March 28, 2023

The agency recently announced it would begin an enforcement campaign related to compliance with the Pilot Records Database (PRD) requirements.

In Notice 8900.653 Pilot Records Database Compliance Oversight, the FAA cites several potential findings, including operators that did not apply for database access by the Sept. 8, 2021, deadline and operators that did apply, but have not accessed any pilot records since the Dec. 7, 2021, deadline to begin using the PRD to review FAA records when hiring pilots.

“If you inadvertently missed the deadline to apply for the database access or any of the additional deadlines, apply now and develop internal processes to come into compliance and remain in compliance,” said Brian Koester, CAM, NBAA’s director of flight operations and regulations. “While there might still be consequences for failing to meet previous deadlines, the notice instructs inspectors to follow the compliance program policy, which tends to look favorably upon operators that correct instances of noncompliance before FAA interaction and develop corrective actions to ensure future compliance.”

The FAA published 14 CFR §111, Pilot Records Database, in May 2021. The rule introduced the electronic PRD with new mandates for certain aircraft operators with the intent to improve safety by improving the pilot hiring process.

Operators required to submit to review information in the PRD include:

  • Part 119 certificate holders
  • Operators that perform operations under the fractional ownership rules
  • Air tour operators holding a letter of authorization

Entities required to report information to the PRD include the operators listed above, plus:

  • Entities conducting public aircraft operations
  • Corporate flight departments (as defined in the PRD rule) and specific entities operating under Part 125
  • A trustee appointed by a bankruptcy court for an operator or entity subject to the reporting requirements.

Affected entities should now be registered for PRD access, must use the database to view FAA and operator records for pilot candidates and must comply with reporting mandates. The following additional deadlines apply:

June 12, 2023 Upload records generated between Jan. 1, 2015, and June 9, 2022
Sept. 9, 2024 Upload records generated prior to 2015

Also on Sept. 9, 2024, the Pilot Records Improvement Act will end and full compliance with PRD is required.

FAA inspectors are instructed to complete Part 135 operator evaluations by March 31, 2023, Part 125 and 91(K) operator evaluations by June 30, 2023, and corporate operator evaluations by Aug. 31, 2024.

NBAA’s Regulatory Issues Advisory Group (RIAG) created the NBAA Pilot Records Database Resource Guide to help member companies comply with PRD requirements.