Skip to content

GUIDE: OPSPEC A025

Electronic maintenance records under Part 135.

To keep required maintenance records electronically, a Part 135 operator needs OpSpec A025. This is what the FAA asks for, what goes in your manual, and how the application runs, from AC 120-78B, the FAA's current guidance.

Get a demoHow Radar keeps records

WHO NEEDS IT

Part 135 needs A025. Part 91 does not.

OpSpec A025 is how the FAA authorizes electronic signatures, electronic recordkeeping systems and electronic manual systems. Nobody has to go electronic. Once a Part 135 operator does, for records the rules require, A025 is the authorization, and it lists each system and the manual that describes it.

Part 91 operators, other than fractional programs under 91K, need no FAA approval, acceptance or authorization to keep records electronically. The FAA still recommends the same guidelines, and it can question a record that ignores them.

A025 required

  • Part 135 operators
  • Part 91K fractional programs
  • Part 121, 125 and 133 operators
  • Part 145 repair stations
  • Part 141, 142 and 147 schools and training centers

No FAA authorization needed

  • Part 91 operators, other than 91K
  • Airmen under Parts 61, 63 and 65
  • Part 129 and 137 operators

THE SYSTEM

What your records system has to do.

An electronic record should give the same or better integrity, accuracy and access than the paper it replaces. For each system, the FAA looks for these:

  • Access is controlled
  • Each record is preserved and cannot change without a new signature or certification
  • Confidential information is protected
  • Data corruption is prevented
  • IT support covers the hardware, software and network, with a plan for outages
  • Software changes are tracked, and your Flight Standards office hears about any that affect record entry, display, access or data quality
  • Backups keep records available if the system fails: a second system, a backup server, external drives or printed records

THE RECORD

What each electronic record must show.

A record preserves the evidence of an event, with enough detail to show what took place. For maintenance, that means:

  • What was done
  • When it was done
  • Where it was done
  • Who did it
  • The signature, where the rule requires one
  • The make and model of the aircraft, engine, propeller, appliance, component or part
  • Everything else the rule behind the record requires

Under 14 CFR 135.439, the status records (total time, life-limited parts, time since overhaul, inspection status, AD status and major alterations and repairs) are kept and transferred with the aircraft when it is sold.

SIGNATURES

What makes an electronic signature count.

An electronic signature on a record Part 135 requires needs an accepted electronic recordkeeping system, and the signature process itself is part of A025. A valid electronic signature:

  • Is unique to the signer
  • Identifies and authenticates the signer
  • Stays under the signer's sole control
  • Shows intent to sign, with a statement such as "Signed by" or "Certified by"
  • Takes a deliberate action by the signer
  • Cannot be denied by the signer later
  • Is permanent: the signed record cannot be edited without a new signature

A correction goes in as a superseding entry, which invalidates the earlier signature. When someone leaves, their signature has to stop working.

YOUR MANUAL

What goes in your manual.

Part 135 already has you keep maintenance records in the system your manual specifies. For A025, the manual that describes the electronic system is listed in the OpSpec. Operators with no manual, such as single-pilot operators, can use a standalone procedures document. The manual should cover:

  • How the system meets the rules that apply to your records
  • A description of each system: hardware, software, network, and which records live where
  • Your software revision control process
  • Which records carry electronic signatures
  • Who is responsible for the system and for controlling access
  • Who the authorized users are, and their roles
  • Quality control and audits at regular intervals, covering backups and record accuracy
  • How you provide records to the FAA and NTSB
  • Moving records to a new system without losing integrity
  • Continuity from paper to electronic, and with your maintenance providers
  • Transferring records with the aircraft (14 CFR 43.10, 91.419 and 135.441)
  • Which changes to the system go to the FAA before you make them

THE APPLICATION

How the application runs.

  1. Letter of intentTo your Flight Standards office: each system by name, the records it keeps, your target date and a point of contact.
  2. The packageThe manual, a sample of each record type, your software revision control process, your backup details and your signature processes.
  3. The demonstrationShow how a record is entered, how unauthorized access and changes are blocked, and how your quality control works.
  4. A025 issuedDeficiencies come back in writing to fix first. When the package and the demonstration pass, your principal inspector signs A025 in WebOPSS.

THE PAPER

Keep the original logbooks.

AC 120-78B asks for continuity when you move from paper to electronic records. It says nothing about discarding paper originals once they are scanned, so ask your principal inspector before you retire anything.

Keep them anyway. Appraisers put 10 to 20% of a business jet's value on complete records.

10 to 20%: Asset Insight appraisers, cited in AvBuyer, 2021.

YOUR SOFTWARE

What to ask any records vendor, us included.

Much of the package describes your software. Get these from the vendor before you write the manual:

  • A written description of the system: hardware, software and network
  • How access is granted, and how it ends when someone leaves
  • How a signed record is locked, and how a correction is entered
  • Where backups live, how often they run, and how you reach records during an outage
  • How software changes are announced, so you can tell your Flight Standards office when entry, display, access or data quality change
  • How to export every record when you change systems or sell the aircraft

QUESTIONS

Before you book.

Something else? Talk to us.

Does a Part 91 flight department need A025?

No. Part 91 operators, other than fractional programs under 91K, need no FAA approval, acceptance or authorization to keep records electronically. The FAA recommends following AC 120-78B anyway.

Do we have to go electronic?

No. The FAA does not require electronic signatures, records or manuals. If a Part 135 operator chooses them for required records, A025 is the authorization.

Can the FAA log in to our system?

Inspectors may ask for direct access to inspect the records listed in A025. Giving direct access is voluntary. Providing the records themselves is mandatory.

What happens when the software changes?

Your manual says which system changes go to the FAA before you make them, and your revision control process tells your Flight Standards office when a change affects record entry, display, access or data quality.

Where is the FAA's own guidance?

AC 120-78B, dated December 11, 2024, which replaced AC 120-78A. Inspectors issue A025 under FAA Order 8900.1, Volume 3, Chapter 18, Section 3.

SOURCES

Read the source.

Every requirement on this page comes from these documents.

This guide summarizes FAA guidance. It is not legal advice, and your principal inspector decides what is acceptable for your certificate.