The Inspection Authorization is one of the most consequential credentials in aircraft maintenance, and one of the most commonly misunderstood. A certificated airframe and powerplant (A&P) mechanic can do an enormous amount of maintenance work — but the A&P alone cannot legally approve an aircraft for return to service after an annual inspection or after a major repair or major alteration. That authority comes from the Inspection Authorization, granted under 14 CFR §65.91.
The IA is also unusual in how it expires. Most airman certificates and ratings run on a rolling anniversary of when they were issued. The IA does not. Under 14 CFR §65.93, every IA is on a fixed two-year cycle that comes due in the month of March of each odd-numbered year — and there is a separate, easy-to-miss requirement to complete a qualifying activity by March 31 of the first year of that cycle, not just at renewal. Mechanics who track their inspection currency by a personal anniversary date get surprised by this.
This guide walks through all three governing sections — §65.91 (eligibility), §65.95 (privileges), and §65.93 (renewal and the activity requirement) — using the exact regulatory thresholds, and then maps the documents an IA holder and a flight department need to keep findable to prove all of it during an FAA surveillance audit.
What an Inspection Authorization Actually Is
An Inspection Authorization is not a separate certificate — it is an authorization layered on top of an existing A&P mechanic certificate. The A&P certificate establishes that a person is qualified to perform and supervise maintenance and to return aircraft to service after most maintenance. The IA expands that authority into two specific, high-stakes areas: approving the annual inspection, and approving aircraft for return to service after major repairs and major alterations.
That distinction is the single most important practical takeaway. A regular A&P can perform — and return an aircraft to service after — a 100-hour inspection, and can perform the repair work an annual generates. But the annual inspection itself is an IA privilege under §65.95(a)(2): it must be performed by an IA holder (or an appropriately rated Part 145 repair station), who also signs the return-to-service approval. An annual performed or signed by an A&P who does not hold an IA is not a valid annual — and that turns the inspection into a logbook defect.
Where the IA Sits in the Regulatory Chain
The IA rules live in 14 CFR Part 65, Subpart D (Mechanics): §65.91 sets eligibility, §65.93 sets the renewal cycle and activity requirement, and §65.95 defines the privileges and the duty to keep the authorization available. Those privileges are what make the IA the answer to the question 14 CFR §91.409(a) poses: an aircraft may not be operated unless, within the preceding 12 calendar months, it has had an annual inspection and been approved for return to service by a person authorized under §43.7 — and for the annual, that person is an IA holder.
Eligibility to Obtain an IA — 14 CFR §65.91(c)
To be eligible for an Inspection Authorization, an applicant must meet all five requirements in §65.91(c). These are gate conditions — the applicant either meets every one or does not qualify.
A&P Certificate Held for at Least 3 Years — §65.91(c)(1)
The applicant must hold a currently effective mechanic certificate with both an airframe rating and a powerplant rating, each of which is currently effective and has been in effect for a total of at least 3 years. A single rating is not enough — both the airframe and powerplant ratings are required, and the three-year clock is a total, not a recent stretch.
2 Years of Active Practice — §65.91(c)(2)
The applicant must have been actively engaged, for at least the 2-year period before the date of application, in maintaining aircraft certificated and maintained in accordance with Title 14. Holding the certificate is not the same as using it; this requirement establishes recent, hands-on maintenance experience on regulated aircraft.
A Fixed Base of Operations — §65.91(c)(3)
The applicant must have a fixed base of operations at which they may be located in person or by telephone during a normal working week. The regulation expressly notes that this base need not be the place where the applicant will exercise the inspection authority — it is about being reachable and locatable, not about where every inspection happens.
Equipment, Facilities, and Inspection Data — §65.91(c)(4)
The applicant must have available the equipment, facilities, and inspection data necessary to properly inspect airframes, powerplants, propellers, or any related part or appliance. In practice this means access to current manufacturer maintenance data, service bulletins, type-certificate data sheets, and the tooling to actually conduct the inspection — not just a certificate on the wall.
Pass the Written Test — §65.91(c)(5)
The applicant must pass a written test on their ability to inspect according to safety standards for returning aircraft to service after major repairs and major alterations, and annual and progressive inspections, performed under Part 43. An applicant who fails this test may not apply for retesting until at least 90 days after the date of the failure.
The "fixed base" and "equipment/data" requirements are continuing — not one-time
Eligibility under §65.91(c)(1) through (4) is not just an entry gate. As we will see in the renewal section, §65.93 requires the holder to still meet §65.91(c)(1) through (4) at every renewal. An IA holder who loses their fixed base or no longer has access to current inspection data is no longer renewal-eligible — and under §65.95(c), changing the fixed base requires written notice to the responsible Flight Standards office before exercising privileges at the new location.
What an IA Lets You Do — 14 CFR §65.95
§65.95(a) grants the holder of an IA two privileges that a standard A&P does not have — and §65.95(b) and (c) attach two duties to exercising them.
Privilege 1 — Approve Return to Service After Major Repairs and Major Alterations (§65.95(a)(1))
An IA holder may inspect and approve for return to service any aircraft or related part or appliance after a major repair or major alteration, provided the work was done in accordance with technical data approved by the Administrator. One exclusion: this does not extend to aircraft maintained in accordance with a Part 121 continuous airworthiness program (those operate under a different maintenance and return-to-service structure). The major-repair/major-alteration sign-off is closely tied to the §43.9 maintenance record entry and the FAA Form 337 documentation for the alteration.
Privilege 2 — Perform the Annual and Perform/Supervise Progressive Inspections (§65.95(a)(2))
An IA holder may perform an annual inspection, or perform or supervise a progressive inspection, in accordance with 14 CFR §§43.13 and 43.15. This is the privilege that satisfies the §91.409(a) annual-inspection requirement and the §91.409(d) progressive-inspection option. It is also why the IA matters far beyond the individual mechanic: a flight department or charter operator cannot keep an aircraft legal for flight without an annual sign-off from an IA or a rated repair station.
Duty — Keep the IA Available and Notify on a Base Change (§65.95(b), (c))
When exercising IA privileges, the holder must keep the authorization available for inspection by the aircraft owner, by the mechanic submitting the aircraft, repair, or alteration for approval, and must present it on request of the Administrator, an authorized representative of the NTSB, or any Federal, State, or local law enforcement officer (§65.95(b)). And if the holder changes the fixed base of operations, they may not exercise IA privileges until they have notified the responsible Flight Standards office (or International Field Office) for the new base, in writing (§65.95(c)).
| Action | A&P (no IA) | A&P with IA | CFR |
|---|---|---|---|
| Return to service after a 100-hour inspection | Yes | Yes | §91.409(b) |
| Approve return to service after an annual inspection | No | Yes | §65.95(a)(2) |
| Approve return to service after a major repair / major alteration | No | Yes | §65.95(a)(1) |
| Perform or supervise a progressive inspection | No | Yes | §65.95(a)(2) |
| Perform routine maintenance and minor repairs | Yes | Yes | Part 65 / §43.3 |
The 100-hour vs annual distinction is the most common real-world confusion: same Part 43 Appendix D inspection scope, different authorization level for the sign-off. See the §91.409 inspection guide for the full breakdown.
The Renewal Cycle — 14 CFR §65.93(a)
This is where IA holders most often get tripped up. Under §65.93(a), an IA is issued for a 2-year period, and to renew it the holder must present evidence during the month of March of each odd-numbered year, at the responsible Flight Standards office, that they still meet the requirements of §65.91(c)(1) through (4).
But §65.93(a) layers a second, separate requirement on top of the renewal itself. During the time the holder held the IA, they must show completion of one of the five activities by March 31 of the first year of the 2-year period, and completion of one of the five activities during the second year of the period. In other words, the IA is not a "set it and forget it for two years" credential — there is a mid-cycle checkpoint at March 31 of the first year, and a separate activity in the second year, and then the formal renewal in March of the next odd-numbered year.
The IA Two-Year Cycle, Step by Step
- Cycle startThe 2-year period begins. The clock to the next renewal (March of the next odd-numbered year) starts running.
- By March 31, Year 1Complete one of the five §65.93(a) activities. Miss this and you cannot exercise IA privileges after March 31 of Year 1 until you pass an FAA oral test (§65.93(c)).
- During Year 2Complete one of the five activities again — the activity requirement repeats in the second year.
- March of the odd-numbered yearPresent renewal evidence to the responsible Flight Standards office that you still meet §65.91(c)(1)-(4) and have completed the required activities.
Relief for a Newly Issued IA — §65.93(b)
§65.93(b) provides relief for IAs that have not been held very long. An IA that has been in effect for less than 90 days before the expiration date need not comply with the §65.93(a)(1) through (5) activity requirement. And an IA that has been in effect for less than 90 days before March 31 of an even-numbered year need not comply with the activity requirement for the first year of the 2-year period. This keeps a mechanic who just earned the IA from being penalized for not yet having accumulated the activity counts.
The Five Renewal Activities — 14 CFR §65.93(a)(1)–(5)
The holder must complete one of these five activities by March 31 of the first year, and one during the second year. They do not have to be the same activity each time. Here are the exact thresholds from §65.93(a):
Annual Inspections — One Per 90 Days Held
Performed at least one annual inspection for each 90 days that the applicant held the current authority. This is a rate, not a flat number — the longer you held the authority during the period, the more annuals you need to have performed to qualify on this basis.
Major Repairs or Major Alterations — Two Per 90 Days Held
Performed at least two major repairs or major alterations for each 90 days that the applicant held the current authority. Like the annuals option, this scales with how long the authority was held during the period.
A Progressive Inspection
Performed or supervised and approved at least one progressive inspection in accordance with standards prescribed by the Administrator. A single qualifying progressive inspection satisfies this option.
An 8-Hour Refresher Course
Attended and successfully completed a refresher course, acceptable to the Administrator, of not less than 8 hours of instruction. This is the path most IA holders use when they did not meet the activity counts — it is the basis for the well-known annual IA refresher seminars.
An Oral Test by an FAA Inspector
Passed an oral test by an FAA inspector to determine that the applicant's knowledge of applicable regulations and standards is current. This is also the mechanism §65.93(c) uses to restore privileges after a missed first-year activity.
Why the running log of your work is the renewal proof
Activity options (1) and (2) are demonstrated by your record of completed annual inspections and major repairs/alterations — the same §43.9 entries and airworthiness records you generate in normal work. If those records are scattered across logbooks, work orders, and email, proving you hit the per-90-day rate at renewal becomes a scramble. Keeping the activity log organized and date-stamped year-round is the difference between a smooth renewal and reconstructing two years of work from memory.
Missing the Activity Deadline or Letting the IA Expire
The consequences of falling behind are specific, and they are not the same as losing the underlying A&P certificate.
Missed the First-Year Activity by March 31 — §65.93(c)
An IA holder who does not complete one of the five §65.93(a) activities by March 31 of the first year of the 2-year period may not exercise inspection authorization privileges after March 31 of the first year. The holder may resume exercising privileges after passing an oral test from an FAA inspector determining that their knowledge of applicable regulations and standards is current. A holder who passes that oral test is deemed to have completed the §65.93(a)(1) through (5) requirement by March 31 of the first year. The authorization is not revoked — but the privilege is paused until the oral test is passed.
Renewing an Expired IA — §65.93(d)
§65.93(d) provides that a person who qualifies for the relief prescribed in 14 CFR §61.40 is eligible to renew an expired inspection authorization under §65.93, provided the §61.40 requirements are met. Because the path for an already-expired IA depends on the specific facts and the §61.40 relief criteria, an IA holder in this situation should confirm the exact route with the responsible Flight Standards office rather than assuming an automatic renewal.
A paused IA can quietly invalidate annual sign-offs
The risk is not abstract. If an IA holder misses the March 31 first-year activity and keeps signing off annuals without realizing their privilege has lapsed under §65.93(c), every one of those annual approvals is questionable — and the aircraft they "returned to service" may not have a valid annual under §91.409(a). For a charter or flight department, that can cascade into multiple aircraft being unairworthy on paper. This is exactly the kind of date-driven lapse that a tracked, alerted record set is built to prevent.
The IA Records You Need to Keep Findable
Nothing in §65.91, §65.93, or §65.95 is hard to satisfy when you are working steadily — the trap is documentation. Proving eligibility at renewal, proving the per-90-day activity counts, and proving the IA was valid on the date of every annual sign-off all depend on records being current, dated, and retrievable. The documents that matter:
The IA Certificate Itself
Must be kept available for inspection by owners, submitting mechanics, the FAA, the NTSB, and law enforcement (§65.95(b)). Know its current expiration (March 31 of the next odd-numbered year).
Refresher-Course Completion Certificates
If you renew via the 8-hour refresher (§65.93(a)(4)), the completion certificate is your evidence. Keep every cycle on file.
Running Log of Annual Inspections
Demonstrates §65.93(a)(1) activity (one annual per 90 days held). Date-stamped, tied to aircraft and tail number.
Major Repair / Major Alteration Records
Demonstrates §65.93(a)(2) activity (two per 90 days held) and underlies your §65.95(a)(1) sign-offs — including FAA Form 337s.
Fixed-Base & Data Access Evidence
Supports continued §65.91(c)(3)-(4) eligibility at renewal: where you are based and what inspection data you maintain access to.
Base-Change Notification to the FSDO
If you moved your fixed base, the written notice under §65.95(c) is what shows you were authorized to work at the new location.
Never get surprised by the March renewal window again
FileFlo is a compliance document intelligence platform — a read-only proof layer that classifies and tracks the records an IA holder and a maintenance organization generate. Upload your IA certificate, refresher-course certificates, and your running record of annuals and major repairs, and FileFlo:
- Classifies each document against the governing CFR (§65.91, §65.93, §65.95, §43.9)
- Extracts the IA expiration and sends 90/60/30-day alerts ahead of the fixed March-of-odd-year renewal window
- Maintains a date-stamped activity log so the §65.93 per-90-day counts are provable, not reconstructed from memory
- Generates an audit-ready binder organized by CFR section for an FAA surveillance visit or a flight-department records review
FileFlo sits alongside the certificated IA, the maintenance provider, and the logbooks — it does not perform inspections, issue authorizations, or replace the FAA, an A&P, an IA, or a Part 145 repair station. It keeps the documents that prove your compliance audit-ready. Starter $89/mo · Professional $299/mo · 5-day free trial, no credit card required.
Related Aviation Compliance Reading
Frequently Asked Questions
What are the eligibility requirements to get an Inspection Authorization (IA)?
Under 14 CFR §65.91(c), an applicant for an Inspection Authorization must: (1) hold a currently effective mechanic certificate with BOTH an airframe rating and a powerplant rating, each of which has been in effect for a total of at least 3 years; (2) have been actively engaged, for at least the 2-year period before the date of application, in maintaining aircraft certificated and maintained under Title 14; (3) have a fixed base of operations at which the applicant can be located in person or by telephone during a normal working week; (4) have available the equipment, facilities, and inspection data necessary to properly inspect airframes, powerplants, propellers, or any related part or appliance; and (5) pass a written test on inspecting to safety standards for returning aircraft to service after major repairs, major alterations, and annual and progressive inspections under Part 43. An applicant who fails the written test may not reapply for retesting until at least 90 days after the failure.
How long is an Inspection Authorization valid, and when does it expire?
Under 14 CFR §65.93(a), an Inspection Authorization is issued for a 2-year period. The renewal cycle is fixed to the calendar, not to the individual issue date: an IA holder must present renewal evidence during the month of March of each odd-numbered year at the responsible Flight Standards office. In practical terms, every IA expires on March 31 of an odd-numbered year, and the renewal window is the preceding month of March. This is different from many certificates that expire on a rolling anniversary of the issue date — the IA cycle is synchronized so that all IAs come due at the same time.
What activity is required to renew an IA?
Under 14 CFR §65.93(a), to renew an IA the holder must (a) still meet the §65.91(c)(1) through (4) eligibility requirements, AND (b) show completion of one of five activities by March 31 of the first year of the 2-year period, plus completion of one of the five activities during the second year. The five activities are: (1) performed at least one annual inspection for each 90 days the applicant held the authority; (2) performed at least two major repairs or major alterations for each 90 days held; (3) performed or supervised and approved at least one progressive inspection per the Administrator's standards; (4) attended and successfully completed a refresher course, acceptable to the Administrator, of not less than 8 hours of instruction; or (5) passed an oral test by an FAA inspector to determine that the applicant's knowledge of applicable regulations and standards is current. Most working IAs rely on activity counts (annuals or major repairs); the 8-hour refresher (often the annual FAA-sponsored IA seminar) is the common path for those who did not meet the activity thresholds.
What happens if I do not complete a renewal activity by March 31 of the first year?
Under 14 CFR §65.93(c), an IA holder who does not complete one of the five §65.93(a) activities by March 31 of the first year of the 2-year period may not exercise inspection authorization privileges after March 31 of that first year. The holder may resume exercising IA privileges after passing an oral test from an FAA inspector that determines the holder's knowledge of applicable regulations and standards is current. An IA holder who passes that oral test is deemed to have completed the §65.93(a)(1) through (5) requirement by March 31 of the first year. So the consequence of missing the mid-cycle activity is not loss of the certificate, but a suspension of the IA privilege until the oral test is passed.
What can an IA holder actually do that a regular A&P cannot?
Under 14 CFR §65.95(a), the holder of an Inspection Authorization may: (1) inspect and approve for return to service any aircraft or related part or appliance after a major repair or major alteration, if the work was done in accordance with technical data approved by the Administrator (this excludes aircraft maintained under a Part 121 continuous airworthiness program); and (2) perform an annual inspection, or perform or supervise a progressive inspection, under 14 CFR §§43.13 and 43.15. A standard A&P mechanic without an IA can perform — and return an aircraft to service after — a 100-hour inspection, but cannot perform or approve the annual inspection or approve return to service after a major repair/major alteration: §65.95(a)(2) makes performing the annual itself an IA privilege, and §43.3(d) does not extend supervised inspection authority to inspections required by Part 91. The IA is the authority that makes the annual and the major-repair/major-alteration sign-offs legal.
Does an IA holder have to keep the authorization available, and what about a change of base?
Yes. Under 14 CFR §65.95(b), when an IA holder exercises the privileges of the authorization, the holder must keep it available for inspection by the aircraft owner, by the mechanic submitting the aircraft, repair, or alteration for approval, and must present it on request of the Administrator, an authorized representative of the NTSB, or any Federal, State, or local law enforcement officer. Under §65.95(c), if the holder changes the fixed base of operations, the holder may not exercise the privileges of the authorization until they have notified the responsible Flight Standards office (or International Field Office) for the area of the new base, in writing, of the change.
Can an IA that has already expired be renewed, or do I have to start over?
Under 14 CFR §65.93(d), a person who qualifies for the relief prescribed in 14 CFR §61.40 is eligible to renew an expired Inspection Authorization, provided the §61.40 requirements are met. Section 61.40 is the regulatory relief mechanism that addresses renewal of expired authorizations in defined circumstances. Note that the §65.93(c) oral-test mechanism is narrower than it sounds: it applies only mid-cycle, allowing the holder of a still-effective IA who missed the first-year March 31 activity to resume exercising privileges after an oral test. It is not a revival path for an IA that expired un-renewed at the end of the 2-year period — outside §61.40 relief, that person must apply for a new Inspection Authorization under §65.91 (in FAA practice, that means retaking the §65.91(c)(5) written test). Because the rules around an expired IA depend on the specific facts and the §61.40 relief criteria, confirm your exact path with your responsible Flight Standards office rather than assuming a clean automatic renewal.
How does FileFlo help an IA holder or a flight department stay on top of these dates?
FileFlo is a compliance document intelligence platform — a read-only proof layer. It does not perform inspections, issue authorizations, or replace the FAA, an A&P, or an IA. What it does: classify the documents an IA holder and a maintenance organization accumulate (the IA certificate itself, refresher-course completion certificates, the running log of annual inspections and major repairs that demonstrate §65.93 activity, and the aircraft inspection records the IA signs), extract the relevant dates, and send 90/60/30-day reminders ahead of the fixed March-of-odd-year renewal window. It also assembles those records into an audit-ready binder organized by CFR section for an FAA surveillance visit. FileFlo keeps the evidence current and findable; the inspecting and signing remain with the certificated IA.
More Aviation Compliance Guides
Part 91.409 Inspection Requirements
Annual, 100-hour, progressive, and AAIP — when each applies and who can sign off each type
What a §43.9 Maintenance Entry Must Contain
The five required elements of every compliant aviation maintenance record entry
What Aircraft Records Must a Part 91 Operator Keep
Permanent vs temporary records and the §91.409/§91.411/§91.413 inspection cycle
Airworthiness Directive Compliance Records
Part 39 AD compliance workflow, applicability, and the §91.417 tracking obligation
Part 145 Repair Station Recordkeeping
What §145.219 demands — work orders, 8130-3 traceability, and the 2-year retention rule
Prepare for a Part 135 FAA Surveillance Audit
What inspectors ask for and how to have the records ready before they arrive
Chad Griffith
Founder, FileFlo — compliance document intelligence. FileFlo classifies, indexes, and tracks the records that prove aviation compliance audit-ready. It does not perform inspections, issue authorizations, or replace an A&P, an IA, a Part 145 repair station, or the FAA. About FileFlo.
Keep your IA — and every record that proves it — current
FileFlo classifies your IA certificate, refresher-course certificates, and your running log of annuals and major repairs against 14 CFR §65.91, §65.93, and §65.95, extracts the renewal date, and sends 90/60/30-day alerts before the March-of-odd-year window closes. Walk into any FAA surveillance review with the activity record assembled, dated, and findable.
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