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14 CFR 43.9 vs 43.11: A&P Maintenance Record Entries Explained

Last updated October 5, 2026

14 CFR 43.9 covers the record entry for maintenance, preventive maintenance, rebuilding and alteration. 14 CFR 43.11 covers the record entry for inspections done under part 91 (such as annual, 100-hour and progressive inspections) and a few other operating rules (AC 43-9D, Maintenance Records and FAA Form 8130-3 Return to Service, para 13.2, p. 8). A 43.9 entry says what work was done, when, and who approved it; a 43.11 entry adds the aircraft’s total time in service and a certification statement that the aircraft was, or was not, found airworthy (14 CFR 43.9 and 14 CFR 43.11).

Why this matters on the General test

Record entries sit in subject I of the A&P General test, Regulations, Maintenance Forms, Records, and Publications. The FAA blueprint gives that subject 5 to 10 percent of the 60 questions (Companion Guide to the mechanic ACS, FAA-G-ACS-1, Change 2, ch. 3, p. 13). The Aviation Mechanic ACS, FAA-S-ACS-1 lists these elements, among others (p. 14):

  • AM.I.I.K3: maintenance record entry for approval for return to service after maintenance and alterations.
  • AM.I.I.K4: maintenance record entry for approval for return to service after inspection.
  • AM.I.I.K5: the purpose and use of FAA forms, including Form 337.
  • AM.I.I.K20: discrepancy records or placards.
  • AM.I.I.R1: completeness or accuracy of documentation.

What a 43.9 entry must contain

Each person who maintains, performs preventive maintenance on, rebuilds or alters an aircraft, airframe, engine, propeller, appliance or component part must make an entry in that item’s maintenance record with (14 CFR 43.9(a)):

  1. A description of the work performed, or a reference to data acceptable to the Administrator (43.9(a)(1)).
  2. The date the work was completed (43.9(a)(2)).
  3. The name of the person who did the work, if that is not the person approving it (43.9(a)(3)).
  4. If the work was done satisfactorily, the signature, certificate number and kind of certificate held by the person approving it (43.9(a)(4)).

The last sentence of 43.9(a)(4) is the one to remember: “The signature constitutes the approval for return to service only for the work performed.” The Aviation Maintenance Technician Handbook - General, FAA-H-8083-30B sums up the entry as what, when and who (ch. 2, p. 2-16).

How much detail? Enough that “a person unfamiliar with the work” can understand what was done and the methods used. For long jobs you may reference documents such as the manufacturer’s manual, service bulletins or work orders instead (AC 43-9D, para 8.4, pp. 3-4).

Two exceptions are written into the section. Part 121 and 135 operators with a continuous airworthiness maintenance program make their records under part 121 or 135 (43.9(b)), and 43.9 does not apply to inspections under part 91, 125, 135.411(a)(1) or 135.419 (43.9(c)). Those inspections go under 43.11.

What a 43.11 entry must contain

The person approving or disapproving an item for return to service after an inspection under part 91, 125, 135.411(a)(1) or 135.419 must make an entry with (14 CFR 43.11(a)):

  1. The type of inspection and a brief description of its extent (43.11(a)(1)).
  2. The date of the inspection and the aircraft total time in service (43.11(a)(2)).
  3. The signature, certificate number and kind of certificate of the person approving or disapproving (43.11(a)(3)).
  4. A certification statement. If the aircraft is airworthy, the rule gives this wording “or a similarly worded statement”: “I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.” (43.11(a)(4)).
  5. If it is not approved, a statement that it was inspected “and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator.” (43.11(a)(5)).

Progressive inspections use their own statement, naming a “routine inspection” and a “detailed inspection” (43.11(a)(6)). If the inspection is part of an inspection program, the entry must identify the program, the part of it accomplished, and state that it was done under that program’s inspections and procedures (43.11(a)(7)).

Time in service, for maintenance records, means the time from when the aircraft leaves the surface of the earth until it touches down at the next point of landing (14 CFR 1.1).

43.9 vs 43.11 side by side

14 CFR 43.9 14 CFR 43.11
Used for Maintenance, preventive maintenance, rebuilding, alteration Inspections under part 91, 125, 135.411(a)(1), 135.419
Who makes it Each person who does the work (43.9(a)) The person approving or disapproving for return to service (43.11(a))
What Description of work, or reference to acceptable data Type of inspection and brief description of its extent
When Date the work was completed Date of the inspection
Total time in service Not required (AC 43-9D, para 8.7.1) Required (43.11(a)(2))
Who Name of person doing the work if different; signature, certificate number and kind of certificate of approver Signature, certificate number and kind of certificate
Set wording None (AMT General handbook, ch. 2, p. 2-16) “I certify…” airworthy or discrepancy statement
Extra paperwork Form 337 for major repairs and major alterations (43.9(d)) Signed, dated discrepancy list if unairworthy (43.11(b))

Discrepancy lists and placards

If an inspector finds the aircraft unairworthy, or not meeting its type certificate data, airworthiness directives or other approved data, they must give the owner or lessee a signed and dated list of the discrepancies (14 CFR 43.11(b)). For items allowed to be inoperative under 91.213(d)(2), the inspector also placards each inoperative instrument and the cockpit control of each inoperative item “Inoperative” and adds them to that list (43.11(b)). The owner or operator must make sure the placards are installed (14 CFR 91.405(d)).

A discrepancy list says, in effect, that the item is airworthy except for the listed items, so every discrepancy must be on it. The entry in the record should reference the list (AC 43-9D, paras 14.2 and 14.4, pp. 8-9).

Once the listed items are fixed and recorded under 43.9, the aircraft is approved for return to service. No second inspection is needed, and you do not have to contact the inspector who disapproved it (AMT General handbook, ch. 2, p. 2-17).

Major repairs and alterations: Form 337

A major repair or major alteration needs the 43.9 entry plus a form (14 CFR 43.9(d)). Under 14 CFR part 43, appendix B, para (a), the person doing the work must:

  • Execute FAA Form 337 at least in duplicate.
  • Give a signed copy to the aircraft owner.
  • Forward a copy to the FAA Aircraft Registration Branch in Oklahoma City within 48 hours after the item is approved for return to service.

A certificated repair station may use the customer’s work order and a maintenance release instead, but only for major repairs made under a manual or specifications acceptable to the Administrator, never for major alterations (appendix B, para (b); AC 43-9D, para 19.1, p. 10). Extended-range fuel tanks in the passenger or baggage compartment need Form 337 in at least triplicate, with one copy on board the aircraft (appendix B, para (d)).

Sample entries (all made up)

These are original examples to show the required parts. The aircraft, names, dates and certificate numbers are invented. “A&P” and “IA” show the kind of certificate, abbreviations AC 43-9D lists (para 8.6, p. 4).

Example 1: a 43.9 maintenance entry

October 2, 2026. Removed and replaced left main landing gear brake linings
per Example Aircraft Co. Maintenance Manual, chapter 32 (made-up reference).
Work performed by Sam Placeholder.
Signed: Alex Example, A&P 0000000

What makes it complete: a description or reference (43.9(a)(1)), the completion date (43.9(a)(2)), the name of the person who did the work because someone else approved it (43.9(a)(3)), and the approver’s signature, certificate number and kind of certificate (43.9(a)(4)). No total time is required.

Example 2: a 43.11 annual inspection, approved

October 3, 2026. Total time in service 2,412.6 hours.
Annual inspection of airframe, engine and propeller per part 43, appendix D.
I certify that this aircraft has been inspected in accordance with an annual
inspection and was determined to be in airworthy condition.
Signed: Jordan Sample, A&P 0000000, IA

Performing an annual inspection is an inspection authorization privilege (14 CFR 65.95(a)(2)), so the example shows an IA. The entry has the type and extent (43.11(a)(1)), date and total time (43.11(a)(2)), signature and certificate (43.11(a)(3)) and the airworthy statement (43.11(a)(4)).

Example 3: a 43.11 100-hour inspection, not approved

October 4, 2026. Total time in service 1,108.3 hours.
100-hour inspection of airframe, engine and propeller per part 43, appendix D.
I certify that this aircraft has been inspected in accordance with a 100-hour
inspection and a list of discrepancies and unairworthy items dated October 4, 2026
has been provided for the aircraft owner or operator.
Signed: Alex Example, A&P 0000000

A mechanic with an airframe rating may perform the 100-hour inspection on an airframe, and one with a powerplant rating on a powerplant or propeller (14 CFR 65.85(a), 65.87(a)). The entry is still required when the aircraft is disapproved, because 43.11(a) applies to the person “approving or disapproving.”

How long the owner keeps the records

The owner or operator keeps the records (14 CFR 91.417):

Record Keep until
Maintenance, alteration and inspection entries (91.417(a)(1)) The work is repeated or superseded, or 1 year after it was done (91.417(b)(1))
Total time, life-limited parts, overhaul times, inspection status, AD status, Form 337s for major alterations (91.417(a)(2)) Transferred with the aircraft when sold (91.417(b)(2))
Discrepancy list under 43.11 The defects are repaired and the aircraft is approved for return to service (91.417(b)(3))

Work under 91.411 and 91.413 (altimeter and transponder tests) is excepted from these periods (91.417(a)).

91.417(a)(1)(iii) asks only for the signature and certificate number, while 43.9(a)(4) also requires the kind of certificate (AC 43-9D, para 8.6, p. 4).

Common mistakes

  • Leaving total time off an inspection entry. 43.11(a)(2) requires it. 43.9 does not (AC 43-9D, para 8.7.1, pp. 4-5).
  • Dropping the kind of certificate. 43.9(a)(4) and 43.11(a)(3) both require it.
  • Thinking one 43.9 signature approves the whole aircraft. It approves only the work performed (43.9(a)(4)). The handbook notes that a closing line like “returned to service” is not required by 43.9 (AMT General handbook, ch. 2, p. 2-16).
  • Logging a major repair with only a logbook entry. It also needs Form 337 or, for a repair station’s major repair, the appendix B alternative (43.9(d)).
  • Mixing up the two statements. “Airworthy condition” is 43.11(a)(4); the discrepancy list wording is 43.11(a)(5).
  • Forgetting placards. Items left inoperative under 91.213(d)(2) are placarded and added to the list (43.11(b)).

Try one (an original question)

A mechanic with an airframe and powerplant rating finishes a 100-hour inspection and finds a cracked exhaust stack that makes the aircraft unairworthy. Which statement is true?

A. No record entry is needed, because the aircraft was not approved.
B. The mechanic makes a 43.11 entry and gives the owner a signed, dated list of discrepancies.
C. The mechanic makes a 43.9 entry, because an inspection counts as maintenance.

Answer: B. 43.11(a) applies to the person approving or disapproving, and 43.11(a)(5) gives the statement for an aircraft not approved. 43.11(b) requires the signed and dated discrepancy list. C is the trap: 14 CFR 1.1 does define maintenance to include inspection, but 43.9(c) says 43.9 does not apply to inspections under part 91.

A short study plan

  1. Read 14 CFR 43.9, 43.11 and part 43, appendix B in full.
  2. Read AC 43-9D, paragraphs 8 and 13 to 20.
  3. Read the part 43 section of AMT General handbook chapter 2 (pp. 2-16 to 2-17).
  4. Write your own entries for a repair, an annual and a failed 100-hour, then check each against the table.
  5. Practice questions on the Regulations, Maintenance Forms, Records, and Publications topic page, and see the A&P General written test guide for the other 11 subjects.

Common questions

What is the difference between 43.9 and 43.11?

43.9 is for maintenance, preventive maintenance, rebuilding and alteration. 43.11 is for inspections under part 91, 125, 135.411(a)(1) and 135.419. Only 43.11 requires total time in service and a certification statement (43.11(a)(2), (a)(4) and (a)(5)).

Does a pilot doing preventive maintenance make a 43.9 entry?

Yes. Everyone who approves preventive maintenance must record it under 43.9 (AC 43-9D, para 9.1, p. 6). Pilots may show the certificate as “PP,” “CP” or “ATP” (para 9.2).

When does Form 337 have to reach the FAA?

Within 48 hours after the item is approved for return to service (14 CFR part 43, appendix B, para (a)(3)).

Can a mechanic sign off an annual inspection?

Part 65 lists the annual inspection among the inspection authorization privileges (14 CFR 65.95(a)(2)). The airframe and powerplant ratings list the 100-hour inspection (14 CFR 65.85(a), 65.87(a)).

How long are maintenance entries kept?

Until the work is repeated or superseded, or 1 year after it was done (14 CFR 91.417(b)(1)). The owner, not the mechanic, keeps them (91.417(a)).

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