Direct Answer — Are Electronic Records and Digital Signatures Allowed?
Yes. 14 CFR does not require electronic maintenance records or digital signatures, and it does not prohibit them. The recordkeeping rules are medium-neutral: §43.9 specifies what an entry must contain — including, in §43.9(a)(1), a description or "reference to data acceptable to the Administrator" — and §91.417 and §145.219 specify how long records are kept and that they must be available to the FAA and NTSB.
An electronic system is acceptable when it satisfies those same rules: every §43.9 data point captured, an electronic signature traceable to one identifiable certificate holder, the record protected from undetected alteration, retained for the full §91.417(b)/§145.219(c) period, and producible on demand under §91.417(c). The FAA describes acceptable electronic recordkeeping and electronic signatures in Advisory Circular AC 120-78B — that is guidance, not a regulation, and it explains how to make an electronic system acceptable rather than mandating one.
Sources: 14 CFR §43.9, §91.417, §145.219. AC 120-78B is FAA guidance.
There is a persistent myth in general aviation maintenance that the FAA either requires electronic records or bans them. Neither is true. The regulations were written to govern the content and availability of a maintenance record, not the paper it is printed on. That is good news and a trap at the same time: good news, because you are free to choose paper logbooks, a maintenance-tracking platform, or a true electronic recordkeeping system; a trap, because the freedom does not lower the bar. An electronic record has to do everything a paper record does — and then prove a few things a paper logbook never had to.
This article walks through the exact CFR language that makes electronic records and digital signatures permissible, what FAA guidance (AC 120-78B) expects of an acceptable electronic system, the four pillars that separate a defensible system from a folder of PDFs, and where operators most often go wrong. It connects to the broader documentation framework in what a §43.9 entry must contain, the §91.417 retention tiers, and the full Part 135 records picture.
What the CFR Actually Says (and Does Not Say)
The permission to keep electronic records is not a standalone rule — it lives inside the ordinary recordkeeping requirements. Here is the exact language.
§43.9 — The "Reference to Data" Hook
14 CFR §43.9(a)(1) & (a)(4)§43.9(a)(1) requires a maintenance record entry to contain a description — or reference to data acceptable to the Administrator — of the work performed. That clause is what lets a computer-maintained work order, an AMM task reference, or a structured digital record stand in for a longhand description, as long as the referenced data is itself acceptable and retrievable. §43.9(a)(4) requires the signature, certificate number, and kind of certificate of the person approving the work for return to service. Nothing in §43.9 specifies the medium of either the description or the signature.
Regulatory text — §43.9(a)(1)
"A description (or reference to data acceptable to the Administrator) of work performed."
§91.417 — Retention and the Duty to Produce
14 CFR §91.417(b) & (c)§91.417 imposes the owner/operator retention obligation, and it applies regardless of medium. §91.417(b)(1) keeps the (a)(1) maintenance and inspection records until the work is repeated or superseded, or for 1 year. The (a)(2) records — total time in service of the airframe, each engine, each propeller and rotor; current status of life-limited parts; time since last overhaul of time-limited items; current inspection status; current status of applicable ADs; and the §43.9(d) forms (FAA Form 337) for each major alteration — are kept and transferred with the aircraft on sale. And §91.417(c) is the production duty.
Regulatory text — §91.417(c)
"The owner or operator shall make all maintenance records required to be kept by this section available for inspection by the Administrator or any authorized representative of the National Transportation Safety Board (NTSB)."
§145.219 — Part 145 Records, Any Medium
14 CFR §145.219For a certificated repair station, §145.219(a) requires records in English that demonstrate compliance with Part 43, §145.219(c) requires retention for at least 2 years from the date the article was approved for return to service, and §145.219(d) requires the records be available for inspection by the FAA and the NTSB. As with §43.9, the rule does not dictate paper or electronic — it dictates content, language, retention, and availability. An electronic system that satisfies all four is acceptable.
The common thread across §43.9, §91.417, and §145.219: the regulation governs content, retention, and availability — never the medium. Choose the medium; satisfy the rule.
AC 120-78B is guidance, not a regulation — and the distinction matters
Advisory Circular AC 120-78B (Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals) is the FAA's current guidance describing acceptable electronic recordkeeping and electronic-signature practices. An Advisory Circular is not the binding rule — it describes a way (often the FAA-preferred way) to comply with the binding rules in §43.9, §91.417, and §145.219. Treat AC 120-78B as the playbook for making an electronic system acceptable, and treat the CFR sections as the law you must actually satisfy. Do not cite an AC as if it were a CFR mandate, and confirm the current AC revision before relying on its specifics.
The Four Pillars of a Defensible Electronic System
Distilled from the CFR requirements and the conditions FAA guidance describes — these are the attributes that distinguish an acceptable electronic recordkeeping system from a folder of image files. Each maps directly to a regulatory obligation.
Traceability to the Individual
Every approval-for-return-to-service must be attributable to one identifiable person whose §43.9(a)(4) certificate number and kind of certificate stay verifiable. An electronic signature, per FAA guidance, must be unique to and under the sole control of that individual and must show intent to sign — not a shared login, not a typed name anyone could enter.
How it fails
A shared workstation account where any technician can apply "the boss's" signature. The entry then cannot be traced to a single certificate holder, defeating §43.9(a)(4).
Tamper-Evidence (Audit Trail)
Once an entry is signed, later changes must be detectable. FAA guidance treats an immutable or append-only audit trail — who changed what, when — as a core attribute of an acceptable electronic system. The point is that an inspector can trust that the signed record they are reading is the signed record that was made.
How it fails
A spreadsheet or free-text database where a completed entry can be silently edited after signing. There is no way to show the record was not altered, so its evidentiary value collapses.
Retrievability for the Full Retention Period
The record must stay readable for as long as §91.417(b) or §145.219(c) requires — including the life-of-aircraft tier for §91.417(a)(2) records. That means the format must outlive any single software version or vendor, and the data must be exportable to a form a person can actually read years later.
How it fails
A proprietary format locked to a discontinued app, or records that vanish when a subscription lapses. A life-of-aircraft record that cannot be opened in year nine is, in practice, not retained.
On-Demand Availability to the FAA / NTSB
§91.417(c) and §145.219(d) require the records to be available for inspection by the Administrator and the NTSB. An electronic system must be able to produce the records, in a readable form, when asked — quickly, completely, and without depending on a single person's memory of a password.
How it fails
An inspector asks for the last annual's records and they sit behind a forgotten login on a laptop that is off-site. "We have them, we just can't get to them right now" is not availability.
A scan of a paper logbook is not, by itself, an electronic system
Photographing or scanning paper records to PDF gives you a digital copy. It does not automatically give you traceable signatures, an audit trail, or guaranteed retrievability — the three things a true electronic system adds. A scan can be a useful convenience copy, and many operators keep the paper logbook as the record of authority while scanning for off-site backup. But decide that deliberately with your IA or principal maintenance inspector — do not assume a folder of scans satisfies the FAA expectations for an electronic recordkeeping system.
Digital Signatures: What §43.9(a)(4) Demands an Electronic Signature Preserve
The signature is the most scrutinized part of any electronic maintenance record, because it is the point where a specific certificate holder takes responsibility for approving the aircraft for return to service. §43.9(a)(4) requires the signature, certificate number, and kind of certificate of the approving person — all three. An electronic signature is acceptable, per FAA guidance, when it preserves the link between the approval and the identifiable individual, and shows that individual's intent to sign. The medium changes; the three data points do not.
Generally Acceptable Characteristics
- Unique to and under the sole control of one identifiable person
- Traceable to that person so the §43.9(a)(4) certificate number and kind of certificate stay verifiable
- Applied through individual authentication (the signer logged in as themselves)
- Shows intent to approve the specific work for return to service
- Record locked or tamper-evident after signing (audit trail)
Generally Problematic
- A typed name in a free-text field with no access control
- A shared login any technician can use to "sign" as someone else
- A pasted image of a signature with no link to authentication
- An entry that can be edited after signing without any trace
- A signature with no retrievable certificate number or kind of certificate
The underlying point is simple: an electronic signature has to carry forward everything §43.9(a)(4) requires of a wet signature, plus prove who applied it and that the record was not altered afterward. If your electronic system cannot, from the record alone, identify the approving person, their certificate number, and their kind of certificate — and demonstrate the entry is unaltered since signing — the signature has not met the bar, regardless of how it looks on screen. For the full anatomy of the entry around that signature, see the six §43.9 data points, and for who is even authorized to sign, Part 65 mechanic and repairman certificates.
Whatever your records system is, prove it is complete before an inspector does
FileFlo classifies your maintenance documents — paper scans, exports from a tracking platform, or files from an electronic system — against the governing CFR, flags entries that appear to be missing a §43.9 data point, tracks §91.417 and §145.219 retention clocks, and assembles an inspector-format binder on demand. See the full Aviation compliance coverage.
Retention and Production: The Tests an Electronic System Must Survive
Going electronic does not shorten — or lengthen — any retention period. The §91.417(b) tiers apply to the records no matter how they are stored, and §145.219(c) applies to repair stations the same way. What electronic storage adds is two failure modes a paper logbook in a hangar drawer never had: the format can become unreadable, and the records can become inaccessible. Both turn a technically-retained record into one that is not truly available.
§91.417(a)(1) Records
Retention: until repeated or superseded, or 1 year
Maintenance, preventive maintenance, alteration, and the 100-hour, annual, progressive, and other required inspection records. Per §91.417(b)(1), kept until the work is repeated or superseded by other work or for 1 year after the work is performed. An electronic system must hold them readable for at least that long.
§91.417(a)(2) Records
Retention: life of aircraft + transfer on sale
Total time in service of the airframe, each engine, each propeller and rotor; status of life-limited parts; time since overhaul of time-limited items; current inspection status; current AD status; and the §43.9(d) FAA Form 337s for each major alteration. Per §91.417(b)(2), retained and transferred with the aircraft. The format must outlive any single software version.
The "transfer on sale" problem is sharper for electronic records
§91.417(b)(2) requires the life-of-aircraft records to transfer with the aircraft when it is sold. For paper, that is a box of logbooks handed to the buyer. For an electronic system, ask before you commit: can the complete record set be exported to a readable, vendor-neutral format the buyer can keep and produce? A pre-purchase records review (and the buyer's lender and insurer) will want the full history — and a record set trapped in a subscription you are about to cancel is a transaction problem. Treat exportability as a §91.417(b)(2) requirement, not a nice-to-have. See the full aviation records retention schedule for the per-record clocks.
"Available" under §91.417(c) means producible — not merely stored
§91.417(c) requires the owner or operator to make the records available for inspection by the Administrator or an NTSB representative; §145.219(d) does the same for repair stations vis-à-vis the FAA and NTSB. An electronic system that stores records perfectly but cannot produce them on request — lost password, off-site laptop, unreadable proprietary format, defunct vendor — has not met the availability standard. Build production into the system: readable export, on-demand retrieval, and no single point of human failure standing between an inspector's request and the record.
Where Operators Go Wrong With Electronic Records
Assuming "electronic" lowers the §43.9 content bar
An electronic entry still needs every §43.9 data point — description (or acceptable data reference), date, performer name when different from the approver, and the approving person's signature, certificate number, and kind of certificate. A slick interface that drops the certificate number produces the same defective entry a sloppy paper logbook would.
Treating a typed name as an electronic signature
A name typed into an unprotected field, with no individual authentication and no audit trail, generally is not an acceptable electronic signature under FAA guidance. It is neither uniquely controlled nor tamper-evident, so it cannot carry the §43.9(a)(4) responsibility the way a controlled electronic signature does.
Locking life-of-aircraft records in a proprietary format
The §91.417(a)(2) records must survive for the life of the aircraft and transfer on sale. A format readable only by one vendor's current software version is a long-term retention risk — and an exportability problem at sale under §91.417(b)(2).
No plan to produce records on demand
When an inspector invokes §91.417(c) (or §145.219(d) for a repair station), "we have them but cannot get to them right now" is not availability. Single-password, single-laptop, single-person dependencies defeat the production duty.
Confusing the records-of-authority with a convenience scan
Decide deliberately, with your IA or principal maintenance inspector, whether the paper logbook or the electronic system is the record of authority — and document that choice. Drifting into "the scans are probably fine" without that decision is how operators end up with two incomplete record sets and no clear controlling one.
Forgetting the air-carrier pathway is different
Part 121 operators and Part 135 CAMP operators record under their approved program per §43.9(b), and their electronic practices are accepted through that program and their operations specifications — not directly under §43.9. A single-aircraft Part 91 owner anchors to §43.9/§91.417 instead.
Related aviation recordkeeping resources
- What a 14 CFR §43.9 maintenance record entry must contain — the six data points
- §91.417 aircraft records retention — the two retention tiers explained
- Airworthiness directive compliance records — §43.9 entries + §91.417(a)(2)(v) AD status
- FAA Form 337 — major repair and alteration records under §43.9(d)
- Part 145 repair station recordkeeping under §145.219
- Aviation records retention schedule — how long to keep every record
How the Picture Differs by Operator Type
The medium-neutral principle is constant, but the approval pathway and the records that matter most differ depending on who is keeping them.
Part 91 owners and corporate flight departments
Anchor directly to §43.9 and §91.417. The two highest-value things an electronic system does for a Part 91 owner are keeping the §91.417(a)(2) life-of-aircraft records intact and exportable for sale, and making §91.417(c) production painless. See corporate flight department records and the ARROW documents.
Part 145 repair stations
High entry volume across many work orders and technicians makes traceability and tamper-evidence essential. §145.219 sets the 2-year retention and the FAA/NTSB availability duty; the repair station's quality system and RSQCM should describe its electronic recordkeeping and signature controls. Systemically missing data points across dozens of digital work orders becomes a systemic finding.
Part 135 and Part 121 air carriers
Carriers using a continuous airworthiness maintenance program record under their approved program per §43.9(b), with electronic practices accepted through that program and their operations specifications. The same core principles — traceability, tamper-evidence, retrievability, availability — apply, but the approval runs through OpSpecs. This connects to broader obligations like operational control, surveillance audit prep, and the 2027 SMS deadline.
Frequently Asked Questions
Does 14 CFR allow electronic aircraft maintenance records and digital signatures?
There is no CFR section that says "electronic records are required" or "digital signatures are mandatory" — and equally, no CFR section that prohibits them. The legal hook is in the recordkeeping rules themselves: 14 CFR §43.9(a)(1) requires a description of work "or reference to data acceptable to the Administrator," and §43.9(a)(4) requires the signature, certificate number, and kind of certificate of the person approving the work. Nothing in §43.9 specifies the medium. The FAA has, through guidance — primarily Advisory Circular AC 120-78B (Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals) — described the conditions under which it will accept electronic records and electronic signatures as satisfying those requirements. AC 120-78B is FAA guidance, not a regulation; it tells you how to make an electronic system acceptable, it does not by itself create a legal mandate. The binding obligation is still §43.9, §91.417, and §145.219 — the medium just has to satisfy them.
What does §43.9 actually require, and how does that map to an electronic record?
Per 14 CFR §43.9(a), a maintenance record entry must contain: (1) a description (or reference to data acceptable to the Administrator) of work performed; (2) the date of completion; (3) the name of the person performing the work if other than the person approving it; and (4) the signature, certificate number, and kind of certificate held by the person approving the work for return to service. An electronic system is acceptable when it captures every one of those data points and binds the approval to a specific, identifiable certificate holder. The phrase in §43.9(a)(1) — "reference to data acceptable to the Administrator" — is exactly the language that lets a digital work order, AMM task reference, or computer-maintained record satisfy the description requirement, provided the referenced data is retrievable. The electronic signature, per FAA guidance, must be traceable to the individual who applied it and must show intent to sign.
What makes an electronic signature acceptable to the FAA on a maintenance record?
The FAA describes acceptable electronic signatures in AC 120-78B (guidance, not regulation). In practice the recurring expectations are: the signature is unique to and under the sole control of one identifiable person; it is traceable back to that individual (so the §43.9(a)(4) certificate number and kind of certificate remain verifiable); it shows the signer's intent to approve the specific work for return to service; and the record cannot be altered after signing without detection. A typed name in a free-text field with no access control and no audit trail is generally not treated as an acceptable electronic signature, because it is neither uniquely controlled nor tamper-evident. The underlying regulatory requirement does not change — §43.9(a)(4) still demands the signature, certificate number, and kind of certificate; the electronic system just has to preserve all three and prove who applied them.
How long must electronic maintenance records be kept, and does the medium change the retention period?
Retention is governed by 14 CFR §91.417(b), and the medium does not change it. §91.417(a)(1) records — maintenance, preventive maintenance, alteration, and the 100-hour, annual, progressive, and other required inspection records — must be retained until the work is repeated or superseded by other work, or for 1 year after the work is performed (§91.417(b)(1)). §91.417(a)(2) records — total time in service of the airframe, each engine, each propeller and rotor; current status of life-limited parts; time since last overhaul of time-limited items; current inspection status; current status of applicable airworthiness directives; and copies of the §43.9(d) forms (FAA Form 337) for each major alteration — must be retained and transferred with the aircraft when it is sold (§91.417(b)(2)). For a Part 145 repair station, §145.219(c) requires records be retained for at least 2 years from the date the article was approved for return to service. An electronic system has to guarantee the record survives, and stays readable, for the full retention period — including the life-of-aircraft tier.
Can the FAA require me to produce my electronic maintenance records on demand?
Yes. 14 CFR §91.417(c) provides that the owner or operator shall make all maintenance records required to be kept by that section available for inspection by the Administrator or any authorized representative of the National Transportation Safety Board (NTSB). For a Part 145 repair station, §145.219(d) similarly requires the records to be available for inspection by the FAA and the NTSB. "Available" is the operative word for an electronic system: if an inspector or investigator asks for the records and the system cannot produce them in a readable form — because of a lost password, an unreadable proprietary format, a server outage, or a vendor that no longer exists — the records are not "available," and the operator carries that exposure. A defensible electronic system therefore has to support export to a readable format and on-demand production, not just storage.
If I scan my paper logbooks to PDF, am I now keeping electronic records?
Scanning paper records to PDF creates an electronic copy, but it does not automatically make the scanned image the controlling record, and it does not satisfy the FAA expectations for an electronic recordkeeping system on its own. A scanned image preserves whatever was on the page — including any defects in the original §43.9 entry — but it typically has no audit trail, no access control, and no structured link between the entry and the governing regulation. Whether you keep the paper as the record of authority and treat the scan as a convenience copy, or move to a true electronic system, is a decision to make deliberately with your principal maintenance inspector or FSDO, consistent with AC 120-78B guidance. What a scan-only approach does not give you is the tamper-evidence, retrievability, and traceability that distinguish an acceptable electronic system from a folder of image files.
Does a Part 135 or Part 121 air carrier follow §43.9 or its own program for electronic records?
Air carriers required by their operations specifications to use a continuous airworthiness maintenance program — Part 121 operators and Part 135 CAMP operators — make their maintenance record entries under their approved program and the relevant operating part rather than directly under §43.9(a), per the direction in §43.9(b). Their electronic recordkeeping and electronic signature practices are accepted as part of that approved maintenance program and the carrier's manual system, again with AC 120-78B as the FAA's guidance reference. The same core principles apply — traceable signatures, tamper-evidence, retrievability, and on-demand availability to the FAA — but the approval pathway runs through the carrier's program and operations specifications. A single-aircraft Part 91 owner, an independent A&P, and a Part 145 repair station, by contrast, anchor directly to §43.9, §91.417, and §145.219.
Is FileFlo an FAA-approved electronic recordkeeping system?
No. FileFlo does not hold any FAA approval, does not certify electronic recordkeeping systems, and is not itself an aircraft maintenance records system of authority. FileFlo is a compliance document intelligence layer: it classifies the maintenance documents you already keep against the governing CFR, indexes them, tracks retention clocks and expirations, flags entries that appear to be missing a §43.9 data point, and assembles an inspector-format binder on demand so the records are easy to produce. Whether your records-of-authority are paper logbooks, a maintenance-tracking platform, or a true electronic recordkeeping system accepted by your FSDO is your decision with your A&P, IA, principal maintenance inspector, or FAA-designated expert. FileFlo helps you prove the records are complete and produce them quickly; it does not replace the recordkeeping system, the mechanic, or the FAA acceptance process.
Related Aviation Compliance Reading
Part 135 Pilot Records Required by the FAA
Airman and currency records that pair with maintenance records
Part 135 Drug & Alcohol Program Records (Part 120)
The 14 CFR Part 120 program records checklist
Part 91.409 Annual Inspection Requirements
§43.11 inspection entries vs §43.9 maintenance entries
Life-Limited Parts Records Requirements
§91.417(a)(2)(ii) status tracking — a life-of-aircraft record
Engine & Propeller Overhaul Time Tracking
§91.417(a)(2)(iii) time-since-overhaul records
Pilot Logbook vs Operator Records (§61.51)
Where personal logbooks end and operator records begin
Paper or electronic, prove your records are complete and producible
FileFlo is a compliance document intelligence platform — the proof layer, not the recordkeeping system. It classifies aviation maintenance documents against the governing CFR (§43.9 entry completeness, §91.417 retention tiers, §145.219 repair-station requirements), flags entries that look like they are missing a required data point, tracks expirations, and assembles an inspector-format audit binder on demand. It does not hold FAA approval, perform maintenance, or replace your A&P, IA, or records system of authority. Starter $89/month · Professional $299/month · 5-day free trial, no credit card required.