Continuing Airworthiness Records: The Airworthiness Memory of the Aircraft

In aircraft maintenance and continuing airworthiness, records are part of the regulatory system that controls and demonstrates the continuing airworthiness status of an aircraft at any point in time.

ICAO distinguishes two closely related record categories: maintenance records and continuing airworthiness records. In practice, the terminology used in regulations and industry guidance is not always consistent, and the term “technical records” is often used to refer to one or both depending on the organization or regulatory context.

Maintenance records: evidence of maintenance performance

Maintenance records are the records that describe maintenance actions performed on an aircraft or component. They provide evidence that maintenance has been carried out in accordance with approved data, procedures, and regulatory requirements.

Typical maintenance records include:

• Technical logbook entries

• Work orders and work packs

• Task cards and inspection sheets

• Non-routine cards

• Certificates of Release to Service (CRS), including Authorized Release Certificates for components

These records are primarily generated and retained by approved Part-145 maintenance organizations. Their purpose is to demonstrate compliance with maintenance requirements and approved maintenance procedures.

In essence, maintenance records document:

• what maintenance was performed

• when it was performed

• under what approval it was released

They describe maintenance execution, not the aircraft’s continuing airworthiness status.

Continuing airworthiness records: evidence of airworthiness status

Continuing airworthiness records are the records that reflect the current continuing airworthiness status of an aircraft, engine, propeller, or component. They are maintained by the operator or the approved Continuing Airworthiness Management Organization (CAMO), in accordance with applicable continuing airworthiness requirements.

They answer a different question from maintenance records:

• what is the current airworthiness status of the aircraft and its components?

These records include, as applicable:

1. Basic data

This includes:

• date of the entry

• total in-service time accumulated (e.g. flight hours or flight cycles)

It provides the usage basis for all airworthiness assessments.

2. Continuing airworthiness status records

This is the core compliance layer, including:

• Airworthiness Directive (AD) compliance status

• Aircraft Maintenance Program (AMP) status and task completion tracking

• modification and repair status affecting the type design

• component requirements status, including Life-Limited Parts and Time-Controlled Components where applicable

• deferred defects status

This layer defines the aircraft’s compliance state.

3. Aircraft technical log system

The aircraft technical log provides the operational interface between flight operations and maintenance. It typically records:

• reported defects

• maintenance actions between flights

• flight crew and maintenance coordination entries

It ensures continuity of airworthiness control during operational use.

4. Supporting maintenance records

These are the detailed maintenance records that provide the technical evidence behind the continuing airworthiness status, including Certificates of Release to Service.

Relationship between maintenance records and continuing airworthiness records

Although distinct in function and responsibility, the two record types are operationally linked and often overlap. For example:

• A Certificate of Release to Service confirms maintenance completion and is used to update airworthiness status records

• Aircraft technical log entries support updates between maintenance events and operations

However, not all maintenance records become continuing airworthiness records.

For example:

• Certificates of conformity for parts and raw materials

• batch traceability documentation

• internal workshop task card details

• internal quality and production records

From a regulatory perspective, these remain within the maintenance organisation as maintenance evidence and are not required to be transferred to the operator’s continuing airworthiness records unless relevant to continuing airworthiness control, compliance demonstration, or reliability analysis, which is why in practice some of them are transferred.

Conclusion

Maintenance records document what has been done. Continuing airworthiness records reflect the resulting airworthiness status.

Together, they form a linked system: maintenance provides the evidence, and continuing airworthiness records translate that evidence into the current airworthiness status of the aircraft.

In this way, continuing airworthiness records act as the operational memory of the aircraft, supporting demonstration of airworthiness at any point in its life.

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