Compliance Record-Keeping
Comprehensive templates and best practices for maintaining Part 135 regulatory compliance documentation
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Regulatory Requirements
1. Overview of Part 135 Record-Keeping
14 CFR Part 135 mandates comprehensive record-keeping for certificate holders. Proper documentation protects your operation during audits, investigations, and demonstrates ongoing regulatory compliance.
Key Regulatory References
- § 135.63: Record keeping requirements
- § 135.64: Retention of contracts and amendments
- § 135.65: Reporting mechanical irregularities
- § 135.415: Service difficulty reports
- § 135.417: Mechanical interruption summary report
- § 135.427: Manual requirements
- § 135.439: Maintenance record requirements
- § 91.417: Maintenance records (applicable to Part 135)
2. Essential Record Categories
| Record Category | Primary Requirements | Minimum Retention | Regulation |
|---|---|---|---|
| Flight Time/Duty Records | Individual crew member flight and duty times | 12 months | § 135.63(a)(4), (b) |
| Crew Qualifications | Training, checks, medical certificates, currency | At least 12 months (§ 135.63(b)) — that is the regulatory floor for every pilot record. Jetfolio's archive schedule keeps most of them longer; see the detailed table below. | § 135.63(a)(4), (b) |
| Aircraft Maintenance | Maintenance, inspections, alterations, repairs | Until the work is repeated or superseded, or 1 year after it; major-alteration records stay with the aircraft and transfer when it is sold | § 91.417 (9 or fewer passenger seats); § 135.439 (10 or more) |
| Airworthiness Directives | AD compliance records | Permanent (for current aircraft) | § 91.417 |
| Weight & Balance | Current W&B data | Until superseded | § 91.417 |
| Operational Control | Load manifests (multiengine aircraft) | 30 days | § 135.63(c), (d) |
| Contract Documents | Charter contracts, amendments | 1 year after execution | § 135.64 |
| Mechanical Irregularities | Discrepancy reports and resolutions | A maintenance record — 1 year, or until the work is repeated or superseded (§ 91.417(b)(1)) | § 135.65 |
| Mechanical Reliability | Service difficulty reports (§ 135.415) and mechanical interruption summaries (§ 135.417) | Submit within 72 hours (SDR) / monthly (MIS); keep copies with the maintenance records | § 135.415 |
Common Recordkeeping Violations
- Incomplete flight time logs: Missing entries or inaccurate totals
- Expired training records: Operating without current proficiency checks
- Missing load manifests: Flights without proper weight documentation
- Inadequate maintenance logs: Incomplete descriptions of work performed
- Premature record disposal: Destroying records before retention period expires
- Inaccessible records: Records not readily available for inspection
Record Organization Systems
1. Filing System Structure
An effective filing system enables quick retrieval during audits and daily operations. Organize records by category with consistent naming and indexing.
Recommended Filing Structure
Part 135 Records/
├── Aircraft Records/
│ ├── N12345/
│ │ ├── Airworthiness/
│ │ │ ├── Certificate of Airworthiness
│ │ │ ├── Registration
│ │ │ └── Airworthiness Directives/
│ │ ├── Maintenance Logs/
│ │ │ ├── Airframe Log
│ │ │ ├── Engine Logs/
│ │ │ └── Propeller Logs/
│ │ ├── Weight & Balance/
│ │ ├── Inspections/
│ │ │ ├── Annual Inspections/
│ │ │ ├── 100-Hour Inspections/
│ │ │ └── Progressive Inspections/
│ │ ├── Service Bulletins/
│ │ └── Modifications/
│ └── N67890/
│ └── [Same structure]
│
├── Crew Records/
│ ├── Pilots/
│ │ ├── Smith_John/
│ │ │ ├── Certificates & Ratings
│ │ │ ├── Medical Certificates/
│ │ │ ├── Training Records/
│ │ │ ├── Proficiency Checks/
│ │ │ ├── Flight Time Logs/
│ │ │ └── Recurrent Training/
│ │ └── [Other pilots]
│ └── Other Crew/
│ └── [Flight attendants, mechanics, etc.]
│
├── Operational Records/
│ ├── Flight Operations/
│ │ ├── Load Manifests/
│ │ │ ├── 2025/
│ │ │ │ ├── January/
│ │ │ │ ├── February/
│ │ │ │ └── [Other months]
│ │ ├── Flight Releases/
│ │ ├── Operational Control/
│ │ └── Flight Plans/
│ ├── Contracts/
│ │ ├── Active Contracts/
│ │ └── Archived Contracts/
│ └── Irregularity Reports/
│
├── Company Documents/
│ ├── OpSpecs (Operations Specifications)/
│ ├── Manuals/
│ │ ├── General Operations Manual (GOM)/
│ │ ├── Maintenance Manual/
│ │ ├── Training Manual/
│ │ └── Emergency Response Plan/
│ ├── Certificate/
│ └── Insurance/
│
└── Safety & Compliance/
├── Safety Reports/
├── Accident/Incident Reports/
├── Audit Reports/
├── Corrective Actions/
└── SMS (Safety Management System)/
2. Index and Cross-Reference System
Master Index Template
Maintain a master index that allows rapid location of any record:
- Document ID: Unique identifier for each record
- Document Type: Category and subcategory
- Date Created: Original date of record
- Date Expires: When record can be disposed (if applicable)
- Location: Physical or digital file location
- Cross-References: Related documents
- Status: Active, Archived, Superseded
3. Color-Coding and Labels
Visual Organization System
- Red Labels: Current, active documents requiring regular review
- Yellow Labels: Documents approaching expiration (within 30 days)
- Blue Labels: Training and qualification records
- Green Labels: Maintenance and airworthiness records
- Orange Labels: Operational records (manifests, releases)
- White Labels: Administrative and archived documents
Templates & Sample Forms
1. Flight Time/Duty Time Log
Pilot Flight Time & Duty Time Record
| Date | A/C Reg | Duty Start | Duty End | Flight Time | Duty Time | Rest Hours |
|---|---|---|---|---|---|---|
| _______ | _______ | _______ | _______ | _______ | _______ | _______ |
| [Additional rows...] | ||||||
Last 24 Hours: _______ | Calendar Quarter: _______ | Two Consecutive Quarters: _______ | Calendar Year: _______
2. Load Manifest Template
Part 135 Load Manifest
1. Name: _________________ Weight: ______ lbs
2. Name: _________________ Weight: ______ lbs
3. Name: _________________ Weight: ______ lbs
[Additional passengers...]
Zone 1: ______ lbs | Zone 2: ______ lbs | Zone 3: ______ lbs
Cargo Description: _________________________________
Basic Empty Weight: ______ lbs | Fuel: ______ lbs
Passengers: ______ lbs | Baggage/Cargo: ______ lbs
Takeoff Weight: ______ lbs (Max: ______ lbs)
CG: ______ inches (Limits: ______ to ______)
3. Crew Training Record
Pilot Training & Qualification Record
Certificate Type: _________________ Certificate #: _________________
Ratings: _______________________________________________________
Class: ______ Issue Date: __________ Expiration: __________
Ground Training: __________ (Date) | Hours: ______
Flight Training: __________ (Date) | Hours: ______
Simulator Training: __________ (Date) | Hours: ______
Date: __________ | Check Airman: _________________
Result: ☐ Pass ☐ Fail | Next Due: __________
Last Completed: __________ | Next Due: __________
Topics Covered: _____________________________________________
4. Mechanical Irregularity Report
Aircraft Discrepancy / Irregularity Report
_________________________________________________________________
_________________________________________________________________
_________________________________________________________________
_________________________________________________________________
☐ Repaired ☐ Deferred (MEL Item: ______) ☐ Aircraft Grounded
5. Pre-Audit Checklist
Compliance Audit Preparation Checklist
- All aircraft maintenance logs current and up-to-date
- All crew training records complete with signatures
- Flight time/duty time logs accurate and within limits
- Load manifests available for past 30 days
- Current Operations Specifications readily available
- All manuals current with latest revisions
- Insurance certificates current and valid
- Aircraft registration and airworthiness certificates displayed
- MEL (if applicable) current and properly documented
- All crew members have current medicals
- Contracts and amendments properly filed
- Safety reports and corrective actions documented
- Records organized and easily retrievable
- Backup copies stored securely off-site
Record Retention Policies
1. Regulatory Minimum Requirements
| Record Type | Regulatory Minimum | Recommended Retention | Rationale |
|---|---|---|---|
| Flight Time/Duty Logs | 12 months | 36 months | Supports trend analysis, investigations |
| Crew Training Records | At least 12 months (§ 135.63(b)) | Initial, indoctrination, upgrade and IOE kept permanently; recurrent 14 calendar-months (Jetfolio archive schedule) | Protects against future claims, supports audits |
| Load Manifests | 30 days | 24 months | Weight/balance trend analysis, investigations |
| Maintenance Logs (routine) | Until the work is repeated or superseded, or 1 year after it (§ 91.417(b)(1); § 135.439(b)(1)) | Life of aircraft | Complete maintenance history, resale value |
| Major Repairs/Alterations | Kept and transferred with the aircraft when it is sold (§ 91.417(a)(2)(vi), (b)(2); § 135.439(a)(2)(vi), (b)(3)) | Permanent (life of aircraft) | Airworthiness history, regulatory requirement |
| Airworthiness Directives | Permanent | Permanent | Regulatory requirement |
| Charter Contracts | 1 year after termination | 7 years | Business disputes, tax records |
| Safety Reports | SMS: safety-assurance outputs 5 years, SRM outputs while the control is relevant, communications 24 months (§ 5.97) | 5 years minimum | Safety trends, SMS requirements |
| Accident/Incident Reports | No specific minimum | Permanent | Legal protection, safety learning |
2. Training Records Retention - Jetfolio Archive Schedule
The regulatory floor is 12 months
§ 135.63(a)(4) lists what the individual pilot record must contain — including the date and result of each competency, proficiency and route check, and the completion date of the initial and each recurrent phase of training — and § 135.63(b) requires that record to be kept for at least 12 months. The periods in the table below are longer. They are Jetfolio's archive schedule, kept because a shorter one leaves the current qualification without its supporting history; they are not additional CFR minimums.
Training and checking records have specific retention requirements under 14 CFR Part 135. Understanding these requirements is critical for compliance and audit preparation.
Grace Period Calculations
§ 135.301(a) treats a test or check completed in the calendar month before or after the month it is due as completed in the due month; § 135.323(b) does the same for recurrent training. The schedule below carries that grace month on both sides of the 12-month cycle, which is where the 14 calendar-months come from; it is a currency convention applied to archiving, not a CFR retention figure.
| Record Type | CFR Reference | Retention Period | Description |
|---|---|---|---|
| Basic Indoctrination | § 135.329 | Permanent | Initial company indoctrination training for all crewmembers |
| Initial Ground Training | §§ 135.63, 135.345 | Permanent | Initial ground training for aircraft type and position |
| Initial Upgrade Training | §§ 135.63, 135.345 | Permanent | Upgrade training from SIC to PIC or between aircraft types |
| Initial Operating Experience (IOE) | § 135.244 | Permanent | Supervised line operating experience hours |
| Recurrent Ground Training | §§ 135.63, 135.351 | 14 months1 | Annual ground training refresher |
| Competency Check | §§ 135.63, 135.293 | 14 months1 | Pilot competency check (normal, abnormal, emergency procedures) |
| PIC Instrument Proficiency Check | §§ 135.63, 135.297 | 12 months2 | Instrument proficiency check for PICs |
| Line Check | §§ 135.63, 135.299 | 14 months1 | Line observation check during actual operations |
| Written/Oral Knowledge Test | § 135.293 | 14 months1 | Written or oral examination results |
| Emergency Training | §§ 135.63, 135.331 | 14 months1 | Emergency procedures and equipment training |
| CRM Training | §§ 135.63, 135.330 | 14 months1 | Crew Resource Management training |
| Hazardous Materials Training | § 135.507; 49 CFR 172.704(d) | While in the job, plus 90 days3 | Hazmat recognition and handling training; the record covers all hazmat training in the preceding 3 years |
| Pilot Proficiency Check | §§ 135.63, 135.293 | 14 months1 | Pilot proficiency check for specific aircraft type |
Footnote Explanations
Footnote 1: 14 Calendar-Month Retention
Records must be retained through the end of the month that is 14 calendar-months after the first incomplete base month following completion.
Calculation Example:
- Training completed: October 15, 2024
- Base month (first incomplete month): November 2024
- 14 months from November 2024 = January 2026
- Retention until: January 31, 2026
Why this matters: This gives operators a grace period for scheduling recurrent training. Training done in October counts as valid through the end of the following calendar year plus one month.
Footnote 2: 12 Calendar-Month Retention
Records must be retained through the end of the month that is 12 calendar-months after the first incomplete base month following completion.
Calculation Example:
- IPC completed: April 18, 2024
- Base month (first incomplete month): May 2024
- 12 months from May 2024 = May 2025
- Retention until: May 31, 2025
Footnote 3: Hazmat Training Records
Keep a record of all hazmat training the person received in the preceding 3 years, for as long as the person performs or directly supervises a hazmat job function and for 90 days after (§ 135.507(a); 49 CFR 172.704(d)). The 3 years is how far back the record reaches, not how long it is kept. Recurrent hazmat training is due every 24 months (§ 135.505(a)), with a grace month either side (§ 135.505(d)).
Permanent Training Records (Must Retain for Duration of Employment + Archive Period)
- Basic Indoctrination (§ 135.329) - Initial company indoctrination
- Initial Ground Training (§§ 135.63, 135.345) - Aircraft type and position training
- Initial Upgrade Training (§§ 135.63, 135.345) - SIC to PIC upgrades
- Initial Operating Experience (IOE) (§ 135.244) - Supervised line experience
Best Practice: Even after employment ends, retain permanent records for at least 3-5 years for audit purposes and to support pilot credentials for future employment verification.
3. Record Disposal Procedures
Secure Disposal Protocol
- Review Retention Schedule: Confirm record has met minimum retention period
- Check for Holds: Verify no ongoing investigations, audits, or legal matters
- Management Approval: Obtain authorization before disposing of any records
- Document Disposal: Log what was disposed, when, and by whom
- Secure Destruction: Shred paper records, securely erase digital records
- Retain Disposal Log: Maintain permanent log of destroyed records
When NOT to Dispose of Records
- Active Investigation: Any record related to ongoing NTSB, FAA, or internal investigation
- Pending Litigation: Records subject to legal hold or discovery
- Recent Incident: Records within 5 years of any accident or serious incident
- Audit Period: During active FAA audit or surveillance
- Incomplete Series: Individual records that are part of ongoing documentation
- Historical Value: Records that document significant operational history
3. Archiving Best Practices
Archiving Procedure
- Archive Trigger: Move records to archive when they reach 12-24 months old (vary by type)
- Archive Format: Maintain same organization structure in archive
- Archive Labeling: Clear labels with date range and contents
- Archive Location: Secure, climate-controlled storage facility
- Archive Index: Maintain searchable index of all archived materials
- Archive Review: Annual review of archived records for disposal eligibility
- Retrieval Procedure: Documented process for retrieving archived records
Audit Preparation & Management
1. Types of Audits
| Audit Type | Frequency | Scope | Preparation Time |
|---|---|---|---|
| Internal Audit | Quarterly or semi-annual | Comprehensive review of all systems | Scheduled, 2-4 weeks notice |
| FAA Flight Standards District Office (FSDO) / principal inspectors | Annual minimum, often more | Operations, maintenance, training | Usually 24-48 hours notice |
| FAA Spot Inspection | Unannounced | Focused on specific areas | No notice |
| NTSB Investigation | After incidents | Incident-related records | Immediate |
| Insurance Audit | Annual or policy renewal | Safety programs, training records | 2-4 weeks notice |
| Customer Audit | Varies | Operations, safety, quality | 1-2 weeks notice |
2. Pre-Audit Preparation
30-Day Pre-Audit Action Plan
- Day 30: Review audit notification, identify scope and focus areas
- Day 28: Assign audit coordinator and support team
- Day 25: Conduct internal pre-audit review of all records
- Day 20: Identify and correct any discrepancies or missing records
- Day 15: Prepare conference room with all requested materials
- Day 10: Brief all personnel on audit procedures and expectations
- Day 7: Conduct mock audit with internal team
- Day 3: Final verification that all materials are ready
- Day 1: Welcome auditors, provide workspace and materials
3. During the Audit
Audit Day Best Practices
- Professional Workspace: Provide quiet, organized space with tables and power
- Audit Coordinator: Designate one person as primary auditor contact
- Responsive Support: Answer questions promptly and accurately
- Document Requests: Log all records requested and provided
- Take Notes: Record auditor comments, questions, and concerns
- Avoid Over-Sharing: Provide requested information, but don't volunteer problems
- Professional Demeanor: Courteous, cooperative, factual responses
- Don't Guess: If you don't know an answer, find the information or commit to follow-up
- Daily Debrief: Meet with auditors at end of each day for updates
4. Post-Audit Actions
Findings Response Process
- Review Findings: Carefully review all audit findings and recommendations
- Root Cause Analysis: Identify underlying causes, not just symptoms
- Corrective Action Plan: Develop specific actions with timelines and responsible parties
- Implementation: Execute corrective actions according to plan
- Verification: Document completion and effectiveness of corrections
- Response Letter: Provide formal response to auditor addressing all findings
- Follow-Up: Coordinate any required follow-up inspections or verifications
- Lessons Learned: Update procedures to prevent recurrence
- Continuous Improvement: Use findings to strengthen overall compliance program
5. Common Audit Findings
Frequently Cited Deficiencies
- Incomplete Training Records: Missing signatures, dates, or instructors
- Flight Time Calculation Errors: Inaccurate totals or rolling period calculations
- Expired Currency: Crew operating without current medical, proficiency check, or training
- Missing Load Manifests: Incomplete documentation for flights within 30-day period
- Outdated Manuals: Operating with superseded versions of required manuals
- Inadequate Maintenance Entries: Vague descriptions of work performed
- OpSpecs Non-Compliance: Operating outside approved Operations Specifications
- Record Retention Violations: Premature disposal or inability to produce required records
Digital Record Management
1. Electronic Record-Keeping Systems
FAA Electronic Signature Guidance
The FAA accepts electronic signatures, electronic recordkeeping and electronic manuals that meet the criteria in AC 120-78B (Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals):
- Uniqueness: Electronic signature must be unique to the individual
- Verification: System must verify identity of signer
- Security: Protected against unauthorized use
- Link to Record: Signature inseparably linked to the signed record
- Retention: Electronic records must meet same retention requirements
- Accessibility: Must be readily available for inspection
2. Digital System Requirements
Essential Features for Compliance Software
- Data Integrity: Records cannot be altered without audit trail
- Backup Systems: Automated daily backups with off-site storage
- Access Controls: Role-based permissions and authentication
- Audit Trail: Log of all record creation, modification, and access
- Search Functionality: Rapid retrieval by multiple criteria
- Export Capability: Ability to export records in standard formats
- Disaster Recovery: Plan for system failure or data loss
- Regulatory Compliance: Meets all FAA electronic record requirements
3. Hybrid Paper/Digital Systems
Managing Mixed Record Systems
- Clear Policy: Define which records are paper vs. digital
- Consistent Process: Standard procedures for scanning and digitizing
- Quality Control: Verify scanned documents are legible and complete
- Original Retention: Determine if paper originals must be retained after scanning
- Index Both: Maintain index covering both paper and digital holdings
- Transition Plan: Gradual migration to fully digital system
4. Cloud Storage Considerations
Cloud Storage Requirements
- Data Security: Encryption in transit and at rest
- Redundancy: Multiple geographic backup locations
- Access Reliability: 99.9%+ uptime guarantee
- Compliance Certification: SOC 2, ISO 27001, or equivalent
- Data Ownership: Contract clearly establishes your ownership of data
- Exit Strategy: Ability to retrieve all data if changing providers
- Disaster Recovery: Proven backup and recovery procedures
5. Backup and Recovery
Backup Best Practices
- Automated daily backups of all digital records
- Weekly verification that backups completed successfully
- Monthly test of restore procedures
- Off-site storage of backups (different location from primary)
- Multiple generations of backups retained (30-90 days)
- Encrypted backups for security
- Documented recovery procedures tested annually
- Recovery Time Objective (RTO): 24 hours or less
- Recovery Point Objective (RPO): No more than 24 hours data loss
Key Takeaways
The Five Pillars of Effective Record-Keeping
- Completeness: Maintain all required records with full details and signatures
- Accuracy: Ensure all information is correct, truthful, and verifiable
- Accessibility: Organize records for rapid retrieval during audits or operations
- Security: Protect records from loss, damage, or unauthorized modification
- Compliance: Meet all regulatory retention requirements and inspection standards
Record-Keeping Philosophy
"If it's not documented, it didn't happen."
In aviation operations, documentation serves as proof of regulatory compliance, protection against liability, and the foundation for continuous safety improvement. Treat every record as a potential piece of evidence in a future audit or investigation—because it might be.
Invest in robust record-keeping systems and processes from the beginning. Poor record-keeping is one of the most common reasons for certificate suspension or revocation. The time spent maintaining accurate records is far less than the cost of responding to violations or incidents.
Related Resources
Explore these additional resources to support your compliance program: