Direct Answer: What Does Part 111 Require?
The FAA Pilot Records Database (PRD) imposes a two-sided obligation under 14 CFR Part 111. As a reporting entity, you must report the records in §§111.220–111.240 generated on or after June 10, 2022, plus each pilot's PRD date of hire (§111.205). As a reviewing entity, you may not permit a pilot to begin service until you have evaluated all relevant PRD information (§111.105) and completed the National Driver Register / motor-vehicle-record check (§111.110).
The five reportable record categories are:
- Drug & alcohol testing records (§111.220) — within 30 days of the event
- Training, qualification & proficiency records (§111.225) — within 30 days of creating the record
- Final disciplinary action records (§111.230) — within 30 days of the action becoming final
- Final separation from employment records (§111.235) — within 30 days of separation
- Verification of the MVR search & evaluation (§111.240) — documented in the PRD within 45 days of the PRD date of hire
The PRD replaces the paper PRIA request process. Records from protected Voluntary Safety Reporting Programs may not be reported (§111.245).
The PRD makes your recordkeeping discipline visible to every future employer of your pilots
Unlike PRIA, where a sloppy or late records response stayed largely between two operators, the PRD is a standing FAA system. Missing a 30-day reporting deadline, failing to document the §111.240 motor-vehicle-record verification, or letting a pilot begin service before evaluating PRD information are administrative failures the FAA can identify directly in the database — and the next operator who hires your departing pilot relies on what you reported. Treat PRD reporting as a deadline-driven document workflow, not a once-a-year cleanup.
What the Pilot Records Database Is — and Why It Replaced PRIA
For decades, hiring air carriers verified a pilot's background through the Pilot Records Improvement Act (PRIA) — a paper-and-fax process in which the hiring operator sent written requests to a pilot's prior employers, the FAA, and the National Driver Register, then waited for responses. PRIA worked, but it was slow, inconsistent, and easy to short-cut. The Pilot Records Database (14 CFR Part 111) replaces that process with a single electronic FAA system. Operators report defined records into the database on an ongoing basis, and hiring operators pull a pilot's consolidated history out of it before making a hiring decision.
The key structural shift is that the PRD is continuous, not request-triggered. Under PRIA, records moved only when someone asked. Under Part 111, a reporting entity uploads training, testing, disciplinary, separation, and drug-and-alcohol records on rolling deadlines tied to when each record is created or becomes final. By the time a pilot applies elsewhere, much of the history is already in the database.
Who Part 111 applies to (14 CFR §111.1)
Part 111 reaches well beyond the airlines. Under §111.1, it applies to:
- Operators holding an air carrier or operating certificate under Part 119 authorized for Part 121, 125, or 135 operations
- Fractional ownership program managers operating under Part 91 Subpart K
- Air-tour operators holding a Letter of Authorization under §91.147
- Certain Part 91 business operators of two or more covered aircraft (type-rated airplanes per §61.31(a), turbine-powered rotorcraft, or large powered-lift)
- Qualifying public aircraft operators (excluding the Armed Forces and their reserve components)
- Trustees in bankruptcy of any of the above operators
- Approved persons identified on a PRD access application, and every pilot employed by or seeking employment with a covered operator
For a typical Part 135 on-demand operator, the practical meaning is that you wear two hats simultaneously. You are a reporting entity for every pilot you currently employ, and a reviewing entity every time you hire one. The same crewmember source documents you already keep under §135.63(a)(4) — training, checking, medical, and testing records — are the raw material the PRD reporting categories draw from.
What You Must Report: The Five PRD Record Categories
Under 14 CFR §111.205, each reporting entity must report, for any individual employed as a pilot beginning on that pilot's PRD date of hire: (1) all records described in §§111.220 through 111.240 generated on or after June 10, 2022, and (2) the PRD date of hire itself. The table maps each category to its governing section and deadline.
| Record Category | Governing CFR | Reporting Deadline | Notes |
|---|---|---|---|
| Drug & alcohol testing records | §111.220 | Within 30 days of verified result, test administration, refusal, or alcohol-misuse occurrence | For operators required to comply with Part 120; the underlying testing program is governed by 49 CFR Part 40. |
| Training, qualification & proficiency records | §111.225 | Within 30 days of creating the record (14 days on request for §111.215(b) operators) | Includes comments and evaluations made by a check pilot or evaluator, plus employer-required checking/testing events. |
| Final disciplinary action records | §111.230 | No later than 30 days after the action is final (removal-from-operations actions are excluded from the §111.215(b) on-request option) | Only final disciplinary actions pertaining to pilot performance — not pending or informal actions. |
| Final separation from employment records | §111.235 | No later than 30 days after separation is final (termination separations are excluded from the §111.215(b) on-request option) | Records kept under §135.63(a)(4) (Part 135), §121.683, §125.401, or §91.1027(a)(3) (Part 91K). |
| Verification of motor-vehicle-record search & evaluation | §111.240 | Document in the PRD within 45 days of the pilot's PRD date of hire | The operator documents that it met §111.110. Substantive state MVR content may not be uploaded into the PRD. |
| Historical (PRIA-era) records — transition | §111.255 | On/after Jan 1, 2015 — by June 12, 2023; before Jan 1, 2015 — by September 9, 2024 | Retain reported historical records for at least 5 years after reporting them. |
Deadlines and categories sourced from 14 CFR Part 111 as published on the Cornell Legal Information Institute (law.cornell.edu). Verify against the current CFR before relying for regulatory compliance determinations. Certificate-holder responsibilities extend beyond this table — consult your DOM and aviation counsel.
1. Drug & Alcohol Testing Records (§111.220)
Each operator required to comply with Part 120 must report drug-and-alcohol testing records for each individual it has employed as a pilot. Under §111.220, these records must be reported within 30 days of the applicable occurrence — verification of a result, administration of the test, a refusal to test, or an alcohol-misuse event.
Note the boundary: the PRD reporting obligation here sits on top of — but is separate from — your underlying testing-program recordkeeping. The substantive program records live under 14 CFR Part 120 and 49 CFR Part 40, and DOT/FAA test-record retention is governed by 49 CFR §40.333. The PRD is where defined results get reported so a future employer can see them; it does not change your Part 40 retention duties.
2. Training, Qualification & Proficiency Records (§111.225)
§111.225 requires reporting of records establishing an individual's compliance with FAA-required training, qualification, and proficiency events — explicitly including the comments and evaluations made by a check pilot or evaluator — plus other employer-maintained records documenting training, checking, testing, or proficiency events related to pilot performance.
The standard deadline is within 30 days of creating the record. For the smaller operators that report on request under §111.215(b), the window is 14 days of receiving a request from a reviewing entity.
3. Final Disciplinary Action Records (§111.230)
Under §111.230, a reporting entity must provide any final disciplinary action record pertaining to pilot performance for an individual it has employed as a pilot — no later than 30 days after the action is final (14 days on request for §111.215(b) operators).
The operative word is final. Pending investigations, informal counseling, and disciplinary matters still under appeal are not reportable until they are concluded. Maintaining a clean record of the date an action became final — and a copy of the final determination — is what keeps this category defensible and correctly timed.
4. Final Separation From Employment Records (§111.235)
§111.235 requires reporting of records concerning a pilot's final separation from employment, kept pursuant to the applicable operating rule — §135.63(a)(4) for Part 135, §121.683 for Part 121, §125.401 for Part 125, or §91.1027(a)(3) for Part 91K. The deadline is no later than 30 days after the date of separation is final (14 days on request).
In practice this is the category most likely to slip, because a departing pilot is — by definition — no longer top-of-mind. Building separation reporting into your off-boarding checklist (alongside badge/system de-provisioning) is the reliable way to hit the 30-day window.
5. Verification of the Motor-Vehicle-Record Search (§111.240)
This one is frequently missed because it is not a copy of a record — it is a verification entry. Under §111.240, the operator must document in the PRD, within 45 days of the pilot's PRD date of hire, that it met the motor-vehicle-driving-record requirements of §111.110.
Two boundaries: protected records and historical (PRIA) records
Protected records (§111.245): no person may report any pilot record for inclusion in the PRD that was reported by an individual as part of an approved Voluntary Safety Reporting Program for which the FAA has designated the information as protected under Part 193. Safety-reporting data stays protected; it does not flow into a pilot's PRD file.
Historical records (§111.255): the transition into the PRD also required reporting legacy PRIA-era records. Under §111.255, historical records dated on or after January 1, 2015 were required to be reported by June 12, 2023, and records dated before January 1, 2015 by September 9, 2024. Operators must retain the historical records they reported for at least five years after reporting them.
What You Must Review Before a Pilot Begins Service
Reporting is only half of Part 111. The other half is the pre-service review gate you must clear every time you hire. These obligations are non-discretionary and time-sequenced: the review happens before the pilot flies, not after.
Evaluate all PRD information (§111.105)
Except as provided in §111.115, no reviewing entity may permit an individual to begin service as a pilot until it has evaluated all relevant information in the PRD. "Evaluated" is an active verb — pulling the report is not enough; you must review and weigh it as part of the hiring decision and be able to show you did.
Run the NDR / MVR check (§111.110)
Obtain the pilot's written consent, query the National Driver Register to learn which states hold relevant records, then request the state motor vehicle driving records from each chief driver-licensing official identified — all before the pilot begins service.
The two gates connect to the reporting side through §111.240: once the §111.110 search and evaluation are done, you record that fact in the PRD within 45 days of the PRD date of hire. So a single new-hire generates a sequenced workflow — consent, NDR query, state MVR requests, PRD review, hiring decision, then the §111.240 verification entry — each step with its own evidence and its own clock.
If you are also preparing for broader FAA scrutiny, the pre-service review file is exactly the kind of artifact a Principal Operations Inspector expects to see in order during a Part 135 surveillance audit. The PRD review and MVR verification belong in the same readiness posture as your operational control documentation and your SMS program build-out for the May 28, 2027 deadline.
The Deadline Structure: 30 Days, 45 Days, and the 14-Day Alternative
PRD reporting is a rolling, event-triggered obligation — not an annual filing. Each record category has its own clock, and the clock starts when the triggering event occurs (a test verified, a record created, an action made final, a separation completed, a pilot hired).
The 30-day standard window (§111.215(a))
Records required to be reported under Subpart B must generally be reported within 30 days of the relevant effective date. This is the default for drug-and-alcohol results (§111.220), training/proficiency records (§111.225), final disciplinary actions (§111.230), and separations (§111.235).
The 45-day MVR-verification window (§111.240)
Distinct from the 30-day categories, you have 45 days from the pilot's PRD date of hire to document in the PRD that you completed the §111.110 motor-vehicle-record search and evaluation. This gives a short runway to finish the NDR and state-record steps after a hire — but it is a hard, separate deadline.
The 14-day on-request alternative (§111.215(b))
Certain operators — those described in §111.1(b)(4), public aircraft operators, and §91.147 air-tour operators (and their trustees) — may report most records to the PRD upon receiving a request from a reviewing entity within 14 days, instead of reporting proactively on the 30-day cycle. Two categories are excluded and must still be reported proactively: removal-from-operations disciplinary actions (§111.230) and termination separations (§111.235). If no records exist, the operator must confirm that in writing within 14 days. Confirm which model applies to your certificate before assuming you are exempt from rolling reporting.
Rolling deadlines fail quietly
An annual filing is hard to forget — it is on the calendar. A 30-day clock that starts the day a check pilot signs a proficiency record, or the day a disciplinary action becomes final, is exactly the kind of obligation that slips through when records live in scattered folders and inboxes. The reliable fix is to treat each reportable event as a tracked deadline the moment its source document is created.
How FileFlo Supports PRD Reporting and Review — as the Proof Layer
Let's be precise about the boundary, because it matters for compliance. FileFlo is not the PRD, and it is not a pipeline that submits records to the FAA on your behalf. The reporting and review actions in the PRD are performed by your authorized personnel inside the FAA system. What FileFlo does is keep the underlying source documents — and the deadlines attached to them — organized, classified, and audit-ready, so the people doing the PRD entries are never working from a pile of misfiled PDFs against a clock they forgot was running.
Classifies the source documents behind every PRD category
Upload a proficiency-check sign-off, a drug-and-alcohol result, a final disciplinary determination, a separation record, or an NDR/MVR consent form — FileFlo classifies each against the right record category so the document is where you expect it when it is time to make the PRD entry.
Tracks the 30-day and 45-day reporting clocks as expiration events
FileFlo treats each reportable event as a tracked deadline. When a §111.225 proficiency record is created or a §111.235 separation becomes final, the 30-day window becomes a visible countdown; the §111.240 MVR-verification gets its own 45-day timer from the PRD date of hire — with alerts before, not after, the deadline.
Assembles a pre-service review file per new hire
For each pilot, FileFlo keeps the consent, NDR/MVR evidence, and PRD-review documentation together so you can prove the §111.105 evaluation and §111.110 search were completed before the pilot began service — the artifact a POI expects to see in order.
Proof layer — not your reporting system or your DOM
FileFlo keeps the evidence that the right records existed and the right deadlines were met. It does not submit to the PRD, does not run your testing program, and does not replace your Director of Operations or aviation counsel. The substantive actions stay with your team; FileFlo keeps the documentation defensible.
See whether your pilot-records documentation would survive a POI visit
FileFlo's FAA Readiness Score tool checks your current documentation posture against key Part 135 and pilot-records requirements — no signup required. Takes under 3 minutes.
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What is the FAA Pilot Records Database (PRD)?
The Pilot Records Database (PRD) is an electronic FAA system that consolidates a pilot's records so a hiring air carrier or operator can review them before allowing that pilot to begin service. Under 14 CFR Part 111, the PRD replaces the paper-letter request process that operators used under the Pilot Records Improvement Act (PRIA). Operators that employ pilots must report defined categories of records to the PRD, and operators that hire pilots must evaluate all relevant PRD information before the pilot starts flying.
Who must comply with 14 CFR Part 111?
Under 14 CFR §111.1, Part 111 applies broadly: each operator holding an air carrier or operating certificate under Part 119 authorized for Part 121, 125, or 135 operations; fractional ownership program managers under Part 91 Subpart K; air-tour operators holding a Letter of Authorization under §91.147; certain Part 91 business operators of two or more aircraft of the covered kinds — standard-airworthiness airplanes that require a type rating under §61.31(a), turbine-powered rotorcraft, or large powered-lift aircraft — operated in furtherance of or incidental to a business; qualifying public aircraft operators; trustees in bankruptcy of those operators; approved persons granted PRD access; and every pilot employed by — or seeking employment with — an operator subject to the part. In short, if you employ pilots under a Part 135 certificate, you are both a reporting entity and a reviewing entity.
What records must a Part 135 operator report to the PRD?
Under 14 CFR §111.205, each reporting entity must report the records described in §§111.220 through 111.240 that were generated on or after June 10, 2022, plus the pilot's PRD date of hire. Those record categories are: drug and alcohol testing records (§111.220); training, qualification, and proficiency records, including check-pilot and evaluator comments (§111.225); final disciplinary action records relating to pilot performance (§111.230); records concerning final separation from employment (§111.235); and verification that the operator completed the motor-vehicle-driving-record search and evaluation (§111.240). Records from FAA-designated protected Voluntary Safety Reporting Programs may not be reported (§111.245).
How long does an operator have to report records to the PRD?
The reporting windows are record-specific. Under §111.215(a), records must generally be reported within 30 days of the relevant effective date. Drug and alcohol testing records must be reported within 30 days of the verified result, test administration, refusal, or alcohol-misuse occurrence (§111.220). Training/qualification/proficiency records are due within 30 days of creating the record (§111.225). Final disciplinary action records are due no later than 30 days after the action is final (§111.230), and separation-from-employment records no later than 30 days after separation is final (§111.235). The operator must also document completion of the motor-vehicle-driving-record search in the PRD within 45 days of the pilot's PRD date of hire (§111.240).
What must an operator review before letting a pilot begin service?
Under 14 CFR §111.105, except as provided in §111.115, no reviewing entity may permit an individual to begin service as a pilot until the reviewing entity has evaluated all relevant information in the PRD. In addition, under §111.110 the reviewing entity must obtain the pilot's written consent, query the National Driver Register (NDR), and request the relevant state motor vehicle driving records from each state the NDR search identifies — before the pilot begins service. The PRD review and the motor-vehicle-record check are pre-service gates: the pilot does not start flying for you until both are complete and evaluated.
Did the PRD replace PRIA, and what about historical records?
Yes. The PRD electronic database replaces the paper Pilot Records Improvement Act (PRIA) request-and-response process. Under §111.255, air carriers and operators were required to report their historical PRIA-era records into the PRD on a transition schedule: records dated on or after January 1, 2015 were required to be reported by June 12, 2023, and records dated before January 1, 2015 by September 9, 2024. Operators must maintain the historical records they reported to the PRD for at least five years after reporting them.
Do small Part 135 and air-tour operators report on the same schedule?
Not exactly. Under §111.215(b), certain operators — including those described in §111.1(b)(4), public aircraft operators, and air-tour operators under §91.147 (and their trustees) — may report most records to the PRD upon receipt of a request from a reviewing entity within 14 days, rather than proactively reporting on the standard 30-day cycle. Two carve-outs still require proactive 30-day reporting even for on-request operators: a disciplinary action that resulted in permanent or temporary removal of the pilot from aircraft operations (§111.230), and a separation from employment resulting from a termination (§111.235). And if a request arrives and no records exist, the operator must confirm that in writing within 14 days.
Where does FileFlo fit in the PRD workflow?
FileFlo is the compliance document and proof layer — not the PRD itself and not your reporting pipeline into the FAA system. FileFlo classifies and indexes the underlying source documents that feed PRD reporting and review (training and proficiency records, drug-and-alcohol results, disciplinary and separation records, NDR/MVR consent and verification), tracks the 30-day and 45-day reporting deadlines as expiration events, and assembles an audit-ready packet so you can prove a record was reported or evaluated on time. The FAA reporting and review actions themselves are performed by your authorized personnel in the PRD; FileFlo keeps the evidence organized and on schedule.
Stop tracking PRD reporting deadlines in a spreadsheet
FileFlo classifies the source documents behind every Part 111 reporting category, tracks the 30-day and 45-day clocks as expiration events with advance alerts, and keeps a pre-service review file you can prove. Starter $89/month, Professional $299/month — 5-day free trial, no credit card required.
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