Light-sport aviation runs on a maintenance framework that looks deceptively simple and trips up newcomers constantly. The same part 43 recordkeeping rules apply, but who is allowed to inspect and maintain a light-sport aircraft depends on a dedicated repairman certificate that most people in conventional general aviation have never had to think about — and on whether the aircraft holds a special or an experimental airworthiness certificate.
14 CFR §65.107 creates a repairman certificate (light-sport) with two very different ratings. §65.109 defines what each rating may do. §43.3(g) gives a sport pilot a narrow preventive-maintenance authority on their own aircraft, and §91.327 sets the maintenance and condition-inspection rules for the special light-sport aircraft fleet. Get the relationship among those four sections right and the records almost organize themselves; get it wrong and you can have a logbook entry signed by someone who was not authorized to make it.
This guide is the light-sport companion to our broader Part 65 mechanic & repairman certificate guide. It walks through the two §65.107 ratings, the §65.109 privileges, the sport-pilot preventive-maintenance line, the §91.327 operating limitations, and the aircraft records an owner or a light-sport operator needs so that every inspection and every return-to-service can be tied to a person who was authorized to do it.
Why Light-Sport Maintenance Is Its Own World
The first thing to settle for any light-sport aircraft is which airworthiness certificate it holds, because that single fact drives almost everything about who may inspect and maintain it.
S-LSA — Special Light-Sport (§21.190)
- Special airworthiness certificate in the light-sport category
- Built to an identified consensus standard with a manufacturer statement of compliance
- Maintenance & condition inspection per §91.327 by an authorized person
- Maintenance-rating repairman can return it to service (§65.109(b))
E-LSA — Experimental Light-Sport (§21.191)
- Experimental airworthiness certificate under §21.191(g), (i), (k), or (l)
- Paragraph (i) covers experimental light-sport aircraft specifically
- Annual condition inspection is the recurring inspection event
- Inspection-rating repairman who owns it may perform that inspection (§65.109(a))
Three people can be in the picture
For light-sport work, the authorized person is usually one of three: a repairman (light-sport) with the right rating under §65.107/§65.109; an appropriately rated mechanic (an A&P, whose privileges we cover in the Part 65 mechanic guide); or an appropriately rated repair station. A sport pilot can also do limited preventive maintenance on their own light-sport aircraft. Which one signed each entry is exactly what your records need to show.
The Two Ratings — 14 CFR §65.107
§65.107(a) provides two ratings on a repairman certificate (light-sport): an inspection rating and a maintenance rating. The general eligibility gate in §65.107(b) applies to both, but the training course differs sharply between them.
General eligibility — §65.107(b)
To be eligible for a repairman certificate (light-sport), a person must be at least 18 years old; be able to read, speak, write, and understand English; complete the training course for the rating sought (under paragraph (c) or (d)); pass a written test administered by the training course provider covering the contents of that course; and present documentary evidence of both the completed FAA-accepted course and the passed written test.
Inspection rating course — §65.107(c)
To obtain an inspection rating, a person must complete a 16-hour training course accepted by the Administrator on inspecting the category, and class as applicable, of experimental aircraft for which the person intends to exercise the privileges of the rating. The course is tied to the category and class the holder will inspect — it is not a general credential.
Maintenance rating course — §65.107(d)
To obtain a maintenance rating, a person must complete a training course accepted by the Administrator that includes content on, at a minimum, the knowledge, risk management, and skill elements for each subject contained in the Aviation Mechanic General, Airframe, and Powerplant Airman Certification Standards, appropriate to the category, and class as applicable. The maintenance-rating course is substantially broader than the 16-hour inspection course — it reflects the broader maintenance authority the rating carries.
The course-completion evidence is the qualifying record
Because §65.107(b) makes documentary evidence of the course and the written test a condition of eligibility, those documents — the certificate of course completion and the written-test result — are the records that prove the rating was properly earned. For an inspection rating, the evidence should also reflect the specific category and class the 16-hour course covered, because §65.109(a) limits the privilege to that same category and class. Capturing the category/class on file, not just "light-sport repairman," is what keeps the qualification defensible.
What Each Rating May Do — 14 CFR §65.109
§65.109 is where the two ratings diverge most. The inspection rating is owner-specific and limited to one task; the maintenance rating reaches actual maintenance and return-to-service authority on the special light-sport fleet.
Inspection rating — §65.109(a)
The holder of a repairman certificate (light-sport) with an inspection rating may perform the annual condition inspection on an aircraft that (1) is owned by the holder; (2) has an experimental airworthiness certificate issued under §21.191(g), (i), (k), or (l); and (3) is in the same category, and class as applicable, for which the holder completed the §65.107(c) course. Three limits sit inside that one sentence: it is the annual condition inspection only, on an experimental light-sport aircraft the holder owns, in the trained category and class.
Maintenance rating — §65.109(b)
The holder of a maintenance rating may (1) approve for return to service an aircraft that has a special airworthiness certificate in the light-sport category under §21.190 (an S-LSA), or any part thereof, after performing or inspecting maintenance — including the annual condition inspection and the 100-hour inspection required by §91.327 — preventive maintenance, or an alteration, excluding a major repair or a major alteration on a product produced under an FAA approval; (2) perform the annual condition inspection on an experimental aircraft under §21.191(g), (i), (k), or (l); and (3) only perform maintenance, preventive maintenance, and alterations on aircraft in the same category, and class as applicable, for which the holder completed the §65.107(d) training. Before performing a major repair, the holder must complete additional training acceptable to the FAA and appropriate to the repair.
The "performed it before" limitation — §65.109(c)
A maintenance-rating holder may not approve for return to service any aircraft or part unless they have previously performed the work concerned satisfactorily. If they have not, they may show the ability by performing it to the satisfaction of the FAA, or under the direct supervision of a certificated and appropriately rated mechanic, or a certificated repairman, who has had previous experience in the specific operation. And the repairman may not exercise the privileges unless they understand the current instructions of the manufacturer and the maintenance manuals for the specific operation concerned — a per-task competency rule, parallel to the mechanic rule in §65.81.
| Action | Inspection Rating | Maintenance Rating | CFR |
|---|---|---|---|
| Annual condition inspection on an E-LSA the holder owns | Yes | Yes | §65.109(a) / (b)(2) |
| Annual condition inspection on an S-LSA | No | Yes | §65.109(b)(1) |
| 100-hour inspection required by §91.327 on an S-LSA | No | Yes | §65.109(b)(1) |
| Maintenance / preventive maintenance / alteration (in category & class) | No | Yes | §65.109(b)(3) |
| Approve an S-LSA for return to service | No | Yes | §65.109(b)(1) |
| Major repair / major alteration on an FAA-approved product | No | No | §65.109(b)(1) |
| Inspect an aircraft the holder does not own (E-LSA) | No | Yes | §65.109(b)(2) |
The single most important distinction: the inspection rating only reaches the annual condition inspection on an E-LSA the holder owns, while the maintenance rating reaches actual maintenance and the return-to-service authority on the S-LSA fleet — and is not limited to aircraft the holder owns.
What a Sport Pilot May Do — 14 CFR §43.3(g)
Separate from the repairman certificate, a sport pilot has a narrow maintenance authority of their own. It is preventive maintenance only — not maintenance — and the scope of "preventive maintenance" is defined in Part 43, Appendix A(c).
The two sentences of §43.3(g)
§43.3(g) works in two parts. First, except for holders of a sport pilot certificate, the holder of a part 61 pilot certificate may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135. Second, the sport-pilot carve-back: the holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.
So a sport pilot's authority is narrower than a higher-grade pilot's: it is preventive maintenance, on an aircraft they own or operate, that holds a light-sport-category special airworthiness certificate. The return-to-service for that preventive maintenance is then handled by §43.7(h), under which the holder of at least a sport pilot certificate may approve that owned/operated light-sport aircraft for return to service after performing the preventive maintenance.
Preventive maintenance still has to be recorded
A sport pilot doing preventive maintenance is not exempt from the records rules. The work is recorded as a maintenance entry under §43.9 — description of the work, date of completion, and the signature and certificate information of the person approving it for return to service. The pilot-logbook discipline that keeps the airman side straight is a different record entirely; we cover the boundary in pilot logbook vs. operator records. The maintenance entry lives with the aircraft, not the pilot.
S-LSA Maintenance & Condition Inspection — 14 CFR §91.327
For an aircraft holding a special airworthiness certificate in the light-sport category, §91.327 is the operating-limitations rule that sets the maintenance and inspection requirements — and, importantly, who may perform them.
Maintenance authority — §91.327(b)
The aircraft must be maintained by a certificated repairman (light-sport) with a maintenance rating, an appropriately rated mechanic, or an appropriately rated repair station, in accordance with the applicable provisions of part 43 and the applicable maintenance and inspection procedures. The rule lists three alternatives — it does not require an A&P, and it does not require a repair station; any one of the three authorized persons may do the work.
Condition inspection — once every 12 calendar months
The condition inspection must be performed once every 12 calendar months by a certificated repairman (light-sport) with a maintenance rating, an appropriately rated mechanic, or an appropriately rated repair station. This is the recurring inspection event for the special light-sport fleet — a recurrence date your records need to track the way an annual inspection is tracked on a type-certificated aircraft.
Major repair / alteration recording — §91.327(b)(6)
The operator must comply with the requirements for recording major repairs and major alterations performed on type-certificated products in accordance with §43.9(d), and with the retention requirements in §91.417. So the heavier paperwork and retention discipline of the broader fleet reaches the light-sport world for major work as well.
"Per the manufacturer's procedures" is doing real work here
Light-sport maintenance is governed not only by part 43 but by the applicable maintenance and inspection procedures — typically the manufacturer's maintenance manual and the consensus standard behind the S-LSA's airworthiness certificate. Those procedures, and any manufacturer service bulletins or safety directives they make mandatory, are part of the data an authorized person must understand and follow. Keep the manufacturer's current maintenance and inspection procedures on file alongside the airworthiness certificate; they are not optional background, they are part of the governing standard for the inspection.
The Records: §43.9 for Maintenance, §43.11 for the Inspection
Light-sport aircraft use the same two recordkeeping sections as the rest of the fleet — and confusing them is a common error. Maintenance entries go under §43.9; the condition inspection entry goes under §43.11.
Maintenance entry — §43.9(a)
For maintenance, preventive maintenance, rebuilding, or alteration, §43.9(a) requires:
- A description (or reference to acceptable data) of the work performed
- The date of completion of the work
- The name of the person performing the work, if different from the approver
- The signature, certificate number, and kind of certificate of the person approving the work
Inspection entry — §43.11(a)
The condition inspection is an inspection, so its entry follows §43.11(a):
- The type of inspection and a brief description of its extent
- The date of the inspection and aircraft total time in service
- The signature, certificate number, and kind of certificate of the person approving/disapproving for return to service
- The airworthiness statement — or, on disapproval, that a list of discrepancies and unairworthy items was provided to the owner/operator
Why the split matters: §43.9(c) expressly states that section does not apply to persons performing inspections — inspections are recorded under §43.11 instead. So the recurring 12-calendar-month condition inspection is documented with the §43.11 inspection language, while the routine maintenance and preventive maintenance between inspections is documented with the §43.9 elements. Mixing them up — for example, recording a condition inspection as if it were a §43.9 maintenance entry without the §43.11 inspection statement — is exactly the kind of defect a reviewer catches. We break the §43.9 entry down further in our §43.9 maintenance entry guide.
Who may sign for return to service is set by §43.7: §43.7(g) authorizes a repairman (light-sport) with a maintenance rating to approve a light-sport-category aircraft for return to service, and §43.7(h) authorizes the holder of at least a sport pilot certificate to approve their owned/operated light-sport aircraft for return to service after preventive maintenance. The kind of certificate the signer held is one of the required entry elements — which is why matching the signature on each entry to the right §65.107 rating (or sport-pilot authority) is the heart of a defensible light-sport record.
The Light-Sport Records to Keep
Pulling it together, here is the document set that lets a light-sport owner or operator prove — for every inspection and every return-to-service — that the person who signed was authorized and that the inspection was performed and recorded correctly.
Airworthiness Certificate (S-LSA or E-LSA)
The certificate establishing §21.190 special vs. §21.191 experimental status — the fact that drives who may inspect and maintain the aircraft.
Repairman (Light-Sport) Certificate + Rating
The certificate and whether it carries the inspection or maintenance rating (§65.107), plus the category/class for an inspection rating.
Training-Course & Written-Test Evidence
The §65.107(b) documentary evidence: the 16-hour inspection course or the maintenance-rating ACS-content course, and the passed written test.
Condition-Inspection Entries (§43.11)
Each 12-calendar-month condition inspection recorded with the type/extent, date and total time in service, signer, and airworthiness statement.
Maintenance / Preventive-Maintenance Entries (§43.9)
Routine work between inspections — including sport-pilot preventive maintenance — with the §43.9(a) elements and the §43.7 signer.
Manufacturer's Maintenance & Inspection Procedures
The maintenance manual and consensus-standard procedures §91.327 requires the work to follow, plus any mandatory service bulletins/safety directives.
This light-sport record set connects to the wider aircraft-records picture: the part 91 aircraft records, the airworthiness directive compliance records (ADs reach light-sport aircraft too), the ARROW documents that must be aboard, and the broader Part 65 mechanic & repairman framework when an A&P rather than a light-sport repairman does the work.
Make every light-sport inspection and sign-off provable
FileFlo is a compliance document intelligence platform — a read-only proof layer that classifies and tracks the documents behind light-sport maintenance. Upload airworthiness certificates, repairman certificates and rating evidence, condition-inspection entries, maintenance records, and the manufacturer's procedures, and FileFlo:
- Classifies each document against the governing CFR (§65.107, §65.109, §43.3(g), §43.7, §43.9, §43.11, §91.327)
- Distinguishes S-LSA from E-LSA from the airworthiness certificate so the right authority is matched to the right work
- Tracks the 12-calendar-month condition inspection recurrence so a lapse does not slip past unnoticed
- Assembles an audit-ready record organized by CFR section so the signer and the inspection statement can be shown per entry
FileFlo sits alongside the certificated people and the manufacturer — it does not certify repairmen, perform maintenance or condition inspections, approve anything for return to service, or replace an A&P, a light-sport repairman, a repair station, the manufacturer, or the FAA. It keeps the documents that prove your compliance audit-ready. Starter $89/mo · Professional $299/mo · 5-day free trial, no credit card required.
An out-of-scope sign-off is still an enforcement exposure
If a light-sport entry traces back to someone outside their authority — a sport pilot signing maintenance rather than preventive maintenance, an inspection-rating holder signing an S-LSA, or anyone approving a major repair without the additional §65.109(b)(3) training — the work may not be properly approved for return to service, and the operator can face FAA enforcement. Under 14 CFR §13.301 (implementing 49 U.S.C. §46301), for violations occurring on or after December 30, 2024, the civil penalty is up to $1,875 for an individual or small-business concern and up to $75,000 for other persons, per violation. Keeping the authority behind each entry provable is cheap insurance against that.
Related Aviation Compliance Reading
Frequently Asked Questions
What are the two ratings on a light-sport repairman certificate under 14 CFR §65.107?
Section 65.107(a) provides two ratings on a repairman certificate (light-sport): an inspection rating and a maintenance rating. They are not interchangeable. The inspection rating, under §65.107(c), requires a 16-hour training course accepted by the Administrator on inspecting the category, and class as applicable, of experimental aircraft for which the person intends to exercise the privileges. The maintenance rating, under §65.107(d), requires a more substantial course — one that includes, at a minimum, content on the knowledge, risk management, and skill elements for each subject in the Aviation Mechanic General, Airframe, and Powerplant Airman Certification Standards appropriate to the category and class. The general eligibility gate in §65.107(b) applies to both: at least 18 years old, able to read, speak, write, and understand English, completion of the applicable course, passage of a written test administered by the training course provider, and documentary evidence of both.
What can a light-sport repairman with an inspection rating actually do?
The inspection rating is narrow and owner-specific. Under §65.109(a), the holder of a repairman certificate (light-sport) with an inspection rating may perform the annual condition inspection on an aircraft that is owned by the holder, that has an experimental airworthiness certificate issued under §21.191(g), (i), (k), or (l), and that is in the same category, and class as applicable, for which the holder completed the §65.107(c) course. Read that carefully: the privilege is the annual condition inspection only, on an experimental light-sport aircraft (E-LSA) the holder personally owns, in the category and class they trained for. It does not let the holder inspect someone else's aircraft, work on a special light-sport aircraft (S-LSA), or perform maintenance beyond the inspection itself.
What can a light-sport repairman with a maintenance rating do that the inspection rating cannot?
The maintenance rating is much broader. Under §65.109(b), the holder may approve for return to service an aircraft that has a special airworthiness certificate in the light-sport category under §21.190 (an S-LSA), or any part thereof, after performing or inspecting maintenance — including the annual condition inspection and the 100-hour inspection required by §91.327 — preventive maintenance, or an alteration, excluding a major repair or a major alteration on a product produced under an FAA approval. The maintenance-rating holder may also perform the annual condition inspection on an experimental light-sport aircraft under §21.191(g), (i), (k), or (l), and may perform maintenance, preventive maintenance, and alterations on aircraft in the category and class for which they completed the §65.107(d) training. In short: the inspection rating is limited to the annual condition inspection on an E-LSA the holder owns; the maintenance rating extends to maintenance and the return-to-service authority on S-LSA, and is not limited to aircraft the holder owns.
Can a sport pilot do their own maintenance under §43.3(g)?
A sport pilot can do preventive maintenance only — not maintenance — and only on a specific kind of aircraft. Section 43.3(g) has two distinct sentences. The first says that, except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135. The second sentence then adds the sport-pilot carve-back: the holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category. So a sport pilot's authority is preventive maintenance, on an aircraft they own or operate that holds a light-sport-category special airworthiness certificate. Return-to-service for that preventive maintenance is then handled by §43.7(h), which lets the holder of at least a sport pilot certificate approve that owned/operated light-sport aircraft for return to service after performing the preventive maintenance.
Who is allowed to maintain and inspect a special light-sport aircraft (S-LSA) under §91.327?
Section 91.327(b) sets the maintenance and inspection authority for an aircraft with a special airworthiness certificate in the light-sport category. The aircraft must be maintained by a certificated repairman (light-sport) with a maintenance rating, an appropriately rated mechanic, or an appropriately rated repair station, in accordance with the applicable provisions of part 43 and the applicable maintenance and inspection procedures. The condition inspection must be performed once every 12 calendar months by one of those same three: a certificated repairman (light-sport) with a maintenance rating, an appropriately rated mechanic, or an appropriately rated repair station. The rule does not collapse to a single authority — it lists the alternatives, and your records should reflect which one actually performed each item.
Are light-sport maintenance and inspection records governed by §43.9 and §43.11 like other aircraft?
Yes — the part 43 recordkeeping framework still applies. Maintenance, preventive maintenance, rebuilding, and alteration entries go under §43.9, whose §43.9(a) requires a description (or reference to acceptable data) of the work performed, the date of completion, the name of the person performing the work if different from the approver, and the signature, certificate number, and kind of certificate held by the person approving the work. Inspection entries are different: §43.9(c) states that section does not apply to inspections, which are recorded under §43.11. Section 43.11(a) requires the type and extent of the inspection, the date and aircraft total time in service, the signature, certificate number, and kind of certificate of the person approving or disapproving for return to service, and the airworthiness statement (or, on disapproval, a statement that a list of discrepancies and unairworthy items has been provided to the owner or operator). The condition inspection on a light-sport aircraft is an inspection, so its entry follows the §43.11 pattern.
What is the difference between an E-LSA and an S-LSA, and why does it change who can inspect it?
It is the airworthiness certificate that drives the authority. An S-LSA holds a special airworthiness certificate in the light-sport category issued under §21.190, which requires the aircraft to comply with an identified consensus standard with a manufacturer's statement of compliance. An E-LSA holds an experimental airworthiness certificate issued under §21.191 — paragraph (i) covers experimental light-sport aircraft, and (k) and (l) cover related kit-built and former-light-sport-category experimental aircraft. The certificate type maps directly onto §65.109: the inspection rating reaches the annual condition inspection on an experimental aircraft (E-LSA) under §21.191(g), (i), (k), or (l) that the holder owns, while the maintenance rating's return-to-service authority reaches the S-LSA under §21.190 (and also reaches the E-LSA condition inspection). Confirming which certificate an aircraft holds is therefore the first records question before anyone signs an inspection.
How does FileFlo help with light-sport maintenance and repairman records?
FileFlo is a compliance document intelligence platform — a read-only proof layer. It does not certify repairmen, perform maintenance or condition inspections, approve anything for return to service, or replace the FAA, an A&P, or a manufacturer. What it does for a light-sport operation is classify the documents that prove compliance — the repairman certificate and its inspection or maintenance rating, the training-course completion and written-test evidence behind §65.107, the §43.11 condition-inspection entries, the §43.9 maintenance entries, the manufacturer's maintenance and inspection procedures, and the airworthiness certificate that establishes E-LSA versus S-LSA status — extract the renewal-relevant and recurrence dates (such as the 12-calendar-month condition inspection), and assemble them into an audit-ready, CFR-organized record so the authority behind each inspection and each return-to-service is provable. The inspecting, maintaining, and signing stay with the certificated people and the manufacturer.
More Aviation Compliance Guides
Part 65 Mechanic & Repairman Certificates
The A&P mechanic credential, the §65.101 employer-tied repairman, and the personnel records behind each sign-off
What a §43.9 Maintenance Entry Must Contain
The required elements of a compliant aviation maintenance record entry — and who may sign it
Part 91.409 Inspection Requirements
Annual, 100-hour, progressive, and AAIP — and how the light-sport condition inspection compares
Part 91 Aircraft Records Requirements
The maintenance, inspection, AD, and life-limited-part records an aircraft must carry
Airworthiness Directive Compliance Records
How AD compliance is recorded and proven — light-sport aircraft included
Preventive Maintenance Records (§43.3 / Appendix A)
What counts as preventive maintenance and how owner/sport-pilot work is documented
Chad Griffith
Founder, FileFlo — compliance document intelligence. FileFlo classifies, indexes, and tracks the records that prove aviation compliance audit-ready, including the repairman certificates, condition-inspection entries, and manufacturer procedures behind every light-sport sign-off. It does not certify repairmen, perform maintenance or inspections, approve work for return to service, or replace an A&P, a light-sport repairman, a repair station, the manufacturer, or the FAA. About FileFlo.
Tie every light-sport inspection to a person who was authorized to make it
FileFlo classifies your airworthiness certificates, repairman certificates and ratings, condition-inspection and maintenance entries, and manufacturer procedures against §65.107, §65.109, §43.3, §43.7, §43.9, §43.11, and §91.327, tracks the 12-calendar-month condition-inspection recurrence, and assembles an audit-ready record so that for every entry an FAA reviewer can see the signer was authorized.
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