Part 91 operators
Part 91 aircraft records-readiness review
A Part 91 records-readiness review checks that an owner-operated aircraft's maintenance records meet the recordkeeping an owner or operator must keep before a sale, an insurance review, or a transfer. It is run by or for the operator ahead of an event that will scrutinize the records. It covers total time in service, AD compliance, life-limited part status, and the inspection records 91.417 requires. You receive a readiness assessment, a gap list against the recordkeeping requirement, and the evidence needed to close each item.
When this review is needed
- A Part 91 aircraft is being sold and the buyer will check records against the recordkeeping requirement.
- An insurer or lender is reviewing the asset and wants confirmation the records are complete.
- The aircraft is moving to a different operating rule and the records have to support the change.
- An owner inherited records of unknown quality and wants a read before relying on them.
The problem
Part 91 records are often kept by the owner or a single shop, with less structure than an air carrier maintains. Total time, AD compliance, and life-limited status may live in logbooks that have changed hands, and the recordkeeping requirement is easy to fall short of without anyone noticing until a buyer or insurer asks.
What gets reviewed
- Total time in service and its consistency across the logbooks
- AD compliance status with accomplishment evidence and method of compliance
- Life-limited part status where applicable to the aircraft
- Inspection records and the current return-to-service basis
- Major repair and alteration records and their approval data
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
- The records present the content 91.417 requires an owner or operator to keep
- Each AD shows accomplishment evidence with the method of compliance recorded
- Total time in service is internally consistent across logbook entries
- Major alterations carry approval data appropriate to the change
- The current return-to-service entry follows from the inspection records on file
Evidence normally required
- Airframe, engine, and propeller logbooks
- Current AD status report and accomplishment records
- Inspection records and the most recent return-to-service entry
- Records of major repairs and alterations
Common discrepancies
- AD compliance asserted without the accomplishment record behind it
- A major alteration without traceable approval data
- Total-time entries that disagree across logbook volumes
- An inspection record gap across a change of ownership
What is at stake
Records that fall short of the recordkeeping requirement weaken a sale, complicate an insurance or lending decision, and can stall a move to a more demanding operating rule. Missing inspection or alteration records are particularly hard to reconstruct on a privately operated aircraft.
How the work runs
Set the yardstick
Establish the recordkeeping content the records must demonstrate for the aircraft.
Check status to evidence
Confirm time, AD, and life-limited status against the logbooks and accomplishment records.
Review approvals
Verify major repairs and alterations carry appropriate approval data.
List the gaps
Record each shortfall and the evidence that closes it.
What the buyer receives
- A readiness assessment against the recordkeeping requirement
- A gap list with the evidence needed to close each item
- A consistency view of total time and AD status across the logbooks
Who uses the output
- Owners confirming the records will hold up before they market the aircraft
- Buyers, insurers, or lenders relying on a readiness read of the file
- Records teams closing gaps before the aircraft changes hands or operating rule
How the work fits into the transaction or program
The review sets a readiness picture before the event that will test the records, whether a sale, an insurance renewal, or a move to a more demanding rule. The gap list it produces feeds remediation while the owner still controls the file.
Start with a single asset
Start with a single tail and expand once the workflow is proven.
Jurisdiction-specific considerations
A Part 91 aircraft moving toward an EASA register has to satisfy continuing-airworthiness recordkeeping that differs from the FAA recordkeeping the file was built on, so the review notes where the records will need rework for the receiving system.
Regulatory limits
The review measures the records against the recordkeeping requirement an owner or operator must keep. It does not perform an inspection, return the aircraft to service, or determine that the aircraft is airworthy.
What this review does not cover
- Physical inspection or the inspection sign-off itself
- Reconstructing maintenance that was never performed
- Any airworthiness determination on the aircraft
Specific to this review
- On a privately operated aircraft the records often sit with one owner or shop, so a change of custody is where gaps most often appear.
- The 91.417 content set is the yardstick a buyer or insurer measures against, even when no transaction has started.
- Inspection and alteration records are harder to reconstruct on a Part 91 aircraft than on an air carrier with structured retention.
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.
U.S. Government (eCFR). Maintenance recordkeeping content and approval-for-return-to-service requirements, including 43.9, 43.11, and Appendix B.
Federal Aviation Administration. FAA guidance on making and keeping maintenance records and acceptable recordkeeping practices.
Frequently asked questions
Do we need a transaction underway to run this?
No. Many owners run a readiness review before marketing the aircraft, before an insurance renewal, or simply to confirm inherited records can be relied on. The recordkeeping requirement is the standard either way.
Relevant glossary terms
Related pages
Where this fits
Talk to an engineer who has done this work
We will walk through your current state, the records or evidence involved, and a scoped first engagement.
Walk through your situation with an engineer who has done this work.