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Software Comparisons — Aviation / FAA Part 135 Operations

Best Part 135 Operations + Recordkeeping Software 2026

Independent comparison of 7 platforms that help FAA-certificated Part 135 charter, air taxi, and on-demand operators capture and retain the §135.63 records — including §135.79 flight locating, §135.65 mechanical irregularity reports, §135.67 hazardous condition reports, and §135.267 crew duty time — that a Principal Operations Inspector requests during surveillance.

Chad Griffith, Founder & CEOLast updated: May 202615 min read

Compliance software perspective, not flight ops, ATP, or director-of-operations certification expertise. This guide compares records management platforms against 14 CFR Part 135 §135.63 + §135.65 + §135.67 + §135.79 + §135.267 documentation requirements — it is not a substitute for a director of operations, chief pilot, or FAA Principal Operations Inspector's regulatory interpretation of any specific Part 135 operational scenario.

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Per 14 CFR §135.63, every FAA-certificated Part 135 operator must maintain current records of each aircraft used, each crewmember, and each flight — at the principal business office or other places approved by the Administrator. Crewmember training records must be retained for the duration of employment plus at least 12 months thereafter, and load manifests must be retained for at least 30 days. Layered on top of §135.63 are the operational records of 14 CFR §135.65 (mechanical irregularity reports written up by mechanics and pilots), 14 CFR §135.67 (reports of potentially hazardous meteorological conditions and irregularities of communications or navigation facilities), 14 CFR §135.79 (flight locating procedures), and 14 CFR §135.267 (flight time limitations and rest requirements for unscheduled one- and two-pilot crews). The §135.21 General Operations Manual under 14 CFR §135.21 is required to set the procedures for every one of those records. Civil penalties under 49 U.S.C. § 46301 reach $37,377 per violation in 2026 (inflation-adjusted annually under the Federal Civil Penalties Inflation Adjustment Act) — and operations-side findings accumulate quickly during a Principal Operations Inspector surveillance visit because each missed record is its own potential violation.

The §135.63 records audit is the spine of every Part 135 surveillance visit. The POI pulls a slice of recent flights from the operator's schedule and walks the audit trail: was a §135.79 flight locating record opened at dispatch and closed at arrival; was the dispatched PIC under the §135.267 daily and weekly flight time limit and inside the prescribed rest window; was each mechanical squawk during the flight written up as a §135.65 entry in the aircraft maintenance log and corrected before the next dispatch; was any §135.67 hazardous condition report properly retained; and do the §135.63 crewmember, aircraft, and load manifest records exist within the retention window. The most common finding is not unsafe operations — it is operations that were safe but had records missing, incomplete, or out of retention.

The platforms ranked below split between the operations-records layer and adjacent layers of the Part 135 stack. Per-tail maintenance platforms (CAMP Systems, Veryon/Traxxall, Flightdocs) capture §135.65 entries once they reach the maintenance log but are not purpose-built for the §135.79 flight locating or §135.267 crew duty time records. Charter operations platforms (WingX) handle live flight following and dispatch but thin on the §135.63 retention clock side. Safety audit platforms (ARGUS PRO) surface records gaps at audit cycle. Document-side platforms (FileFlo) capture every §135.63 record at the point of operational creation, retain the §135.79 closure audit trail, route §135.65 entries to the maintenance side, and tie each record back to the §135.21 GOM revision in effect — across the entire Part 135 records audit.

Primary regulations cited in this guide: 14 CFR §135.63 (Recordkeeping requirements), 14 CFR §135.65 (Reporting mechanical irregularities), 14 CFR §135.67 (Reporting potentially hazardous meteorological conditions), 14 CFR §135.79 (Flight locating requirements), 14 CFR §135.21 (Manual requirements), 14 CFR §135.267 (Flight time and rest — unscheduled one- and two-pilot crews), and 49 U.S.C. § 46301 (FAA civil penalties). Operational citations: FAA Order 2150.3C (Compliance and Enforcement Program) and FAA Order 8900.1 Volume 3 (Principal Operations Inspector surveillance).

$37,377
Max FAA civil penalty per Part 135 violation (2026 inflation-adjusted) — each missed §135.63 record is its own potential violation
49 U.S.C. § 46301(a)(1)
12 mo
§135.63(a)(4) crewmember training records retention — duration of employment PLUS at least 12 months after the crewmember leaves
14 CFR §135.63(a)(4)
30 days
§135.63(c) load manifest retention minimum — most common §135.63 finding is load manifests not retained or not retrievable on POI request
14 CFR §135.63(c)

Operations-side findings stack up faster than maintenance-side findings

Per §135.63, a Part 135 certificate holder must maintain current records of each aircraft, each crewmember, AND each flight. A 30-day operations sample at a single-tail air taxi may include 60–100 flights, each generating its own §135.79 flight locating record, §135.267 crew duty time entry, and (when applicable) §135.65 mechanical irregularity entry — and any missing record is a potential violation under 49 U.S.C. § 46301. The certificate-side maintenance audit may turn up one or two findings on a clean operator; the operations-side audit can turn up dozens. Records software that captures every operations record at the point of creation is the only structural defense.

The 7 Best Part 135 Operations + Recordkeeping Platforms

Ranked by §135.63 retention clock automation, §135.79 flight locating audit trail completeness, §135.65 mechanical irregularity capture at the crew side, §135.67 hazardous condition reporting, §135.267 crew duty time tracking for unscheduled one- and two-pilot crews, and §135.21 GOM revision tie-back across the operations-records layer an FAA Principal Operations Inspector audits during surveillance.

#1

FileFlo

Top Pick — Best for Part 135 Operations Records + §135.63 Audit Trail
$299/mo flat (unlimited pilots, aircraft, and documents)5-day free trial, no credit card

Best For

Part 135 charter, air taxi, on-demand, and commuter operators (1-50 aircraft) that need §135.63 recordkeeping, §135.79 flight locating audit trail, §135.65 mechanical irregularity reporting, §135.67 hazardous condition reports, and §135.267 crew duty time records — without per-aircraft pricing

Key Feature

AI document classification — upload any §135.65 mechanical irregularity report, §135.79 flight locating closure, §135.267 crew duty record, or §135.63 load manifest and FileFlo files it against the correct §135 subpart with the right retention clock applied automatically

Part 135 Focus

§135.63 recordkeeping audit trail, §135.79 flight locating dispatch-to-close evidence, §135.65 mechanical irregularity capture, §135.67 hazardous condition reporting, §135.267 unscheduled one- and two-pilot crew duty time records, §135.21 GOM revision tie-back, one-click POI surveillance binder

Strengths

  • AI document parsing — every uploaded operations record classified against the correct 14 CFR Part 135 subpart and retention clock
  • Flight locating audit trail under §135.79 — dispatch event opens the record, arrival event closes it, surveillance binder retains the chain
  • §135.65 mechanical irregularity capture at the point the crew writes it up, routed to the maintenance side under §91.417 / §135.439
  • §135.267 crew duty time tracking for unscheduled one- and two-pilot crews — surfaces approaching limits before next dispatch
  • Retention clock automation — §135.63(a)(4) crew records (employment + 12 months), §135.63(c) load manifests (30 days), aircraft records aligned to §135.439
  • §135.21 GOM revision tie-back — every operations record indexed to the GOM revision in effect at the time of the event
  • One-click POI surveillance binder — produces a complete EDP-defensible packet of §135.63 + §135.65 + §135.67 + §135.79 + §135.267 records in under 60 seconds
  • $299/mo flat regardless of pilot or aircraft count — no per-tail or per-flight fees
  • 5-day free trial, no credit card required, no annual contract
  • Cross-regulation support: pairs with OSHA, EPA, and DOT records for diversified operators in one platform

Limitations

  • Not a charter scheduling, dispatch, or flight following platform — pair with WingX, Avianis, or ARGUS PRO for live ops workflow
  • Not a per-tail aviation maintenance tracking system — pair with CAMP, Veryon, or Flightdocs for inspection forecasting and AD applicability per aircraft
  • No native MEL/CDL configuration or revision-by-tail management

Our take: FileFlo is the purpose-built answer to the §135.63 + §135.79 + §135.65 + §135.267 records problem: it captures every operations-side record at the moment of creation, indexes it against the correct §135 subpart, applies the correct retention clock, ties it to the §135.21 GOM revision in effect, and produces an EDP-defensible audit binder on demand. For Part 135 charter and on-demand operators whose primary surveillance risk is flight locating closures, mechanical irregularity write-ups, and crew duty time exceedances — not per-tail maintenance forecasting — FileFlo fills the records-side gap at a flat rate that scales from a single-tail air taxi to a 50-aircraft on-demand fleet.

#2

CAMP Systems

Best for Per-Tail Maintenance Records (Aircraft-Side)
~$50–$500/aircraft/mo (sales-led, varies by tail count + fleet type)Demo only

Best For

Part 135 operators whose primary records-side need is per-aircraft maintenance logging and AD compliance — not §135.79 flight locating or §135.267 crew duty time tracking

Key Feature

Decades-deep per-tail maintenance tracking with airframe, engine, and component history feeding the §91.417 / §135.439 maintenance record

Part 135 Focus

Per-tail maintenance records, AD compliance forecasting; secondary mechanical irregularity workflow on the maintenance side; not purpose-built for §135.63 crewmember records, §135.79 flight locating, or §135.267 crew duty time records

Strengths

  • Industry-leading per-tail maintenance records database with mature airframe and engine history
  • Strong receiving side for §135.65 mechanical irregularity entries once they reach the maintenance log
  • Deep integration with FAA AD and SB notification feeds for §91.417 aircraft record completeness
  • Established vendor relationships across Part 135 charter and corporate flight departments

Limitations

  • Per-aircraft pricing — costly for §135.63 + §135.79 + §135.267 records use cases that scale with pilots and flights, not tails
  • Not purpose-built for the operations-side §135.79 flight locating audit trail or §135.267 crew duty time tracking
  • §135.65 capture happens after the entry reaches the maintenance log — not at the moment the crew writes it up
  • Sales-led pricing — requires a sales engagement to evaluate
  • Annual contracts standard; multi-week onboarding
  • No 5-day free trial

Our take: CAMP Systems is the per-tail maintenance records incumbent. For the maintenance-log side of §135.65 mechanical irregularity entries and the §91.417 / §135.439 aircraft record, CAMP is strong. For the operations-side §135.63 crew records, §135.79 flight locating audit trail, and §135.267 unscheduled crew duty time tracking that an FAA POI requests during surveillance, CAMP is the wrong layer of the stack.

#3

Veryon (Traxxall)

Best Post-Merger Maintenance Records Suite
Sales-led (per-aircraft/per-tail tier)Demo only

Best For

Part 135 operators that want consolidated per-tail maintenance records and limited flight ops after the 2024 Traxxall + Continuum CMP rebrand

Key Feature

Combined per-tail maintenance records and limited flight ops platform after Traxxall + Continuum CMP consolidation

Part 135 Focus

Per-tail maintenance records + parts modules; per-aircraft architecture similar to CAMP; not purpose-built for the operations-side §135.63 / §135.79 / §135.267 records

Strengths

  • Post-2024 merger consolidated Traxxall + Continuum CMP into a single maintenance records suite
  • Cloud-first architecture with modern UI compared to legacy on-prem maintenance systems
  • Strong international footprint (EASA + FAA dual-environment) for operators with cross-border charter
  • Limited flight ops modules feed into the §135.65 maintenance log chain

Limitations

  • Per-aircraft pricing — same structural mismatch as CAMP for §135.63 + §135.79 + §135.267 operations records
  • Post-merger integration period creates feature-roadmap uncertainty on the ops side
  • Sales-led pricing — no published rates
  • No purpose-built §135.79 flight locating audit trail or §135.267 unscheduled crew duty time workflows
  • Annual contracts standard; no 5-day free trial

Our take: Veryon is the rebranded post-2024 result of the Traxxall + Continuum CMP merger. For per-tail maintenance records and the maintenance-log side of §135.65 entries, Veryon is competitive. For the §135.63 crew records, §135.79 flight locating, and §135.267 crew duty time audit trail an FAA POI requests during surveillance, Veryon is not purpose-built.

#4

WingX

Best Charter Scheduling, Dispatch, and Flight Following
Sales-led (per-operator tier; ~$500–$2,000+/month range typical)Demo only

Best For

Part 135 charter and on-demand operators that need integrated scheduling, dispatch, quoting, crew pairing, and live flight following with secondary §135.79 flight locating

Key Feature

Purpose-built Part 135 charter scheduling, quoting, dispatch, crew-pairing, and live flight following platform

Part 135 Focus

Charter operations workflow — scheduling, dispatch, quoting, crew pairing, fuel uplift records, and live flight following; secondary §135.79 flight locating capture; not purpose-built for §135.63 recordkeeping retention or §135.65 mechanical irregularity audit trail

Strengths

  • Purpose-built Part 135 charter scheduling and dispatch workflow
  • Strong adoption in mid-size on-demand and charter operators
  • Live flight following helps satisfy the §135.79 monitoring expectation operationally
  • Integrated quoting and crew-pairing reduces tool sprawl on the operations side

Limitations

  • Primary value is charter operations workflow, not records-side §135.63 + §135.65 + §135.267 audit trail
  • Per-operator pricing — not flat-rate
  • No AI document classification for §135.65 mechanical irregularity reports or §135.21 GOM revisions
  • Limited §135.63 retention clock automation; thin §135.267 crew duty time records for unscheduled crews
  • Sales-led pricing — annual contracts standard

Our take: WingX is the Part 135 charter operations workflow incumbent. For dispatch, quoting, crew pairing, and live flight following, it is the right layer and addresses the operational side of §135.79. For the §135.63 + §135.65 + §135.67 + §135.267 records-side audit trail an FAA POI requests during surveillance, WingX is not purpose-built — pair it with FileFlo for the certificate-side records audit trail.

#5

Flightdocs

Best Cloud-First Maintenance Records
Sales-led (per-aircraft tier, often $30–$200/tail/mo range)Demo available

Best For

Part 91 corporate flight departments and Part 135 charter operators that want a cloud-first per-tail maintenance records platform — operations-side §135.63 + §135.79 records are secondary

Key Feature

Cloud-native per-tail maintenance records with strong mobile experience for technicians and pilots writing up §135.65 entries

Part 135 Focus

Per-tail maintenance records; secondary work order and parts modules; not purpose-built for §135.79 flight locating closure tracking, §135.63 crew records retention, or §135.267 crew duty time records

Strengths

  • Cloud-first, mobile-friendly UI ahead of legacy maintenance records systems
  • Mobile §135.65 mechanical irregularity entry from the flight line is workflow-friendly
  • Modern API stack for integration with charter operations and dispatch platforms
  • Per-tail subscription with predictable scaling for fleet operators

Limitations

  • Primary value is per-tail maintenance records, not the operations-side §135.63 + §135.79 + §135.267 records audit trail
  • Per-aircraft pricing — structural mismatch for §135.63 records that scale with pilots and flights
  • No purpose-built §135.79 flight locating audit trail
  • No §135.21 GOM revision tie-back for operations-side records
  • Sales-led pricing; no 5-day free trial

Our take: Flightdocs is the modern cloud-first alternative to CAMP for per-tail maintenance records. For operators whose primary records-side pain is the operations layer — §135.63 crew records retention, §135.79 flight locating audit trail, §135.65 mechanical irregularity capture at the crew side, and §135.267 unscheduled crew duty time — Flightdocs is not the right tool. Pair it with FileFlo for the operations-side records audit trail.

#6

ARGUS PRO

Best Safety Audit and Operator Rating
Sales-led (annual subscription + audit fees)Demo only

Best For

Part 135 charter operators that need the ARGUS Gold/Platinum/Platinum Elite safety rating for broker network access and corporate customer requirements — independent of FAA POI surveillance

Key Feature

Industry-standard Part 135 safety audit and operator rating used by charter brokers and corporate flight departments to qualify operators

Part 135 Focus

Third-party safety audit, operator rating, and recurrent compliance verification; complements but does not replace §135.63 + §135.79 + §135.267 records platforms

Strengths

  • Industry-standard safety rating that unlocks broker network and corporate customer access
  • Recurrent audit cycle surfaces operations-side records gaps independent of FAA POI surveillance
  • Established brand recognition with charter brokers and Fortune 500 flight departments
  • Useful complement to a purpose-built §135.63 + §135.79 records platform

Limitations

  • Not a records management platform — does not capture §135.65 entries, §135.79 closures, or §135.267 daily duty time at the point of operational creation
  • Annual subscription plus per-audit fees create variable cost structure
  • No AI document classification or §135.63 retention clock automation
  • Most useful as a complement to a broader records platform, not standalone
  • Sales-led pricing; no flat-rate tier

Our take: ARGUS PRO is the safety audit and operator rating layer of the Part 135 stack — essential for charter operators that need broker network access and corporate customer qualification. It is not a substitute for the §135.63 + §135.65 + §135.79 + §135.267 records platform a Part 135 certificate holder operates day-to-day. Best used alongside FileFlo, with ARGUS PRO handling the rating layer and FileFlo handling the records audit trail.

#7

Paper / Spreadsheet / Network Drive

The Status Quo Most Part 135 Operations Departments Are Quitting
$0 software + hidden labor costN/A

Best For

Very small single-tail Part 135 operators with a single-pilot owner-operator structure and stable OpSpecs envelope

Key Feature

No software vendor relationship; full local control over the operations binder

Part 135 Focus

Whatever the director of operations or chief pilot builds in Excel + a network drive — vulnerable to §135.79 closures that never happen, §135.65 entries that never make it from verbal to written, §135.267 daily duty time exceedances, and §135.63 retention clock gaps during POI surveillance

Strengths

  • Zero software cost
  • No vendor lock-in
  • Familiar to long-tenured directors of operations and chief pilots
  • Works for a single-tail air taxi with one PIC and a stable OpSpecs envelope

Limitations

  • No flight locating closure tracking — §135.79 audit trail breaks when the arrival entry is forgotten
  • §135.65 mechanical irregularity entries routinely live verbally between flight crew and maintenance until something goes wrong
  • §135.267 daily/weekly duty time tracking by hand routinely lets one- and two-pilot unscheduled crews approach or exceed limits
  • No automated retention clock — §135.63(a)(4) crew records and §135.63(c) load manifests slip past required retention windows
  • No audit trail of who touched what record when — fails §135.21 manual control intent
  • Building an EDP-defensible surveillance binder by hand takes days, not seconds
  • Hidden labor cost: a director of operations spending 6+ hours/week on operations records costs more annually than the software

Our take: Paper, spreadsheets, and network drives are the status quo most Part 135 operations departments are actively quitting in 2026. The hidden labor cost of manual §135.79 flight locating and §135.267 crew duty time tracking plus the asymmetric downside of a single FAA Enforcement Decision Process (EDP) finding — up to $37,377/violation under 49 U.S.C. § 46301, with certificate suspension exposure for systemic findings — makes the status quo more expensive than a flat-rate records platform within the first surveillance cycle.

Side-by-Side Comparison

All 7 platforms across the criteria that matter most for Part 135 operations and recordkeeping: §135.63 retention, §135.267 crew duty time, §135.79 flight locating, §135.65 mechanical irregularity, §135.67 hazardous condition reporting, §135.21 GOM tie-back, pricing, and free trial.

CriteriaFileFloCAMPVeryonWingXFlightdocsARGUSPaper
§135.63 Records Retention✅ Automated clocks per record type⚠️ Maintenance side only⚠️ Maintenance side only⚠️ Limited⚠️ Maintenance side only⚠️ Audit-cycle review❌ Manual
Crew Duty Time (§135.267)✅ Per-PIC daily/weekly clocks + alerts❌ Out of scope❌ Out of scope⚠️ Basic dispatch-side❌ Out of scope⚠️ Audit-cycle review❌ Excel
Flight Locating (§135.79)✅ Dispatch-to-close audit trail⚠️ Live following⚠️ Audit-cycle review❌ Drift
Mechanical Irreg Reports (§135.65)✅ Crew-side capture + routing⚠️ Maintenance log only⚠️ Maintenance log only⚠️ Limited✅ Mobile crew-side capture⚠️ Audit-cycle review❌ Often verbal
§135.67 Hazardous Conditions✅ Indexed reports⚠️ Pilot reports only⚠️ Audit-cycle review❌ Email
§135.21 GOM Revision Tie-back✅ Every record indexed to GOM rev⚠️ Audit-cycle review
Pricing$299/mo flat~$50–$500/aircraftPer-aircraftPer-operator ($500–$2,000+/mo)Per-aircraftAnnual subs + audit fees$0 + hidden labor
Free Trial✅ 5 days❌ Demo only❌ Demo only❌ Demo only❌ Demo available❌ Demo onlyN/A

⚠️ = partial or limited support. ❓ = unknown / not published. Data based on vendor documentation as of May 2026 and post-2024 Veryon merger context.

How to Choose the Right Part 135 Operations + Recordkeeping Platform

§135.63 Operational Records Retention

Per 14 CFR §135.63, a Part 135 certificate holder must maintain current records of each aircraft used (including airworthiness status), each crewmember (initial qualification, recurrent training, competency checks, line checks, IPCs, medicals, and pilot certificate currency), and each flight (dispatch authorization, load manifest, and flight times). The §135.63 retention rules vary by record type: §135.63(a)(4) crewmember training records for the duration of employment plus 12 months thereafter; §135.63(c) load manifests for at least 30 days; aircraft records consistent with §135.439 maintenance retention. The most common §135.63 finding during a POI surveillance visit is a load manifest the operator cannot produce within the 30-day window or a crewmember training file missing the §135.293 recurrent testing evidence. Compliance software must capture each record at the point of operational creation, apply the correct §135.63 retention clock automatically, and surface near-expiration records before they fall outside the retention window. Paper-based retention routinely lets records slip past their clocks — the right software prevents the slip structurally.

Flight Locating (§135.79) Documentation

Per 14 CFR §135.79, every Part 135 certificate holder must have flight locating procedures that ensure each flight is monitored from origin to destination, with established alert and search-and-rescue notification when a flight becomes overdue, and retention of the flight locating record. The §135.79 procedures must be set forth in the §135.21 General Operations Manual and approved by the operator's Principal Operations Inspector. The most common §135.79 finding during a surveillance visit is not a procedure problem — it is a dispatcher or director of operations who opened a flight locating record at departure and never closed it at arrival, so the audit trail shows a record that's been "open" for weeks or months. Compliance software must open the §135.79 record at dispatch, surface it as outstanding until the arrival event is captured, and retain the closed audit trail tied to the §135.21 GOM revision in effect at the time of the flight. The §135.79 audit trail is the single cleanest piece of evidence a POI uses to validate that the §135.21 GOM revision was actually executed.

Crew Duty Time + Rest Recordkeeping (§135.267)

Per 14 CFR §135.267, unscheduled one-pilot crews may not fly more than 8 hours in any 24 consecutive hours, and unscheduled two-pilot crews may not fly more than 10 hours in any 24 consecutive hours, with corresponding 7-day and 30-day rolling limits and prescribed rest periods. The §135.267 clock is independent of the §135.293 12-month recurrent testing clock — a PIC can have a current §135.293 record AND be over the §135.267 limit on the same day. The most common §135.267 finding during a POI surveillance visit is a multi-day operational period where the rolling 24-hour or 7-day flight time exceeded the limit because nothing prevented dispatch when the PIC was approaching the cap. Compliance software must track §135.267 daily, weekly, and monthly clocks per PIC, surface approaching limits before next dispatch, and retain the §135.63(a)(2) crewmember flight time records aligned to the §135.267 audit. The dispatcher should never have to do the math in their head — the right software enforces the limit at the point of dispatch authorization.

Mechanical Irregularity Reports (§135.65)

Per 14 CFR §135.65, each Part 135 certificate holder must require its mechanics and pilots to report each mechanical irregularity that comes to their attention during flight time. The report must be entered promptly in the aircraft maintenance log, and any corrective action taken to clear the irregularity must also be entered. The §135.65 entry is the regulatory handoff between flight operations and maintenance — a written squawk creates the record, and the maintenance side has to close it before the next dispatch under §91.405 and §135.439. The most common §135.65 finding during a POI surveillance visit is a mechanical irregularity that flight crews discussed verbally with maintenance but never wrote up as a §135.65 entry, so the maintenance log chain of custody breaks. Compliance software must capture the §135.65 entry at the point the crew writes it up (mobile entry from the flight line, not paper at the maintenance desk), route the entry to the maintenance side automatically, and retain the corrective-action evidence on the aircraft record under §91.417 and §135.439. Section 14 CFR §135.67 layers an analogous reporting obligation for potentially hazardous meteorological conditions and irregularities of communications or navigation facilities — both should be captured in the same operations records system.

Section §135.21 GOM Tie-back for Every Operations Record

Per 14 CFR §135.21, the Part 135 General Operations Manual (GOM) must include the §135.63 recordkeeping procedures, §135.65 mechanical irregularity reporting procedures, §135.67 hazardous condition reporting procedures, §135.79 flight locating procedures, and §135.267 crew flight, duty, and rest time procedures. Every operations record created under those sections is therefore evidence of execution against a specific §135.21 GOM revision. The POI surveillance audit walks both directions: from the §135.21 GOM revision to the operations records that should exist, and from the operations records to the §135.21 GOM revision that should authorize them. The most common §135.21 finding is a GOM revision that no longer matches the procedures actually in use — usually because an OpSpecs amendment or regulatory change went into effect operationally but the GOM revision lagged. Compliance software must tie each operations record to the §135.21 GOM revision in effect at the time of the event, surface drift between GOM revisions and operational practice, and retain the GOM-revision-to-operations-record audit trail the POI requests during surveillance. FileFlo indexes every operations record against the active GOM revision automatically, so the §135.21 audit trail and the §135.63 audit trail tell the same story without manual cross-referencing.

EDP Defense and POI Surveillance Binder

The FAA Enforcement Decision Process (FAA Order 2150.3C) is the administrative framework under which POI surveillance findings are investigated, dispositioned, and resolved — typically through compliance action, civil penalty, or certificate action. Operations-side findings — missed §135.79 flight locating closures, §135.65 mechanical irregularity reports that were never written up, §135.267 crew duty time exceedances, and §135.63 recordkeeping gaps — are some of the most common entries in EDP cases against Part 135 operators because each missed record is its own potential violation under 49 U.S.C. § 46301. The most cost-effective structural defense is records software that captures every operations record at the point of creation, retains it against the correct §135.63 retention clock, indexes it against the §135.21 GOM revision in effect, and produces an EDP-defensible surveillance binder on demand. FileFlo's one-click POI surveillance binder packages the §135.63 + §135.65 + §135.67 + §135.79 + §135.267 records for any time window into a single export the POI can review during a surveillance visit — collapsing what would otherwise be a multi-day records reconstruction into a single click. The cost of digging out from an EDP finding plus the asymmetric downside of a civil penalty up to $37,377 per violation makes the records-side software pay for itself within the first surveillance cycle.

Part 135 operations records, captured at the moment of creation

FileFlo captures every §135.63 record, retains the §135.79 flight locating audit trail, routes §135.65 mechanical irregularity reports to the maintenance side, tracks §135.267 unscheduled crew duty time, and ties every record back to the §135.21 GOM revision in effect — for unlimited pilots and unlimited aircraft. AI document classification routes every uploaded record to the correct §135 subpart automatically. $299/month flat, no contract, no per-flight fees.

Frequently Asked Questions

What is Part 135 operations and recordkeeping software?

Part 135 operations and recordkeeping software helps FAA-certificated air taxi, charter, on-demand, and commuter operators capture, retain, and surface the operational records required under 14 CFR §135.63 (recordkeeping), §135.65 (mechanical irregularity reports), §135.67 (hazardous meteorological and navigation/communication irregularity reports), §135.79 (flight locating procedures), §135.21 (manual requirements), and §135.267 (crew flight, duty, and rest time limits for unscheduled one- and two-pilot crews). The best platforms automate flight locating documentation, capture every mechanical irregularity report at the point the crew writes it up, retain crew duty time records against the §135.267 clock, and produce the FAA Principal Operations Inspector binder on demand — closing the EDP enforcement gap that paper-based ops binders routinely leave open.

What does §135.63 require Part 135 operators to retain?

Per 14 CFR §135.63, every Part 135 certificate holder must maintain current records of each aircraft used (including airworthiness status and an up-to-date list of the aircraft), each crewmember (initial qualification, recurrent training, competency checks, line checks, IPCs, medicals, and pilot certificate currency), and each flight (load manifests, dispatch authorizations, and flight times). The §135.63 records must be kept at the operator's principal business office or other places approved by the Administrator. Crewmember training records must be retained for the duration of employment AND for at least 12 months after the crewmember leaves under §135.63(a)(4). Load manifests must be retained for at least 30 days under §135.63(c). In practice, most operators retain materially longer because §91.417 aircraft records, §135.439 maintenance records, insurance underwriter requests, and FAA Enforcement Decision Process defense all reference the same records on different retention clocks. Software that captures the record at the point of operational creation and indexes it against the correct retention clock is the lowest-cost path to surviving a POI surveillance pull.

How does flight locating under §135.79 work in practice?

Per 14 CFR §135.79, every Part 135 certificate holder must have flight locating procedures that ensure each flight is monitored from origin to destination — including procedures for company communication, the establishment of an alert and search-and-rescue notification process when a flight becomes overdue, and retention of the flight locating record. The §135.79 procedures must be set forth in the General Operations Manual under §135.21 and approved by the operator's Principal Operations Inspector. The most common §135.79 finding during a surveillance visit is a flight locating procedure documented in the GOM that the dispatcher or director of operations does not actually execute consistently — or a flight locating record that was created at dispatch but never closed when the flight arrived. Compliance software must capture the flight locating event at dispatch, surface the open record until the arrival is logged, and retain the audit trail tying the locating procedure to the GOM revision in effect at the time of the flight.

What is a §135.65 mechanical irregularity report and why does it matter?

Per 14 CFR §135.65, each Part 135 certificate holder must require its mechanics and pilots to report each mechanical irregularity that comes to their attention during flight time. The report has to be entered in the aircraft maintenance log promptly, and any corrective action taken to clear the irregularity must also be entered. The §135.65 obligation is the operational handoff between flight ops and maintenance — a flight crew writes up a squawk, the §135.65 entry creates the regulatory record, and the maintenance side of the certificate has to close the entry before the aircraft is dispatched again. The most common §135.65 finding during a Principal Operations Inspector surveillance visit is a mechanical irregularity that flight crews discussed verbally with maintenance but never wrote up as a §135.65 entry, breaking the maintenance log chain of custody. Compliance software must capture the §135.65 entry at the point the crew writes it up, route the entry to the maintenance side of the certificate, and retain the corrective-action evidence on the aircraft record under §91.417 and §135.439.

How are §135.267 crew duty time limits different from §135.293 pilot currency?

Section §135.267 (Flight time limitations and rest requirements: unscheduled one- and two-pilot crews) governs the daily/weekly/monthly clock — how many flight hours a Part 135 PIC can fly in 24 consecutive hours (8 for one-pilot crews, 10 for two-pilot crews), how many hours in any 7 consecutive days (no more than 28 hours of scheduled flight time for one-pilot under §135.267, with corresponding limits for unscheduled operations), and the prescribed rest period before assignment to flight duty. Section §135.293 (Initial and recurrent pilot testing) governs the annual competency clock — the testing event every Part 135 PIC must complete every 12 calendar months on aircraft systems, performance, emergency procedures, and applicable regulations. The two clocks run independently — a PIC can be current under §135.293 and over the §135.267 limit on a given day, or under the §135.267 limit and lapsed on the §135.293 12-month clock. Compliance software for Part 135 operators must track both — the §135.267 dispatch clock per flight, and the §135.293 recurrent testing clock per PIC. Paper-based tracking routinely lets one or the other slip.

What is the relationship between §135.21 and the §135.63 + §135.79 records?

Per 14 CFR §135.21 (Manual requirements), every Part 135 certificate holder must prepare and keep current a General Operations Manual (GOM) and, where the operator maintains aircraft, a General Maintenance Manual (GMM). The §135.21 manuals must include — among many other items — the §135.79 flight locating procedures, the §135.65 mechanical irregularity reporting procedures, the §135.67 hazardous meteorological and navigation/communication irregularity reporting procedures, the §135.63 recordkeeping procedures, and the §135.267 crew flight, duty, and rest time procedures. The §135.21 GOM is the regulatory framework; the §135.63 + §135.65 + §135.67 + §135.79 + §135.267 records are the operational evidence that the framework is actually being executed. A POI surveillance finding under §135.79 or §135.65 is therefore usually a downstream consequence of a §135.21 GOM revision that lapsed or never reflected the procedure actually in use. Compliance software must tie each operational record to the GOM revision in effect at the time of the event — so the §135.21 audit trail and the §135.63 audit trail tell the same story.

How much does Part 135 operations and recordkeeping software cost?

Pricing splits across the same three categories as broader Part 135 compliance tooling. Charter operations platforms (WingX, Avianis, ARGUS PRO) handle scheduling, dispatch, quoting, flight following, and limited §135.79 flight locating and §135.267 crew duty time — priced per-operator under sales-led annual contracts, typically $500–$2,000+/month. Per-tail maintenance platforms (CAMP Systems, Veryon/Traxxall, Flightdocs) capture maintenance-side records but are not purpose-built for §135.65 mechanical irregularity reporting from the flight crew side — per-aircraft pricing $30–$500/tail/month. Document-side compliance platforms (FileFlo) capture every §135.63 record, retain the §135.79 flight locating audit trail, route §135.65 mechanical irregularity reports to the maintenance side, and surface stale §135.21 manual revisions — $299/month flat for unlimited pilots, aircraft, and documents. Most Part 135 operators need software from at least two categories, and the certificate-side document layer is the one that drives most EDP findings.

What FAA civil penalty applies to §135 operations and recordkeeping violations?

Under 49 U.S.C. § 46301(a)(1), the FAA may impose civil penalties up to $37,377 per violation for most Part 135 regulatory violations as of the 2026 inflation-adjusted schedule (penalties adjusted annually under the Federal Civil Penalties Inflation Adjustment Act). Operations-side findings — missed §135.79 flight locating closures, §135.65 mechanical irregularity reports that were never written up, §135.267 crew duty time exceedances, or §135.63 recordkeeping gaps — accumulate quickly during a Principal Operations Inspector surveillance visit because each missed record is its own potential violation. Repeat or systemic findings under §135.21 (manual deficiencies that allowed the operational gaps) can result in compliance action, certificate suspension exposure, or seven-figure cumulative civil penalty assessment for EMS air ambulance and on-demand charter operators with patterned findings. The right software does not add safety to the underlying operation — it captures the records that prove the underlying operation was safe, before the POI asks for them.

Stop reconstructing §135.79 flight locating records the morning of the POI surveillance visit

FileFlo holds the operations-side Part 135 records audit trail across every flight. §135.63 retention clock automation, §135.79 dispatch-to-close flight locating, §135.65 mechanical irregularity capture, §135.67 hazardous condition reports, §135.267 unscheduled crew duty time, and §135.21 GOM revision tie-back — all for $299/month flat, no contract, no per-aircraft fees, no per-flight fees.

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