Direct Answer: Who Owns Which Pilot Records?
Three separate record systems coexist, and none substitutes for another. The pilot personally owns the logbook: under 14 CFR §61.51(a), a pilot is required to document only the training and aeronautical experience used to meet the requirements for a certificate, rating, or flight review, plus the experience needed for recent-flight-experience (currency) requirements — logging anything more is voluntary. The certificate holder owns the individual pilot record: under §135.63(a)(4), the operator must keep ten defined items per pilot at its principal business office, available to the Administrator, for at least 12 months. And the FAA owns the Pilot Records Database: under Part 111, operators report defined hiring-relevant categories in, hiring operators evaluate them before a pilot begins service (§111.105), and pilots hold review and correction rights (§§111.315, 111.320).
The boundary most people miss: under §111.225, the PRD expressly excludes flight time, duty time, rest time, and recent-flight-experience documentation — so currency proof never lives in the PRD. It lives in the pilot's logbook and the operator's §135.63(a)(4) file.
The dangerous assumption: that one system covers the others
Operators get caught in the gaps between systems, not inside any one of them. A DOM who assumes the pilot's logbook satisfies the company's §135.63(a)(4) duty has no answer when an inspector asks for the operator's file. A pilot who assumes the company tracks their currency discovers at checkride time that §61.51(a) sits on the individual. And a hiring manager who assumes the PRD shows total time is reading a database that, by rule, excludes it. Map who owns what — then make each owner's system independently complete.
The Three Systems at a Glance
Before the detail, the map. Three record systems, three owners, three sets of access rules. Each row is a legally independent obligation — completing one does nothing for the other two.
| Record System | Governing Rule | Who Creates & Keeps It | Core Contents | Who Can Demand It | Minimum Retention |
|---|---|---|---|---|---|
| Pilot's personal logbook | 14 CFR §61.51 | The pilot, personally — in a manner acceptable to the Administrator | Training and aeronautical experience used for a certificate, rating, or flight review, plus recent-flight-experience (currency) evidence; per-entry items under §61.51(b) | Presented on reasonable request to the Administrator, an authorized NTSB representative, or any Federal, State, or local law enforcement officer (§61.51(i)(1)) | No fixed period stated in the rule — the entries must exist whenever the pilot needs to prove the requirement they document |
| Operator's individual pilot record | 14 CFR §135.63(a)(4) | The certificate holder — at its principal business office or other places approved by the Administrator | Ten required items: name, certificates and ratings, aeronautical experience, duties and assignment date, medical class and date, check results, flight time, check pilot authorization, disqualification actions, training-phase completion dates | Available for inspection by the Administrator (§135.63(a)) | At least 12 months (§135.63(b)) — a floor most operators exceed in practice |
| FAA Pilot Records Database (PRD) | 14 CFR Part 111 | The FAA — operators report defined categories in; hiring operators review out | Drug & alcohol testing records, training/qualification/proficiency records with evaluator comments, final disciplinary actions, final separations, MVR-search verification (§§111.220–111.240) — flight time, duty time, rest time, and currency documentation are excluded | Reviewing entities with the pilot's written consent (§111.310); the pilot, for their own complete file (§111.315) | Held in the FAA system; operator reporting clocks run 30 days per record category and 45 days for the MVR verification |
Sourced from 14 CFR §61.51, §135.63, and Part 111 as published on the Cornell Legal Information Institute (law.cornell.edu). Verify against the current CFR before relying on this table for compliance determinations — and consult your DOM or aviation counsel for certificate-specific interpretation.
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Run the Free CheckSystem 1: The Pilot's Personal Logbook (14 CFR §61.51)
Start with the system everyone thinks they understand. §61.51 is titled Pilot logbooks, and its first surprise is how little it actually requires. Under §61.51(a), each person must document and record — in a manner acceptable to the Administrator — exactly two categories of time: the training and aeronautical experience used to meet the requirements for a certificate, rating, or flight review, and the aeronautical experience required for meeting the recent flight experience requirements of this part. That is the whole mandatory scope. A pilot who flies a leg that is not being used toward a certificate, rating, flight review, or currency requirement has no §61.51 duty to log it at all.
In practice, of course, professional pilots log nearly everything — total time drives hiring minimums, insurance approvals, and upgrade eligibility. But the distinction matters for the ownership question: the logbook is the pilot's evidentiary asset, built to prove what the pilot needs to prove. It is not built for the operator's compliance file, and the regulation never asks the operator to maintain it.
What each logged entry must contain (§61.51(b))
For time that is logged to meet §61.51(a), each entry needs three layers:
- General: date, total flight time or lesson time, departure and arrival location (or where the lesson occurred in a simulator), and the type and identification of the aircraft or training device
- Type of experience or training: solo, pilot in command, second in command, flight and ground training from an authorized instructor, or device training from an authorized instructor
- Conditions of flight: day or night, actual instrument, simulated instrument, and night-vision-goggle operations
Logging rules are their own legal universe (§61.51(e)–(h))
§61.51(e) governs what may be logged as pilot-in-command time — which is a different question from who is acting as PIC of the operation. Under (e)(1), a sport, recreational, private, commercial, or ATP pilot may log PIC time as the sole manipulator of the controls of an aircraft for which the pilot is rated, or as sole occupant; the third prong — logging PIC while acting as PIC of an aircraft on which more than one pilot is required — is available under (e)(1)(iii) except to sport and recreational pilot certificate holders. (e)(2) lets an ATP log all flight time while acting as PIC in operations requiring an ATP certificate, and (e)(5) covers approved second-in-command professional development programs under §135.99(c).
Instrument time has its own gate — only time operating the aircraft solely by reference to instruments under actual or simulated conditions (§61.51(g)(1)), with the location and type of each instrument approach recorded for currency (§61.51(g)(3)). Training time received must carry the authorized instructor's legible endorsement, including a description of the training, the lesson length, and the instructor's signature and certificate number (§61.51(h)(2)).
Who can demand the logbook (§61.51(i))
The logbook is personal property, but it is not private from the government. Under §61.51(i)(1), the pilot must present it for inspection upon a reasonable request by the Administrator, an authorized representative of the NTSB, or any Federal, State, or local law enforcement officer. Carriage rules then scale with certificate level: student pilots carry the logbook on solo cross-country flights ((i)(2)), sport pilots carry logbook evidence of required endorsements on all flights ((i)(3)), and recreational pilots carry it on solo flights that trigger any of the four independent (i)(4) conditions — beyond 50 NM from the training airport, in airspace requiring ATC communication, between sunset and sunrise, or in an aircraft for which they lack the category/class rating.
Notice who is missing from that list: the employer. Part 61 gives the operator no right to the pilot's personal logbook — which is exactly why Part 135 builds the operator its own record system instead of borrowing the pilot's.
One more structural point: §61.51 attaches no retention period. The practical rule is that entries must still exist whenever the pilot needs to prove the certificate, rating, or recency they document — which makes the logbook effectively a career-length record, in contrast to the operator's 12-month floor below.
System 2: The Operator's Individual Pilot Record (14 CFR §135.63(a)(4))
The second system belongs to the certificate holder, full stop. Under §135.63(a), each certificate holder shall keep at its principal business office or at other places approved by the Administrator — and shall make available for inspection by the Administrator — its operating certificate, its operations specifications, a current list of its aircraft, and, under (a)(4), an individual record of each pilot used in operations under this part. The duty runs to the operator. A pilot's beautifully maintained personal logbook is legally irrelevant to it.
The ten required items in each pilot's record, per §135.63(a)(4)(i)–(x):
Retention: 12 months is the floor, not the practice
§135.63(b) sets the minimums: the aircraft listing under (a)(3) must be kept for at least 6 months, and the records under (a)(4) — and the flight attendant records under (a)(5) — for at least 12 months. But treat 12 months as a regulatory floor. Part 111 separation reporting reaches into this file when a pilot leaves, future employers evaluate history through the PRD, and enforcement or insurance questions routinely look back further than a year. Most operators retain pilot records far longer — deliberately.
Two items deserve special attention because they connect to the other two systems. Item (vi) — the date and result of each competency test and proficiency and route check, with the aircraft type — is the same checking history that feeds PRD training-record reporting under §111.225, evaluator comments included. And item (vii) — flight time in sufficient detail to determine compliance with the flight time limitations of Part 135 — means the operator maintains its own flight-time ledger for limitation purposes, independent of whatever the pilot logs personally under §61.51. Two flight-time records, two different legal jobs.
This file is also among the first things a Principal Operations Inspector pulls in a surveillance audit — alongside your operational control documentation and training program records. For the broader records landscape beyond pilot files, see what records a Part 135 operator must keep.
System 3: The FAA's Pilot Records Database (14 CFR Part 111)
The third system is the only one neither the pilot nor the operator owns. The Pilot Records Database is the FAA's — operators report defined categories of records into it, hiring operators evaluate a pilot's consolidated history out of it, and the pilot holds standing rights inside it. Under §111.1, Part 111 reaches Part 119 certificate holders operating under Parts 121, 125, or 135, fractional ownership program managers under Part 91 Subpart K, §91.147 air-tour operators, certain Part 91 business operators of two or more covered aircraft, qualifying public aircraft operators, their bankruptcy trustees — and every pilot employed by or seeking employment with any of them.
What goes in (§111.205)
Each reporting entity reports, per pilot from the PRD date of hire: all records described in §§111.220 through 111.240 generated on or after June 10, 2022, plus the PRD date of hire itself. The categories: drug and alcohol testing records within 30 days (§111.220); training, qualification, and proficiency records within 30 days of creating the record (§111.225); final disciplinary actions; final separations within 30 days of becoming final (§111.235); and verification of the motor-vehicle-record search within 45 days of the PRD date of hire (§111.240).
What comes out (§111.105)
Before permitting an individual to begin service as a pilot, a reviewing entity must evaluate all relevant information in the PRD — FAA records, records submitted by reporting entities, motor vehicle driving records obtained under §111.110, and the employment history the pilot provides — subject to a narrow exception in §111.115. If records from a previous employer appear to be missing, the reviewing entity must request them through the database.
The pilot's rights (Subpart D)
Part 111 Subpart D makes the PRD permissioned and transparent to its subject. Access by a hiring operator runs through the pilot's written consent (§111.310). The pilot may access the PRD to review all records pertaining to that pilot — or request review via an Administrator-provided identity form without electronic access (§111.315) — and may report errors and request corrections (§111.320).
What the PRD deliberately does NOT hold
§111.225 excludes flight time, duty time, rest time, protected medical records, and the documentation of recent flight experience from training-record reporting — and §111.240 prohibits reporting any substantive information from a pilot's state motor vehicle driving record (you verify the search happened; you do not upload what it found). The PRD is a hiring-history and safety-signal system, not a flight-time ledger and not a currency tracker. Anyone who tells you the PRD covers logbook or flight-time questions has the boundary wrong.
The PRD is its own deep topic — reporting clocks, the on-request alternative for smaller operators, historical PRIA-era records — covered in our dedicated guide to Part 111 PRD reporting and review requirements. The drug-and-alcohol records that feed §111.220 have their own program and DOT retention rules under 49 CFR Part 40, mapped in the Part 135 drug and alcohol records checklist.
Who Owns What: The Four Boundary Failures
Each system is reasonably well understood on its own. The failures happen at the boundaries — when someone assumes a record they can see in one system discharges a duty that lives in another. Four patterns account for most of the damage.
Failure 1: "It's in the pilot's logbook"
An inspector asks for the operator's individual pilot record, and the answer is that the pilot keeps all that in their personal logbook. That answer fails on every element: §135.63(a) places the duty on the certificate holder, locates the record at the principal business office or Administrator-approved places, and makes it available to the Administrator on the operator's side. The pilot's logbook is the pilot's property, organized for the pilot's purposes, and — critically — it leaves with the pilot. An operator whose checking history, medical dates, and flight-time detail live only in employees' personal logbooks does not have a §135.63(a)(4) record system at all.
Failure 2: "The company tracks my currency"
The mirror image. A pilot assumes the operator's scheduling or training department is maintaining their personal currency evidence. But §61.51(a) puts the documentation duty on each person individually — including the recent-flight-experience record, with the location and type of each instrument approach when instrument currency is in play (§61.51(g)(3)). The operator's (a)(4)(vii) flight-time record exists to prove compliance with Part 135 flight-time limitations; it is not maintained in the §61.51(b) entry format and it is not the pilot's to present. Two ledgers, two owners, two purposes — a pilot who conflates them finds out at the worst possible moment.
Failure 3: "The PRD has everything"
A hiring manager treats the PRD pull as the complete picture of a candidate. It is not designed to be. The PRD holds the §§111.220–111.240 categories — testing, training and checking outcomes with evaluator comments, final discipline, final separations, MVR verification — and excludes flight time, duty and rest time, and currency documentation by rule (§111.225). Total-time claims still get verified against the pilot's logbook; currency still gets established under §61.51; and your own §135.63(a)(4) file still gets built from scratch on day one of employment. The PRD evaluation under §111.105 is a mandatory pre-service gate — but it is the start of your records obligations for that pilot, not the end.
Failure 4: Departure day — when all three systems move at once
A pilot resigns. The logbook walks out the door with them — as it should; it is theirs. What must not walk out is the operator's file: the §135.63(a)(4) record stays with the certificate holder for at least 12 months under §135.63(b), including any (a)(4)(ix) action concerning release from employment for physical or professional disqualification. And a new clock starts: under §111.235, the records concerning the final separation — kept pursuant to §135.63(a)(4) — must be reported to the PRD no later than 30 days after the separation becomes final, where the pilot can review them (§111.315) and dispute errors (§111.320), and where an overturned separation may not be reported at all. Off-boarding is a three-system event; most operators only have a checklist for one.
The operator side of this map is buildable in an afternoon. FileFlo classifies your pilot files against the §135.63(a)(4) items and turns check dates into tracked deadlines.
One Flight, Three Records: How a Single Event Fans Out
The cleanest way to internalize the boundaries is to follow real events through all three systems. Here is how three common moments in a Part 135 pilot's life fan out.
A routine revenue leg
- Pilot logbook: no §61.51 entry is required unless the pilot is using the leg toward a certificate, rating, flight review, or currency requirement — for example, counting an instrument approach toward recency, which then requires the location and type of the approach under §61.51(g)(3). Most professionals log it anyway, voluntarily.
- Operator record: the flight time lands in the §135.63(a)(4)(vii) record — in sufficient detail to determine compliance with the flight time limitations of Part 135. This entry is mandatory for the operator regardless of what the pilot logs personally.
- PRD: nothing. Flight time is excluded from Part 111 training-record reporting under §111.225. A routine leg generates zero PRD obligations.
A recurrent check event
- Operator record: the date and result of the check and the type of aircraft flown go into §135.63(a)(4)(vi); completion of a recurrent training phase is dated under (a)(4)(x).
- PRD: the same event becomes a §111.225 training/qualification/proficiency report due within 30 days of creating the record — including the comments and evaluations made by the check pilot or evaluator, and, for an unsatisfactory event, the tasks or maneuvers considered unsatisfactory. The check airman's own authorization paperwork is a separate operator-side record — see check airman and instructor records.
- Pilot logbook: if the pilot uses the event toward a §61.51(a) requirement, it gets logged with the §61.51(b) entry elements — and any training time received needs the instructor's endorsement with a description of the training and the lesson length under §61.51(h)(2).
A separation from employment
- Pilot logbook: leaves with the pilot — the only one of the three systems the pilot physically controls, and the continuity record across every employer in a career.
- Operator record: stays. §135.63(b) requires the (a)(4) record be kept at least 12 months — and prudent operators keep it much longer, because it is the source file for anything the FAA or a future employer asks about later.
- PRD: a 30-day reporting clock starts when the separation becomes final (§111.235). The next operator will evaluate this report before the pilot begins service (§111.105) — and the pilot can read and dispute it (§§111.315, 111.320).
Notice the asymmetry of consequence. The pilot's logbook failures hurt the pilot. But the operator's failures — a missing (a)(4)(vi) check entry, an unreported separation, flight-time detail that cannot demonstrate limitation compliance — surface during certificate surveillance and in the PRD where every future employer of your pilots can see your reporting discipline. The operator-owned systems are where a maturing compliance posture ahead of the 2027 SMS deadline gets demonstrated — or undermined.
Would your operator-side records survive a POI visit?
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Run the FAA Readiness Score — FreeHow FileFlo Helps — on the Operator's Side of the Map
Let's be precise about where a document platform belongs in this picture. FileFlo is the compliance document and proof layer for the operator-owned systems. It is not the pilot's logbook, it does not submit anything to the FAA's Pilot Records Database, and it does not run your training program, your scheduling, or your operation. What it does is make the records the certificate holder owns — the §135.63(a)(4) file and the source documents behind every PRD report — classified, indexed, deadline-tracked, and provable.
Classifies pilot documents against the ten §135.63(a)(4) items
Upload certificates, medical documentation, check forms, training-phase completions, and duty-assignment records — FileFlo classifies each into the right pilot file and the right requirement, so the question "show me this pilot's record" has a one-click answer instead of a folder hunt.
Turns check dates and reporting windows into tracked deadlines
A recurrent check result is also the start of a 30-day PRD reporting clock under §111.225; a separation starts the §111.235 clock. FileFlo tracks these as expiration events with advance alerts — before the deadline, not after — alongside medical dates and training-phase due dates.
Shows the gaps before an inspector does
Per-pilot completeness is visible at a glance: which of the ten record items have current documents behind them, which check entries are missing an aircraft type, which files are coasting past the 12-month retention floor without a policy decision. Gap visibility is the difference between a records program and a records pile.
Proof layer — not the logbook, not the PRD, not your DOM
FileFlo keeps the evidence that the operator-owned records existed, were current, and met their deadlines. The pilot still keeps the personal logbook under §61.51; your authorized personnel still perform the PRD reporting and review actions in the FAA system; your DOM and counsel still make the judgment calls. FileFlo keeps the documentation defensible.
Aviation Compliance: Related Guides
What Pilot Records Does the FAA Require for Part 135?
The §135.63(a)(4) Deep DivePilot Records Database (PRD): What Part 111 Requires
PRD Reporting & ReviewWhat Records Must a Part 135 Operator Keep?
Records OverviewPart 135 Training Program Recordkeeping Requirements
Training RecordsPart 135 Drug & Alcohol Program Records Checklist
Part 120 / 49 CFR 40How to Prepare for a Part 135 FAA Surveillance Audit
Audit ReadinessPart 135 Check Airman & Flight Instructor Records
Checking InfrastructureWhat Is Operational Control in Part 135?
Core ConceptFrequently Asked Questions
Does a Part 135 pilot have to log every flight in a personal logbook?
No. Under 14 CFR §61.51(a), a pilot must document and record — in a manner acceptable to the Administrator — only two things: the training and aeronautical experience used to meet the requirements for a certificate, rating, or flight review, and the aeronautical experience required for meeting the recent flight experience requirements of Part 61. Everything beyond that is optional. Most professional pilots log far more than the regulatory minimum because total time and currency evidence matter for employment, insurance, and upgrades — but the legal duty in §61.51 is narrower than most people assume.
Can an operator rely on the pilot's personal logbook to satisfy §135.63(a)(4)?
No. 14 CFR §135.63(a) requires the certificate holder itself to keep — at its principal business office or other places approved by the Administrator, available for inspection by the Administrator — an individual record of each pilot used in operations under Part 135, containing the ten items listed in §135.63(a)(4)(i) through (x). The pilot's logbook is the pilot's personal record under §61.51; it belongs to the pilot, leaves with the pilot, and does not satisfy the operator's independent recordkeeping duty. An inspector asking for your §135.63(a)(4) file will not accept "the pilot has it in their logbook" as an answer.
Who can demand to see a pilot's personal logbook?
Under 14 CFR §61.51(i)(1), a pilot must present the logbook (along with the pilot certificate, medical certificate, or other required record) for inspection upon a reasonable request by the Administrator, an authorized representative of the National Transportation Safety Board, or any Federal, State, or local law enforcement officer. Separate carriage rules apply to specific certificate levels: student pilots must carry their logbook on solo cross-country flights (§61.51(i)(2)), sport pilots must carry logbook evidence of required endorsements on all flights (§61.51(i)(3)), and recreational pilots must carry the logbook on certain solo flights (§61.51(i)(4)).
Does the FAA Pilot Records Database contain a pilot's flight time and currency?
No — and this is the most common misconception about the PRD. Under 14 CFR §111.225, the training, qualification, and proficiency records reported to the PRD expressly exclude flight time, duty time, rest time, protected medical records, and the documentation of recent flight experience. Currency and total-time evidence live in the pilot's §61.51 logbook and, for Part 135 flight-time-limitation purposes, in the operator's §135.63(a)(4)(vii) record. The PRD is a hiring-history system, not a currency ledger.
How long must a Part 135 operator keep its pilot records?
Under 14 CFR §135.63(b), the certificate holder must keep each record required by §135.63(a)(4) — the individual pilot record — and §135.63(a)(5) — the flight attendant record — for at least 12 months. That is a floor, not a target. Part 111 reporting obligations, PRD evaluations by future employers, enforcement lookback, and insurance claims all reach further back than 12 months, so most operators retain pilot records much longer. The aircraft listing under §135.63(a)(3) carries a shorter 6-month minimum.
What happens to each record system when a pilot leaves the operator?
Three different things. The pilot walks away with the personal §61.51 logbook — it is the only one of the three systems the pilot physically controls. The operator must continue to hold its §135.63(a)(4) individual pilot record for at least 12 months under §135.63(b). And under 14 CFR §111.235, the operator must report the records concerning the pilot's final separation from employment — kept pursuant to §135.63(a)(4) — to the Pilot Records Database no later than 30 days after the separation becomes final. A separation that is later overturned may not be reported.
Can a pilot see what an operator reported about them to the PRD?
Yes. 14 CFR Part 111, Subpart D gives pilots standing rights in the database: under §111.315, the pilot may access the PRD to review all records pertaining to that pilot (or request review through an Administrator-provided identity-verification form without electronic access), and under §111.320 the pilot may report errors and request corrections. Access by a hiring operator runs through the pilot's written consent under §111.310. So the PRD is not a one-way mirror — what you report into a pilot's file is visible to the pilot and disputable by the pilot.
Where does FileFlo fit across the three record systems?
FileFlo is the compliance document and proof layer for the operator's side of the map. It does not replace the pilot's personal logbook, does not submit records to the FAA's Pilot Records Database, and does not run your training program or operation. What it does: classifies and indexes the source documents behind the §135.63(a)(4) individual pilot record, tracks check and training dates and the 30-day PRD reporting windows as deadline events with advance alerts, and assembles an audit-ready file per pilot so you can prove to an inspector that the operator-owned record system is complete, current, and reported on time.
Make the operator-owned record systems provable
FileFlo classifies pilot files against the §135.63(a)(4) items, tracks check dates and the 30-day PRD reporting windows as deadline events with advance alerts, and keeps a per-pilot audit-ready file you can hand an inspector. Starter $89/month, Professional $299/month — 5-day free trial, no credit card required.
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