Most Part 135 operators flying nine-or-fewer-seat aircraft inspect under Part 91 — the familiar annual and 100-hour cycle. But Part 135 offers a different option built specifically for an on-demand operation: the Approved Aircraft Inspection Program, or AAIP. Instead of generic Part 91 intervals, the AAIP lets you run a single, FAA-approved inspection program designed around your exact make and model, your utilization, and your operation — recorded the way your shop actually works.
The authority is 14 CFR §135.419 — a compact section that is easy to under-read. It tells you who can require or allow an AAIP, what the program must contain, how it gets approved, where it has to be documented, and how the FAA can compel changes to it later. This guide walks every paragraph, then maps the records an AAIP actually generates — because the inspection program is only as good as the entries that prove it ran.
If you want the master index of every Part 135 record — pilot files, drug-and-alcohol, training, maintenance, SMS — start with What Records Must a Part 135 Operator Keep. And if your fleet sits on the ten-or-more-seat side of the line, the AAIP is not your tool — see Part 135 Maintenance Recordkeeping: CAMP, CASS, and §135.439 instead.
What an AAIP Actually Is
An Approved Aircraft Inspection Program is an FAA-approved, operator-specific inspection program — a written set of inspection instructions, intervals, and discrepancy-handling procedures that a Part 135 certificate holder uses in place of the standard Part 91 inspections for a specific make and model of aircraft. It is authorized by 14 CFR §135.419, which sits in Part 135 Subpart J — Maintenance, Preventive Maintenance, and Alterations.
What §135.419(a) Establishes
Whenever the Administrator finds that the aircraft inspections required or allowed under part 91 are not adequate to meet Part 135, or upon application by a certificate holder, the Administrator may amend the certificate holder operations specifications under §119.51 to require or allow an approved aircraft inspection program for any make and model aircraft of which the certificate holder has the exclusive use of at least one aircraft (as defined in §135.25(b)).
Three things to read carefully out of that sentence. First, the AAIP can be either FAA-required or operator-requested. Second, the trigger for the FAA-required version is a finding that the part 91 inspections are inadequate — the AAIP is positioned as the upgrade from the Part 91 inspection baseline. Third, it is keyed to a specific make and model, and only where the operator has exclusive use of at least one such aircraft.
"Exclusive use" is a defined term — §135.25(b) and (c)
§135.419(a) borrows the "exclusive use" concept from §135.25(b). Under §135.25(c), a person has exclusive use of an aircraft if that person has the sole possession, control, and use of it for flight, as owner — or has a written agreement (including arrangements for performing required maintenance), in effect when the aircraft is operated, giving that possession, control, and use for at least six consecutive months. So an AAIP attaches to aircraft you genuinely control, not to every tail you might occasionally use.
When the AAIP Applies — the §135.411 Seat Line
The AAIP lives on one specific side of the line that §135.411 draws through every Part 135 aircraft: the aircraft's type-certificated passenger seating configuration, excluding any pilot seat.
Nine Seats or Fewer — §135.411(a)(1) — the AAIP lives here
Aircraft type certificated for a passenger seating configuration of nine seats or fewer (excluding any pilot seat) shall be maintained under parts 91 and 43 plus §§135.415, 135.417, 135.421, and 135.422 — and the rule then says, in so many words, that an approved aircraft inspection program may be used under §135.419. That single clause is the entire statutory home of the AAIP. It is an option for these operators: run Part 91 inspections (annual/100-hour or a Part 91 progressive program), or run an AAIP instead.
Ten Seats or More — §135.411(a)(2) — no AAIP
Aircraft type certificated for a passenger seating configuration of ten seats or more (excluding any pilot seat) shall be maintained under a maintenance program in §§135.415, 135.417, 135.423 through 135.443 — the full continuous-airworthiness program (the CAMP). These aircraft do not use the §135.419 AAIP; their inspection program is built into the manual under §135.427 and their records rule is §135.439. Under §135.411(b), a nine-or-fewer operator may voluntarily elect the (a)(2) program — and would then leave the AAIP world for the CAMP world.
The threshold is type-certificated seats — not installed seats, not passengers carried
§135.411 measures the line by type-certificated passenger seating configuration, excluding any pilot seat. A nine-passenger airframe stays a nine-passenger airframe for §135.411 even if you fly it with empty seats, and a ten-seat type design is on the CAMP side even if you block a seat. Confirming the type-certificated configuration for each tail is the first compliance step before you decide whether an AAIP is even available to you. For the broader maintenance-track split, see our CAMP vs AAIP maintenance guide.
What the Program Must Contain — §135.419(d)
An AAIP is not a one-paragraph letter to the FAA. §135.419(d) requires the program submitted for approval to contain three specific components. Miss any one and the program is not approvable — and once approved, those three components are exactly what an FAA Principal Maintenance Inspector will hold your records against.
§135.419(d)(1) — Inspection instructions and procedures
Instructions and procedures for the conduct of aircraft inspections — which must include necessary tests and checks — setting forth in detail the parts and areas of the airframe, engines, propellers, rotors, and appliances, including emergency equipment, that must be inspected. This is the substance of the program: the actual checklist-level definition of what gets looked at, and how.
§135.419(d)(2) — The inspection schedule
A schedule for the performance of the aircraft inspections under paragraph (d)(1), expressed in terms of the time in service, calendar time, number of system operations, or any combination of these. This is the flexibility the AAIP buys you over fixed Part 91 intervals — you can phase inspections to your utilization rather than a blunt 100-hour/annual cadence.
§135.419(d)(3) — Recording discrepancies
Instructions and procedures for recording discrepancies found during inspections and the correction or deferral of discrepancies, including form and disposition of records. This is the records hook inside §135.419 itself: the program has to define how a squawk found during an AAIP inspection gets written up, tracked to correction or deferral, and where those records go.
§135.419(e) — and then it goes in the §135.21 manual
After approval, §135.419(e) requires the certificate holder to include the approved aircraft inspection program in the manual required by §135.21. That is the general operating manual every certificate holder must keep current under §135.21 — not the §135.427 maintenance manual used by the ten-or-more-seat CAMP. For nine-or-fewer-seat operators that also keep a general operations and maintenance manual, see how the AAIP fits the manual structure in our GOM/MOM requirements guide.
How an AAIP Is Approved — and the Operations-Specifications Link
§135.419 contains two approval routes, depending on whether the AAIP is operator-requested or FAA-required — and both run through an operations-specifications amendment.
A certificate holder who applies for an amendment of its operations specifications to allow an AAIP must submit that program with its application for approval by the Administrator. You build the program first, then submit it as part of the opspec-amendment package.
A certificate holder required by its operations specifications to have an AAIP shall submit a program for approval within 30 days of the amendment of its operations specifications — or within any other period the Administrator prescribes in the operations specifications.
The operations specifications carry the AAIP — and the tail numbers
The amendment that authorizes an AAIP is made to the certificate holder operations specifications under §119.51 (amending certificates and operations specifications). And §135.419(h) closes the loop on the fleet side: the registration number of each aircraft that is subject to an approved aircraft inspection program must be included in the operations specifications of the certificate holder.
§135.419(g) then states the operating obligation plainly: each certificate holder who has an AAIP shall have each aircraft subject to the program inspected in accordance with the program. The program is not aspirational — once it is approved and the tail is listed, the inspections happen on the schedule you committed to.
Because the AAIP rides in the operations specifications, it is part of the same document set an inspector reviews during a surveillance visit. If you are preparing for one, our Part 135 FAA surveillance audit guide walks the documents an inspector requests, in order — and our OpSpecs explained guide covers how operations specifications work as a living authorization.
When the FAA Can Compel Changes — §135.419(f)
An approved AAIP is not frozen. The FAA can require revisions, and the rule gives the operator a narrow window to push back.
The §135.419(f) amendment-and-petition process
Whenever the Administrator finds that revisions to an approved aircraft inspection program are necessary for the continued adequacy of the program, the certificate holder shall, after notification by the Administrator, make any changes in the program found by the Administrator to be necessary.
The certificate holder may petition the Administrator to reconsider the notice. The petition must be filed with the FAA representatives assigned to it within 30 days after the certificate holder receives the notice. Except in the case of an emergency requiring immediate action in the interest of safety, filing the petition stays the notice pending a decision by the Administrator.
Version-control your AAIP like a controlled document
Because the AAIP can be revised on FAA notice — and because you may revise it yourself as your fleet or operation changes — the program is a controlled, versioned document. The revision history matters: an inspector reviewing your records expects the inspections you actually performed to match the AAIP revision that was in effect at the time. Keeping a clean record of which AAIP revision was current on any given date is the difference between "the program evolved" and "the program drifted."
Not sure whether your AAIP records would survive a §135.419(g) review? Run a free readiness check and see where your inspection-records evidence stands before the FAA does.
Check FAA ReadinessThe Records an AAIP Operator Must Keep
Here is the part operators most often get wrong: §135.419 is an inspection-program rule, not a comprehensive records-retention rule. The only records language inside §135.419 itself is §135.419(d)(3) — the program must specify how discrepancies are recorded and the form and disposition of records. The retention framework comes from elsewhere, because the AAIP operator is on the parts 91/43 track.
Do not apply the §135.439 retention scheme to an AAIP
§135.439 (with its airworthiness-release records and its "transfer with the aircraft on sale" status records) is the ten-or-more-seat records rule. A nine-or-fewer-seat AAIP operator is governed by the Part 91 records rule — §91.417 — and the entry-content rules in §43.9 (maintenance) and §43.11 (inspections). Mixing the two frameworks is a classic finding.
In practice, here is the records picture for an AAIP operator:
The AAIP records set
- The approved AAIP itself, current revision, in the manual required by §135.21 — plus the revision history that shows which version was in effect on any date.
- The inspection record entries that show each aircraft was inspected in accordance with the AAIP, per §135.419(g) — recorded under the §43.11 inspection-entry content rules (description, date, total time in service, signature, certificate number, and kind of certificate, and the airworthy/not-airworthy determination).
- The discrepancy records the AAIP itself requires under §135.419(d)(3) — write-ups, corrections, and any deferrals, in the form and disposition the program specifies.
- The operations specifications listing each affected aircraft registration number, per §135.419(h).
- The §91.417(a)(1) maintenance records (records of maintenance, preventive maintenance, alteration, and the required/approved inspections) — kept until repeated, superseded, or for one year.
- The §91.417(a)(2) status records — total time in service, current life-limited part status, time since overhaul, current inspection status, current AD compliance status, and the current FAA Form 337 for major alterations — retained and transferred with the aircraft on sale.
§135.421 still applies — and it generates its own records
Running an AAIP does not relieve a nine-or-fewer-seat operator of §135.421. For each aircraft engine, propeller, rotor, and each item of required emergency equipment, the operator must comply with the manufacturer's recommended maintenance programs or a program approved by the Administrator. And for single-engine aircraft used in passenger-carrying IFR operations, §135.421 requires an engine trend monitoring program — including an oil analysis where appropriate — and the operator must record and maintain in the engine maintenance records the results of each test, observation, and inspection. The AAIP covers your airframe inspection cadence; §135.421 covers the component-program obligations alongside it.
For the full Part 91 records framework that underpins an AAIP operator, see Part 91 Aircraft Records Requirements and our deep dive on the aviation records-retention schedule. For AD documentation specifically — the most-missed status record — see AD compliance records.
AAIP vs CAMP — the Side-by-Side
Because the two programs are so often confused, here is the clean comparison. The AAIP is the nine-or-fewer-seat inspection-program alternative; the CAMP is the ten-or-more-seat full maintenance program.
| Dimension | AAIP §135.419 | CAMP (10+ seat program) §§135.423–135.443 |
|---|---|---|
| Applies to | Nine-or-fewer-seat aircraft (§135.411(a)(1)) | Ten-or-more-seat aircraft (§135.411(a)(2)) |
| What it is | An FAA-approved inspection program (alternative to Part 91 inspections) | A full continuous-airworthiness maintenance program |
| Mandatory or optional | Optional — may be used; or FAA-required if part 91 inspections found inadequate | Mandatory for 10+ seat aircraft |
| Approved via | Operations-specifications amendment (§119.51) | Maintenance program / manual approval |
| Documented in | Manual required by §135.21 (§135.419(e)) | Maintenance manual required by §135.427 |
| Records rule | §91.417 + §43.9/§43.11 (plus §135.419(d)(3) discrepancy records) | §135.439 |
| Return to service | §43.9 / §43.11 entry | §135.443 airworthiness release |
| CASS required? | No | Yes — §135.431 |
The AAIP is not a Part 91 progressive inspection either
Operators sometimes equate the AAIP with the Part 91 progressive inspection in §91.409(d). They are parallel ideas — both replace fixed intervals with a scheduled, documented program — but they are different rules with different homes. A §91.409(d) progressive inspection is requested through the responsible Flight Standards office, requires an inspection procedures manual and a schedule designed to complete the full inspection within each 12 calendar months, and applies to a Part 91 owner/operator. An AAIP is a Part 135 construct under §135.419, approved through a §119.51 operations-specifications amendment, documented in the §135.21 manual, with affected tail numbers listed in the operations specifications. If you run a Part 135 nine-or-fewer-seat operation, the AAIP is the Part 135-native option; see how inspection choices map in our §91.409 inspection-requirements guide.
Keep your AAIP and its inspection records audit-ready
FileFlo is a compliance document intelligence platform — a read-only proof layer that classifies and tracks the records your inspection program produces. It does not run your AAIP, perform inspections, sign a return to service, or make a live connection to your maintenance-tracking system. You upload the documents; FileFlo:
- Classifies each document against the governing CFR (§135.419, §91.417, §43.9, §43.11, §135.421)
- Tracks the AAIP revision in effect and flags inspection record entries against the schedule the program commits to
- Extracts dates and statuses and tracks expirations — AD next-due, inspection status, life-limited part timelines — with 90/60/30-day alerts
- Generates an audit-ready inspection-records binder organized by section for an FAA surveillance visit or a pre-purchase review
FileFlo sits alongside your Director of Maintenance, your A&P/IA, and any Part 145 repair station you contract with — it keeps the documents that prove your compliance; it does not perform or sign off inspections or maintenance. Starter $89/mo · Professional $299/mo · 5-day free trial, no credit card required.
Why the records discipline matters
Operating an aircraft subject to an AAIP that has not been inspected in accordance with the program — or that you cannot show was inspected — is an airworthiness and recordkeeping exposure. The FAA's general civil-penalty figures are inflation-adjusted in 14 CFR §13.301. For violations occurring on or after December 30, 2024, the §13.301(c) table lists a maximum of $75,000 per violation under 49 U.S.C. 46301(a)(1) for a person other than an individual or small business concern, and $1,875 for an individual or small business concern (and for an airman serving as an airman).
Those are statutory ceilings, not a schedule of what any particular discrepancy draws — most records gaps are resolved through corrective action long before a civil penalty. The practical cost is operational: an aircraft you cannot prove is current on its inspection program is an aircraft you should not be dispatching.
Related Aviation Recordkeeping Guides
Frequently Asked Questions
What is an Approved Aircraft Inspection Program (AAIP) under 14 CFR §135.419?
An AAIP is an FAA-approved, operator-specific inspection program that a Part 135 certificate holder uses in place of the standard Part 91 inspection requirements for a particular make and model of aircraft. It is authorized by 14 CFR §135.419. Under §135.419(a), whenever the Administrator finds that the aircraft inspections required or allowed under part 91 are not adequate to meet Part 135, or upon application by a certificate holder, the Administrator may amend the certificate holder operations specifications under §119.51 to require or allow an AAIP for any make and model aircraft of which the certificate holder has the exclusive use of at least one aircraft (as defined in §135.25(b)). The AAIP is principally associated with the nine-or-fewer-seat track: §135.411(a)(1) says that for aircraft type certificated for a passenger seating configuration of nine seats or fewer (excluding any pilot seat), an approved aircraft inspection program may be used under §135.419.
When does an AAIP apply instead of the standard Part 91 inspection?
The AAIP is the alternative inspection path for the nine-or-fewer-seat side of the §135.411 split. 14 CFR §135.411(a)(1) provides that aircraft type certificated for a passenger seating configuration of nine seats or fewer (excluding any pilot seat) shall be maintained under parts 91 and 43 plus §§135.415, 135.417, 135.421, and 135.422 — and that an approved aircraft inspection program may be used under §135.419. So instead of relying on the Part 91 annual and 100-hour inspections (or a Part 91 progressive inspection), a nine-or-fewer-seat operator can run its inspections under an AAIP tailored to its specific fleet and operation. The ten-or-more-seat track in §135.411(a)(2) does not use the AAIP; those aircraft are maintained under the full §§135.423 through 135.443 program — the program the industry calls a CAMP — whose inspection program lives in the manual under §135.427.
What must an AAIP contain under §135.419(d)?
Under 14 CFR §135.419(d), the aircraft inspection program submitted for approval must contain three things. First, §135.419(d)(1): instructions and procedures for the conduct of aircraft inspections — which must include necessary tests and checks — setting forth in detail the parts and areas of the airframe, engines, propellers, rotors, and appliances, including emergency equipment, that must be inspected. Second, §135.419(d)(2): a schedule for the performance of the inspections, expressed in terms of time in service, calendar time, number of system operations, or any combination of these. Third, §135.419(d)(3): instructions and procedures for recording discrepancies found during inspections and the correction or deferral of discrepancies, including the form and disposition of records. After approval, §135.419(e) requires the certificate holder to include the AAIP in the manual required by §135.21.
Where does the AAIP have to be documented — §135.21 or §135.427?
The AAIP itself goes into the general operating manual required by §135.21. That is the specific cross-reference in 14 CFR §135.419(e): after approval, the certificate holder shall include the approved aircraft inspection program in the manual required by §135.21. This is worth flagging because the ten-or-more-seat maintenance program uses a different manual cross-reference: §135.439(a) ties the maintenance-record system to the manual required in §135.427, and §135.427 is titled Manual requirements for that program. For a nine-or-fewer-seat AAIP operator, the controlling manual cite for the inspection program is §135.21, not §135.427. In addition, §135.419(h) requires that the registration number of each aircraft subject to an AAIP be listed in the certificate holder operations specifications.
How does an operator get an AAIP approved, and what is the timeline?
There are two routes in 14 CFR §135.419. If the operator wants an AAIP, §135.419(b) requires it to submit the program with its application for an amendment of its operations specifications, for approval by the Administrator. If instead the FAA requires an AAIP — because it found the Part 91 inspections inadequate — §135.419(c) requires the certificate holder to submit a program for approval within 30 days of the amendment of its operations specifications, or within any other period the Administrator prescribes in the operations specifications. The operations-specification amendment that authorizes the AAIP is made under §119.51. The AAIP only applies to aircraft of which the certificate holder has exclusive use of at least one aircraft, as defined in §135.25(b) — broadly, sole possession and control, or a written agreement giving that control for at least six consecutive months.
Can the FAA require changes to an approved AAIP after it is in place?
Yes. Under 14 CFR §135.419(f), whenever the Administrator finds that revisions to an approved aircraft inspection program are necessary for the continued adequacy of the program, the certificate holder shall, after notification by the Administrator, make any changes the Administrator finds necessary. The certificate holder may petition the Administrator to reconsider the notice; that petition must be filed with the assigned FAA representatives within 30 days after the certificate holder receives the notice. Except in the case of an emergency requiring immediate action in the interest of safety, filing the petition stays the notice pending a decision by the Administrator. Separately, §135.419(g) requires the certificate holder to have each aircraft subject to the program inspected in accordance with the program.
What records does running an AAIP generate, and what are the retention rules?
The AAIP itself does not contain a standalone records-retention clause beyond §135.419(d)(3) (which requires the program to specify how discrepancies are recorded and the form and disposition of records). For a nine-or-fewer-seat operator on the parts 91/43 track, the underlying recordkeeping framework is the Part 91 rule in §91.417 and the entry-content rules in §43.9 (maintenance) and §43.11 (inspections). In practice, an AAIP inspection is recorded as a maintenance/inspection record entry, and the §91.417(a)(1) maintenance records (records of maintenance, preventive maintenance, and alteration, and records of the 100-hour, annual, progressive, and other required or approved inspections) are kept until the work is repeated, superseded, or for one year; the §91.417(a)(2) status records (total time in service, current life-limited part status, time since overhaul, current inspection status, current AD compliance status, and a copy of the current FAA Form 337 for major alterations) are retained and transferred with the aircraft on sale. Note that the §135.439 retention scheme (with its airworthiness release records) is the ten-or-more-seat rule, not the AAIP rule — though §135.421 adds its own duty to keep engine trend-monitoring results for single-engine IFR aircraft.
Is an AAIP the same thing as a Part 91 progressive inspection?
No, although they are conceptually similar alternatives to the fixed annual/100-hour cycle. A Part 91 progressive inspection is authorized by 14 CFR §91.409(d): the owner or operator submits a written request to the responsible Flight Standards office and provides a current inspection procedures manual, an inspection schedule, qualified supervision, housing and equipment, and current technical information, with the inspection frequency designed to complete a full inspection of the aircraft within each 12 calendar months. An AAIP is a Part 135 construct authorized by §135.419 and approved through an operations-specifications amendment under §119.51; it applies only to a Part 135 certificate holder and its make/model fleet, and once approved it lives in the §135.21 manual with the affected registration numbers listed in the operations specifications. Different rule, different approval mechanism, different paperwork home — even though both replace the standard inspection cadence with a scheduled, documented program.
More Part 135 & Aviation Compliance Guides
Part 135 Maintenance Recordkeeping: CAMP, CASS & §135.439
The ten-or-more-seat program — CAMP vs AAIP, the §135.431 CASS, and the two §135.439 record categories
What Records Must a Part 135 Operator Keep
The master index: every Part 135 record mapped to its CFR cite, owner, and retention period
Part 91.409 Inspection Requirements
Annual, 100-hour, progressive, and continuous programs — who signs each and what records they produce
Part 91 Aircraft Records Requirements
The §91.417 framework that governs nine-or-fewer-seat aircraft on the parts 91/43 track
What a §43.9 Maintenance Entry Must Contain
The required elements of every compliant aviation maintenance record entry
Document AD Compliance for a Ramp Check
Logbook wording, recurring-AD next-due math, and §91.417(a)(2) retention
Operations Specifications (OpSpecs) Explained
How operations specifications work as a living authorization — and where the AAIP tail numbers live
Part 135 GOM / MOM Requirements
How the manual required by §135.21 is structured — and where the AAIP fits in it
Prepare for a Part 135 FAA Surveillance Audit
The documents an FAA inspector requests during a SAS surveillance visit, in order
Adding Aircraft to a Part 135 Certificate
The conformity and opspec steps when a new tail joins the certificate — and its inspection program
Engine & Propeller Overhaul Time Tracking
Tracking time-since-overhaul against the schedule your inspection program commits to
Life-Limited Parts Records
The current life-limited part status record every AAIP and CAMP operator must keep
Prove your AAIP inspection records before the FAA asks
FileFlo classifies your inspection and maintenance records against 14 CFR §135.419, §91.417, §43.9, §43.11, and §135.421, extracts inspection and AD due dates, and sends 90/60/30-day alerts before any item lapses. Keep your approved AAIP, every inspection entry, discrepancy record, and status record documented and organized by CFR section — ready for a surveillance visit or a pre-purchase review.
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