every retention period above is a regulatory minimum drawn from the cited CFR sections; your OpSpecs, CHDO guidance, or SMS policy may require longer, and a reportable accident/incident triggers an absolute preservation hold under 49 CFR §830.10. Always verify against the current published eCFR before relying on any period for your operation.

Put every record on the right clock — and prove it in 60 seconds

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