The Short Answer
A 14 CFR Part 145 repair station's authority is bounded by §145.201 — it may perform maintenance, preventive maintenance, and alterations under Part 43 only on articles for which it is rated and within its operations specifications, and it may not maintain an article it is not rated for or one that needs special data, equipment, or facilities it does not have. Inside those bounds, three sections govern work that leaves the bench: §145.217 (contracting a maintenance function to an outside source), §145.203 (performing work away from the fixed location), and §145.205 (maintaining a part 121/125/135 or part 129 operator's aircraft to that operator's program).
The through-line: the station can move the work, but not its responsibility for the result or the records that prove it. §145.217(a) requires the FAA to approve each contracted function and the station to keep a list of every outside source with its certificate and ratings; §145.217(b) requires a noncertificated source to follow an equivalent quality control system with the station remaining directly in charge and verifying the work by test and inspection; and §145.217(c) forbids the station from providing only a return-to-service approval for a complete type-certificated product someone else maintained. Underneath it all, §145.219(c) fixes the FAA records floor: keep the required records at least 2 years from the date the article was approved for return to service.
Repair stations rarely do everything in-house at one address. Specialized processes get sent to a plating shop or an NDT vendor; a customer's aircraft gets a line check at an outstation; an airline contract means working to the airline's manual rather than your own. Part 145 anticipates all three — and each one carries its own records obligation that an FSDO inspector knows to ask for. The mistakes that turn into findings are almost never about the quality of the work. They are about a contracted function that is not on the list, an off-site job with no procedure in the manual, or a release that outruns what the station can document it actually did.
This article keeps to what the regulation says. The four sections — §145.201, §145.203, §145.205, and §145.217 — are stated from the 14 CFR Part 145 text, along with the recordkeeping standard at §145.219. This is the repair-station side of contract maintenance. For the operator's side — when a Part 135 certificate holder farms out its maintenance and still owns the airworthiness — see our companion piece on Part 135 contract maintenance records. The two interlock: the airline of §145.205 is the operator of that companion post.
Two sides of the same word: "contract"
"Contract maintenance" means different things depending on which seat you are in. Under §145.205, the repair station is the contractor doing work for an air carrier and must follow that operator's program. Under §145.217, the same station becomes the customer, contracting a function out to a third source — and now it owns the §145.217 controls. A station doing line maintenance for an airline and sending the wheels out to a noncertificated overhaul source is living in both sections at once. Keep the seats straight and the records sort themselves out.
The Four Sections, Side by Side
§145.201 sets the outer boundary; the other three describe specific kinds of work inside it. Here is what each one actually requires, verified against the CFR.
Privileges & limitations — the outer boundary
Privileges (a): a certificated repair station may perform maintenance, preventive maintenance, or alterations in accordance with Part 43 on any article for which it is rated, within the limits in its operations specifications; may arrange for another person (a source not certificated under Part 145) to perform that work if the source follows a quality control system equivalent to the station's; and may approve any article it is rated for for return to service after performing work on it under Part 43.
Limitations (b): the station may not maintain or alter any article for which it is not rated, and may not maintain or alter an article it is rated for if doing so requires special technical data, equipment, or facilities that are not available to it. Approval for return to service is further conditioned on the work having been done using applicable approved technical data or data acceptable to the FAA.
Records consequence: every release the station signs has to fall inside its ratings and OpSpec limits. A release for an article outside the rating — or one the station lacked the data/equipment to properly maintain — is a §145.201 limitation breach no matter how the §43.9 entry reads.
Work performed at another location
A certificated repair station may temporarily transport material, equipment, and personnel needed to perform maintenance, preventive maintenance, alterations, or specialized services at a place other than the repair station's fixed location under two conditions:
- (a)A special circumstance, as determined by the FAA, makes the work necessary; or
- (b)It is necessary to perform such work on a recurring basis, and the repair station's manual includes the procedures for accomplishing maintenance, preventive maintenance, alterations, or specialized services at a place other than the fixed location.
Records consequence: the recurring pathway is conditioned on the manual. If a station performs field work on a recurring basis without those off-site procedures in its manual, the work itself is non-conforming under §145.203(b) — and the off-site records have to show the work followed the manual procedures that do exist.
Maintenance for part 121/125/135 holders and part 129 operators
When a repair station performs maintenance, preventive maintenance, or alterations for an air carrier or commercial operator that has a continuous airworthiness maintenance program under part 121 or 135, §145.205(a) requires it to follow the air carrier's or commercial operator's program and the applicable sections of its maintenance manual — not merely the station's own repair station manual.
For a certificate holder operating under part 125, the station performing inspections must follow the operator's FAA-approved inspection program. For a foreign air carrier or foreign person operating a U.S.-registered aircraft in common carriage under part 129, the station must follow the operator's FAA-approved maintenance program. And the FAA may authorize a station to perform line maintenance for a part 121 or 135 carrier (or a part 129 operator) when the work follows the operator's manual and approved program, the station has the equipment, trained personnel, and technical data, and the authorization is reflected in the station's operations specifications.
Records consequence: the record has to tie the work to the operator's program and manual revision, not just the station's procedures. "We did it our way" is a finding when §145.205 required you to do it the operator's way. See our companion Part 135 contract maintenance and CAMP recordkeeping guides for the operator's half of this.
Contract maintenance — sending a function out
A certificated repair station may contract a maintenance function pertaining to an article to an outside source — covered in depth in the next section. In short: under §145.217(a), the FAA must approve the function being contracted out, and the station must maintain a record of the contracted functions and the name, certificate type, and ratings of each outside facility, available to the FAA. Under §145.217(b), a noncertificated source is permitted only if it follows an equivalent QC system, the station remains directly in charge of the work, and the station verifies by test and inspection that the work is satisfactory and the article airworthy before approving return to service. Under §145.217(c), the station may not provide only approval for return to service of a complete type-certificated product following contract maintenance.
Records consequence: the contracted-functions list is the document an inspector opens first. The work the station's records show was contracted out must match the list, and a noncertificated source's work must have the station's own verification record sitting on top of it.
§145.217 in Depth: Certificated vs Noncertificated Sources
The single most important distinction in contract maintenance is whether the outside source holds its own certificate. The rule treats the two paths very differently — and so should your records.
Certificated source — §145.217(a)
Who: another Part 145 repair station, or a person otherwise certificated to do the work.
FAA approval: the function being contracted out must be one the FAA has approved the station to contract.
The list: the station maintains a record of the maintenance functions contracted, the name of each outside facility, and the type of certificate and ratings (if any) it holds — kept available to the FAA.
Responsibility: the certificated source approves its own work for return to service under its certificate; the contracting station still cannot, under §145.217(c), provide only an RTS approval for a complete type-certificated product it did not maintain.
Noncertificated source — §145.217(b)
Who: a source without its own maintenance certificate — a specialty process house, for example.
Equivalent QC: the source must follow a quality control system equivalent to the certificated station's.
Directly in charge: the station must remain directly in charge of the work performed by the noncertificated source.
Verify before release: the station must verify, by test and/or inspection, that the work was performed satisfactorily and the article is airworthy before it approves the article for return to service. That verification is the station's own record — and the work cannot reach a release without it.
The §145.217(c) line, stated plainly
§145.217(c) provides that a certificated repair station may not provide only approval for return to service of a complete type-certificated product following contract maintenance, preventive maintenance, or alterations. The practical meaning: a station cannot be a signature-for-hire on a whole aircraft, engine, or propeller it did not maintain. To approve a complete type-certificated product for return to service, the station has to have actually performed maintenance on it — not merely accepted someone else's work and signed. This is one of the more frequently cited contract-maintenance pitfalls, and the records tell on it immediately when the release does not match the work the station can document.
Where the controls live: the list and the QC manual
Two documents carry the §145.217 controls. The first is the contracted-functions list itself, required by §145.217(a)(2) and kept available to the FAA. The second is the quality control manual required by §145.211 — its contents under §145.211(c) include the procedures the station uses for qualifying and surveilling the noncertificated persons who perform maintenance for it. An auditor cross-checks the two: the list says who is doing what, and the QC manual says how the station keeps those sources inside its quality system. For the full records picture these feed into, see our Part 145 recordkeeping requirements and repair station quality control manual (RSQCM) breakdowns.
§145.203: Working Away From the Fixed Location
A repair station's certificate is tied to a fixed location with rated facilities. §145.203 is the narrow door that lets the work happen somewhere else — and it is a door with two specific keys.
Key 1 — Special circumstance, as determined by the FAA
§145.203(a) allows off-site work when a special circumstance makes it necessary, as determined by the FAA. This is the one-off path — a disabled aircraft that cannot be moved, an unusual situation the FAA agrees warrants temporarily taking the station's people and equipment to the work. The determining authority is the FAA, not the station's own convenience, so the record should reflect the basis on which the off-site work proceeded.
Key 2 — Recurring basis, with procedures in the manual
§145.203(b) allows off-site work performed on a recurring basis only if the repair station's manual includes the procedures for accomplishing that work away from the fixed location. This is the path most shops with regular field work build around: get the off-site procedures into the manual, follow them, and document each off-site job to the same standard as bench work. The manual procedures are the condition — without them, recurring field work is non-conforming under §145.203(b) on its own terms.
The standard does not drop off-site — the §43.9 backbone still applies
Performing work away from the station does not relax the maintenance-record standard. The underlying entry still has to meet 14 CFR §43.9(a) — a description of the work performed (or a reference to data acceptable to the FAA), the date of completion, the name of the performer if different from the approver, and the signature, certificate number, and kind of certificate of the person approving return to service. (Inspections are governed by §43.11, not §43.9.) If anything, off-site work demands tighter documentation discipline, because the job did not pass across the station's own inspection floor.
Line maintenance is its own authorization — don't confuse it with §145.203
Performing line maintenance for an air carrier at an outstation is authorized through §145.205(d) and reflected in the station's operations specifications — a different mechanism than the §145.203 special-circumstance / recurring-procedures pathways for general off-site work. A station doing recurring line maintenance for an airline relies on the §145.205(d) line-maintenance authorization in its OpSpecs; a station occasionally taking its people to a one-off field job relies on §145.203(a). Knowing which authority a given off-site job rests on is the first thing the record should make clear.
The Records Floor: What §145.219 Requires
Contracted work and off-site work do not get a separate, lighter records rule — they fall under the same §145.219 that governs everything the station does. Three subsections carry the load.
Records demonstrating Part 43 compliance
The station must keep records, in English and in a format acceptable to the FAA, that demonstrate compliance with the requirements of Part 43. For a contracted or off-site job, that means the §43.9 maintenance entry (or §43.11 inspection entry) is complete and the article's release traces to it — wherever the work physically happened and whoever performed it.
A copy of the release to the owner or operator
The station must provide a copy of the maintenance release to the owner or operator of the article. When the work was contracted or done off-site, the release the customer receives is the station's — the station stands behind the result, including any verification it performed on a noncertificated source's work under §145.217(b).
The 2-year retention floor
The station must retain the records required by this section for at least 2 years from the date the article was approved for return to service — and that includes the contracted-functions list's supporting records and off-site work records. Two years is the FAA floor; customer contracts, an air carrier's program under §145.205, and export or bilateral work routinely demand longer.
See our aviation records retention schedule for how the §145.219 floor lines up against the longer clocks other rules and customers impose.
Not sure your contracted-functions list reconciles to your records? A free FAA readiness check surfaces the §145.217 and §145.219 gaps before an inspector does.
Six Records Contract & Off-Site Work Lives On
Each row names the controlling section, what the record must contain, how long to keep it, and the audit finding a complete record prevents.
Contracted-functions list (outside sources)
14 CFR §145.217(a)(2)What's Required
A record of the maintenance functions contracted to outside sources, naming each facility and the type of certificate and ratings (if any) it holds. This is the master list an FSDO inspector opens first when probing contract maintenance, and it must be kept available to the FAA. It is the documentary anchor for everything else in this topic.
Retention
Kept current and available to the FAA; tied to the records of the work contracted out
Audit Finding Prevented
A contracted function performed by a source that is not on the list, or a list naming a facility whose certificate/ratings do not cover the work. The mismatch puts every affected release in question.
Noncertificated-source verification record
14 CFR §145.217(b)(2)–(3)What's Required
When the outside source is noncertificated, the station's own record that it remained directly in charge of the work and verified by test and inspection that the work was done satisfactorily and the article is airworthy before approving return to service. This inspection record sits on top of the contractor's work and is what lets the station stand behind the release.
Retention
2 years from the date the article was approved for return to service (§145.219(c))
Audit Finding Prevented
A part maintained by a noncertificated source with no station test/inspection record behind it — the station took a release it cannot show it controlled or verified.
Work order / maintenance record (the §43.9 backbone)
14 CFR §145.219(a) + §43.9What's Required
Records, in English, demonstrating Part 43 compliance. For maintenance, §43.9(a) content applies: a description of the work performed (or a reference to data acceptable to the FAA), the date of completion, the name of the person performing the work if other than the approver, and the signature, certificate number, and kind of certificate of the person approving return to service. (Inspections carry their own content rule at §43.11, not §43.9.)
Retention
2 years from return-to-service approval (§145.219(c)) — the FAA floor
Audit Finding Prevented
Approving signature missing certificate number or kind of certificate; vague work description. Each deficient entry is a separate finding — and it undermines any contracted or off-site work built on it.
Off-site / away-from-station work record
14 CFR §145.203What's Required
Documentation that work performed at a place other than the fixed location met one of the two §145.203 pathways: a special circumstance determined by the FAA, or recurring work performed under procedures the station's manual includes. The record should show the off-site work followed those manual procedures and met the same §43.9 / §145.213 standards as bench work.
Retention
2 years from return-to-service approval; off-site manual procedures kept current
Audit Finding Prevented
Recurring field work with no off-site procedures in the manual, or off-site work that diverges from the procedures the manual does contain — a §145.203 finding regardless of work quality.
Air-carrier program conformity record (§145.205 work)
14 CFR §145.205(a)What's Required
When the station maintains a Part 121 or 135 operator's aircraft, evidence the work followed that air carrier's or commercial operator's continuous airworthiness maintenance program and the applicable sections of its maintenance manual — not just the station's own repair station manual. For Part 125 work, the operator's FAA-approved inspection program; for Part 129, the operator's FAA-approved maintenance program.
Retention
2 years (station side); the operator also keeps records under its own part (e.g., §135.439)
Audit Finding Prevented
Work performed to the station's generic procedures instead of the air carrier's program/manual, or no record tying the job to the operator's program. Findings can land on both the station and the operator.
Maintenance release + receiving/final inspection
14 CFR §145.219(b) + §145.211 + §145.213What's Required
A copy of the maintenance release provided to the owner or operator (§145.219(b)); receiving inspection of incoming material and preliminary/final inspection per the QC manual (§145.211); and inspection before return to service with airworthiness certified on the release (§145.213). At a US station, only an appropriately certificated Part 65 mechanic or repairman signs the final inspection and release (§145.213(d)).
Retention
2 years from return-to-service approval (§145.219(c))
Audit Finding Prevented
Released part with no receiving inspection record, a release the owner/operator never received a copy of, or a release signed by someone outside the Part 65 authority §145.213(d) requires.
Related: Part 145 & FAA Aviation Compliance
What an FSDO Inspector Checks on Contract & Off-Site Work
A surveillance review of contract maintenance and off-site work follows a predictable sequence. Here is the order the records get pulled — and how to pass each step cleanly.
Pull the §145.217 contracted-functions list
The inspector opens the list of maintenance functions contracted to outside sources and the certificate/ratings of each facility, required to be available under §145.217(a)(2). This is the map for the rest of the review — every contracted job in the records should trace back to a source on this list.
How to pass this step cleanly: Keep the list live, dated, and reconciled to the work the records actually show was contracted out. A list that names a vendor you no longer use, or omits one you do, is the first crack an inspector widens.
Match contracted work to the list and the rating
For a sample of contracted jobs, the inspector confirms the outside source was on the list and that its certificate and ratings (for a certificated source) covered the work. A function performed by a source not on the list — or outside its ratings — is a §145.217(a) finding.
How to pass this step cleanly: Before sending a function out, confirm the source is on the list with ratings that fit. If it is a new source, the list and (where required) the FAA approval go first, not after the work.
Noncertificated source — find the verification record
Where a noncertificated source did the work, the inspector looks for the station's own record that it stayed directly in charge and verified the work by test and inspection before release, per §145.217(b). No verification record means the station released work it cannot show it controlled.
How to pass this step cleanly: Treat the verification of a noncertificated source as a station inspection that produces its own record. The release should not exist without it.
The §145.217(c) complete-product check
The inspector confirms the station did not provide only a return-to-service approval for a complete type-certificated product it did not maintain. If the release covers a whole aircraft, engine, or propeller, the records must show the station actually performed maintenance on it.
How to pass this step cleanly: Never sign an RTS for a complete product as a pure pass-through. If you did not perform maintenance on the product, you cannot approve it for return to service under §145.217(c).
Off-site work — procedures and authority
For work performed away from the fixed location, the inspector checks which §145.203 pathway it rested on — a special circumstance determined by the FAA, or recurring work under procedures in the manual — and, for line maintenance, the §145.205(d) authorization in OpSpecs. Recurring field work with no off-site procedures in the manual is a §145.203(b) finding.
How to pass this step cleanly: Get the off-site procedures into the manual before recurring field work starts, and make each off-site record state the authority it relied on. Do not let a line-maintenance job and a §145.203 field job blur together.
Program conformity for §145.205 work
For work done for a part 121/135 operator, the inspector confirms it followed the operator's continuous airworthiness maintenance program and manual, not just the station's procedures, per §145.205(a) — and that the record ties to the operator's program and manual revision.
How to pass this step cleanly: When you work an air carrier's aircraft, document to the operator's program and manual revision in effect. 'We followed our own procedures' is a finding when §145.205 required the operator's.
See how your contract-maintenance records score before an inspector does
FileFlo's FAA readiness score reviews your record documentation across the §145.217 and §145.219 areas an FSDO inspector checks — the contracted-functions list, noncertificated-source verification, off-site work records, release traceability, and retention — and surfaces the gaps before they become findings. Takes under 10 minutes.
Check Your FAA Readiness Score — FreeThe Through-Line: Move the Work, Keep the Responsibility
Every one of these four sections is built on the same principle. Internalize it and the records follow.
Trap 1: Treating a contractor's file as your file
When a function goes to an outside source, the station's obligation to document and stand behind the result does not transfer with it. The §145.217(a)(2) list, the §145.217(b) verification of a noncertificated source, and the §145.219 release and retention are all the station's records — not something to leave sitting in the contractor's drawer.
Trap 2: A release that outruns the work you can document
§145.217(c) and §145.201 together draw a hard edge: the station can only approve for return to service what it is rated for and what it actually maintained. A release for a complete type-certificated product the station did not work, or for an article outside its ratings, is a finding the records expose on their face — regardless of how the work was performed.
The practical answer: one indexed record set, keyed to the work
Rather than scatter contract and off-site records across vendor folders and field laptops, keep one indexed set: the contracted-functions list reconciled to the jobs, each noncertificated-source verification attached to its work order, each off-site record stating its §145.203 (or §145.205(d)) authority, and every release retained per the longest applicable clock from the return-to-service date. That is exactly the assembly an FSDO records review walks through.
How this connects to the rest of your Part 145 records
Contract and off-site work sit on top of the same Part 145 foundation as everything else: the manual at §145.207 and its contents at §145.209, the quality control system at §145.211, inspection and release at §145.213, and recordkeeping at §145.219. A weakness in any of them flows straight into your contracted and off-site work.
For the rest of the repair-station records picture, see our Part 145 recordkeeping requirements, the Part 145 audit binder inspectors ask for, the personnel roster & training records (§145.161/§145.163), the ratings & capability list records, and how parts paperwork ties into 8130-3 parts traceability and FAA Form 337 major repair & alteration records. The EASA dual-approval layer is covered in our FAA-EASA bilateral records guide.
Where a Document Intelligence Platform Fits in Contract & Off-Site Records
FileFlo is a compliance document intelligence platform — a read-only proof layer that sits alongside the maintenance stack and makes the records you already have audit-ready. It does not perform maintenance, hold your repair station certificate, sign maintenance releases, issue 8130-3 tags, or approve anything for return to service; those come from your certificated personnel under your certificate and operations specifications. It handles the document compliance layer those systems leave exposed.
For contract and off-site work specifically, FileFlo classifies inbound documents (work orders, maintenance releases, the §145.217 contracted-functions list and its supporting records, noncertificated-source verification records, off-site work records, receiving and final inspection records, certifying-staff rosters) against the right requirement, flags incomplete §43.9 elements before they become findings, tracks the §145.219(c) 2-year clock and any longer customer or air-carrier-program retention you configure, links releases to their work orders and verification records, and assembles an audit-ready binder organized the way an FSDO records review actually proceeds. What takes a quality manager a full day to assemble by hand before a surveillance visit takes under 60 seconds in FileFlo.
Classify contract & off-site documents
Upload any work order, maintenance release, contracted-functions list, verification record, or off-site work record — FileFlo classifies it against the right requirement and flags missing §43.9 elements before an inspector does.
Reconcile the contracted-functions list
Surface contracted jobs in the records that do not match a source on the §145.217(a)(2) list — and noncertificated-source work missing its verification record — before a surveillance review finds the gap.
Retention tracking on a per-article clock
Per-article retention clocks run from the return-to-service date: the §145.219(c) 2-year FAA floor plus any longer customer or §145.205 air-carrier-program policy you configure. Records nearing disposal surface in the 90/60/30-day queue.
Audit binder for an FSDO review
Generates a records packet organized the way a §145.219 review proceeds — the contracted-functions list, verifications, off-site records, release traceability, and retention — ready for a surveillance visit.
FileFlo does not perform maintenance, approve articles for return to service, hold your repair station certificate, or run your quality or safety program. It keeps the documents that prove those systems exist and are maintained — audit-ready, at the moment an FSDO inspector asks. It does not replace your accountable manager, quality manager, chief inspector, certificated personnel, or your FAA-accepted contracting procedures.
Pricing: Starter $89/month, Professional $299/month. 5-day free trial, no credit card required. Learn more at FileFlo for Part 145 Repair Stations.
Frequently Asked Questions
Can a Part 145 repair station contract out part of its maintenance work to an outside shop?
Yes, within strict conditions. 14 CFR §145.217 lets a certificated repair station contract a maintenance function to an outside source, but it draws a sharp line between certificated and noncertificated sources. Under §145.217(a), the function the station contracts out must be one the FAA has approved for that station to contract, and the station must maintain — and make available to the FAA — a record listing the functions contracted and the name, certificate type, and ratings (if any) of each outside facility. Under §145.217(b), if the outside source is noncertificated, the source must follow a quality control system equivalent to the station's, the station must remain directly in charge of that work, and the station must verify by test and inspection that the work was done satisfactorily and the article is airworthy before approving return to service. Contracting out the wrench-turning never contracts out the station's responsibility for the result.
What is the difference between §145.205 (work for an air carrier) and §145.217 (contract maintenance)?
They sit on opposite sides of the repair station. §145.205 governs the work the repair station performs for a Part 121, 125, or 135 certificate holder or a Part 129 foreign operator — when a station maintains a part 121 or 135 operator's aircraft, §145.205(a) requires it to follow that air carrier's or commercial operator's continuous airworthiness maintenance program and the applicable sections of its maintenance manual, not just its own repair station manual. §145.217 governs the work the repair station sends further out — when the station itself contracts a maintenance function to a third source. One is about whose program you follow when you are the contractor for an air carrier; the other is about staying responsible when you become the customer of yet another shop. A station doing line maintenance for an airline can hit both at once.
Can a Part 145 repair station perform work somewhere other than its fixed location?
Yes, under 14 CFR §145.203, but only on two pathways. The station may temporarily transport material, equipment, and personnel needed to perform maintenance, preventive maintenance, alterations, or specialized services at a place other than its fixed location either (a) when a special circumstance, as determined by the FAA, makes the work necessary, or (b) when it is necessary to perform such work on a recurring basis — and for the recurring case, the repair station's manual must include the procedures for accomplishing that work away from the fixed location. The recurring pathway is the one most shops build around: get the off-site procedures into the manual, follow them, and document the work to the same standard as bench work. Work away from the station does not lower the §43.9 or §145.219 records bar — it raises the documentation discipline because the work happened off the inspection floor.
What records prove a contracted maintenance function was handled correctly?
Several layers, and the station owns the top of the stack. §145.217(a)(2) requires the station to keep a record of the maintenance functions contracted to each outside source, naming the facility and its certificate and ratings. For a noncertificated source, §145.217(b)(3) requires the station to verify by test and inspection that the work was satisfactory and the article airworthy, which produces the station's own inspection record sitting on top of the contractor's work. The underlying maintenance entry still has to meet 14 CFR §43.9 content — a description of the work or reference to acceptable data, the completion date, the performer's name if different from the approver, and the approving signature with certificate number and kind of certificate. And the whole package falls under §145.219, which requires records in English demonstrating Part 43 compliance, a copy of the maintenance release to the owner or operator, and retention for at least 2 years from the date the article was approved for return to service.
Can a repair station just sign off and return to service a product another shop maintained under contract?
No. 14 CFR §145.217(c) is explicit: a certificated repair station may not provide only approval for return to service of a complete type-certificated product following contract maintenance, preventive maintenance, or alterations. In plain terms, the station cannot act as a pure paperwork pass-through that rubber-stamps a release for a whole aircraft, engine, or propeller that someone else maintained. The station has to have actually performed maintenance on the product to approve its return to service — it cannot sell its certificate as a signature for work it did not do and did not control. This is a frequent enforcement theme and a common audit finding when a shop's release does not match the work it can document performing.
Where does the list of contracted functions have to live, and who can see it?
Under §145.217(a)(2), the repair station must maintain a record containing the maintenance functions contracted to each outside facility and the name of each such facility together with the type of certificate and ratings, if any, that facility holds — and that record must be available to the FAA. The station's quality control manual, required by §145.211, also has to describe how the station qualifies and surveils any noncertificated persons who perform maintenance under §145.211(c). So the contracting controls show up in two related places: the live list of who is doing what for the station, and the QC manual procedures that govern how the station keeps those outside sources inside its quality system. An auditor will ask for both and check that the list on the wall matches the work the station's records show was actually contracted out.
Does the 2-year §145.219 retention clock cover contracted and off-site work too?
Yes. §145.219(c) requires the station to retain the records required by that section for at least 2 years from the date the article was approved for return to service, and that applies to records of contracted functions and work performed away from the fixed location just as it applies to bench work. The clock starts on the return-to-service approval date — the date of the approving signature — which can fall later than the date the work was physically done, so purging by work date alone risks discarding records still inside the window. Two years is the FAA floor; customer contracts, an air carrier's program under §145.205, export paperwork, or bilateral work commonly demand longer, so most shops set one retention policy keyed to the longest applicable requirement and run it per article from the return-to-service date.
Does FileFlo perform maintenance, hold the repair station certificate, or approve return to service?
No. FileFlo is a compliance document intelligence platform — a read-only proof layer. It does not perform maintenance, hold your repair station certificate, sign maintenance releases, issue 8130-3 tags, or approve anything for return to service; those come from your certificated personnel under your certificate and operations specifications. What FileFlo does is classify the documents you already generate — work orders, maintenance releases, the §145.217 contracted-functions list, receiving and final inspection records, off-site work records, certifying-staff rosters — against the right requirement, flag incomplete §43.9 elements before they become findings, track the §145.219 2-year clock and any longer retention you configure, and assemble an audit-ready binder the way an FSDO records review actually proceeds. It is the documentation layer, not the maintenance or certification authority.
Chad Griffith
Founder, FileFlo — compliance document intelligence
FileFlo helps aviation operators and repair stations keep their compliance documents classified, indexed, and audit-ready. This article is a compliance-document perspective on Part 145 contract maintenance and off-site work — it is not legal, airworthiness, or A&P/IA certification advice, and it is not a substitute for your accountable manager, quality manager, chief inspector, certificated personnel, or an aviation attorney on any specific scenario. Regulatory requirements are stated from 14 CFR; FAA Orders, OpSpecs, and form numbers are described as agency guidance.
More Aviation Compliance Resources
Part 145 Recordkeeping Requirements (§145.219)
Work orders · release traceability · 2-year retention
Part 145 Audit Binder — What Inspectors Ask For
FSDO surveillance · the records review sequence
Part 135 Contract Maintenance Records
The operator side · §135.413 airworthiness responsibility
Repair Station Quality Control Manual (RSQCM)
§145.211 · QC procedures · noncertificated-source surveillance
Part 145 Ratings & Capability List Records
What the station is rated to do · self-evaluation
Part 145 Personnel Roster & Training Records
§145.161 roster · §145.163 training program
PMA Parts Traceability & 8130-3 Records
Approved data · release-tag correlation
FAA-EASA Bilateral & Dual Release Records
BASA/MAG · 8130-3 vs EASA Form 1
Know where your contract-maintenance records stand before the audit
FileFlo's FAA readiness score reviews your record documentation across the areas an FSDO inspector examines on contract and off-site work — the §145.217 contracted-functions list, noncertificated-source verification, off-site work records, §43.9 entries, release traceability, and §145.219 retention. Takes under 10 minutes. No credit card required.
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