Part 107 recordkeeping: what you need to retain and for how long

Part 107 is the FAA regulation that governs commercial small unmanned aircraft operations in the United States. It is also the rule most commercial drone operators read once and then operate against from memory. The recordkeeping section of that memory is usually inaccurate in both directions: operators assume Part 107 requires more than it does, and they assume the records it does not explicitly require are unnecessary. Both assumptions create exposure.

The actual structure of Part 107 recordkeeping is narrower and more specific than most operating manuals reflect. A small number of records are explicitly required. A much larger set is implied by the rule's other provisions, by waiver conditions, and by what the FAA expects to see during surveillance. Retention periods for several categories are not stated in the rule, leaving operators to default to durations that hold up under audit. This article walks the actual landscape, with reference to the regulatory text at the eCFR Part 107 page.

What Part 107 explicitly requires

The rule's explicit recordkeeping obligations are narrow.

Aircraft registration. Section 107.13 requires the small unmanned aircraft to be registered before operation. The registration is renewable every three years, and the registration certificate (or evidence of registration) must be available during operations.

Remote Pilot Certificate. The remote pilot in command must hold a current Remote Pilot Certificate with sUAS rating, requiring recurrent training every 24 calendar months under Section 107.65. The certificate itself does not expire, but currency does, and operating without current recurrent training violates the rule.

Accident reporting. Section 107.9 requires the remote PIC to report certain operations to the FAA within 10 calendar days. The trigger is either serious injury or loss of consciousness, or damage to property other than the UA where the cost of repair or fair market value exceeds $500. The reporting obligation creates an implicit recordkeeping obligation: the operator needs to have documented the operation in enough detail to file the report accurately.

Waiver compliance. For operations conducted under a Part 107 waiver (night, BVLOS, operations over people, controlled airspace, and others), the waiver typically specifies conditions and limitations. Compliance requires records that show the conditions were met for each operation flown under it.

That is the explicit set. Notably absent is any general requirement to maintain flight logs under Part 107 the way Part 91 requires for manned aircraft. The rule does not mandate a flight log.

What Part 107 implies but does not require

The absence of a flight log requirement leads some operators to skip flight records entirely. This is a mistake for several reasons that follow from other provisions of the rule.

Section 107.49 requires preflight familiarization, inspection, and actions before each flight. The rule does not require these to be documented, but without documentation, the operator cannot demonstrate that the preflight assessment occurred. During surveillance, an inspector who asks "what did the preflight cover for the operation last Tuesday at the substation" needs an answer. Memory is not an answer.

Section 107.65 currency tracking requires the remote PIC to have current recurrent training. Tracking which pilots are current and when their currency expires requires records the operator maintains.

Waiver conditions typically specify operating limitations (visibility minimums, altitude limits, specific equipment, observer roles). Each operation flown under a waiver should produce a record showing those conditions were met.

Maintenance records are not required by Part 107 but are implicit in Section 107.49's preflight inspection. An airframe with no maintenance history cannot reliably pass a preflight inspection beyond a visual check.

Beyond the rule itself, insurance carriers and asset owners often require records that Part 107 does not. The operator's actual recordkeeping obligation is the union of the regulatory requirement and the contractual requirement.

Retention periods

The rule does not state retention periods for most records. The defaults below reflect what holds up under FAA surveillance and what aligns with most commercial program practices.

Aircraft registration: for the life of the registration plus three years after the aircraft leaves service. Registration history matters during incident investigations.

Remote Pilot Certificate and currency records: for the duration of the pilot's tenure plus three years after departure. The records establish that the pilot was qualified during the period they flew.

Accident reports (§107.9 filings): indefinitely. Administrative and legal exposure following a reportable accident can extend for years. Most programs retain seven years or longer.

Waiver compliance records: for the duration of the waiver plus three years. The FAA can request records demonstrating compliance, and renewal often depends on compliance history.

Maintenance records: for the operational life of the airframe plus three years after disposal. Maintenance history is part of the airworthiness story.

Flight records (where maintained): three to five years is common practice. Programs flying under waivers often retain longer because the waiver records and flight records are linked.

Training and currency records: for the duration of employment plus three years.

When the rule is silent, the operating principle is to retain records for as long as a reasonable person might ask to see them in any plausible scenario, including FAA surveillance, insurance claims, civil litigation, or internal review.

Format, accessibility, and FAA requests

The rule does not specify the format records must be kept in. Paper, digital, or some combination are all acceptable in principle. The practical considerations push most programs toward digital.

Accessibility on demand. Section 107.7 obligates operators to make available, on request, any document or record required by the rule. "Available" in practice means the operator can produce the record in a reasonable time. Records scattered across email, shared drives, and individual pilots' devices cannot meet that standard.

Tamper-evidence. Records that an inspector might rely on should be maintained in a way that makes after-the-fact modification visible. An append-only audit log supports this; a freely editable spreadsheet does not.

Scoping to specific requests. An FAA surveillance request typically asks for specific records related to specific operations, not the program's entire history. Producing the requested records without exposing unrelated material protects the program's broader operations from a surveillance event that started narrow.

Personal device exposure. Records held only on individual pilots' phones create access continuity problems when pilots leave the program and privacy issues when the records contain information beyond the operational scope.

Common mistakes in Part 107 recordkeeping

Assuming Part 107 requires a flight log. It does not. But flight records are implicit in several other provisions and are what most surveillance requests end up asking for. Operate as if the records are required.

Treating registration as a one-time event. Aircraft registration renews every three years. Programs that registered their fleet once and never tracked renewals end up with aircraft flying on expired registrations.

Letting pilot currency lapse without records to prove it had not lapsed earlier. The recurrent training requirement is every 24 calendar months. Programs that cannot show when each pilot last completed training cannot demonstrate currency for operations flown earlier in the cycle.

Storing records on personal devices. Records that exist only on a pilot's phone disappear when the pilot leaves. Centralized storage with access controls protects the records from departure events.

Confusing the §107.9 reporting threshold with general incident reporting. Section 107.9 has specific triggers (serious injury, loss of consciousness, property damage above $500). Other incidents (near-misses, minor mishaps, equipment failures) do not require FAA reporting but should be tracked internally for safety management.

FAQ

Does Part 107 require a flight log? The rule does not explicitly require a general flight log. However, Section 107.49 (preflight requirements), Section 107.65 (currency), waiver compliance, and the §107.7 obligation to produce records on request all imply flight-level documentation. Most commercial programs maintain flight records as a practical necessity even though the rule does not name them.

How long should we keep records of operations performed under a waiver? For the duration of the waiver plus three years is a reasonable default. The FAA can request compliance records during the waiver period, and waiver renewals often depend on compliance history. Some programs retain longer when the waiver covers operations near sensitive infrastructure or in populated areas.

Are paper records acceptable under Part 107? Yes. The rule does not specify format. Paper records are acceptable as long as they meet the §107.7 accessibility obligation. Most programs of any scale move to digital because the operational overhead of paper recordkeeping does not match the tempo of commercial drone work.

What happens if records are lost or destroyed? Loss of records does not by itself violate Part 107, but the inability to produce records on FAA request creates a compliance exposure. The expected response in surveillance is that the operator either produces the records or can demonstrate that the records existed and were lost through a documented event (fire, system failure with backup confirmation).

Closing thought

Part 107 recordkeeping is narrower than most operators believe and broader than the rule's explicit language suggests. The explicit requirements cover registration, certification, accident reporting, and waiver compliance. The implicit requirements cover everything Section 107.49 expects to be demonstrable, every waiver condition, and every record an inspector might reasonably request during surveillance. Retention periods are mostly defaults rather than mandates, drawn from what other parties (FAA, insurance, asset owners, litigation counsel) might plausibly ask to see. Programs that build their recordkeeping around this fuller picture do not get surprised.

If you are managing Part 107 recordkeeping for a commercial drone program, FlybyOps was built for the operational record problem at the center of regulated drone work. A pilot registry with certification and currency tracking, a document vault for registration and waiver records, project and job hierarchy that connects flight records to the operations they support, and an append-only audit log are all part of how the platform supports the recordkeeping the rule implies even where it does not require it.