Direct Answer
To prepare for a Part 135 records audit, get every required record into three states before the FAA arrives: current (no expired medicals, checks, inspections, or manual revisions), complete (every element the CFR lists is actually in the file), and retrievable (you can produce any record on demand). The most reliable way to get there is to assign ownership by role — the Director of Operations owns the certificate, OpsSpecs, manuals, and overall recordkeeping (14 CFR 135.21, 135.63); the Chief Pilot owns the per-pilot training and currency records (14 CFR 135.63(a)(4), 135.293, 135.297, 135.299); and the Director of Maintenance owns airworthiness status and maintenance records (14 CFR 135.439, 91.417, 39.7) — then self-audit each role's checklist at least 30 days out.
The FAA's surveillance under the Safety Assurance System (SAS) is risk-based and continuous, not a fixed calendar interval — so there is no single "audit day" to cram for. The operators who pass clean treat readiness as a standing state. This page is the readiness checklist; for the inspection walkthrough itself, see how to prepare for a Part 135 FAA surveillance audit.
If you have read our companion guide on how a Part 135 FAA surveillance audit unfolds and our overview of what records a Part 135 operator must keep, this page is the action layer that sits on top of both: a checklist you actually work through, organized by who is accountable for each record.
The Only Three States That Matter: Current, Complete, Retrievable
Audit preparation gets framed as "do you have the records?" — but having a record is not the same as being ready. A record can exist and still produce a finding if it is expired, missing a required element, or buried where no one can find it during the visit. Before you work the role checklists, internalize the three-state test. Every single record below has to pass all three.
Current
No expired medical, no lapsed 135.293 or 135.297 check, no out-of-date manual revision, no overdue inspection. Currency is a moving target — what was current last quarter may not be today.
Complete
Every element the regulation names is present. A pilot record under 135.63(a)(4) lists ten-plus specific items; an inspector reads the file expecting all of them. A missing recurrent-check date is read as a missed check.
Retrievable
You can produce any record on demand without a scramble. An inspector who waits 45 minutes while you assemble a file that should already exist is forming an impression before a finding is even written.
There is no "audit every N months" rule
The FAA oversees Part 135 certificate holders through the Safety Assurance System, a risk-based, data-supported, continuous-surveillance model — not a fixed calendar interval. Scheduled base inspections are usually coordinated in advance; ramp checks and en-route observations are unannounced. Because you cannot reliably predict the timing, the three-state test has to be a standing condition, not something you achieve the week before. Anyone quoting a fixed "every N months" FAA audit cadence is describing a rule that does not exist in the public surveillance model. See how often the FAA audits a Part 135 operator.
The Records Audit Checklist, by Role
One person cannot keep thirty-plus record types current across a fleet and a crew roster. Three accountable owners can. 14 CFR 119.69(a) requires a Director of Operations, a Chief Pilot, and a Director of Maintenance for operators using more than one pilot — so split the readiness work along the same lines the regulation already draws. Each card below is that role's checklist; every item links to its governing section on Cornell's Legal Information Institute.
Director of Operations
Owns: Certificate, OpsSpecs, manuals & overall recordkeeping
14 CFR 119.69(a); 135.21; 135.63The DO owns the documents that establish the operator is authorized to fly at all and that the program governing operations is current and accessible. These are the first records an inspector confirms, so a gap here colors everything that follows.
Air Carrier / Operating Certificate
14 CFR part 119Current; no expiry, but must reflect the operations actually being conducted. CURRENT: matches your fleet and authorizations. COMPLETE: amended after any change in scope. RETRIEVABLE: in the binder, not a drawer in someone else's office.
Where operators trip up: An unamended certificate after a fleet or operations change is among the fastest ways an inspection escalates.
Operations Specifications (OpsSpecs)
14 CFR 119.49Current revision on file at the base; amended before any new operation type, area, or aircraft. Each OpSpec paragraph the operator holds (e.g., D095 MEL authorization) should be retrievable as proof of the authority being exercised.
General Operations Manual (GOM) — current revision
14 CFR 135.21Section 135.21 requires a certificate holder (other than single-pilot operators) to prepare and keep the manual current, keep at least one copy at the principal base, furnish it to crewmembers and to FAA representatives, and ensure the appropriate parts are accessible to flight, ground, and maintenance personnel during their duties.
Where operators trip up: A revision that was made but not distributed and acknowledged is a finding even when the content is correct — keep distribution records with the revision.
General Maintenance Manual (GMM) — current revision
14 CFR 135.21; 135.427Same currency and accessibility logic as the GOM, on the maintenance side. CURRENT revision, COMPLETE revision history, RETRIEVABLE for the inspector and for maintenance personnel.
Management personnel designation letters (DO / Chief Pilot / DOM)
14 CFR 119.69Section 119.69(a) requires qualified persons in the Director of Operations, Chief Pilot, and Director of Maintenance positions for operators using more than one pilot (the Administrator may approve alternatives). Keep current designation letters and the qualification records that support each appointment.
Current aircraft list
14 CFR 135.63(a)(3)The list of aircraft used or available for use. Retained for at least 6 months under 14 CFR 135.63(b). Must match the tails actually on the certificate.
Completed load manifests (multiengine)
14 CFR 135.63(c), (d)For multiengine aircraft the PIC carries a completed load manifest; copies are kept for at least 30 days at the principal operations base (or an approved alternate location) under 135.63(d).
Chief Pilot
Owns: Per-pilot training, checking & currency records
14 CFR 135.63(a)(4); 135.293; 135.297; 135.299The Chief Pilot owns the individual pilot file. An inspector reads each one element by element — a missing recurrent-check date is treated as evidence the check may not have happened. The job here is to make every pilot file complete and every currency window green before the file is ever opened.
Individual pilot record — all 135.63(a)(4) elements
14 CFR 135.63(a)(4)Each pilot record must contain the full name; certificate type/number and ratings; aeronautical experience in sufficient detail; present duties and assignment date; medical certificate effective date and class; the date and result of each initial and recurrent competency test, proficiency check, and route check with aircraft type; flight time in sufficient detail to show flight-time-limit compliance; check-pilot authorization if any; any disqualification release; and training completion dates. Retained at least 12 months per 135.63(b).
Where operators trip up: Completeness is the test here — every listed element must be present. A file missing one element reads as a gap, not a rounding error.
Airman Certificate — category, class, type
14 CFR 135.243No expiry, but the certificate held must match the aircraft and the operation. ATP-level requirements apply to certain operations under 135.243(a). Verify category/class/type against each pilot's assignments.
Medical Certificate — class verified against operation
14 CFR 61.23; 135.243Class and validity period depend on the operation and the pilot's age. CURRENT: not expired for the class required. COMPLETE: correct class for the operation flown. This is the single most common silent-expiry item — track it with an alert, not a memory.
Where operators trip up: An expired or wrong-class medical for the operation is an immediate grounding-level finding.
135.293 Competency Check (knowledge + competency)
14 CFR 135.293A written or oral knowledge test plus a competency check. The regulation requires it "since the beginning of the 12th calendar month before that service" — effectively a 12-calendar-month window. Verified per pilot, per aircraft type or class.
135.297 Instrument Proficiency Check (IPC)
14 CFR 135.297Required for any pilot serving as PIC under IFR — "since the beginning of the 6th calendar month before that service," a 6-calendar-month window. Verified independently from the 135.293 competency check.
Where operators trip up: A current 135.293 competency check does NOT satisfy the 135.297 IPC. They are separate records with separate windows; the shorter IPC window is the one operators most often let slip.
135.299 Line / Route Check
14 CFR 135.299A line check over a representative route segment, required on a 12-calendar-month cadence for PICs. Recorded in the individual pilot file.
Recurrent & initial/transition training records
14 CFR 135.351; 135.323Ground and flight training completion recorded per the approved training program. See the companion guide on Part 135 training program recordkeeping for how these map to the program curriculum.
Flight & duty time records
14 CFR 135.63(a)(4)(vii)Flight time in sufficient detail to determine compliance with the applicable flight-time limitations. Kept current and retained with the pilot record (12 months minimum).
The DOM owns the records that prove each aircraft is airworthy and the maintenance was properly performed and returned to service. Inspectors trace a sample item — an AD, a life-limited part, the last inspection — from the status summary back to the entry that proves it. Every link in that chain must exist and be retrievable.
Airworthiness & registration certificates
14 CFR 91.203Required aboard each aircraft. Airworthiness certificate displayed at the cabin/cockpit entrance; registration current. RETRIEVABLE means aboard and findable, not in a hangar file.
Maintenance records — work performed
14 CFR 135.439(b)(1); 91.417(a)For aircraft on a continuous airworthiness maintenance program, records of maintenance, preventive maintenance, and alteration are retained until the work is repeated or superseded by other work, or for one year after performance (135.439(b)(1)). Aircraft not on a CAMP follow the 91.417 scheme.
Airworthiness-status records (transfer with aircraft)
14 CFR 135.439(b)(3); 91.417(a)(2)Total time in service of airframe/engine/propeller/rotor; current status of life-limited parts; time since last overhaul of time-limited items; current inspection status; current AD status. Kept and transferred with the aircraft when it is sold (135.439(b)(3)).
Where operators trip up: These are the records an inspector samples first. A status summary that cannot be traced back to a signed compliance entry is the same as no record at all.
Airworthiness Directive (AD) compliance record
14 CFR 39.7; 91.417(a)(2)(v)Must show both applicability (which ADs apply to this airframe/engine/propeller serial) and compliance (AD number and revision, method, date, and next-due for recurring ADs). The record, not just the work, is the requirement.
Inspection program signoffs (AAIP or 91.409)
14 CFR 135.419; 91.409Know which inspection regime governs each tail. Aircraft under an Approved Aircraft Inspection Program are inspected per that program; others follow annual/100-hour. The most recent signoff must match the governing program. See the companion guide on Part 135 maintenance recordkeeping and CAMP requirements.
Where operators trip up: Mixed fleets create AAIP-vs-91.409 confusion — maintaining the wrong inspection type for a given tail is a recurring finding.
Required equipment test records (altimeter, transponder, ELT)
14 CFR 91.411; 91.413; 91.207Altimeter/static and transponder tests on a 24-calendar-month cadence (paired for IFR); ELT inspection on a 12-calendar-month cadence. Track each as its own expiring record.
Shared / Program-Level Records
Owns: Drug & alcohol, SMS, and security program records
14 CFR part 120; part 5; 14 CFR 135.293 et al.Some records do not belong to a single role — they are program-level and are typically owned jointly or by a designated program manager. Confirm ownership explicitly so these do not fall between the DO, Chief Pilot, and DOM.
Drug & alcohol testing program records
14 CFR 120.111Program plan plus testing records by type (pre-employment, random, post-accident, reasonable-suspicion, return-to-duty, follow-up). Records confirmed positive are kept 5 years and annual MIS reports 5 years under 120.111. See the companion drug-and-alcohol program records checklist.
SMS documentation & records (2027 mandate)
14 CFR part 5The 2024 final rule extends Safety Management System requirements to all Part 135 operators with a single compliance date in May 2027. SMS policy, risk-management, assurance, and promotion records become part of the readiness picture. See the FAA Part 135 SMS 2027 deadline guide.
Security program records (when applicable)
49 CFR 1544 / 1550 (TSA)Operators subject to the Twelve-Five or other TSA standard security programs keep the program and its training/records per TSA requirements — separate from the FAA file but often requested in the same window.
Grade your records before the FAA does
The free FAA Readiness Score walks the same record domains the DO, Chief Pilot, and DOM own — and flags which gaps are most likely to surface as findings. No signup required; under 3 minutes.
Run the Free FAA Readiness ScoreHow to Run the Self-Audit (30 Days Out, Then Standing)
A self-audit is simply grading your own records against the same checklist an inspector would use, then fixing what you find before the FAA finds it. Run it at least 30 days before any coordinated base inspection, and then keep it running on a cadence so readiness becomes a standing state rather than a fire drill. Here is the sequence that works.
Assign the three owners in writing
Confirm the Director of Operations, Chief Pilot, and Director of Maintenance each have a named checklist and know they own it. Explicitly assign the program-level records (drug & alcohol, SMS, security) so they do not fall between roles.
Chief Pilot: pull every active pilot file
Verify each 135.63(a)(4) element is present, then check the currency of the 135.293 competency check (12 calendar months), the 135.297 IPC (6 calendar months) for IFR PICs, the 135.299 line check, and medical class/expiry. Flag anything inside 90 days of lapsing.
DOM: trace a sample item end to end
Pick an AD and a life-limited part and trace each from the airworthiness-status summary back to the signed entry that proves compliance. If the chain breaks anywhere, the record is incomplete — fix it before the inspector samples it.
DO: verify currency and accessibility of program documents
Confirm the certificate, OpsSpecs, GOM, and GMM are at their current accepted revisions, that distribution/acknowledgment records exist, and that the manual is accessible to the personnel 135.21 requires.
Document findings and corrective actions
Record what you found and what you did about it. A self-audit you can show — with dated corrective actions — demonstrates a functioning compliance system. One you cannot show is hard to distinguish from one that never happened.
Set the cadence and the alerts
Move from one-time to standing: schedule the file review on a recurring basis and put expiration alerts on every dated record so currency never depends on someone remembering. This is the step that converts a pre-audit sprint into continuous readiness.
FileFlo: the proof layer that keeps every record current, complete, and retrievable
FileFlo is a compliance document intelligence platform — a proof layer that sits alongside your existing stack (flight scheduling, maintenance tracking, training software) and organizes the documents those systems produce into an audit-ready state. It does not conduct the audit, represent you to the FAA, or give legal advice, and it does not replace your safety management system, dispatch software, or maintenance tracking platform. What it does is classify over 600 document types against the governing regulation, track expiration windows on every medical, training check, and required inspection so nothing lapses silently, and let you produce any record — a specific pilot's 135.293 check, an aircraft's AD compliance status, the current GOM revision — on demand.
Mapped to this checklist: it gives the Chief Pilot a live per-pilot currency matrix, gives the Director of Maintenance a traceable airworthiness-status view, and gives the Director of Operations one place to confirm manual currency and pull any record an inspector asks for. The binder most operators assemble by hand over two days becomes a search query.
Part 135 Records Retention Periods at a Glance
Completeness includes keeping records long enough. These minimum retention periods are set by regulation — discarding a record before its minimum is itself a compliance gap. Verify each against the linked section; durations can be amended.
| Record | Minimum retention | Citation |
|---|---|---|
| Individual pilot & flight-attendant records | At least 12 months | 14 CFR 135.63(b) |
| Current aircraft list | At least 6 months | 14 CFR 135.63(b) |
| Completed load manifests (multiengine) | At least 30 days, at principal ops base | 14 CFR 135.63(d) |
| Maintenance records — work performed (CAMP aircraft) | Until repeated/superseded, or 1 year | 14 CFR 135.439(b)(1) |
| Airworthiness-status records (CAMP aircraft) | Kept & transferred with the aircraft on sale | 14 CFR 135.439(b)(3) |
| Drug-program records confirmed positive | 5 years | 14 CFR 120.111 |
| Annual drug & alcohol MIS reports | 5 years | 14 CFR 120.111 |
Aircraft not maintained under a continuous airworthiness maintenance program follow the maintenance-record retention scheme of 14 CFR 91.417(b).
Work the record-by-record guides
Frequently Asked Questions
How do you prepare for an FAA audit of a Part 135 operator?
You prepare by getting every required record into three states before the inspector arrives: current (no expired medicals, checks, inspections, or manual revisions), complete (every element the CFR lists is actually in the file, not just most of them), and retrievable (you can produce any record on demand without a scramble). The most reliable way to do that is to assign ownership by role — the Director of Operations owns the certificate, OpsSpecs, manuals, and crew records; the Chief Pilot owns the per-pilot training and currency matrix; the Director of Maintenance owns airworthiness status and maintenance records — and then run a self-audit against each role's checklist at least 30 days out. The FAA's surveillance under the Safety Assurance System is risk-based and continuous, so there is no single "audit day" to cram for; the operators who pass clean treat readiness as a standing state, not a project.
What records does the FAA ask for in a Part 135 records audit?
On a base or records inspection the FAA works from the records the regulations require you to keep at your principal business office. Expect requests for: the Air Carrier Certificate and current Operations Specifications; the General Operations Manual and General Maintenance Manual at their current FAA-accepted revisions (14 CFR 135.21); the current aircraft list; an individual record for each pilot containing every element of 14 CFR 135.63(a)(4); flight and duty time records sufficient to show compliance with the flight-time limits; airworthiness status and maintenance records (14 CFR 135.439 for aircraft on a continuous airworthiness maintenance program, or 14 CFR 91.417 otherwise); and your drug and alcohol testing program records under 14 CFR part 120. The records overlap heavily with a ramp check but live in the file room rather than the cockpit.
How long must a Part 135 operator keep records?
The retention periods are set by regulation and differ by record type. Under 14 CFR 135.63(b), individual pilot and flight-attendant records must be kept for at least 12 months, and the current aircraft list for at least 6 months. Under 14 CFR 135.63(d), completed load manifests are kept for at least 30 days at the principal operations base. For aircraft on a continuous airworthiness maintenance program, 14 CFR 135.439(b) keeps records of work performed until the work is repeated or superseded, or for one year, while the airworthiness-status records (total time, life-limited parts, time since overhaul, inspection status, AD status) are kept and transferred with the aircraft when it is sold. Drug-program records confirmed positive are kept 5 years and annual MIS reports 5 years under 14 CFR 120.111. "We threw it out" is not a defense when the regulation sets a minimum.
Does the FAA give notice before a Part 135 audit?
It depends on the type of surveillance. A scheduled base or records inspection is usually coordinated with your certificate-holding district office in advance, so you typically get notice and a date. Ramp inspections and en-route observations are different: an aviation safety inspector can conduct those any time they encounter your aircraft, with no advance notice. Because the Safety Assurance System is risk-based and continuous rather than calendar-driven, the safe assumption is that you could be observed at any time. That is exactly why the role-based readiness checklist on this page is built around a standing state — current, complete, retrievable — rather than a pre-audit assembly sprint.
What is a Part 135 self-audit and how do you run one?
A self-audit is an internal review where you grade your own records against the same regulatory checklist an FAA inspector would use, and fix the gaps before the FAA finds them. The most practical structure is to split it by role: the Chief Pilot pulls every active pilot file and verifies each element of 14 CFR 135.63(a)(4) plus the currency of the 135.293 competency check (12 calendar months) and the 135.297 instrument proficiency check (6 calendar months); the Director of Maintenance traces a sample airworthiness directive and a life-limited part from the status summary back to the entry that proves compliance; and the Director of Operations confirms the certificate, OpsSpecs, and manual revisions are current and accessible. Document what you find and the corrective action — a self-audit you cannot show is hard to distinguish from one you never ran.
Who is responsible for Part 135 audit records — the DO, Chief Pilot, or DOM?
All three, by domain. 14 CFR 119.69(a) requires a Part 135 certificate holder using more than one pilot to have a Director of Operations, a Chief Pilot, and a Director of Maintenance (the Administrator can approve alternatives for smaller operations). In practice the Director of Operations owns the certificate, Operations Specifications, the General Operations Manual, and overall recordkeeping responsibility; the Chief Pilot owns the per-pilot training, checking, and currency records; and the Director of Maintenance owns airworthiness status, maintenance records, and the maintenance manual. Splitting the readiness checklist along those lines is how the work actually gets done — one person cannot keep 30-plus record types current across a fleet and a crew roster, but three accountable owners can.
What is the difference between a records audit checklist and a surveillance-audit walkthrough?
A surveillance-audit walkthrough explains how the FAA's visit unfolds — who shows up, the order they pull documents, and how findings get written. Our companion guide on how to prepare for a Part 135 FAA surveillance audit covers that flow document-by-document. A records audit preparation checklist, like this page, is the readiness side: a role-by-role list you work through on your own schedule to get every record current, complete, and retrievable before anyone arrives. Use the walkthrough to understand the inspection; use this checklist to be ready for it. They are complementary, and most operators want both.
How does FileFlo help with Part 135 audit preparation?
FileFlo is a compliance document intelligence platform — the proof layer that makes your records current, complete, and instantly retrievable. It does not conduct the audit, represent you to the FAA, or give legal advice, and it does not replace your safety management system, dispatch software, or maintenance tracking platform. What it does is classify your uploaded documents against the governing regulation, track expiration windows on every medical, training check, and required inspection so nothing lapses silently, and let you produce any record — a specific pilot's 135.293 check, an aircraft's AD compliance status, the current GOM revision — on demand. The binder most operators assemble by hand over two days becomes a search query. That is the entire point: be audit-ready, and produce any record the moment it is asked for.
Be audit-ready — and produce any record on demand
FileFlo keeps every record across all three role domains — DO, Chief Pilot, and DOM — current, complete, and instantly retrievable, so the moment an inspector asks for a specific pilot's 135.297 IPC or an aircraft's AD compliance status, you produce it in seconds. Starter at $89/month. Professional at $299/month (unlimited pilots + aircraft). Five-day free trial, no credit card required.
5-day free trial · No credit card required · Cancel anytime · FileFlo is the compliance document/proof layer — it does not conduct the audit, represent you to the FAA, or replace your SMS, dispatch, or maintenance tracking system.