Direct Answer — What §43.9(a) Requires
Every maintenance record entry made under 14 CFR §43.9(a) must contain these elements:
- 1Description of work performed — or a reference to data acceptable to the Administrator (e.g., an AMM task number, SB reference, or work order with full description). Must be specific enough to identify what was done.
- 2Date of completion — the date work was completed, which starts the §91.417(b) retention clock.
- 3Name of the person performing the work — required when the performer is different from the person approving the work for return to service.
- 4Signature of the person approving the work for return to service.
- 5Certificate number of the approving person — links the FAA Civil Aviation Registry to the entry and confirms the person held the appropriate authorization.
- 6Kind of certificate held by the approving person (e.g., "Mechanic," "Mechanic with Inspection Authorization," "Repairman").
Source: 14 CFR §43.9(a) — eCFR. Note: elements 4–6 all derive from §43.9(a)(4) and are often grouped; the regulatory text lists them together. Some practitioners count this as four elements (with element 4 being a compound "signature + certificate number + kind of certificate"); others count six. Either reading must produce the same six data points in the record.
Defective maintenance record entries are among the most common findings during FSDO records-side reviews and Part 145 Surveillance Visits. FAA civil penalties for recordkeeping violations under 49 U.S.C. § 46301 reach $75,000 per violation under 14 CFR §13.301. The good news: §43.9 violations are almost always administrative failures — a missing certificate number, an undated entry, an omitted approver name — that compliant documentation management prevents structurally.
This article covers exactly what each element means, what a correct entry looks like versus a defective one, how §43.9 interacts with §43.13 performance rules and §43.11 inspection records, and how long entries must be retained under §91.417(b) and the §91.411/ §91.413 inspection recurrence framework.
Each Required Element, Explained
What each §43.9(a) element means in practice, why it is required, and the exact mistake that produces a defective entry.
Description of Work Performed
§43.9(a)(1)A description of the work performed, or a reference to data acceptable to the Administrator (such as an AMM task number, SB reference, or work order number that itself contains the full description). The description must be specific enough that an inspector can determine what was done without additional investigation. Generic language like "inspected and found airworthy" without specifying what was inspected is non-compliant.
Most common mistake
"Performed maintenance" — no description of what system, component, or task was worked. Or "See work order #1234" when the work order is not attached to or retrievable with the record.
Date of Completion
§43.9(a)(2)The date the work was completed. This must be the completion date, not the date work was begun. In practice, the date establishes the start of the §91.417(b) retention clock for the entry and allows an inspector to verify whether the maintenance was performed before a subsequent flight. An entry dated after a flight that the work was supposed to have preceded creates an airworthiness chain gap.
Most common mistake
Using the work-start date instead of the completion date, or leaving the date field blank because the mechanic assumed the signature date was sufficient.
Name of Person Performing the Work
§43.9(a)(3)The name of the person performing the work — required only when the person doing the work is different from the person approving the work for return to service. When a single A&P performs the work and approves it (for non-annual work), the signature block in element 4 covers both. When a technician performs work and a supervisor or IA approves it, both the technician's name and the approving person's signature are required.
Most common mistake
Omitting the technician's name when the work was performed by a team member and approved by a different person (e.g., a line mechanic performed the task; the chief inspector signed it off). The entry then has no record of who actually did the work.
Signature of the Approving Person
§43.9(a)(4)The signature of the person approving the work for return to service. The signature must be an original (wet) or, for electronic records, a legally valid electronic signature. The approving person must hold certificate authority appropriate to the category and class of work being approved. An A&P can approve most airframe and powerplant work; an IA is required to approve annual inspections and certain major repairs and alterations.
Most common mistake
Printed name instead of signature. Initialing instead of signing. Stamping without a signature. Or a signature that is illegible with no printed name, making certificate verification impossible.
Certificate Number
§43.9(a)(4)The FAA airman certificate number of the person approving the work. The certificate number allows the FAA to cross-reference the FAA Civil Aviation Registry and verify that the approving person held the appropriate certificate and rating at the time of maintenance. The certificate number is distinct from the approving person's name — both are required under §43.9(a)(4). This is the element most commonly omitted in practice.
Most common mistake
Omitting the certificate number entirely, or writing only the last four digits. Some mechanics write their name and sign but do not include their A&P certificate number because they assume the signature is sufficient. It is not — the certificate number is a separately required element.
Kind of Certificate
§43.9(a)(4)The kind of certificate held by the approving person. Common values: "A&P Mechanic" or "Mechanic" (holding Airframe and/or Powerplant rating under 14 CFR Part 65); "IA" or "Mechanic with Inspection Authorization" (required for annual inspections and certain major repairs and alterations); "Repairman" (within a Part 145 repair station). The kind of certificate tells the reviewer what authorization the approving person held — and allows the inspector to verify that the kind of certificate was appropriate for the category of work performed.
Most common mistake
Omitting the kind of certificate entirely because it seems duplicative of the certificate number. Best practice is writing "Mechanic — Airframe and Powerplant" in full; the shorthand "A&P" by definition denotes a Mechanic certificate with both ratings.
Why the §43.9(a)(4) cluster is three separate requirements
The regulatory text in §43.9(a)(4) states "the signature, certificate number, and kind of certificate held by the person approving the work." All three are independently required. A common misconception is that a legible signature is sufficient because the FAA can look up the certificate. That is not the standard — the certificate number and kind of certificate must appear in the record itself, not require an external lookup to reconstruct. An FSDO inspector is not required to query the civil aviation registry to complete what is missing from the entry.
Correct vs Defective Entry — Side-by-Side
The same maintenance event (left magneto replacement) rendered as a compliant entry and as a defective entry with four common violations.
Compliant Entry
[Date] June 4, 2026
[Work Description] Removed and replaced left magneto per AMM Chapter 74-10-01 Rev. 12. Performed P-lead continuity check. Timed magneto to engine per manufacturer specifications. Engine run-up performed and magneto drop within limits. Aircraft approved for return to service.
[Performed by] James Torres (technician)
[Approved by — signature] R. Williams
[Certificate No.] 2345678
[Kind of Certificate] Mechanic — Airframe & Powerplant
- Description: specific task, AMM reference, run-up result
- Date: completion date present
- Performer: technician named (different from approver)
- Signature: original signature present
- Certificate number: 2345678
- Kind of certificate: A&P Mechanic specified
Defective Entry — 4 Violations
[Date] (blank)
[Work Description] Replaced left magneto. Approved for return to service.
[Performed by] (omitted — different technician did the work)
[Approved by — signature] R. Williams
[Certificate No.] (omitted)
[Kind of Certificate] A&P
- Description: generic — no AMM reference, no verification steps
- Date: missing — §91.417 retention clock cannot start
- Performer: omitted — technician who did work unidentifiable
- Signature: present
- Certificate number: missing — inspector cannot verify authorization
- Kind of certificate: "A&P" present (best practice: write "Mechanic — Airframe and Powerplant" in full)
A defective entry is not the same as no entry — it is harder to defend
An FSDO inspector who finds a defective entry knows work was performed and that the record is incomplete. That is worse than missing documentation in some enforcement contexts because it demonstrates the operator knew about the maintenance event and failed to properly document it. The three most common deficiencies — missing date, missing certificate number, and missing performer name — are each independently citable violations under §43.9.
§43.9 vs §43.11 — Which Rule Applies to Annual Inspections?
14 CFR §43.9 is the general maintenance record rule for maintenance, preventive maintenance, rebuilding, and alteration work on US-registered civil aircraft — but the rule carries two express carve-outs. Under §43.9(b), air carriers required by their operations specifications to use a continuous airworthiness maintenance program (Part 121, and Part 135 CAMP operators) make their records under Part 121/135 rather than §43.9(a). And under §43.9(c), inspections performed in accordance with part 91, part 125, §135.411(a)(1), or §135.419 are excluded from §43.9 entirely. 14 CFR §43.11 is the inspection record rule — it applies specifically to annual inspections, 100-hour inspections, progressive inspections, and other inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419.
Annual, 100-hour, and progressive inspection entries are governed by §43.11 alone — not §43.9. §43.11 is self-contained: alongside the items below, it carries its own date, signature, certificate number, and kind-of-certificate requirements. §43.9 governs the separate entries documenting repairs made to correct discrepancies found during an inspection. A §43.11 inspection record requires:
§43.11(a)(1) — Type of Inspection + Extent
The entry must state the type of inspection (e.g., "Annual Inspection") and a brief description of the extent of the inspection. This goes beyond the §43.9 work description — it establishes which inspection program under §91.409 was performed.
§43.11(a)(2) — Aircraft Total Time in Service
The entry must include the total time in service of the aircraft at the time of the inspection. This element feeds the §91.417(a)(2) life-of-aircraft records. It is not required in a §43.9-only entry for routine maintenance, but it is required in every annual or 100-hour inspection entry.
§43.11(a)(4)–(5) and (b) — Return-to-Service Language or Discrepancy List
If the aircraft is approved for return to service, the entry must contain the verbatim language: "I certify that this aircraft has been inspected in accordance with [insert type] inspection and was determined to be in airworthy condition." If the aircraft is disapproved, the IA must provide a signed and dated list of discrepancies and unairworthy items to the aircraft owner or lessee. The absence of this verbatim language in an annual inspection entry is one of the most frequently cited §43.11 deficiencies.
The rule that applies to each scenario:
| Maintenance Event | §43.9 | §43.11 |
|---|---|---|
| Routine repair (e.g., magneto replacement) | ✅ Required | ❌ Not applicable |
| Airworthiness Directive compliance | ✅ Required | ❌ Not applicable |
| Component replacement / overhaul | ✅ Required | ❌ Not applicable |
| Annual inspection | ❌ Excluded by §43.9(c) | ✅ Required |
| 100-hour inspection | ❌ Excluded by §43.9(c) | ✅ Required |
| Progressive inspection cycle | ❌ Excluded by §43.9(c) | ✅ Required |
Repairs made to correct discrepancies found during an annual, 100-hour, or progressive inspection are documented in separate §43.9 maintenance entries.
How Long Must §43.9 Maintenance Records Be Retained?
Retention is governed by 14 CFR §91.417(b), not §43.9 itself. The §43.9 rule establishes what goes in the entry; §91.417 establishes how long the entry must be kept. The two retention tiers are:
§91.417(a)(1) Records
Retention: 1 year after the work is performed, or until superseded
Covers routine maintenance, alterations, and most repair entries under §43.9. The clock starts at the date of completion in the entry. Once superseded by work on the same component, the older entry may be discarded — but many operators retain them longer for chain-of-custody continuity and resale value.
§91.417(a)(2) Records
Retention: Life of aircraft + transfer on sale
Covers total time in service, current status of life-limited parts, time since overhaul, current AD status, and copies of the FAA Form 337 prescribed by §43.9(d) for each major alteration. These records must be retained for the life of the aircraft and transferred to the buyer when the aircraft is sold. They cannot be discarded.
Part 145 Repair Station Retention (§145.219)
For work performed by a Part 145 certificated repair station, 14 CFR §145.219(c) requires retention of maintenance records for at least 2 years after the article is approved for return to service. The repair station must make these records available to the FAA and the NTSB; under §145.219(b), the owner or operator of the article is entitled to a copy of the maintenance release. The §145.219 retention obligation runs from the return-to-service date; the §91.417 obligation runs against the aircraft owner from the same entry. Both clocks run simultaneously against the same record — the repair station must retain for 2 years, and the aircraft owner must retain per §91.417.
For A&P mechanics and IAs operating under 14 CFR Part 65, the maintenance record they make under §43.9 becomes the aircraft owner's record under §91.417 at the moment it is entered in the aircraft logbook. The mechanic's obligation ends at making a complete, compliant entry; the operator's retention obligation begins. This is why a defective entry — one missing a certificate number or date — is both a §43.9 violation (the mechanic's responsibility) and a §91.417 records problem (the operator's exposure on inspection).
Related §43 and §91 compliance resources
- Part 145 Repair Station Compliance — certificate-side document requirements
- Part 91 General Aviation Operations — §91.417 maintenance records + §91.409 inspection programs
- Part 135 On-Demand Charter — §135.443 airworthiness release + maintenance record requirements
- 14 CFR §91.409 — Inspection Programs (annual, 100-hour, progressive)
- 14 CFR §91.411 — Altimeter / Pitot-Static 24-month Recurrence
- 14 CFR §91.413 — ATC Transponder 24-month Recurrence
- 14 CFR §43.13 — Performance Rules: General (standard of work)
- Airworthiness Directive Compliance — §43.9 entries for AD-mandated work
Know how your records stack up before an FSDO inspector does
FileFlo classifies aviation maintenance documents against the governing CFR — including §43.9 entry completeness, §91.417 retention clocks, and §145.219 repair station requirements — and generates an inspector-format audit binder on demand. See the full Aviation compliance coverage.
Who §43.9 Applies To — and Where the Compliance Risk Concentrates
14 CFR §43.9 applies to those authorized to perform maintenance under §43.3: A&P mechanics working independently, IAs, and Part 145 repair stations — while Part 121 and Part 135 air carriers operating under a continuous airworthiness maintenance program record their maintenance under Part 121/135 instead, per §43.9(b). The compliance risk concentrates differently across these groups.
A&P Mechanics and IAs
The highest risk of a defective entry occurs at the field-level logbook entry: certificate numbers are left blank, dates are omitted when work spans multiple sessions, and the distinction between §43.9 (routine work) and §43.11 (annual/100-hour) content requirements is confused. For an IA signing off an annual, the inspection entry is governed by §43.11 alone — §43.9(c) expressly excludes these inspections — and §43.11 itself requires the date, signature, certificate number, kind of certificate, aircraft total time, inspection type/extent, and verbatim return-to-service language. Repairs correcting discrepancies found during the annual are documented in separate §43.9 entries.
Part 145 Repair Stations
Repair stations produce high volumes of §43.9 entries across multiple work orders, technicians, and aircraft. The compliance risk concentrates on the §145.219 recordkeeping obligation (records in English demonstrating compliance with Part 43 in a format acceptable to the FAA, a copy of the maintenance release provided to the owner or operator, 2-year retention, and availability to the FAA and NTSB) and on ensuring that every entry has the performer and approver distinguished when work is performed by one technician and approved by another. Systemically defective entries — for example, missing certificate numbers across dozens of work orders — produce a systemic §145.219 + §43.9 finding during a Surveillance Visit.
Part 135 and Part 121 Operators
Air carriers required by their operations specifications to use a continuous airworthiness maintenance program (Part 121, and Part 135 CAMP operators) make maintenance record entries under Part 121/135 rather than §43.9(a) — that is the express direction of §43.9(b). The interaction with SMS documentation obligations — particularly for maintenance-related safety reports that feed the §5.71 Safety Assurance system — means an incomplete §43.9 entry can also create a safety data gap that an FAA SMS audit surfaces. The §135.443 airworthiness release requirement cross-references back to the underlying §43.9 entries that established the aircraft was maintained correctly.
Frequently Asked Questions
What are the six required data points of a 14 CFR §43.9 maintenance record entry?
Per 14 CFR §43.9(a), a compliant maintenance record entry must contain: (1) a description (or reference to data acceptable to the Administrator) of work performed; (2) the date of completion of the work performed; (3) the name of the person performing the work if other than the person specified in paragraph (a)(4); and (4) the signature, certificate number, and kind of certificate held by the person approving the work for return to service. §43.9(a) has four numbered subparagraphs, and subparagraph (a)(4) packages three distinct data points — signature, certificate number, and kind of certificate — so the four subparagraphs yield six data points. A compliant entry must carry: description, date, name of person doing the work (required only when different from the approving person), signature of the approving person, certificate number of the approving person, and kind of certificate held by the approving person.
Does every A&P mechanic need to include their certificate number in a maintenance logbook entry?
Yes. Per 14 CFR §43.9(a)(4), the person approving the work for return to service must include their signature, certificate number, and kind of certificate in the entry. For an A&P mechanic, the kind of certificate is "Mechanic" (or "Mechanic with Inspection Authorization" for an IA signing off an annual). Omitting the certificate number — even if the signature and kind of certificate are present — produces a non-compliant entry. The certificate number links the FAA civil aviation registry record to the entry and is specifically what an FSDO inspector pulls to verify the person held the appropriate rating at the time of maintenance.
What is a "kind of certificate" in a §43.9 entry and what should it say?
The "kind of certificate" field in a §43.9(a)(4) entry describes the type of airman or repairman certificate that authorizes the person to approve the aircraft for return to service. Common values include: "Mechanic" (A&P mechanic holding an Airframe and/or Powerplant rating under 14 CFR Part 65, Subpart D); "Mechanic with Inspection Authorization" (IA — required for annual inspections and certain major repairs/alterations); "Repairman" (for work within a certificated repair station under 14 CFR Part 145); and for air carriers maintaining under 14 CFR Part 121 or §135.437, the certificate of the air carrier itself. Writing only a signature and certificate number without specifying the kind of certificate produces a defective entry. An FSDO inspector reviewing the record must be able to verify from the entry itself that the approving person held the authorization required for that specific category of work.
What is the difference between §43.9 and §43.11? Which applies to annual inspections?
Both sections govern maintenance records but for different contexts. 14 CFR §43.9 applies to maintenance, preventive maintenance, rebuilding, and alteration work — but its title and paragraph (c) expressly exclude inspections performed in accordance with part 91, part 125, §135.411(a)(1), and §135.419. Those inspections are governed by 14 CFR §43.11, which applies specifically to inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 — meaning annual inspections, 100-hour inspections, progressive inspections, and similar. A §43.11 inspection record requires: the type of inspection and brief description of its extent; the date of the inspection and the total time in service of the aircraft; the signature, certificate number, and kind of certificate held by the person approving or disapproving the aircraft; and the required return-to-service language verbatim ("I certify that this aircraft has been inspected in accordance with [type] inspection and was determined to be in airworthy condition"), or in the case of disapproval, a signed and dated list of discrepancies and unairworthy items. Annual, 100-hour, and progressive inspection entries are governed by §43.11 alone — §43.11 is self-contained, and §43.9 governs the separate entries documenting repairs made to correct discrepancies found during the inspection. Routine airworthiness directive compliance entries and component replacement entries must satisfy §43.9 only.
Who is authorized to make a §43.9 maintenance record entry?
Per 14 CFR §43.3, persons authorized to perform maintenance include: certificated mechanics with Airframe and/or Powerplant ratings (14 CFR Part 65, Subpart D); certificated repairmen at Part 145 repair stations; certificated air carriers and air agencies; certificated pilots performing preventive maintenance on aircraft they own or operate and which are not used under Part 121, 129, or 135; and certain Canadian persons — aviation maintenance engineers and approved maintenance organizations — authorized under §43.17 (cross-referenced in §43.3(a)) to perform work on US-registered aeronautical products. The person who performs the work and the person who approves the work for return to service may be different — that is why §43.9(a)(3) requires the name of the person performing the work "if other than the person specified in paragraph (a)(4)." Only the person approving the work for return to service needs to hold the appropriate certificate authority for that approval.
How long must §43.9 maintenance records be retained under §91.417?
Retention is governed by 14 CFR §91.417(b), not §43.9 itself. Records made under §43.9 fall into two retention categories. §91.417(a)(1) records — covering maintenance, alterations, and the required inspection entries that are not in the (a)(2) category — must be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. §91.417(a)(2) records — including total time in service of the airframe, engine, and propeller; current status of life-limited parts; time since last overhaul of time-limited items; current status of applicable ADs; and copies of the FAA Form 337 prescribed by §43.9(d) for each major alteration — must be retained for the life of the aircraft and transferred to the buyer when the aircraft is sold. For Part 145 repair stations, retention obligations under 14 CFR §145.219(c) require records of maintenance performed to be retained for at least 2 years after the article is approved for return to service.
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