What Comply365 says it offers
Read October 14, 2026, from Comply365's own pages, each listed in the sources below.
- One platform for content, safety and training. The home page describes an operational performance platform that joins operational content management, safety and risk management and training management, and that gets procedure changes to the right people with proof that they acknowledged them.
- ContentManager365 manages airline technical documents and publications: authoring with an XML editor, publishing, distribution, a web and mobile viewer that works online or offline, electronic forms, workflow automation and automated regulation tracking. It comes as an authoring platform, a managed service or both.
- SafetyManager365 is safety, risk and audit management, presented as a platform for airlines, with mandatory and voluntary occurrence reporting, confidential ASAP reporting and a mobile offline mode.
- TrainingManager365 is its training management system: courses, classrooms, instructors and trainees; digital exams and evaluations with automated grading; scheduling of instructors, simulators and equipment; training content delivery; and automated qualification tracking, on web and mobile. The platform page describes it as the module for competency and recurrent training.
- MINT. On December 17, 2025 Comply365 announced the acquisition of MINT, a training management company whose system manages qualification programs, scheduling and training, and said MINT will be a foundational element of TrainingManager365.
- Who it serves. The about page names aviation, defense and rail and counts over 500 customers in more than 80 countries. The content and safety pages are written for airlines, and the training page for airlines and training organizations. A February 2023 release on its news page describes Wheels Up, a private aviation company, using its document and compliance management system and electronic forms across five air operator certificates.
- Buying. The pages list no prices; they ask the reader to talk to Comply365, request a demo or request a meeting.
For a Part 135 operator the suite covers three jobs: the manuals and procedures crews read, safety reporting, and the crew training record. This page is about the third, the record an FAA inspector reads under 14 CFR 135.63(a)(4).
The kinds of alternative for a Part 135 operator
| Kind | What it does | Note |
|---|---|---|
| Airline-scale suite | Manuals, safety reporting and training on one platform | Comply365 is this kind, by its own pages |
| Training management system | Schedules courses, instructors and simulators, runs exams and keeps the training history | TrainingManager365 is this kind; Comply365 says MINT, acquired in December 2025, will be a foundation of it |
| Document system for manuals | Revises and distributes manuals and collects each crewmember's acknowledgment | ContentManager365 is this kind |
| Spreadsheet | The chief pilot or training manager keeps the names, the dates and the due months | Costs nothing extra; the calendar math lives in one person's formulas |
| Records software for Part 135 | Dates each pilot's checks and training against the rule and names what is missing | FileFlo is this kind |
The kinds combine. An operator can keep a document system for its manuals and move only the crew training record; Part 135 does not put both in one system. What the rules ask of the training record is the same whichever kind holds it: the items in 135.63(a)(4), each check counted in calendar months from its base month, and each entry tied to the person who certified it.
14 CFR 135.63(a)(4): the record that has to arrive intact
Whatever system the record leaves, the individual pilot record has to arrive whole. Section 135.63(a)(4) lists what it holds; for a training records move, these are the items that come across with their dates:
- the date and result of each initial and recurrent competency test and proficiency and route check, and the type of aircraft flown (135.63(a)(4)(vi));
- the effective date and class of the pilot's medical certificate (135.63(a)(4)(v));
- the pilot's check pilot authorization, if any (135.63(a)(4)(viii));
- the date of completion of the initial phase and each recurrent phase of the required training (135.63(a)(4)(x)).
The certificate holder keeps the record at its principal business office or another place the FAA approves and makes it available for inspection (135.63(a)). The full list is in what pilot records the FAA requires for Part 135.
14 CFR 135.301(a) and 135.323(b): the base month moves with the record
A test or flight check completed in the calendar month before or after the month it is required counts as completed in the month it is required (135.301(a)), and recurrent training counts the same way (135.323(b)). So the date a check was passed and the month it counts for can differ by a month either way.
That month is the base month, and a 2006 interpretation by the FAA's Office of the Chief Counsel calls it, with the month before and the month after, the eligibility period. An export that carries only the date passed loses the base month, and the new system counts every next due date from the wrong month. The counting itself is worked through in Part 135 crew training records software.
14 CFR 135.323(c): the certifier moves with each entry
Each instructor, supervisor or check pilot responsible for a ground training subject, a segment of flight training, a course of training, a flight check or a competence check certifies the crewmember's proficiency and knowledge on completion, and the certification is part of the crewmember's record. When the record is a computerized system, the certifier must be identified with each entry, and a signature is not required (135.323(c)).
The same name appears in two other places: the check pilot certifies a line check in the pilot training record (135.299(b)), and the competency of each pilot who passes the 135.293 test or check is certified in the pilot records (135.293(f)). An import that drops the certifier keeps the date and loses what 135.323(c) asks each computerized entry to carry.
14 CFR 135.63(b): twelve months of retention run through the switch
Each pilot record under 135.63(a)(4) is kept for at least 12 months (135.63(b)). Ending a subscription does not shorten that. Keep the old system's export, as exported, for at least that long, beside what the new system imported.
14 CFR 135.293, 135.297, 135.299 and 135.343: the clocks the new system counts
| Record | Rule | Counted from the month of service |
|---|---|---|
| Knowledge test and competency check | 135.293(a), 135.293(b) | Since the beginning of the 12th calendar month before |
| Instrument proficiency check, pilot in command under IFR | 135.297(a) | Since the beginning of the 6th calendar month before |
| Line check, pilot in command | 135.299(a) | Since the beginning of the 12th calendar month before |
| Recurrent training | 135.343 | Since the beginning of the 12th calendar month before |
Each look-back starts on the first day of a calendar month, so a check passed on any day of a month counts the same as one passed on the first.
Worked example: one pilot's check history, moved on October 14, 2026
Illustration, not an operator
An operator moves its crew training records to new software on October 14, 2026. One pilot's competency check history in the old system reads: base month March, last check passed April 14, 2026, certified by the operator's check pilot.
- April is the month after March, so the April 14, 2026 check counts as completed in March 2026 (135.301(a)). The next check is due in March 2027, and the eligibility period runs from February 1 to April 30, 2027.
- An import that carries only the date counts from April instead: due in April 2027, with an eligibility period from March 1 to May 31, 2027. In May 2027 it would show the pilot inside the window, a month after the rule's window closed on April 30, 2027.
- An import that carries the base month keeps March. With it come the type flown (135.63(a)(4)(vi)) and the check pilot who certified the check (135.323(c)), so the next check and its certifier read correctly on the first day.
- The old system's export of this record stays beside the new one for at least 12 months (135.63(b)).
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. Each pilot's checks and training are worked out from the records you already hold and cited to the rule, and a date FileFlo cannot read is shown as unknown rather than guessed. Checks and recurrent training are dated in calendar months with base-month crediting, and when the POI asks for the crew's training records, an inspector link scoped to that crew answers it. You approve what goes out, and your Director of Operations makes the operational decision.
Sources
Checked
- Comply365 home page, Comply365. Read October 14, 2026
- ContentManager365, operational content management, Comply365. Read October 14, 2026
- SafetyManager365, safety management, Comply365. Read October 14, 2026
- TrainingManager365, training management, Comply365. Read October 14, 2026
- The Operational Performance Platform, Comply365. Read October 14, 2026
- About Comply365, Comply365. Read October 14, 2026
- Comply365 announces acquisition of MINT (December 17, 2025), Comply365. Read October 14, 2026
- Wheels Up selects Comply365 (February 16, 2023), Comply365. Read October 14, 2026
- 14 CFR 135.63, recordkeeping requirements, eCFR
- 14 CFR 135.293, initial and recurrent pilot testing, eCFR
- 14 CFR 135.297, instrument proficiency check, eCFR
- 14 CFR 135.299, line checks, eCFR
- 14 CFR 135.301, grace provisions, eCFR
- 14 CFR 135.323, training program and certification, eCFR
- 14 CFR 135.343, initial and recurrent training, eCFR
- Interpretation to Gregory S. Winton on recurrent training and the eligibility period (2006), FAA Office of the Chief Counsel
Questions
What does Comply365 offer?
From its own pages, read October 14, 2026: ContentManager365 for authoring, publishing, distributing and viewing manuals and technical documents; SafetyManager365 for safety, risk and audit management, including occurrence reporting; and TrainingManager365 for training administration, exams, scheduling and qualification tracking, on one platform. On December 17, 2025 it announced the acquisition of MINT, a training management company.
Who is Comply365 built for?
Its about page names aviation, defense and rail and counts over 500 customers in more than 80 countries. Its content and safety product pages are written for airlines, and its training page for airlines and training organizations. A February 2023 release on its news page describes a private aviation company using its document and compliance management system.
Does Comply365 publish prices?
Not on the pages read on October 14, 2026. They ask the reader to talk to Comply365, request a demo or request a meeting.
What has to carry over when crew training records move?
The items in 14 CFR 135.63(a)(4), among them the date, result and aircraft type of each test and check and the completion date of each training phase; the month each check and each round of recurrent training counts for under 135.301(a) and 135.323(b); and the identity of the instructor or check pilot who certified each entry under 135.323(c). Each pilot record is kept for at least 12 months under 135.63(b), so the export from the old system is kept too.
Can an operator keep Comply365 for manuals and move only the crew training records?
Yes. Manual distribution and the crew training record are separate jobs, and Part 135 does not put them in one system. The training record has to hold the 135.63(a)(4) items and be available to the FAA for inspection under 135.63(a).