Retention gap
Records-retention gaps across the required retention period
Records-retention gaps mean documents that should have been kept for a required period were discarded, lost, or never captured, leaving holes in the history the rules and the lease depend on. It is a problem for lessors, airlines, and MROs at audit, transition, or transaction diligence. The check reads what the records should contain over the retention period against what is actually held. You receive a list of retention gaps, their period and scope, and the path to bound or reconstruct each.
When this review is needed
- An audit or transition needs the history kept over the period the rules and lease require.
- Records before a certain date cannot be located and the extent of the loss has to be bounded.
- A prior operator's archive practice is unknown and the retained history needs verifying.
The problem
Some records must be kept for the life of the part, some for a fixed period, and some until superseded, and the requirement is met only if the document was actually retained that long. A discarded record, a failed archive migration, or a prior operator's short retention practice leaves a hole that no amount of later effort can fully fill. The gap is in the past, and the history can only be bounded, not invented.
What gets reviewed
- What records the retention requirements call for over the relevant period
- Life-of-part, fixed-period, and until-superseded retention categories
- What is actually held against what should have been retained
- The period and scope of each identified gap
- Prior-operator archive and migration practice where it bears on retention
Scope this review
Tell us the asset, the event, and the evidence in scope, and we will outline a focused first engagement.
Send a representative, redacted record set and we will scope the review.
What gets validated
- Records required for the life of the part are present for the parts still in service
- Fixed-period records cover the period the rules and lease require
- Until-superseded records hold the current issue and any history the gap touches
- Each identified gap is bounded by date, scope, and the records it affects
- Archive and migration events are checked as points where retention can break
Evidence normally required
- Maintenance, inspection, and compliance record sets
- Component and LLP history covering the retention period
- Archive, migration, and retention logs where available
- Retention requirements from the applicable rules and the lease
Common discrepancies
- A life-of-part record absent for a part still in service
- A fixed-period record set that stops short of the required period
- A retention gap traced to a failed archive migration
- A prior-operator practice that retained records for less than required
What is at stake
A retention gap can leave a life-limited part, a repair, or a compliance status without the history it depends on, forcing conservative treatment or rework. The loss is often unrecoverable, so the practical task is to define its boundary, and at a transition an unbounded retention gap blocks acceptance of the history the asset carries.
Move from findings to resolution
Sequence the fixes and the documentation that closes each finding.
How the work runs
Map the requirement
Establish what the rules and the lease require to be kept, by life-of-part, fixed-period, and until-superseded category.
Compare held to required
Check what the records actually hold over the relevant period against what should have been retained.
Bound each gap
Define the date range, scope, and affected records for every hole found, and trace it to its likely cause.
Set the handling path
For each gap, decide between reconstruction, substantiation, or accepting and disclosing the bounded limit.
What the buyer receives
- A register of retention gaps with each gap's period, scope, and affected records
- The boundary of each gap and what history can still be reconstructed
- A handling path per gap, whether reconstruction, substantiation, or accepting the bounded limit
Who uses the output
- Records teams bounding and disclosing each irrecoverable gap
- Quality assurance confirming life-of-part history exists for parts still in service
- Asset and transaction teams pricing a bounded retention gap into the deal
How the work fits into the transaction or program
The review treats retention as a question of whether the history existed long enough to be relied on, so an irrecoverable past gap is bounded and disclosed rather than confused with a present filing error. It feeds the discrepancy register and the acceptance decision.
Jurisdiction-specific considerations
Retention periods and categories differ across authorities and programs. Where the aircraft is moving registries, the held history is read against the receiving authority's retention expectations rather than only those the records were kept under.
Regulatory limits
The review confirms whether records were retained over the required period and bounds any gap. It does not waive a retention requirement, recreate lost history as approved data, or make an airworthiness determination.
What this review does not cover
- Waiving a retention requirement or accepting a gap on the authority's behalf
- Recreating lost history as approved data
- Issuing any airworthiness determination on the bounded history
Specific to this review
- Retention requirements vary by category, so a record kept the right length for a fixed-period item can still fall short for a life-of-part item it sits beside.
- A retention gap sits in the past and usually cannot be filled, so the practical work is bounding its date and scope rather than recovering it.
- Archive migrations are a recurring origin of retention loss, because a failed transfer can drop a record set without anyone noticing until it is needed.
Sources
U.S. Government (eCFR). Records an owner or operator must keep, including total time in service, current status of life-limited parts, and AD compliance.
Federal Aviation Administration. FAA acceptance criteria for electronic recordkeeping systems and electronic signatures.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
Frequently asked questions
Can a retention gap be filled after the fact?
Usually not. The records that should have been kept are gone, so the practical work is bounding the gap by date and scope and deciding whether a substantiated reconstruction is possible. A bounded, disclosed gap is treated differently from a present-day filing error.
Relevant glossary terms
Related pages
Where this fits
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We will walk through your current state, the records or evidence involved, and a scoped first engagement.
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