Pilot Records Database Requirements: Part 91 vs Part 135

Pilot Records Database Requirements: Part 91 vs Part 135

  • November
  • 10
  • 2021
  • Erika Armstrong

Advanced Aircrew Academy has received several calls inquiring about the obligation of Part 91 vs Part 135 flight departments to participate in the Pilot Records Database (PRD), so we'll sum up what we know.

Part 91 Operators

If you have two or more type‑rated aircraft (or two turbine powered rotorcraft), you are included in the requirements and you were supposed to register for PRD access by September 8th. If you don't have two aircraft, you can stop reading.

Basically, what it means is that if you receive a request for pilot information, within 14 days you will be required to provide information on the following:

  • Drug and alcohol testing (if applicable)
  • Pilot training, qualifications, and proficiency/testing
  • Final disciplinary actions related to pilot performance (if any)
  • Final separation from employment
  • Certain historical data (voluntary)

The caveat and gray area is the statement that "Part 91 operators will only have to submit this data if they possess the information." We'll let you decide what that means, but Aircrew Academy's robust record keeping with help you with keeping track of your ground training.

Part 91 operators are issued Letters of Authorization (LOAs) to operate in Reduced Vertical Separation Minimum (RVSM), Performance Based Navigation (PBN), and High‑Level Airspace (HLA). To be issued an LOA, operators must develop and submit to the FAA their manuals to support the procedures they will follow, including a requirement for training crews.

Our Worldwide International Procedures curriculum complies with the International Standard for Business Aircraft Operations (IS-BAO) training requirement for "International Operations" defined in Chapter 8 of IS-BAO. The Business Aviation Safety Consortium (BASC) standard also requires training when LOAs are issued for international operations. Advanced Aircrew Academy will track and provide certificates for record keeping on all your required LOA training.

Part 135 Operators

Part 135 operators have more obligations through the PRD. Part 135 must comply with all the obligations of Part 91 plus the following:

  • Register for the PRD by Sept 8th, just like Part 91.
  • Establish a responsible person to supervise the PRD process and name authorized users.
  • You must access pilot records during the hiring process.
  • You must begin using the PRD no later than December 7, 2021.
  • Air carriers must upload historical records starting June 12, 2023.
  • Pilots will have access to the information and can see what the employer is sending.
  • Do not submit records that are not required.

Without you even realizing it, we've been keeping track of your employee's eLearning for you through our complete training documentation. All student progress, usage time, marks, etc., are tracked in detail. We provide FAST+ clients with a special login account for their supervisors/managers which gives you access to the following information via the web at any time:

  • Module Progress
  • Scores
  • Login Time
  • Exams Review
  • Certificates

Quizzes/exams are stored in their completed format, so you view and print them any time. Upon successful completion of a module, a Certificate of Completion is automatically emailed to the student and/or whoever you designate to receive them.

Advanced Aircrew Academy has over 100 eLearning modules for pilots, flight/cabin attendants, mechanics/engineers, line service technicians, schedulers/dispatchers, and office staff. We include, at no additional cost, Total Customization with our FAST+ and Air Carrier packages.

If you'd like more information about record keeping or any of our training options, email

AC 120-68J (

Pilot Records Database (PRD) (