Direct Answer: What Pilot Records Does Part 135 Require?
Under 14 CFR §135.63(a)(4), every Part 135 certificate holder must maintain a current per-crewmember record file containing: current pilot certificates and ratings, current medical certificate, satisfactory completion of all tests and training required by Part 135, the most recent §135.299 line check, and current flight experience records.
The three time-limited checkride records that define whether a pilot file is current are:
- §135.293 Annual Recurrent Check — within the preceding 12 calendar months (knowledge + proficiency; every PIC and SIC)
- §135.297 Instrument Proficiency Check (IPC) — within the preceding 6 calendar months (required for IFR / IMC PIC operations)
- §135.299 Line Check — within the preceding 12 calendar months (PIC only; at least one flight over one route segment, with takeoffs and landings at one or more representative airports — a revenue flight is not required)
All three use a calendar-month rule, not a rolling-day rule — expiration falls at the end of the relevant calendar month, which can grant up to ~30 days of effective grace beyond the precise anniversary date. Records must be retained for the duration of employment plus at least 12 months after departure.
Pilot file gaps are the enforcement category you can prevent entirely with the right system
Unlike airworthiness findings that require physical aircraft work, incomplete or expired pilot files are purely administrative failures. An FAA POI discovering that three of your PICs have lapsed §135.293 or §135.297 records has grounds for an immediate enforcement action — not a corrective-action option. Civil penalties under 49 U.S.C. §46301(a)(1) reach $75,000 per violation for operators other than individuals or small business concerns — $1,875 per violation for individuals and small business concerns — under the inflation-adjusted penalty table at 14 CFR §13.301 (violations on or after December 30, 2024).
Building the Per-Crewmember File: Every Required Record
The per-crewmember record file is not a single document — it is a living folder of at least 10 distinct record categories that must all be current and available for FAA inspection on request. Under 14 CFR §135.63(a)(4), the certificate holder — not the pilot — is responsible for maintaining these records. "I thought the pilot kept his own logbook" is not a defense.
The table below maps every required record to its governing regulation, renewal interval, and minimum retention period. Use it as a build-from-scratch checklist for any new hire, and as a standing audit reference for existing crew files.
| Record | Governing CFR | Renewal Interval | Retention | Grace Rule |
|---|---|---|---|---|
| Pilot Certificate (ATP or Commercial + ratings) | §135.63(a)(4)(i); §135.243 | Current (no expiration on certificate itself) | Retain copy duration of employment + 12 months | None — certificate must be valid at time of operation |
| FAA Medical Certificate | §135.63(a)(4)(i); §61.23 | First Class: 12 calendar months under age 40, but first-class (ATP) privileges last only 6 calendar months at age 40+; Second Class: 12 calendar months for Part 135 PIC | Current copy in file at all times | None — lapses on the calendar-month expiration date |
| §135.293 Annual Recurrent Knowledge & Proficiency Check | §135.293 | Within preceding 12 calendar months | Retain for duration of employment + 12 months post-departure | Calendar month — expires end of 12th calendar month after last completion |
| §135.297 Instrument Proficiency Check (IPC) — IFR Operations | §135.297 | Within preceding 6 calendar months for IFR / IMC PIC | Retain for duration of employment + 12 months post-departure | Calendar month — expires end of 6th calendar month after last check |
| §135.299 Line Check (PIC only) | §135.299 | Within preceding 12 calendar months | Retain for duration of employment + 12 months post-departure | Calendar month — expires end of 12th calendar month after last check |
| §135.293 Initial Check (on hire — before first revenue flight) | §135.293(a) | Once at hire (satisfactory completion required) | Permanent part of crewmember file | None — must be completed before first Part 135 flight as PIC or SIC |
| Aircraft Type / Differences Training Record | §135.345; §135.347; §135.351 | Initial before first flight on type; recurrent per approved training program | Retain for duration of employment + 12 months post-departure | Per approved training program schedule |
| Emergency Equipment & Procedures Training (Subpart H) | §135.331 | Initial + annual recurrent per approved training program | Retain for duration of employment + 12 months post-departure | Per approved training program schedule |
| 49 CFR Part 40 Drug & Alcohol Pre-Employment Result | 14 CFR §120.109(a); 49 CFR Part 40 | Pre-employment (verified negative result required before first safety-sensitive duty) | Negative results: minimum 1 year; verified positives, refusals & follow-up records: 5 years (49 CFR §40.333) | None — no operation before receipt of negative result |
| Pilot Records Database (PRD) Evaluation — replaced PRIA September 9, 2024 | 14 CFR Part 111 | On hire (PRD records must be reviewed before the pilot begins service) | Document the PRD evaluation in the crewmember file per 14 CFR Part 111 | None — pilot may not begin Part 135 service until the PRD review is complete |
Data sourced from 14 CFR Parts 61, 135, and 49 CFR Part 40 as published on eCFR.gov. Verify against current eCFR before relying for regulatory compliance determinations. Certificate-holder responsibilities extend beyond this table — consult your DOM and approved training program.
1. Pilot Certificate & Ratings
Under 14 CFR §135.243, the certificate a PIC must hold depends on the operation. An Airline Transport Pilot (ATP) certificate — with the appropriate type rating where required — is mandatory to act as PIC of a turbojet airplane, an airplane with a passenger-seat configuration of 10 seats or more, or a multiengine airplane in commuter operations. All other Part 135 PIC operations, including multiengine and IFR on-demand operations, may be flown on a Commercial certificate: VFR operations require a Commercial certificate with appropriate category and class ratings plus at least 500 hours (including 100 cross-country and 25 night); IFR operations require a Commercial certificate with an instrument rating plus at least 1,200 hours (including 500 cross-country, 100 night, and 75 instrument). The certificate holder must retain a copy of the current certificate and verify the ratings are appropriate for the operations conducted and aircraft type flown.
A pilot certificate has no expiration date — but ratings on the certificate are operationally limited by currency, and a pilot operating without the appropriate type rating is an immediate §135.243 violation. The crewmember file must document which ratings apply to which aircraft in the operator's fleet, and must be updated any time a pilot adds or loses a rating relevant to the operations.
2. FAA Medical Certificate
Part 135 PIC operations require a First Class or Second Class FAA medical certificate. Under 14 CFR §61.23(d), a First Class certificate issued to a pilot under age 40 remains valid for 12 calendar months for Part 135 operations; a pilot age 40 or older holding a First Class certificate has a validity period of 6 calendar months for First Class privileges, but the certificate retains Second Class privileges through 12 calendar months from the date of examination. Second Class certificates are valid for 12 calendar months for Part 135 PIC operations.
Medical certificates use calendar-month logic too: under §61.23(d), a medical certificate expires at the end of the last day of the 6th or 12th month after the month of the date of examination, depending on the certificate class, the operation, and the pilot's age. An FAA medical cannot lapse mid-month — and FAA Form 8500-9 shows the date of examination, not a printed expiration date, so the operator must compute the expiration month from the exam date, the certificate class, and the pilot's age.
3. §135.293 Annual Recurrent Knowledge & Proficiency Check
14 CFR §135.293 is the foundational checkride requirement for Part 135 operations. Every PIC and SIC must complete:
- Initial check — satisfactory completion before the pilot acts as PIC or SIC under Part 135 for the first time
- Annual recurrent check — within the preceding 12 calendar months; covers knowledge of applicable FAR/AIM, the GOM, and aircraft emergency/normal procedures
The check must be administered by an FAA inspector, an approved check airman, or another person authorized under the certificate holder's approved training program. The record retained in the crewmember file must document the type of check, the date of completion, the aircraft type (for practical portions), and the signature of the person who administered the check.
A §135.293 check completed on June 9, 2025 gives currency through the end of June 2026 — not just through June 9, 2026 — because the calendar-month rule applies. See the calendar-month grace rule section below for how to apply this correctly across a pilot roster.
4. §135.297 Instrument Proficiency Check (IPC) — IFR Currency
For pilots who conduct IFR operations as PIC under Part 135, 14 CFR §135.297 requires completion of an Instrument Proficiency Check within the preceding 6 calendar months. The IPC is separate from and in addition to the §135.293 annual recurrent check — a pilot can be current on §135.293 and still be ineligible to fly IFR as PIC if the §135.297 IPC has lapsed.
The §135.297 IPC is type-specific: a pilot who flies a single aircraft type takes the check in that type, and a pilot who flies multiple types takes the check in each type in rotation. Portions of the flight check may be given in an aircraft simulator or other appropriate training device if approved by the Administrator. The check consists of an oral or written equipment test plus a flight check covering navigation by instruments, recovery from simulated emergencies, and standard instrument approaches — with at least one straight-in approach, one circling approach, and one missed approach demonstrated. The record in the crewmember file must document date, aircraft type or simulator, the approaches flown, and the check airman's signature.
5. §135.299 Line Check (PIC Only)
14 CFR §135.299 requires each PIC to complete an annual line check consisting of at least one flight over one route segment, with takeoffs and landings at one or more representative airports — and, for pilots authorized to fly IFR, a flight over a civil airway or an approved off-airway route. The rule does not require a revenue flight: the check may be flown as a non-revenue flight. The line check verifies that the PIC can conduct operations over a route to destination airports in the certificate holder's operations area, following the procedures in the GOM.
The §135.299 line check must be conducted within the preceding 12 calendar months by an FAA inspector or a check airman designated under the certificate holder's training program. The record must document the date, route flown, and the evaluator's signature. SIC pilots are not required to complete a §135.299 line check — this requirement applies only to PICs.
Scheduling §135.299 line checks is operationally complex for operators with large or geographically distributed pilot rosters — the check must be flown in the aircraft over a representative route segment with an authorized check pilot or FAA inspector aboard. Many operators build line check windows into their route scheduling to ensure every PIC receives a check before the calendar-month window closes.
6. Subpart H Training Records: Aircraft Type, Emergency Procedures & Special Operations
Part 135 Subpart H (Training) establishes the training program requirements for all crewmembers. The certificate holder's approved training program — which is incorporated by reference in the GOM under §135.21 — specifies the exact training modules, recurrence intervals, and acceptable completion methods for:
- Aircraft-type or differences training (§135.345–§135.351): initial before first flight on type; recurrent per approved program
- Emergency equipment and procedures training (§135.331): initial + annual recurrent
- Water survival training for overwater operations (§135.331): initial + annual recurrent
- Dangerous goods / hazmat training (14 CFR §135.503 and Part 135 Appendix O): initial + recurrent per the approved program
- CRM (Crew Resource Management) per approved program: initial + recurrent per OpSpecs
Each training module completion must be documented in the crewmember file with date, training method (simulator, CBT, classroom, OJT), and the instructor's or designee's signature. Training records that reference the approved training program by section number rather than just date are more defensible in an enforcement context.
7. Drug & Alcohol Records (14 CFR Part 120 / 49 CFR Part 40) & Pilot Records Database (PRD) Review
Under 14 CFR Part 120 and 49 CFR Part 40, Part 135 operators must maintain a drug and alcohol testing program. Every crewmember file must document a verified negative pre-employment drug test result — required by 14 CFR §120.109(a) — before the pilot performs any safety-sensitive function. Random, post-accident, reasonable suspicion, and return-to-duty test results are retained separately under the testing program records — but the pre-employment negative result belongs in the crewmember file. Retention under 49 CFR §40.333 is record-specific: verified positive drug results, alcohol results of 0.02 or greater, refusals, SAP reports, and follow-up testing records are kept at least 5 years; previous-employer testing-history information 3 years; collection-process and calibration records 2 years; and negative or cancelled results — including the pre-employment negative itself — at least 1 year.
The pre-hire pilot records review now runs through the FAA Pilot Records Database (PRD) under 14 CFR Part 111. The certificate holder must access and evaluate a new-hire pilot's PRD records — FAA certificate, rating, and enforcement data, records from previous employers, and National Driver Register information — before the pilot begins service, and evidence of that evaluation belongs in the crewmember file. The Pilot Records Improvement Act (PRIA), codified at 49 U.S.C. §44703(h), governed this process historically, but it ceased to be effective on September 9, 2024 under 14 CFR §111.5(b) — operators still running paper PRIA requests are following a superseded regime.
Reading the Renewal Intervals: Calendar Month vs. Rolling Day
The three core Part 135 checkride records — §135.293, §135.297, and §135.299 — all use a calendar-month interval, not a rolling-day interval. This is one of the most important structural facts in Part 135 pilot file management, and it has two practical effects that operators frequently misread.
How the calendar-month interval works
A §135.293 check completed on February 10, 2025 is current through the end of February 2026 — not just through February 10, 2026. A §135.297 IPC completed on October 28, 2025 is current through the end of April 2026 — not just through April 28, 2026.
This means pilots completing checks early in a calendar month get more effective currency than the stated interval — and completing checks late in a month minimizes the schedule compression at renewal time.
Early renewal and the §135.301(a) grace provision
If a pilot completes the §135.297 IPC in February, the next check is due in August. Renewing in July — the calendar month before the due month — does not consume the window: under §135.301(a), the July check is considered completed in August, so the new currency window runs through the end of the following February.
Under §135.301(a), a check completed in the calendar month before or after the due month counts as completed in the due month. Only a check completed two or more months before the due month actually resets the clock to the new check date — that is the "calendar-month compression" operators need to track when pilots complete checks well ahead of schedule.
The practical implication for a compliance file system is that the expiration date displayed to the operator should reflect the end of the relevant calendar month after the last completion — not the day 12 months (or 6 months) from the check date. A system that displays "expires 2026-06-09" for a §135.293 completed on June 9, 2025 is wrong — the actual currency runs through June 30, 2026. But a system that says "expires 2026-07-01" for that same check date is also wrong for different reasons. The correct display is "current through end of June 2026."
The medical certificate follows calendar-month logic as well: under §61.23(d), it expires at the end of the last day of the final month of its validity period — not on a mid-month date, and not on a date printed on the certificate (FAA Form 8500-9 shows the examination date). What the medical does not get is the §135.301(a) grace provision: the month-before/month-after rule applies to Part 135 tests and checks, not to medical certificate duration.
The Grace-Month Rule Explained
The "grace month" in Part 135 currency discussions is not informal shorthand — it is an explicit regulatory provision: 14 CFR §135.301(a). Under §135.301(a), a crewmember who completes a required test or flight check in the calendar month before, or the calendar month after, the calendar month in which it is due is considered to have completed it in the calendar month in which it is required. This sits on top of the calendar-month interval itself: a §135.293 check completed on January 15, 2025 is due again in January 2026 and remains valid through the end of January 2026, not just through January 15 — and a renewal completed in December 2025 or February 2026 is treated as a January 2026 completion, keeping the cycle anchored to January.
The practical significance runs in both directions. Renewing in the month before the due month costs no currency — the check is deemed completed in the due month, so the renewal schedule does not compress. And a check that slips into the month after the due month is deemed completed in the due month, so the cycle does not drift — though the pilot may not serve between the end of the due month and the date the late check is actually passed. A pilot who completed the §135.297 IPC on June 3 last year has through June 30 this year to renew, and a renewal flown in May or July is treated as a June completion.
Do not use calendar-month logic as a buffer for late scheduling
The calendar-month rule is not a planning tool for last-minute scheduling — it is a factual description of when currency expires. Operators who habitually schedule checks in the final week of the currency month create systemic risk: a check that cannot be completed before month-end for any reason (aircraft AOG, weather, evaluator unavailability) leaves the pilot out of currency with no administrative cushion. Best practice is a 60-day alert + a 30-day hard-alert, targeting completion at least 3 weeks before the calendar-month end.
For the §135.299 annual line check, the same calendar-month logic applies: a line check completed on March 3 is current through the end of March the following year. Given the operational constraints of scheduling line checks on actual revenue flights, operators with geographically distributed crews should build a 90-day alert buffer for line check renewals — earlier than the 60-day buffer that works for simulator-based §135.293 and §135.297 checks.
How FileFlo Manages Part 135 Pilot Files as a Living System
The per-crewmember file under §135.63(a)(4) is not a static folder — it is a living compliance record that generates expiration events continuously across a pilot roster. An operator with 15 active PICs generates roughly 120 expiration events per year across the 10 record categories in this guide: 15 §135.293 renewals, 15 §135.299 line checks, up to 30 §135.297 IPC renewals (if all fly IFR), 15 medical renewals, and dozens of Subpart H training module renewals.
FileFlo is a compliance document intelligence platform that sits alongside the operational stack — it does not replace the Part 135 operator's scheduling system, flight operations software, or training provider. It classifies uploaded documents against the governing CFR section, tracks their expiration dates using calendar-month logic, and surfaces approaching renewals 90, 60, and 30 days in advance — before an FAA Principal Operations Inspector's surveillance checklist finds them first.
AI document classification against §135.63(a)(4) taxonomy
Upload a check airman's §135.293 record, a §135.297 IPC sign-off sheet, a medical certificate, or a Pilot Records Database (PRD) evaluation record — FileFlo classifies the document against the correct CFR section automatically. No manual filing decisions. No misfiled §135.297 records sitting in the §135.293 folder.
90/60/30-day expiration alerts using calendar-month logic
FileFlo's expiration tracking computes deadlines using the calendar-month rule — not rolling-day math. A §135.297 IPC completed on June 9 shows "current through June 30 next year," not "expires June 9." Alerts fire 90, 60, and 30 days before the end of the relevant calendar month.
One-click POI surveillance binder by crewmember or roster-wide
When an FAA POI requests crew records during a Part 135 surveillance visit, FileFlo generates a complete, §135.63(a)(4)-organized binder for any individual crewmember or for the full pilot roster. What used to take a DOM an afternoon of file-pulling takes under 60 seconds.
Proof layer — not a replacement for the DOM or training provider
FileFlo keeps the documents that prove your crewmembers completed the required training, checks, and testing. It does not conduct the training, administer checks, or replace the certificate holder's Director of Operations. The DOM and approved training provider remain accountable for the substantive side; FileFlo keeps the evidence audit-ready.
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Software GuideFrequently Asked Questions
What does 14 CFR §135.63(a)(4) require for crewmember records?
Under 14 CFR §135.63(a)(4), a Part 135 certificate holder must maintain a current record for each crewmember that includes the crewmember's current certificates and ratings, current medical certificate, type and date of satisfactory completion of tests and training required by 14 CFR Part 135, the most recent completion of the line check required by §135.299, and the most recent flight experience required. These records must be kept at the certificate holder's principal business office or another FAA-approved location, must be available for inspection by the FAA on request, and must be retained for the duration of the crewmember's employment plus at least 12 months after the crewmember leaves the certificate holder.
How often must a Part 135 pilot complete recurrent testing under §135.293?
Under 14 CFR §135.293, each pilot in command and second in command for operations under Part 135 must complete initial and annual recurrent testing. The annual recurrent check must be completed within the preceding 12 calendar months. The test covers knowledge of the applicable portions of 14 CFR Parts 61 and 135, the certificate holder's General Operations Manual (GOM), and the emergency and normal procedures for the aircraft operated. Failing to keep a current §135.293 record for every active crewmember is among the most-cited findings in FAA surveillance of Part 135 operators.
What is the difference between a §135.297 IPC and a §135.293 recurrent check?
The §135.293 annual recurrent check covers knowledge and proficiency across all operations — it is the baseline annual test every Part 135 pilot must pass. The §135.297 Instrument Proficiency Check (IPC) is an additional requirement for pilots who conduct IFR operations: it must be completed within the preceding 6 calendar months for a pilot to act as PIC under IFR or in IMC. A §135.297 IPC covers the instrument flight procedures, approaches, and emergency procedures relevant to the aircraft and operations authorized. The records are separate documents in the crewmember file — the §135.293 record shows the annual date; the §135.297 record shows the 6-month IFR currency date. Both must be current for a pilot conducting IFR charter flights.
What records must be in a Part 135 crewmember file before a pilot flies as PIC?
Before a pilot acts as PIC under a Part 135 certificate, the crewmember file must contain: (1) a pilot certificate meeting 14 CFR §135.243 — an ATP certificate for turbojet airplanes, airplanes with 10 or more passenger seats, or multiengine airplanes in commuter operations; otherwise a Commercial certificate with the appropriate ratings and experience; (2) a current First or Second Class FAA medical certificate; (3) satisfactory completion of the §135.293 initial check within the preceding 12 calendar months; (4) satisfactory completion of the §135.297 IPC within the preceding 6 calendar months for IFR operations; (5) the line check under §135.299; (6) aircraft-specific training records showing type-specific or differences training; and (7) a completed pre-hire records evaluation through the FAA Pilot Records Database (PRD) under 14 CFR Part 111. Any gap in these records — even a medical certificate lapsed by one day — constitutes an illegal operation that FAA can cite under §135.293 or §135.63.
How long must Part 135 crewmember records be retained?
Under 14 CFR §135.63(a)(4), crewmember training and testing records must be retained for at least 12 months after the crewmember leaves the certificate holder. Records of completed checks and tests required under Part 135 — including §135.293, §135.297, and §135.299 records — must be current and available for FAA inspection at all times during that retention window. In practice, many Part 135 legal counsels recommend retaining crewmember files for at least 3–5 years after departure to defend against enforcement actions that can arrive long after the crewmember is gone. Digital retention with indexed, searchable, and exportable records is the lowest-risk path.
What happens if an FAA Principal Operations Inspector finds a gap in a pilot's file?
When a FAA Principal Operations Inspector (POI) finds an incomplete or lapsed crewmember file during a Part 135 surveillance visit, the typical enforcement path proceeds through the FAA Enforcement Decision Process (EDP) under FAA Order 2150.3C. A first isolated gap — such as a §135.297 IPC expired by weeks — often results in a Warning Notice or Letter of Correction. Pattern findings across multiple pilot files, or a gap combined with evidence the pilot flew operations in the non-current window, escalate to civil penalties under 49 U.S.C. §46301(a)(1) — up to $75,000 per violation for operators other than individuals or small business concerns, and $1,875 per violation for individuals and small business concerns, per the inflation-adjusted penalty table in 14 CFR §13.301. Systemic recordkeeping failures — particularly §135.63(a)(4) crewmember file deficiencies across a significant portion of the pilot roster — can trigger a certificate suspension or revocation proceeding.
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FileFlo classifies every §135.293, §135.297, §135.299, and Subpart H training record against the correct CFR section, tracks expirations using proper calendar-month logic, and generates a POI-ready binder in 60 seconds. Starter $89/month, Professional $299/month — 5-day free trial, no credit card required.
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