UA.I.A.K7: Record retention.

ACS Area I — Regulations Task A: General References: 14 CFRCode of Federal RegulationsCloseThe federal rulebook where Part 107, Part 89, Part 48, and other aviation rules live. parts 89 and 107, subpart A; ACAdvisory CircularCloseFAA guidance that explains acceptable ways to comply with rules or understand FAA procedures. 107-2; FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-H-8083-25; FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-G-8082-22

Key Concepts

Where record retention matters under Part 107 (focus on Category 4)

Under §107.140, Category 4 operations over human beings use a small unmanned aircraft that holds an airworthiness certificate issued under part 21 and is operated in accordance with its approved Flight Manual or other Administrator-specified operating limitations. Category 4 also requires that maintenance, preventive maintenance, alterations, or inspections be performed in accordance with §107.140(c) before conducting these operations. This is the Part 107 context in which maintenance and record retention obligations explicitly arise. For the test, connect “Category 4” with “airworthiness certificate (part 21)” and “maintenance/records under §107.140(c).”^[4] Category 4 prescribes fewer maintenance and record retention requirements than parts 43 and 91. That difference matters if you plan to alternate between operating under part 107 and part 91; the leaner Category 4 scheme can make it difficult to demonstrate compliance when switching. An owner or operator may elect to comply with the relevant parts 43 and 91 requirements even while operating in accordance with part 107 to facilitate moving back and forth between operational parts.^[8]

Accountability: owner vs operator

Know who must keep the maintenance and records. Consistent with other regulatory frameworks (e.g., parts 91 and 135), the owner is responsible for maintaining the small unmanned aircraft in accordance with §107.140(c). If the owner enters into an agreement with another entity to operate the small unmanned aircraft, the operator is responsible for the maintenance and records retention requirements for small unmanned aircraft operated in accordance with Category 4. On the exam, if you see “owner-operated” versus “owner contracts an operator,” assign the records obligation to the owner in the first case and to the operator in the second.^[8]

Practical documentation touchpoints for pilots

• Operating limitations and eligibility: For Category 4, the remote PICRemote Pilot in CommandCloseThe certificated remote pilot responsible for the Part 107 operation. must use an aircraft eligible for Category 4 and operate it per all applicable operating limitations specified by the Administrator and the approved Flight Manual. These limitations must not prohibit operations over human beings. This operational context frames what maintenance/inspection documentation you should expect to exist and be retained under §107.140(c).^[4]
• Aircraft identification and markings checks: As part of sound inspection practices, verify registration markings for proper display and legibility (part 48, §48.205). While this is a preflight inspection item rather than a “record,” it is closely related to airworthiness and compliance documentation that supports safe and legal operations.^[3]
• Labels versus records: If a Category 2 or Category 3 label is damaged, destroyed, or missing, the remote PICRemote Pilot in CommandCloseThe certificated remote pilot responsible for the Part 107 operation. must affix a legible, prominent, durable replacement in English that correctly identifies the category or categories before conducting operations over human beings. This is a physical labeling requirement (§107.135), not a record retention obligation—useful to distinguish on test questions that mix “labels,” “markings,” and “records.”^[4]
• FAA-provided resources: The ACAdvisory CircularCloseFAA guidance that explains acceptable ways to comply with rules or understand FAA procedures. includes sections and appendices on “Remote Pilot Responsibilities When Conducting Operations Over People,” “Small UASUnmanned Aircraft SystemCloseAn unmanned aircraft plus its control station, communication links, and supporting components. Maintenance and Inspection Best Practices,” and a “Sample Preflight Assessment and Inspection Checklist.” These resources support consistent documentation and inspection practices that align with Category 4 maintenance and records responsibilities.^[5]

Operating under multiple parts: implications for records

When a small unmanned aircraft has an FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-issued airworthiness certificate and you contemplate operating sometimes under part 107 and other times under part 91, remember that Category 4 does not require as many maintenance and record retention elements as parts 43 and 91. Because of this mismatch, switching between operating rules can be difficult. Electing to comply with the relevant parts 43 and 91 requirements, even while operating under part 107, can make transitions easier by maintaining a more stringent maintenance and recordkeeping trail. For broader regulatory context tied to documentation and identification, Part 48 (Registration and Marking) and Part 91 (General Operating and Flight Rules) are key references listed for small UASSmall Unmanned Aircraft SystemCloseA small drone plus the control and communication links used to operate it. operators.^[8][1]