A Part 135 operator must keep six categories of records under 14 CFR §135.63, §135.443, and §91.417:
- Pilot / Crew records — training, check, and time records for each crew member (§135.63(a)(4)); retained for at least 12 months (§135.63(b)).
- Maintenance records — airworthiness releases for aircraft type certificated for 10 or more passenger seats (§135.443; aircraft with 9 or fewer seats return to service under Part 43), AD compliance status (§91.417(a)(2)(v)), life-limited parts status, total time in service, inspection status, and FAA Form 337 copies for major alterations; retention ranges from 1 year / until-superseded for routine entries and major repairs (§91.417(b)(1)) to life-of-aircraft for the permanent §91.417(a)(2) records.
- Drug & alcohol testing records — positive results and refusals 5 years; negative and canceled results 1 year (14 CFR Part 120; 49 CFR Part 40).
- Duty / rest records — flight time records and rest period documentation proving §135.267/§135.269 limits were met; 12 calendar months.
- Training records — initial, transition, ground, and recurrent training completion records (§135.341, §135.345); retained for at least 12 months (§135.63(b)). Hazmat training records are kept for as long as the employee works as a hazmat employee plus 90 days thereafter (49 CFR §172.704(d); §135.507).
- SMS records — SMS Manual, safety reports, hazard logs, risk assessments, and safety assurance outputs required under 14 CFR Part 5 (2024 Final Rule) for ALL Part 135 certificate holders — no aircraft-count threshold, compliance due May 28, 2027. Retention per §5.97: safety assurance outputs minimum 5 years, SRM outputs while the risk control remains relevant, SMS training records for the duration of employment.
Source: eCFR 14 CFR §§135.63, 135.443, 91.417; 14 CFR Part 120; 49 CFR Part 40; 14 CFR Part 5. All retention periods are minimums unless otherwise specified by OpSpecs.
Part 135 on-demand charter and commuter operations run under the most document-intensive regulatory framework in general aviation. A single CHDO Principal Operations Inspector surveillance visit can surface findings in any of six record categories simultaneously — and unlike a motor carrier DOT audit, the FAA can move from a finding to a certificate action without a grace period if records are systematically absent.
This page is the master reference index for every record a Part 135 operator must keep. Each row names the governing CFR section (with a live eCFR link), who owns the record, and the minimum retention period. The table is structured so a DOM or Director of Safety can use it directly during an audit prep session or internal self-audit.
For the background on why each category exists and how the regulations interconnect, see the section-by-section analysis below the table. For the companion recordkeeping software comparison, see Best Part 135 Operations + Recordkeeping Software 2026.
Records are the only evidence the FAA sees — they cannot inspect safe judgment
CHDO inspectors cannot observe every flight or maintenance event. The record IS the evidence of compliance. An operator with perfect operational practices and missing records presents the same enforcement risk as one that actually failed to comply. The FAA has no way to distinguish them without the records.
Complete Part 135 Recordkeeping Table
Every required record mapped to the governing CFR cite, responsible owner, and minimum retention period. Click a category filter to isolate a section.
| Category | Record | CFR Cite | Owner | Retention |
|---|---|---|---|---|
| Pilot / Crew | Crew member training records (initial, recurrent, ground, flight) Must be produced for FAA inspection on request | §135.63(a)(4) | Operator (DOM) | At least 12 months (§135.63(b)) |
| Pilot / Crew | Crew member check records (proficiency checks, line checks, §135.293 airman competency checks) Includes initial and recurrent checks | §135.63(a)(4); §135.293 | Operator (DOM) | At least 12 months (§135.63(b)) |
| Pilot / Crew | Instrument proficiency check (IPC) records — §135.297 Required for PIC IFR currency under Part 135 | §135.297 | Operator (DOM) | At least 12 months (§135.63(b)) |
| Pilot / Crew | Pilot-in-command (PIC) authority and qualification records Includes aircraft type qualification evidence | §135.63(a)(4); §135.243 | Operator (DOM) | At least 12 months (§135.63(b)); kept current while the pilot is used |
| Pilot / Crew | Crew member time records (flight time, duty time, rest periods) Used to verify compliance with duty/rest rules | §135.63(a)(4); §135.267 | Operator (DOM) | 12 calendar months |
| Maintenance | Airworthiness release or maintenance log entry before flight after maintenance, preventive maintenance, or alterations (aircraft type certificated for 10+ passenger seats — §135.411(a)(2); smaller aircraft return to service under Part 43) Four-part certification: work performed per the certificate holder's manual; required-inspection items inspected by an authorized person and found satisfactorily completed; no known condition makes the aircraft unairworthy; aircraft is in condition for safe operation | §135.443 | Authorized certificated mechanic or repairman (§135.443(c)) | Until repeated or superseded, or 1 year (§91.417(b)(1)); release form per §135.443 |
| Maintenance | Current status of applicable Airworthiness Directives (ADs) including AD number, revision date, method of compliance Must include method of compliance for repetitive ADs | §91.417(a)(2)(v) | Operator (DOM / Director of Maintenance) | Life of aircraft (transfer on sale) |
| Maintenance | Current status of life-limited parts (total time/cycles in service; remaining life) Includes engines, propellers, rotors, appliances with life limits | §91.417(a)(2)(ii) | Operator (DOM) | Life of aircraft (transfer on sale) |
| Maintenance | Total time in service for each airframe, engine, propeller, and rotor Hours, cycles, and/or landings as applicable | §91.417(a)(2)(i) | Operator (DOM) | Life of aircraft (transfer on sale) |
| Maintenance | Current inspection status (100-hour, annual, AAIP, progressive — whichever applies) Part 135 aircraft on continuous airworthiness programs have different intervals | §91.417(a)(2)(iv); §91.409 | Operator (DOM) | 12 calendar months after inspection; status record — life of aircraft |
| Maintenance | Records of major alterations (FAA Form 337 copies) Form 337 copies for each major alteration transfer with the aircraft; major repair records fall under §91.417(a)(1) — kept until repeated or superseded, or 1 year | §91.417(a)(2)(vi) | Operator (DOM) | Life of aircraft (transfer on sale) |
| Maintenance | Mechanical irregularity reports (§135.65) Irregularities in aircraft equipment that are not corrected before the next flight | §135.65 | Operator (DOM) | No retention period in §135.65; corrective-action log entries are maintenance records retained per Part 43 / §91.417(a)(1) |
| Drug & Alcohol | Positive / refused drug test results and documentation Includes adulterated and substituted results | 14 CFR Part 120; 49 CFR Part 40 | Operator DER | 5 years |
| Drug & Alcohol | Alcohol test results ≥ 0.02 BAC Documentation of the BAC result and actions taken | 14 CFR Part 120; 49 CFR §40.333 | Operator DER | 5 years |
| Drug & Alcohol | Negative and canceled drug test results; alcohol tests < 0.02 Separate from positive results retention | 49 CFR §40.333 | Operator DER | 1 year |
| Drug & Alcohol | Pre-employment drug test records (negative results required before safety-sensitive function) Operator must receive negative result before employee performs safety-sensitive function | §120.109; 49 CFR §40.25 | Operator DER | 1 year (negative); 5 years (positive) |
| Drug & Alcohol | Random testing program records (selection pool documentation, test rates) Must demonstrate compliance with the current FAA-published annual random testing rates (set by the Administrator on a sliding scale and published annually in the Federal Register) | 14 CFR Part 120; 49 CFR Part 40 | Operator DER | Per §40.333 tiers (no separately stated tier for selection-pool documentation; EBT and collection-process records 2 years; §40.25 previous-employer information 3 years) |
| Duty / Rest | Flight time records and rest period documentation (§135.267 — flight time limitations and rest requirements, unscheduled one- and two-pilot crews; §135.269 — unscheduled three- and four-pilot crews; §135.265 — scheduled/commuter operations) Must show crew member did not exceed limits and received required rest | §135.267; §135.269 | Operator (DOM / Scheduler) | 12 calendar months |
| Duty / Rest | Dispatch records, trip releases, and flight locating information (§135.79) Includes position reports for aircraft not on IFR flight plan in remote areas | §135.79 | Operator (Dispatcher / DOM) | Flight locating information: until completion of the flight (§135.79(b)) |
| Training | Crewmember initial and transition training records (§135.341) Includes completion of aircraft-specific training items required by the approved training program | §135.341; §135.63(a)(4) | Operator (DOM / Director of Training) | At least 12 months (§135.63(b)) |
| Training | Ground training records (emergency procedures, aircraft systems, flight regulations) Includes emergency evacuation procedures (§135.331) | §135.345; §135.63(a)(4) | Operator (Director of Training) | At least 12 months (§135.63(b)) |
| Training | Flight training records — initial, transition, upgrade, and differences, including training conducted in approved simulators and flight training devices §135.347 permits approved simulators and flight training devices in the training program; device qualification itself is governed under 14 CFR Part 60 | §135.347; §135.63(a)(4) | Operator (Director of Training) | At least 12 months (§135.63(b)) |
| Training | Dangerous goods / hazardous materials training records Required for all personnel who handle, offer for transport, or accept hazmat | 49 CFR §172.704; 14 CFR §§135.501–135.507 | Operator (DOM) | Duration of employment as a hazmat employee + 90 days thereafter (49 CFR §172.704(d); §135.507) |
| SMS | SMS Manual (current approved version) and revision history Applies to ALL Part 135 certificate holders — SMS + declaration of compliance due May 28, 2027 | 14 CFR Part 5 (2024 SMS Final Rule) | Operator (Accountable Executive) | Maintain SMS documentation (§5.95); Part 5 sets no specific revision-retention formula |
| SMS | Safety reports, hazard identification logs, and risk assessments Non-punitive safety report system; records must support trend analysis | 14 CFR §§5.51–5.57 (Subpart C) | Operator (Safety Manager) | As long as the risk control remains relevant (§5.97(a)) |
| SMS | Safety promotion and SMS training records Documents that personnel are trained on SMS policies and procedures | 14 CFR §5.91 | Operator (Safety Manager / Director of Training) | As long as the individual is employed (§5.97(c)) |
| SMS | Safety assurance outputs — safety performance monitoring records, audit findings, corrective action plans Provides evidence of continuous safety improvement for ASAP/FOQA correlation | 14 CFR §5.75 | Operator (Safety Manager) | Minimum 5 years (§5.97(b)) |
Retention periods are regulatory minimums. Your OpSpecs, CHDO guidance, or SMS policy may impose longer requirements. Always verify against the current published eCFR at ecfr.gov/current/title-14/.../part-135.
Section-by-Section Analysis
Why each category exists, how the regulations interact, and the most common finding pattern for each section during a CHDO surveillance visit.
Pilot / Crew Records
§135.63(a)(4) — the most inspector-requested documents at a CHDO surveillance visit
Section 135.63(a)(4) is the most frequently cited recordkeeping deficiency in CHDO surveillance visits. The rule requires operators to retain each crew member's training, check, and time records for at least 12 months — that is the §135.63(b) floor; longer retention is operator policy, not the rule text. In practice, records must be retrievable on short notice — a CHDO inspector arriving for a surveillance visit expects to see, without delay, the last proficiency check record for any crew member currently on the operations specification.
The most common finding: training records that are current on paper but disorganized such that the crew member cannot be cleared for the flight that day. An operator who cannot produce the check record for the PIC on a given tail within minutes of an inspector's request is indistinguishable from one that never did the check. For the pilot training standards under Part 135, see the deep-dive at Part 135 On-Demand Charter compliance hub.
Records in this category: §135.63(a)(4) · §135.63(a)(4); §135.293 · §135.297 · §135.63(a)(4); §135.243 · §135.63(a)(4); §135.267
Maintenance Records
§135.443 + §91.417 — airworthiness release and aircraft lifecycle records
The airworthiness release under §135.443 is the most operationally acute maintenance record for aircraft type certificated for 10 or more passenger seats — §§135.423–135.443 apply to those aircraft (or to operators electing that maintenance program under §135.411(b)); aircraft with nine or fewer passenger seats are returned to service under Part 43 instead. The release is required before each flight after maintenance, preventive maintenance, or alterations. It is a certification, signed by an authorized certificated mechanic or repairman, that the work was performed in accordance with the certificate holder's manual; that all required-inspection items were inspected by an authorized person who determined the work was satisfactorily completed; that no known condition exists that would make the aircraft unairworthy; and that the aircraft is in condition for safe operation. Missing or incomplete airworthiness releases are a direct §135.443 finding.
Beyond the release itself, operators must maintain the lifecycle records required by §91.417 — AD status, life-limited parts, total time in service, inspection status, and FAA Form 337 copies for each major alteration. The permanent §91.417(a)(2) records transfer with the aircraft on sale. Operators who cannot account for the AD compliance history on a tail they purchased face a constructive AD non-compliance finding. For Airworthiness Directive compliance strategy, see AD compliance hub.
Records in this category: §135.443 · §91.417(a)(2)(v) · §91.417(a)(2)(ii) · §91.417(a)(2)(i) · §91.417(a)(2)(iv); §91.409 · §91.417(a)(2)(vi) · §135.65
Drug & Alcohol Records
14 CFR Part 120 + 49 CFR Part 40 — 1–5 year retention tiers by result type
Part 135 operators conducting flight operations under 14 CFR Part 120 are subject to DOT drug and alcohol testing requirements under 49 CFR Part 40. The two-tier retention structure (5 years for positive/refused results, 1 year for negative results) reflects the DOT's enforcement philosophy: positive results are the evidentiary backbone of any subsequent enforcement action and must be retained long enough for the statute of limitations to run. See the dedicated deep-dive at Part 120 Drug & Alcohol Testing hub.
Records in this category: 14 CFR Part 120; 49 CFR Part 40 · 14 CFR Part 120; 49 CFR §40.333 · 49 CFR §40.333 · §120.109; 49 CFR §40.25 · 14 CFR Part 120; 49 CFR Part 40
Duty / Rest Records
§135.267 / §135.269 — 12-month retention proving limits were not exceeded
Flight time limitation and rest period records under §135.267 and §135.269 are the crew-fatigue equivalent of the HOS records DOT motor carriers maintain. The records must demonstrate that no crew member exceeded the applicable flight time limits and received the required rest before any duty assignment. The 12-calendar-month retention minimum means the records must survive the full annual surveillance cycle plus a buffer — operators should retain them for at least 14 months to eliminate any gap risk.
Records in this category: §135.267; §135.269 · §135.79
Training Records
§135.341 / §135.345 — training completion records kept at least 12 months (§135.63(b))
Training records under §135.341 and §135.345 document that each crew member completed the operator's FAA-approved training program before performing the function. These records are the proof layer for the training program — without them, the program exists on paper only. Hazardous materials training records are the outlier: 49 CFR §172.704(d) requires the training record (covering the preceding three years of training) to be retained for as long as the employee works as a hazmat employee and for 90 days thereafter — mirrored for Part 135 by §135.507. The three-year figure is the recurrent-training interval, not a retention period.
Records in this category: §135.341; §135.63(a)(4) · §135.345; §135.63(a)(4) · §135.347; §135.63(a)(4) · 49 CFR §172.704; 14 CFR §§135.501–135.507
SMS Records
14 CFR Part 5 (2024 Final Rule) — SMS manual, hazard logs, and safety assurance records
The 2024 FAA SMS Final Rule (14 CFR Part 5) added a formal records layer to safety management that many Part 135 operators previously handled informally. The four components — safety policy, risk management, safety assurance, and safety promotion — each generate records. Safety reports from the non-punitive reporting system are the most sensitive: operators must be able to demonstrate they received, investigated, and closed safety reports, but the records must also be protected from punitive use per the non-punitive policy. Retention is set by regulation, not guidance: under 14 CFR §5.97, safety assurance outputs must be retained for a minimum of 5 years and Safety Risk Management outputs for as long as the risk control remains relevant.
For Part 135 operators approaching the 2027 SMS compliance wave, see the dedicated analysis at FAA SMS 2027 Compliance hub.
Records in this category: 14 CFR Part 5 (2024 SMS Final Rule) · 14 CFR §§5.51–5.57 (Subpart C) · 14 CFR §5.91 · 14 CFR §5.75
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Related Part 135 Compliance Resources
Frequently Asked Questions
What is the primary recordkeeping regulation for Part 135 operators?
14 CFR §135.63 is the master recordkeeping rule for Part 135 operators. It requires the certificate holder to keep its certificate and operations specifications, a current list of the aircraft used in its operations (§135.63(a)(3)), an individual record for each pilot used in operations (§135.63(a)(4)), individual flight attendant records (§135.63(a)(5)), and load manifest copies (§135.63(c)–(d)). Maintenance records are governed separately — by §91.417 and Part 43 for most aircraft, and by §§135.423–135.443 for aircraft type certificated for 10 or more passenger seats. For those aircraft, §135.443 governs the content and form of the airworthiness release document. Section 91.417 provides the baseline for civil aircraft maintenance record retention: under §91.417(b)(1) the routine maintenance and inspection entries are kept until the work is repeated or superseded, or for 1 year after the work is performed, while the §91.417(a)(2) records — total time in service, current inspection status, current AD compliance status, and FAA Form 337 copies for each major alteration — are retained and transferred with the aircraft when it is sold. Major repair records fall under §91.417(a)(1) and follow the until-repeated-or-superseded / 1-year rule. Part 135 operators must satisfy these alongside the Part 135-specific requirements.
How long must a Part 135 operator keep pilot training records?
Under 14 CFR §135.63(b), a Part 135 operator must keep each individual pilot record required by §135.63(a)(4) — training, qualification, and check records — for at least 12 months. The regulation sets a minimum duration; practically, most operators retain these records for the duration of employment plus 12 months, because they must be available for FAA inspection on request and feed Pilot Records Database reporting under 14 CFR Part 111. Note that drug and alcohol program records (49 CFR Part 40, incorporated through 14 CFR Part 120) carry separate retention requirements — 1 to 5 years depending on record type under 49 CFR §40.333.
What records must a Part 135 operator keep for each aircraft?
A Part 135 operator must maintain the following aircraft records: (1) the approval for return to service — for aircraft type certificated for 10 or more passenger seats (or operators electing that maintenance program under §135.411(b)), an airworthiness release or maintenance log entry under §135.443; for aircraft with 9 or fewer passenger seats, a Part 43 return-to-service approval under §43.5 and §43.9; (2) a record of the current status of all Airworthiness Directives (ADs) and exemptions per §91.417(a)(2)(v), retained for the life of the aircraft; (3) records of inspections required by §91.409 — the inspection entry itself is kept until the work is repeated or superseded or for 1 year (§91.417(b)(1)), while the current inspection status is a permanent §91.417(a)(2)(iv) record that transfers with the aircraft; (4) a record of current life-limited parts status and time-in-service for each engine, propeller, rotor, and appliance; (5) a record of current status of the aircraft, engine, and propeller including total time-in-service (hours, cycles, landings as applicable); and (6) FAA Form 337 copies for each major alteration (§91.417(a)(2)(vi)), retained for the life of the aircraft and transferred on sale — major repair records are kept under §91.417(a)(1) until the work is repeated or superseded, or for 1 year.
Does a Part 135 operator need SMS records and how long must they be kept?
Yes. The FAA's 2024 Safety Management System final rule (effective May 28, 2024) applies to ALL Part 135 certificate holders regardless of fleet size — there is no aircraft-count threshold — with a single compliance date of May 28, 2027, by which the operator must implement an SMS meeting 14 CFR Part 5 and submit a declaration of compliance to the FAA. Retention is set by 14 CFR §5.97: Safety Risk Management outputs must be retained for as long as the risk control remains relevant to the operation; Safety Assurance outputs (audits, monitoring, performance assessments) for a minimum of 5 years; SMS training records for as long as the individual is employed; and §5.93/§5.57 safety communications for a minimum of 24 consecutive calendar months.
What are the drug and alcohol testing record retention requirements for Part 135?
Part 135 operators subject to DOT drug and alcohol testing under 14 CFR Part 120 and 49 CFR Part 40 must retain: (1) alcohol test results showing a BAC of 0.02 or above — 5 years; (2) documentation of verified positive, adulterated, or substituted drug test results — 5 years; (3) documentation of refusals — 5 years; (4) calibration records and quality control data — 2 years; (5) negative and canceled drug test results — 1 year; (6) alcohol tests with a result below 0.02 — 1 year. The Medical Review Officer (MRO) retains certain records separately. The Designated Employer Representative (DER) must be able to produce all records on short notice for DOT inspection.
What is the difference between §135.63 and §91.417 for maintenance records?
14 CFR §91.417 is the baseline maintenance record retention rule for U.S.-registered civil aircraft, but it is not universal: under §91.401(b) it does not apply to aircraft maintained under a continuous airworthiness maintenance program (CAMP) per part 121, part 129, §91.1411, or §135.411(a)(2) — so Part 135 aircraft on a CAMP (type certificated for 10 or more passenger seats) keep maintenance records under §135.439 instead. Where §91.417 applies, it requires: (a) records of maintenance, preventive maintenance, alterations, and required inspections — kept until the work is repeated or superseded by other work, or for 1 year after the work is performed (§91.417(b)(1)); (b) records of current status of applicable ADs, life-limited parts, and inspection status — retained and transferred with the aircraft when it is sold (§91.417(b)(2)); and (c) FAA Form 337 copies for each major alteration (§91.417(a)(2)(vi)) — retained for the life of the aircraft and transferred upon sale; major repair records fall under (a) above. Section 135.63 then layers on additional operational record requirements specific to Part 135 certificate holders, including crew member records, training records, and check records. Together, both sections define the complete maintenance and operational record retention obligations for a certificated Part 135 operator.
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