An Inspection Authorization, commonly called an IA, is a special privilege granted by the FAA to qualified certificated mechanics that allows them to perform annual inspections and approve aircraft for return to service following major repairs and major alterations. With that elevated authority comes a corresponding set of record-keeping obligations that go beyond what a standard A&P mechanic must maintain. Understanding these obligations thoroughly is essential not only for passing the FAA General knowledge test but also for any IA holder who wants to keep their authorization in good standing and contribute to the safety of the national airspace system.
The rules governing IA holder record-keeping are found primarily in 14 CFR Part 65, Subpart D (specifically §65.91 through §65.95) and in 14 CFR Part 43, which covers maintenance, preventive maintenance, rebuilding, and alteration records for aircraft. Together, these regulations create a complete picture of what an IA holder must document, how long those records must be kept, and how they must be presented to the FAA when requested.
Who Qualifies for an Inspection Authorization
Before examining the record-keeping duties, it helps to understand exactly who holds an IA. Under 14 CFR §65.91, an IA is issued to a certificated mechanic who holds both an airframe and powerplant (A&P) rating, has held those ratings for at least three years, has been actively engaged in maintaining aircraft during the preceding two years, and meets a fixed-base location requirement — meaning the mechanic has a permanent place of business or works from a facility equipped with the necessary tools and inspection equipment. The IA must be renewed annually and is tied to a specific fixed base of operations, which is itself a record-keeping consideration because the location on file with the FAA must remain current.
How the Record-Keeping Obligation Works
The core record-keeping requirement for an IA holder is established by 14 CFR §65.91(c)(2). This regulation requires that the holder of an Inspection Authorization keep, at the fixed base of operations listed on the authorization, a record of each inspection performed. Specifically, the IA holder must record:
- The make, model, and serial number of the aircraft inspected.
- The date the inspection was performed.
- The total time in service of the airframe at the time of inspection.
- The type of inspection performed (annual or progressive, for example).
- Whether the aircraft was approved or disapproved for return to service after the inspection.
- The certificate number of the IA holder who performed the inspection.
These records must be kept for a minimum of two years from the date of the inspection. The two-year retention period is a commonly tested number on the FAA knowledge exam, and it applies specifically to the IA holder's personal log of inspections — separate from the aircraft maintenance records that the aircraft owner or operator is required to retain under 14 CFR §91.417.
It is worth emphasizing the distinction here: the IA holder must keep their own separate record of every inspection they personally conducted. Simply making an entry in the aircraft's logbook is not sufficient to satisfy §65.91(c)(2). The IA holder must maintain an independent running record at their fixed base of operations, even if the aircraft logbook entry is complete and thorough.
Entries in the Aircraft's Maintenance Records
In addition to their personal inspection log, the IA holder is responsible for making proper entries in the aircraft's maintenance records under 14 CFR Part 43, §43.11. After an annual inspection, the IA holder must record in the aircraft's permanent maintenance records the following items:
- The type of inspection and a description of the extent of the inspection (a reference to the manufacturer's or FAA-approved checklist used is acceptable).
- The date of the inspection and the aircraft's total time in service.
- The signature, the certificate number, and the kind of certificate held by the person approving or disapproving the aircraft for return to service.
- If the aircraft is approved for return to service, the phrase indicating it has been inspected in accordance with an annual inspection and found airworthy.
- If the aircraft is disapproved, a list of the discrepancies that must be corrected before the aircraft can be approved.
This entry in the aircraft logbook becomes a permanent part of the aircraft's maintenance history and is retained by the aircraft owner, not by the IA holder. The IA holder's separate log at their fixed base serves an accountability function — it allows the FAA to audit the volume, scope, and consistency of work a particular IA holder is performing, independent of the aircraft's own records.
Availability and FAA Access
Under 14 CFR §65.91(c)(2), the IA holder's personal inspection records must be made available for inspection by the FAA upon request. This means the records must be organized, legible, and accessible at the fixed base of operations. If an IA holder relocates their base of operations, they must notify the FAA and ensure the records travel with them or remain retrievable. Failing to produce records on FAA request can constitute a violation of the regulation and may jeopardize both the IA and the underlying A&P certificate.
The FAA uses these records during certificate action investigations, accident investigations, and routine surveillance. An IA holder whose records are incomplete or missing may face certificate suspension or revocation under 14 CFR §65.95(a), which requires that the authorization be exercised in a manner consistent with the privileges and limitations of the certificate.
Annual Renewal and the Role of Records
The Inspection Authorization is valid for only one calendar year and must be renewed by March 31 of each year. The renewal is tied directly to activity and record-keeping: under 14 CFR §65.93(a), an IA may be renewed only if, during the preceding 24 months, the holder has performed at least one annual inspection, or has performed 100-hour inspections, or has performed or supervised the major repair or major alteration approval work, or has attended and successfully completed an FAA-sponsored or -approved inspection authorization refresher course within the 24 months before the date of application for renewal. The IA holder's personal records of inspections performed serve as the documentary evidence that they meet the activity requirements for renewal. Without those records, proving eligibility for renewal can be difficult or impossible.
Key Numbers and Rules
- 2 years: Minimum retention period for an IA holder's personal inspection records (14 CFR §65.91(c)(2)).
- March 31: Annual renewal deadline for an Inspection Authorization (14 CFR §65.93).
- 3 years: Minimum A&P certificate holding period before an IA can be issued (14 CFR §65.91).
- 2 years active maintenance: Required period of active maintenance work preceding the IA application (14 CFR §65.91).
- Fixed base of operations: Records must be kept at the location on file with the FAA, not just anywhere convenient.
- Part 43, §43.11: Governs the required content of maintenance record entries for inspection approvals and disapprovals.
- Aircraft records (§91.417): The aircraft owner must retain routine maintenance and minor repair/alteration records until the work is repeated, superseded, or for one year, whichever occurs first, while records of major repairs and alterations must be retained as permanent records until the work is superseded or the aircraft is sold with the records properly transferred — separate from the IA holder's own two-year log.
Common Test Traps
- Confusing the two-year IA log requirement with aircraft record retention periods. The FAA exam frequently presents both requirements and tests whether you can match the correct retention period to the correct record type. The IA holder's personal log: two years. Major repair and alteration records in the aircraft: retained as permanent records until superseded or properly transferred.
- Assuming the logbook entry is enough. A common misconception is that once the IA makes an entry in the aircraft logbook, their obligation is complete. The separate personal record at the fixed base is an independent, additional requirement under §65.91(c)(2).
- Forgetting the fixed-base location requirement. Test questions may describe an IA holder performing inspections at multiple remote locations. The records must be maintained at the fixed base on file with the FAA, not at the location where the inspection happened to take place.
- Mixing up renewal deadlines and activity requirements. Students sometimes confuse the March 31 renewal date with requirements from Part 91 or confuse the 24-month activity lookback with the two-year record retention period. These are different rules that happen to share a similar timeframe.
- Overlooking the disapproval entry requirement. Some students focus only on the approval scenario. If an aircraft fails the annual inspection, the IA holder must still make a proper entry listing each discrepancy, and the aircraft owner must be notified in writing. The aircraft may not be flown until the discrepancies are corrected and the aircraft is re-inspected and approved.