NBAA Advocacy Leads to Revised FAA Electronic Signatures, Recordkeeping and Manuals Authorization Process

Dec. 30, 2024

The FAA recently revised templates in response to conversations with NBAA for authorizing the use of electronic signatures, recordkeeping and manuals.

Certificate holders, program managers, operators or letter of deviation authority (LODA) holders who wish to use these systems obtain FAA authorization through operations specification (OpSpec), management specification (MSpec) or letter of authorization (LOA) A025, as applicable.

Notice 8900.726, OpSpec/MSpec/LOA A025, Electronic Signatures, Electronic Recordkeeping Systems and Electronic Manual Systems, effective Dec. 11, provides revised guidance to FAA inspectors and industry. The notice instructs inspectors to issue the revised A025 template and archive the previous revisions no later than 90 calendar days from the Dec. 11 issue date.

The revisions are meant to simplify the continuing authorization process, eliminating the need for operators to update their OpSpec/MSpec/LOA each time software system is updated, or a manual or signature process is revised.

“These revisions create a comparable but less burdensome way to ensure safe use of electronic systems through A025,” said Brian Koester, aviation compliance and operations analyst at Jetlaw.

“This new process is far more practical, as A025 users no longer have to update the OpSpec, MSpec or LOA every time there’s a software version or manual change, which could be as frequently as every couple of weeks,” he said. “The change results in considerable time savings for FAA and industry resources while maintaining an equivalent level of safety. This is an example of small but meaningful policy change effected by industrywide consensus and collaboration.”

Members of the NBAA’s Advanced Air Mobility Roundtable, Domestic Operations Committee and Regulatory Issues Advisory Group brought these concerns to the association, which coordinated industrywide advocacy through the FAA/Industry Operations Specifications Working Group.

Template Revisions

For Electronic Signatures

Previously, the A025 template required listing the revision number and date for each electronic signature process. Now, the certificate holder/program manager/operator/LODA holder (depending on the regulatory part) to notify the responsible Flight Standards office when changes are made to the electronic signature process, and to revise the manual containing the electronic signature process to reflect changes to the process.

For Electronic Recordkeeping

Previously, the A025 template required listing the software version number for each electronic recordkeeping system. Now, the certificate holder/program manager/operator/LODA holder must have a process for software revision control.

For Electronic Manuals

Previously, the A025 template required listing the number and date of the latest revision to the master manual containing a description of the electronic manual system and list of electronic manuals. Now, the certificate holder/program manager/operator/LODA holder must notify the responsible Flight Standards Office when changes are made to the electronic manual system and revise the master manual to reflect changes to the electronic manual system.