Pilot Records Database (PRD): What Part 135 Operators Must Report — and When

Under 14 CFR § 111.225, Part 135 operators generally have 30 days from the effective date of a covered record to report it to the FAA’s pilot records database. Miss that window, and the operator faces potential enforcement action — and a gap in the very system designed to prevent unqualified pilots from slipping through the cracks.

This article covers what Part 135 operators must report to the pilot records database, the precise deadlines they must meet, and the internal workflows that make timely compliance possible. This is not a beginner’s explainer. It is a regulatory briefing for compliance professionals, chief pilots, training managers, and records personnel who need to understand PRD as an ongoing record governance obligation — not a one-time prehire checkbox.

What Is the FAA Pilot Records Database?

The pilot records database is the FAA’s centralized system for sharing pilot employment and safety records among covered operators. Governed by 14 CFR Part 111, the PRD FAA system replaced the older PRIA-based process that required operators to chase down records from previous employers through a fragmented, paper-driven workflow. The FAA PRD consolidates that function into a single, authoritative database.

Covered operator categories include Part 121 air carriers, Part 135 operators, and certain other commercial operators. The pilot records database serves three primary functions: pre-employment record evaluation, ongoing record reporting by current employers, and pilot self-review. Each function carries its own compliance obligations and timelines.

For Part 135 operators specifically, the PRD framework means that record governance is now a continuous responsibility — not a task that ends once a pilot is onboarded. The FAA PRD is the mechanism through which hiring decisions are informed, employment histories are documented, and safety-critical records are made accessible across the industry.

PRD vs. PRIA: What Changed for Part 135 Operators

A persistent misconception in the Part 135 community is that PRIA and PRD are the same thing. They are not. The Pilot Records Improvement Act (PRIA) of 1996 established a decentralized, request-based process: operators had to individually contact previous employers and the FAA to obtain pilot records, often relying on faxes, mailed requests, and manual tracking. The FAA pilot records database replaced that workflow with a centralized, digital system where covered records are reported, stored, and accessed through a single FAA-managed portal.

The transition from PRIA to PRD also created a one-time but high-stakes migration obligation. Part 135 operators were required to migrate historical PRIA records dating from August 1, 2005 through June 10, 2022 into the PRD in the FAA-prescribed format. June 10, 2022 is the FAA’s historical cutoff date for legacy records. Operators who failed to complete this migration left a gap in their compliance posture — one that an FAA audit would surface quickly.

The difference between PRIA and the FAA pilot records database is structural, not cosmetic. PRIA was a process. PRD is a platform. Understanding the pilot records database requirements starts with recognizing that distinction.

What Part 135 Operators Must Report to the Pilot Records Database

The types of records Part 135 operators must report are defined in 14 CFR Part 111, Subpart C. Reporting begins on the pilot’s PRD “date of hire” — the date that triggers the operator’s obligation as a reporting entity. From that point forward, the operator must report covered records to the PRD as they occur. PRD reporting Part 135 obligations are not a one-and-done filing at the time of hiring.

Key reportable record categories under the pilot records database requirements include:

• Training records — completion of required training events, including initial, recurrent, and upgrade training tied to the pilot’s qualification under 14 CFR Part 135.
• Qualification and proficiency events — checkrides, competency evaluations, and other qualification milestones or failures.
• Disciplinary action records — any formal disciplinary action taken against the pilot related to performance, conduct, or compliance, including those related to drug and alcohol testing.
• Separation-from-employment records — documentation of the pilot’s departure from the operator, including the circumstances of the separation.
• Pilot employment records — factual data about the pilot’s dates and terms of service with the operator.

The misconception that once a pilot is hired the records file can be left alone is a compliance liability. Updates, corrections, and new reportable events all remain ongoing obligations. PRD reporting for Part 135 operators is a continuous compliance process, not a prehire screen.

The 30-Day PRD Reporting Deadline — and Where It Gets Nuanced

This is where the regulatory clock matters most. Under 14 CFR § 111.225, covered records must generally be reported to the pilot records database within 30 days of the effective date of the record. That is a hard deadline, not a guideline. If the operator is short-staffed, mid-audit, or in peak season, the 30-day clock does not pause.

The critical nuance lies in how that clock starts for certain record types. For disciplinary action and separation-from-employment records, the 30-day reporting window begins only after the record becomes final — not from the date of the event itself. This distinction trips up operators regularly. A disciplinary action that is still under internal appeal or grievance review has not been finalized. The regulatory clock starts when the outcome is confirmed and the record is no longer subject to reversal.

Beyond the primary reporting deadline, industry compliance guidance references additional timelines that Part 135 operators should track:

• 14-day window — industry guidance cites this as the expected response time for certain PRD information requests after receipt.
• 10-to-30-day window — industry guidance for investigating and correcting disputed records once an inaccuracy is identified.

These timeframes are drawn from industry compliance materials rather than directly from the CFR. They reflect the operational tempo the FAA expects of reporting entities. The PRD reporting timeline of 30 days for Part 135 operators is not flexible. Treat it as a regulatory clock with enforcement consequences.

The Pre-Employment Gate: No PRD Review, No Covered Service

Before a pilot begins covered service under Part 135, the operator must complete a pre-employment pilot record check through the pilot records database. This is a hard regulatory gate, not a formality that can be deferred or completed after the pilot’s first trip. A pilot may not begin covered service until the PRD review is complete.

The FAA PRD portal and FAA pilot records database login workflow are the mechanisms for completing this review. Operators access the FAA pilot records database login to initiate and document the pre-employment evaluation. The system is fully operational and embedded in current hiring practice across covered operators.

The liability exposure is direct: if an operator allows a pilot to fly without completing the PRD record check, and that pilot has undisclosed disciplinary history or qualification deficiencies, the operator bears both the enforcement risk and the safety consequence. Pilot hiring requirements under the PRD framework are non-negotiable. The pre-employment gate exists to catch what previous employers have reported — but only if the operator actually checks before assigning the pilot to covered service.

Building Internal PRD Compliance Workflows

Knowing the rules is one thing. Executing them reliably across a Part 135 operation is another. Operators need standardized internal procedures for capturing reportable events, routing them for review, and meeting the 30-day timeline — every time, for every pilot.

The most common failure point is unclear role assignment. Who owns PRD compliance: HR, the chief pilot, the training department, or operations? In many Part 135 organizations, the answer is ambiguous, and ambiguity breeds missed deadlines. Operators should assign clear ownership with defined escalation paths. When a reportable event occurs — a training completion, a disciplinary action, a separation — the responsible party must know they own the submission and understand how to report records to the FAA PRD.

Effective PRD compliance workflows should include:

• Role-specific training — HR, chief pilots, training managers, and records personnel should each understand the PRD workflow steps relevant to their function, including document retention requirements and escalation rules.
• Secure access and permissions — FAA PRD portal access should be managed with role-based permissions and documented login procedures. Not everyone needs full access, but the right people must have it.
• Event-capture triggers — standardized procedures that flag reportable events as they happen, rather than relying on end-of-month batch reviews that risk blowing the 30-day deadline.
• Dispute and correction protocols — industry guidance emphasizes that operators must maintain strong internal procedures so pilot records database entries are uploaded promptly and corrected quickly if inaccurate. A disputed record still has a clock running on it.

PRD compliance should be treated as part of a formal safety management and quality assurance culture — an audit-ready system, not an ad hoc process. Aviation safety record governance is a discipline, and it requires repeatable, trained workflows.

E-learning programs designed for Part 135 operators can provide the structured, repeatable training needed to keep PRD submissions timely and audit-ready across every role in the organization. Explore CTS’s Part 135 training programs to build PRD-ready compliance workflows across your operation.

Frequently Asked Questions About the Pilot Records Database

What Must Part 135 Operators Report to the FAA Pilot Records Database?

Under 14 CFR Part 111, Subpart C, Part 135 operators must report training records, qualification events, disciplinary actions, and separation-from-employment records. Reporting begins on the pilot’s PRD date of hire and continues throughout the pilot’s tenure. The pilot records database requirements apply to all covered pilot employment records, not only those generated at the time of hiring.

How Long Do Part 135 Operators Have to Submit Records to the PRD?

The general deadline under 14 CFR § 111.225 is 30 days from the effective date of the covered record. For disciplinary action and separation-from-employment records, the 30-day clock starts after the record becomes final. These are hard regulatory deadlines — not targets that flex based on operational workload.

What Is the Difference Between PRIA and the FAA Pilot Records Database?

PRIA was a decentralized, paper-heavy process requiring operators to individually request records from prior employers and the FAA. The FAA PRD replaced that workflow with a centralized database. Historical PRIA records from August 1, 2005 through June 10, 2022 had to be migrated into the PRD by covered operators, including Part 135 certificate holders.

Can a Pilot Begin Flying Before a PRD Record Check Is Complete?

No. A pilot may not begin covered service until the PRD review is complete. This is a hard regulatory gate under the PRD framework, not a recommended best practice. Operators who allow pilots to fly before completing the pre-employment pilot record check face enforcement risk and direct liability exposure.

How Does a Pilot Check Their Own FAA Pilot Records Database Entry?

Pilots can access the FAA PRD portal to review their own records. The FAA pilot records database login provides individual pilots with visibility into what current and former employers have reported. Pilots should check their records periodically for accuracy, since errors or omissions can affect future employment decisions.

The pilot records database is not a passive archive. For Part 135 operators, it is a living compliance system with hard deadlines, defined record categories, and real enforcement consequences. Operators who build disciplined internal workflows — with clear ownership, role-specific training, and audit-ready documentation — will meet their obligations under 14 CFR Part 111 without scrambling. Those who treat PRD reporting as an administrative afterthought will find that the regulatory clock does not wait.