What the pilot record holds
Section 135.63(a)(4) lists the contents of each pilot's record:
- Full name.
- The pilot certificate, by type and number, and the ratings held.
- Aeronautical experience in enough detail to show the pilot is qualified for the operations flown.
- Current duties and the date of assignment to them.
- The effective date and class of the medical certificate.
- The date and result of each initial and recurrent test and check Part 135 requires, and the aircraft type flown.
- Any check pilot authorization.
- Any action taken on release from employment for physical or professional disqualification.
- The completion date of the initial phase and each recurrent phase of the required training.
The record is kept at the principal business office or another place the FAA approves, made available to the FAA on request (135.63(a)), and kept for at least 12 months (135.63(b)).
The checks and their intervals
| Record | Rule | Interval |
|---|---|---|
| Knowledge test and competency check | 135.293(a), (b) | Within the preceding 12 calendar months |
| Instrument proficiency check (pilot in command under IFR) | 135.297 | Within the preceding 6 calendar months |
| Line check (pilot in command) | 135.299 | Within the preceding 12 calendar months |
| Recurrent training | 135.351 | Within the preceding 12 calendar months |
| Medical certificate | 61.23(d) | By class, privilege and age |
| Pilot certificate and ratings for the operation | 135.243 | Held for the operation flown |
| Pilot Records Database review | Part 111 | Before the pilot begins service |
| Pre-employment drug test | 120.109(a) | Before safety-sensitive duty |
The intervals run in calendar months: a check passed on any day of a month counts through the last day of the month it falls due. Under 135.301(a), a test or check completed in the calendar month before or after the due month is considered completed in the due month, so the cycle keeps its base month.
The medical certificate follows 61.23(d): a second-class certificate used for commercial privileges runs 12 calendar months; a first-class certificate used for airline transport pilot privileges runs 12 calendar months for a pilot under 40 at the exam and 6 calendar months for a pilot 40 or over.
Before a new pilot flies
Two records come before the first Part 135 flight: the review of the pilot's records in the FAA Pilot Records Database under Part 111, and a verified negative pre-employment drug test result under 14 CFR 120.109(a). The initial 135.293 test and check and the initial training under the approved program come before the pilot serves in that role.
Worked example: one pilot on August 15, 2026
Illustration, not an operator
A pilot in command who flies IFR has these dates on file:
- 135.293 competency check in March 2026: current through March 31, 2027. A check in February, March or April 2027 counts as March (135.301(a)).
- 135.297 instrument proficiency check in January 2026: current through July 31, 2026.
- 135.299 line check in May 2026: current through May 31, 2027.
- 135.351 recurrent training in March 2026: current through March 31, 2027.
- Second-class medical, exam in February 2026, used for commercial privileges: current through February 28, 2027 (61.23(d)).
On August 15, 2026 every line is current except the instrument proficiency check, which ran out at the end of July. Under 135.297 the pilot does not serve as pilot in command under IFR until a new check is passed. The record that settles it is the 135.297 entry, its date and the check airman's signature.
Where FileFlo does the work
Most compliance tools track a date someone typed in and send a notice. FileFlo does the work behind the date: it reads each record, finds the date, checks it against the rule, files it where the rule wants it and works out what is due next, for every pilot, every aircraft and every recurring item. A pilot sends a new medical from their own portal link, and it is dated and filed. Each pilot's checks and medical are worked out from the records you already hold and cited to the rule, and an item opens 45 days before one lapses. You approve what goes out, and your Director of Operations makes the operational decision.
Sources
Checked
- 14 CFR 135.63, recordkeeping requirements, eCFR
- 14 CFR 135.293, initial and recurrent pilot testing, eCFR
- 14 CFR 135.297, instrument proficiency check, eCFR
- 14 CFR 135.299, line checks, eCFR
- 14 CFR 135.301, grace provisions, eCFR
- 14 CFR 135.351, recurrent training, eCFR
- 14 CFR 61.23, medical certificate duration, eCFR
- 14 CFR Part 111, Pilot Records Database, eCFR
- 14 CFR 120.109, drug testing, eCFR
Questions
What does 14 CFR 135.63 require in a pilot record?
Section 135.63(a)(4) requires an individual record of each pilot used under Part 135: full name, the pilot certificate and ratings held, aeronautical experience in enough detail to show the pilot is qualified, current duties and the date assigned, the effective date and class of the medical certificate, the date and result of each initial and recurrent test and check the part requires with the aircraft type flown, any check pilot authorization, any action taken on release from employment for physical or professional disqualification, and the completion dates of initial and recurrent training.
How often are Part 135 pilot checks due?
The 135.293 knowledge test and competency check are due within the preceding 12 calendar months, the 135.297 instrument proficiency check within the preceding 6 calendar months for a pilot in command under IFR, the 135.299 line check within the preceding 12 calendar months for a pilot in command, and the 135.351 recurrent training within the preceding 12 calendar months.
What is the grace month?
Under 135.301(a), a crewmember who completes a required test or check in the calendar month before or after the month it is due is considered to have completed it in the month it was due.
How long must a Part 135 operator keep pilot records?
Section 135.63(b) requires the certificate holder to keep each pilot record under paragraph (a)(4) for at least 12 months. The records are kept at the principal business office or another place the FAA approves, and made available to the FAA on request.
What must happen before a new pilot begins service?
Part 111 requires the operator to review the pilot's records in the FAA Pilot Records Database before the pilot begins service, and 14 CFR 120.109(a) requires a verified negative pre-employment drug test result before the pilot performs a safety-sensitive function.