D E D I C A T E D T O H E L P I N G B U S I N E S S A C H I E V E I T S H I G H E S T G O A L S.

PILOT RECORDS DATABASE

RESOURCE GUIDE

Pilot Records Database 1

BACKGROUND
On May 26, 2021, the the Federal Aviation Administration (FAA) announced a new rule that enables the sharing of pilot
records among employers in an electronic database maintained by the FAA. The Pilot Records Database (“PRD”) rule, found
in new part 111 of the Federal Aviation Regulations (“FAR”), became effective on August 9, 2021. It requires air carriers and
certain other operators to: (i) report pilots’ employment history, training, and qualifications to the database (“Reporting Re-
quirements”); and (ii) review records contained in the database when considering pilots for employment (“Review Require-
ments”). Subpart A of the PRD rule describes the general applicability of the rule, including definitions and instructions for
database access. Subpart B of the PRD rule outlines the Reviewing Requirements, while subpart C outlines the Reporting
Requirements. Finally, subpart D is dedicated to Pilot Access and Responsibilities.

The PRD rule will phase out the current Pilot Records Improvement Act (“PRIA”) procedures that require air carriers to solicit
pilot records from past employees and instead attempts to consolidate relevant records in one database. The PRIA will re-
main in effect for approximately three years (or until September 9, 2024) to allow for all of the requirements of the new PRD
rule to be implemented. NBAA’s PRIA guide can be accessed here.

DISCLAIMER: This guide has been prepared to provide general advice to NBAA members regarding their responsibility to make or
respond to PRD requirements and obligations. While every effort has been made to include only accurate information, this guide
should not be considered legal advice, and NBAA members are encouraged to consult with their aviation counsel regarding any
specific questions or concerns regarding compliance with PRD and/or PRIA.

COMPLIANCE TIMELINE

DATE Sept. 8, 2021 Dec 7, 2021 June 10, 2022 June 12, 2023 Sept. 9, 2024
EVENT Register for PRD Must use PRD Begin (1) report- Complete re- PRIA ends; full
access to view FAA ing current & porting historical compliance with
records. historical pilot records gener- PRD. Upload
records; (2) re- ated on or after historical records
viewing operator 1/1/2015. generated be-
records in PRD. fore 1/1/2015

ENTITY Reporting and Air Carriers; Reporting enti- Air Carriers (part All reporting
reviewing enti- not required for ties and review- 121, 125, 135, or and reviewing
ties Flight Dept. or ing entities. 91K) entities.
Public Aircraft
Operations
(PAO)

• Reviewing Entity: Part 119 certificate holders, fractional ownership programs and persons conducting air tour
operations.
• Reporting Entity: All reviewing entities, as well as corporate flight departments and public aircraft operations

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APPLICABILITY

The PRD rule applies to various operators, although not all parts apply to each operator. In general, the Review Require-
ments apply to:

• Part 119 certificate holders;
• Operators that perform operations under the fractional ownership rules (“fractional ownership operators”); and
• Air tour operators holding a Letter of Authorization (LOA).

On the other hand, the Reporting Requirements apply to:

• Part 119 certificate holders;

• Fractional ownership operators;
• Air tour operators;
• Entities conducting public aircraft operations (PAO);
• Corporate flight departments (as defined in the PRD rule) and specific entities operating under part 125; and
• A trustee appointed by a bankruptcy court for an operator or entity subject to the Reporting Requirements.

NOTE: Please note that under the PRD rule the following conditions must be satisfied to meet the definition of a “corporate flight
department”: (i) the operator operates two or more aircraft; (ii) the aircraft are standard airworthiness airplanes that require a type
rating under 14 CFR part 61, § 61.31(a) and/or turbine-powered rotorcraft; (iii) the aircraft is operated in furtherance of or incidental
to a business; and (iv) the operation is solely pursuant to the general operating and flight rules in 14 CFR part 91, or pursuant to a
Letter of Deviation Authority (LODA) issued under 14 CFR part 125, § 125.3.

REPORTING REQUIREMENTS

What Must be Reported?

Reporting entities, as described herein, are required to report certain records to the PRD for each individual employed as a
pilot in accordance with part 111 subpart C. These records include training, qualification and proficiency records, final disci-
plinary actions, drug and alcohol records, and records concerning separation of employment. It is important to note that not
all records must be submitted by all reporting entities as the requirements vary based on the type of operator. We recom-
mend reviewing the Appendices included in AC 120-68J when determining the type of documents that must be reported
by an individual operator.

For ease of reference, the following table summarizes the type of records that are required to be reported by the reporting
entities:

TYPE OF Part 121 and 135 Part 125 Part 91K Air Tour Opera- Corp. Flight
RECORDS Operators Operators Operators tors per §91.147 Dept. & PAO
Drug and  X X  X
Alcohol

Training, Qual-     
ification and (may be report- (may be report-
Proficiency ed on request) ed on request
Records

Final     
Disciplinary (may be report- (may be report-
Action ed on request; ed on request;
exceptions exceptions
apply) apply)

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 Separation of     
Employment (may be report- (may be report-
ed on request; ed on request;
exceptions exceptions
apply) apply)

Motor   X X X
Vehicle
Driving

When to Report

Generally, these records must be reported to the PRD contemporaneously, within the time set by the FAA upon occur-
rence of the event causing creation of the record, which is typically 30 days. However, operators conducting PAO, air tour
operators and corporate flight departments are not required to report training qualification and proficiency records, certain
final disciplinary action records, or certain records concerning separation of employment, unless and until they receive a
request from a reviewing entity. If, however, the record memorializes a disciplinary action resulting in permanent or tempo-
rary removal of the pilot from aircraft operations or separation from employment resulting in termination, the record must
be reported to the PRD contemporaneously.

No operator may report pilot records related to a safety event that the entity reported as part of the Aviation Safety Action
Program (ASAP) or any other approved Voluntary Safety Reporting Program.

Reported records containing inaccurate information must be corrected within 10 days of knowledge that the record con-
tains an error. When the operator does not agree that the record contains an error, it must notify the pilot that the dispute
will be resolved in accordance with the operator’s dispute resolution procedures. Each reporting entity must have a doc-
umented process for investigating and resolving record disputes in a reasonable amount of time. Once resolved, final
disposition of the dispute must be documented in the PRD.

Historical vs. Current Records

Records dated before one year after publication of part 111 (or before June 10, 2022) are considered historical records and
any records created on or after one year after publication of part 111 (or after June 10, 2022) are considered new records.

The following table summarizes the record reporting requirements by type of entity:

Corporate Flight Dept., Air

Part 121 and 135 Air Part 121, 125, and 135 Opera-
Type of Records Tour Operators per §91.147
Carriers tors and Part 91K Fractionals
& PAO

Records predating
N/A N/A N/A
8/1/2005

Records dating 8/1/2005-

Must Report N/A N/A
7/31/2010

Records dating 8/1/2010-

Must Report Must Report Voluntary Reporting
6/9/2022

New Records: Records

Must Report Must Report Must Report
created after 6/10/2022

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REPORTING REQUIREMENTS: SPOTLIGHT ON PAO, AIR TOUR OPERATORS, AND CORPORATE FLIGHT DEPARTMENTS

Beginning on June 10, 2022, entities conducting public aircraft operations, air tour operators holding a LOA issued in accor-
dance with 14 CFR part 91, § 91.147, and corporate flight departments (as defined in the PRD rule) must report the follow-
ing types of company records, which were created 1 year after publication of the PRD rule or June 10, 2022:

• Drug/Alcohol Testing (§ 111.220)

• Training/Qualification/Proficiency (§ 111.225)
• Final Disciplinary Action (§ 111.230)

These records must be reported within 14 days of request. If the operator does not possess the requested document,
the operator must provide a statement to that effect.

However, in cases where disciplinary action results in permanent or temporary removal of the pilot from aircraft operations
or a separation from employment results in termination, the record must be reported to the PRD contemporaneously,
meaning within 30 days of occurrence/creation of the document.

The PRD rule does not require PAC operators and corporate flight departments to provide historical data (see §111.255).

REVIEWING REQUIREMENTS

Subpart B of part 111 requires reviewing entities to use the PRD to access and evaluate the qualifications of an individual
candidate in demining whether to hire the person as a pilot. As defined under the PRD rule, reviewing entities include
part 119 certificate holders, fractional ownership programs and persons conducting air tour operators holding LOA under
§91.147, as well as trustees in bankruptcy of those entities. As stated herein, in order to access and evaluate a pilots’ re-
cords, a reviewing entity must receive consent from that pilot.

Review entities are encouraged to involved subject matter experts in the records review process so that potential training
issues may be properly identified. Furthermore, it is important to protect the pilot’s privacy and confidentiality by ensuring
that the information contained in the PRD is not shared with anyone not directly involved in the hiring process.

Reviewing entities must evaluate both the FAA records and records provided by an operator. FAA maintained records
include: (i) current pilot and medical certificate information, including associated type ratings and information on any lim-
itations to those certificates and ratings; (ii) any failed attempt of an individual to pass a practical test required to obtain a
certificate or type rating under 14 CFR part 61; (iii) enforcement actions resulting in a finding by the FAA that was not sub-
sequently overturned; and (iv) records related to an individual acting as pilot in command or second in command during an
aviation accident or incident. Non-FAA records that should be included in the PRD include an individual’s pre-employment
drug and alcohol testing history and other U.S. Department of Transportation drug and alcohol testing.

Reviewing entities must also compare the pilot’s list of former employers dating back five years and verify that no discrep-
ancy exists between the pilot-provided employment history and the records available in the PRD.

Reviewing entities must begin using the PRD to evaluate the FAA records by December 7, 2021 and all other records
submitted by reporting entities (operators) by June 10, 2022. Reviewing entities must also evaluate any records obtained
through the National Driver Register (NDR) process from the chief driver licensing official of a State.

MOTOR DRIVING RECORDS

Each operator authorized to conduct operations under part 121, 125, or 135 is required to request and review all relevant
information identified through a NDR search before allowing that person to begin service as a pilot. Verification of such is
required within 45 days of the PRD Date of Hire.

To obtain records from the NDR, a request must be made to the state which issued the airman’s driver’s license (other
states may also be willing to process NDR requests). Not all states will forward the DMV records request to the NDR. In
these cases, reviewing the record of the state which issued the airman’s driver’s license is sufficient. Most states will use
a unique form to request the driving history of the airman. While the FAA does provide FAA Form 8060-13, National Driver
Register Records Request (PRIA), to request driving records, it should only be used in cases when the state of issuance
does not provide a state-specific form. The NDR will provide a report that indicates if a negative record is located. If a nega-
Pilot Records Database 5
tive record is located, the reviewing entity air carrier or operator must obtain the individual’s record from the state reporting
the negative record. A negative report would include:

• A record of any suspension or revocation of the pilot’s driver’s license from the previous 5-year period, including the
state where the offense occurred; and/or
• A record of any convictions of driving under the influence (DUI) from the previous 5-year period, including the state
where the offense occurred.

Pilots are responsible for designating which reviewing entities are able to access records for review. Before any operator
may access a pilot’s records in the PRD, the pilot must give written consent. Pilots must also provide separate written
consent for operators to submit a request to the NDR for motor vehicle driving records. The pilot has the right to review
both the pilot record reflected in the PRD, as well as a copy of any State motor vehicle driving records that may have been
provided to a prospective employer.

PILOTS

Written Consent

Before any operator may retrieve a pilot’s records in the PRD the pilot must: (i) apply for access to the PRD; and (ii) provide
written consent to the FAA for the release of their records. The pilot’s consent must include an affirmation that the em-
ploy¬ment history of the pilot for the five (5) years prior to the date of the pilot’s consent is accurate and complete. If the
pilot finds that their employment history is not complete, the pilot must update their employment history. This should be
done by clicking on the Experience tab and then clicking on the Add Employer button as indicated below.

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The consent may also include a release from liability for any claim airing from access to the individual’s records in the
PRD by the reviewing entity. An air carrier may refuse to hire a pilot who does not provide the consent and release from
liability. It should be noted, however, that no air carrier may require a pilot to execute a release from liability for any claim
arising from furnishing fraudulent or intentionally false information or known omissions maintained in violation of a criminal
statute. Notwithstanding the consent and release of liability, air carriers should be mindful to produce only those records
required and not any extraneous records. The production of extraneous records or materials falling outside the scope of
what the air carrier is required to produce could lead to potential claims (e.g. invasion of privacy, defamation, tortious inter-
ference) by the pilot against the air carrier for which the liability release may not be effective.

Initially, consent allowing Part 121, 125, 135 or 91K air carriers access to a pilot’s records within the PRD can be granted by
clicking on the “consent” tab on the PRD menu.

Category of Information Who to contact to correct inaccuracies

Certificate or Medical Information provided by the FAA Airmen Certification Branch at 866-878-2498

Accident/Incident Information FAA Office who investigated the Accident/Incident

Enforcement Action FAA Office that investigated the enforcement case

Employer or prospective employer who reported the

Drug and Alcohol Testing Information
violation

Employment Records Former Employer

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In order to provide consent to allow other air carrier’s access to a pilot’s records, the pilot should use FAA Forms 8060-10,
8060-10A, 8060-11, 8060-11A, 8060-12, and/or 8060-13.

Pilot Employer Disputes

Reporting entities must have a documented process for investigating and resolving disputes as to the accuracy of reported
records. The process must provide for a resolution within a reasonable amount of time.

If a reporting entity learns of an inaccuracy in previously reported records the reporting entity must correct same within
ten (10) days of knowledge that the record contains an error. If the reporting entity does not agree that there is an error,
the reporting entity must advise the pilot that the dispute will be resolved in accordance with the reporting entity’s dispute
resolution procedures.

Once a dispute is resolved, the final disposition must be documented in the PRD.

TRANSITION FROM PRIA

According to the PRD rule, the FAA intends for the transition from PRIA to PRD to take slightly more than three years and
to be completed on or about September 9, 2024. The transition will be in phases.

Action Starting Date

FAA records accessed through PRD September 9, 2021

Reporting entity adds new records to PRD June 10, 2022

Reviewing entity starts reviewing records in PRD while

June 10, 2022
still complying with PRIA

During the transition, reporting entities are required to respond to PRIA requests for historical records but have the option
of reporting those historical records by adding them to the PRD for review. The PRD will display a statement that a report-
ing entity has completed reporting all records for a pilot or a statement advising that a PRIA request should be submitted.
Operators not required to request records when hiring pilots should still respond to request for PRIA-related records (not to
be confused with company records).

SETTING UP AN ACCOUNT

Each operator must submit an application for access to the PRD by September 8, 2021 or at least 30 days before the oper-
ator or entity initiates aircraft operations.

The following information will be required during the application:

• Full name, job title, telephone number, and electronic mail address of the responsible person (RP);
• The name of the operator;
• The FAA air carrier or operating certificate number, as applicable; and
• Any other item the Administrator determines is necessary to verify the identity of all individuals designated by an
operator to access the PRD.

NOTE: PRD is only for uploading, reviewing, or retrieving records in accordance with the requirements of part 111. No person may
use the PRD for any purpose other than to inform a hiring decision concerning a pilot or to report information on behalf of the
operator. Each person that accesses the PRD to retrieve a pilot’s records must protect the confidentiality of those records and the
privacy of the pilot as to those records.

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TYPES OF ACCOUNTS

Responsible Person (RP)

An individual employed by an operator who manages records and user accounts and is responsible for all actions taken
within the PRD for a particular operator. The RP is accountable for ensuring that any person accessing the PRD complies
with part 111 when reporting or reviewing records on behalf of the RP. The PRD Administrator approves the RP. All oth-
er user roles and accounts, excluding pilot accounts, are approved by each operator’s RP or user manager. The RP may
delegate his or her authority to access the database to certain other persons, but continued access is contingent on the
validity of the RP’s electronic access. If an RP’s electronic access is cancelled, the database access of authorized users and
proxies will be cancelled unless the operator submits an amended application for database access. Only certain individuals
can qualify as the RP depending on the type of operator:

• For operations under part 125, the RP should be a person serving in a management position required by § 125.25(a).
• For operations under part 135, the RP should be a person serving in a management position required by § 119.69(a).
• For operations under § 91.147, the RP should be a person designated as the RP on the operator’s LOA.
• For operations under part 91K, the RP should be a person designated by the fractional ownership program manager
and who is employed by the fractional ownership program.
• For all other operators, the RP should be employed by the operator.

Authorized User

An individual employed by an operator who is designated by a RP to access the PRD on behalf of the employer for purposes
of reporting and evaluating records that pertain to an individual pilot applicant. Authorized user roles include the following:

• For operations under part 125, the RP should be a person serving in a management position required by § 125.25(a).
• For operations under part 135, the RP should be a person serving in a management position required by § 119.69(a).
• For operations under § 91.147, the RP should be a person designated as the RP on the operator’s LOA.
• For operations under part 91K, the RP should be a person designated by the fractional ownership program manager
and who is employed by the fractional ownership program.
• For all other operators, the RP should be employed by the operator.

Proxy

An organization or individual that is not directly employed by an operator that has been assigned access rights to the
PRD. The Proxy RP will be approved by the operator’s RP. The Proxy RP may delegate additional proxy roles as needed to
perform the required functions within the PRD.

REGISTRATION INSTRUCTIONS

Electronic access to the PRD has two separate registration steps: (i) Creation of an account in MyAccess and (ii) PRD account
registration. Each PRD account can have multiple user roles as needed.

Each user should not create multiple MyAccess accounts with different email addresses. Because a user’s permissions in
the various applications which use MyAccess are directly controlled by the user’s unique MyAccess account, if a user creates
multiple MyAccess accounts, the user may be locked out of various applications or have restricted access to applications.

Registering for MyAccess

• Before proceeding with the registration process, clear the internet browser’s cache/cookies, close the browser, open it,
and proceed to prd.faa.gov. Either Chrome or Internet Explorer may be used to access the PRD.
• Create a MyAccess profile first by clicking “PRD Airman Records,” which leads to the MyAccess landing page.

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 • Click “Register Now” and follow the directions. Enter the information required for identity verification. The FAA
recommends using a personal email address, as this account will stay with the user even if the user changes
companies in the future.

• After registering for an account, log in from the MyAccess page to complete the Pilot New User Registration. After
completing the new user registration, the user be able to view any records that have been uploaded under the pilot’s
name or certificate number.

NOTE: If the user is unable to successfully complete the identity verification process, that person may not be able to create an
account in MyAccess. Contact the FAA Help Desk at 844-322-6948 for assistance with MyAccess. To ensure the user contacts the
correct support staff, users should specify that they are having trouble creating an account in MyAccess. If the caller tells them the
trouble is with the PRD, the Help Desk will send the user to the PRD support staff who cannot assist with MyAccess concerns.

Registering as a Responsible Person (RP)

RP registrations are approved by the FAA’s PRD administrator. The PRD administrator may contact the applicant or other
company personnel to verify eligibility.

• To register as an RP, first sign out of MyAccess and return to the prd.faa.gov page.
• Click on “Air Carrier Tools”, which will once again leads to the MyAccess login page.
• Once logged in the PRD Air Carrier/Operator New User Registration page will appear.
• Fill out all required* information, and also choose a user title (not marked with an asterisk) from one of the drop-down
options. When filling out the “Air Carrier/Operator” block, begin typing the name of the company (not a dba) that the
FAA has on file for any registered approvals (OpsSpec/MSpec/LOA). If the database has a match with the company
name, it should appear as an option along with the identifier that the FAA has on file (this is different than the operator
ID that appears on OpsSpecs and LOAs). Click on it to select it.
• Once the form is complete, submit the application for approval.
• RP access provides the ability to view and download airman records. The ability to upload records will begin in August
2022.

If an operator’s RP changes, the operator must submit an amended application identifying the new RP immediately when
the operator becomes aware of information that would cause the current RP’s database access to be cancelled or denied.

Creating User Accounts and Roles in the PRD

Although each individual should have only one MyAccess account, a person may register for various user roles in the PRD,
as appropriate. Users may register as an Authorized Consumer, Contributor, or User Manager. These roles are approved,
edited, or rejected by the operator’s RP. After a registration request is submitted for one of these roles, the RP or a user
manager, approves or rejects the request.

During the registration process for certain user accounts and roles in the PRD, a person
will be asked to indicate for which operator that individual is registering. It is important that the correct company entry be
selected. The available operators are loaded from one of the FAA’s databases. Some operators use a “doing business as”
(DBA) name which is different from the official operator name recognized by the FAA. The PRD does not support DBAs, so
it is important to use the primary company name as entered in the FAA’s database.

Many operators have very similar names, so the PRD also displays a unique code alongside the operator. If an operator
has been issued a “designator” by the FAA, then the designator will be displayed with the operator’s name. If the operator
does not have a designator code, the PRD generates a unique key which is displayed in place of a designator. For example,
“Sample Operator (NM00RNTECODSF TEST)”.

It is also possible that an operator is not known to the FAA and does not appear in the selection list. If the appropriate
operator name cannot be found when registering in the PRD, email 9-AMC-AVS-PrdSupport@faa.gov for assistance.

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Registering as a Proxy

Proxies who wish to access the PRD on behalf of an operator will create a Proxy RP account. Additional proxy roles are
available and those roles generally work the same as non-proxy accounts. The biggest difference is that a Proxy RP account
is always a specific combination between an operator and a proxy company. When a Proxy RP wishes to register for
access to an operator’s records, the operator RP must approve the request. Once approved, the Proxy RP has access to
the same records as the operator RP. The Proxy RP can also approve other proxy users, such as proxy consumers, to have
access to the same records for that specific operator. The operator RP or PRD administrator can revoke access at any time.

Registering as a Pilot

The PRD is prepopulated with information about pilots who hold commercial pilot, remote pilot, and ATP certificates. This
preloading of pilot information allows the PRD to register pilots in the PRD and ensure valid pilot certificate numbers are
being used when operators are entering records. After a pilot logs in via MyAccess, the pilot will arrive at the PRD pilot
registration screen unless they have already created a pilot role in the PRD.

If the pilot has created an account in MyAccess, but cannot register as a pilot in the PRD, the pilot should consult AC 120-
68J, or email the PRD support account at 9-AMC-AVS-PRDSupport@faa.gov for assistance.

ADDITIONAL RESOURCES

According to the PRD rule, the FAA intends for the transition from PRIA to PRD to take slightly more than three years and
to be completed on or about September 8, 2024. The transition will be in phases.

14 CFR 111 – Pilot Records Database

FAA Advisory Circular 12-68J, Pilot Records Database and Pilot Records Improvement Act
FAA Pilot Records Database
FAA Pilot Records Database User Guides
National Drivers Registry (NDR)

ACKNOWLEDGMENTS

NBAA thanks the volunteers of NBAA’s Regulatory Issues Advisory Group who developed and reviewed this association
publication. The principal authors are Alison Squiccimarro of Law Offices of Paul A. Lange, and Marina O’Brien of Holland
& Knight. For additional guidance on the Pilot Records Improvement Act, visit the NBAA website at www.nbaa.org/pria.

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