Training · 8 min read

Part 61 vs Part 141 Training Records

Part 61 vs Part 141 training records: Part 61 relies on logbooks and instructor records, while a Part 141 school keeps its own certified record per student.

The difference in Part 61 vs Part 141 training records comes down to who has to keep the record. Under Part 61, the record of training is mostly the student's logbook (14 CFR 61.51), signed by the instructor, plus the instructor's own record of the endorsements they've given, kept for 3 years (14 CFR 61.189). Under Part 141, the school itself must keep a current, accurate record for every student in an approved course, certified by the chief instructor when the student graduates, terminates, or transfers, and kept for at least 1 year (14 CFR 141.101).

And under Part 141, the logbook doesn't count. Section 141.101(b) says the records required in a student's logbook will not suffice for the school's record. A 141 school that relies on student logbooks doesn't meet 141.101, however complete the logbooks are.

Part 61 vs Part 141 training records at a glance

Part 61 Part 141
Primary record The student's logbook (61.51) The school's record for each enrolled student (141.101)
Who keeps it The pilot keeps the logbook; the instructor keeps an endorsement record (61.189) The school
Who signs The instructor signs each training entry The chief instructor (or a delegate under 141.85) certifies the record at graduation, termination, or transfer
Retention Instructor records: at least 3 years At least 1 year after the student graduates, terminates, or transfers
Is the logbook enough? It is the main record No (141.101(b))

Check each section for the full text and any exceptions. The rest of this post goes through what each part actually requires, and what a school should keep beyond the minimum.

Part 61: the logbook and the instructor's record

Section 61.51(a) requires each person to document and record, in a manner acceptable to the FAA, the training and aeronautical experience used to meet the requirements for a certificate, rating, or flight review, and the experience used to meet recent flight experience requirements. Each logged flight or lesson needs the date, total time, departure and arrival points (or where a simulator lesson happened), the aircraft or device type and identification, the type of experience (solo, PIC, dual received, and so on), and the conditions (day or night, actual or simulated instrument).

For training time, 61.51(h) requires the entry to be endorsed legibly by the authorized instructor and to include:

  • A description of the training given
  • The length of the lesson
  • The instructor's signature and certificate number
  • The instructor's certificate expiration date or recent experience end date, consistent with 61.197

The recent experience end date option lines up with 61.19(d): flight instructor certificates issued on or after December 1, 2024, have no expiration date. Older entries in a student's logbook will show a certificate expiration date; newer ones may show a recent experience end date instead.

The instructor's side is in 61.189. A flight instructor must sign the logbook of each person they've given flight or ground training. They must also keep a record, in a logbook or a separate document, of:

  • Each person they endorsed for solo flight privileges, and the date
  • Each person they endorsed for a knowledge or practical test, with the kind of test, the date, and the result

Those records must be kept for at least 3 years.

What Part 61 doesn't require, and what a school should keep anyway

Part 61 has no school-level training record requirement. The record belongs to the student and the instructor. That's fine until:

  • An instructor leaves. Their 61.189 record goes with them. The school is left with whatever the student's logbook says.
  • A student loses the logbook, or brings in one with lessons the school can't match to its own flights.
  • A student moves into a Part 141 course. Credit for previous training is limited, and it has to be certified in the student's training record with the kind and amount of training and the result of each stage check and end-of-course test, if appropriate (14 CFR 141.77(c)). Training from outside a 141 or 142 course can count for no more than 25 percent of the curriculum's flight training requirements, after the receiving school's own proficiency and knowledge tests. See the regulation for the full conditions.
  • There's a billing dispute about how many lessons a student actually flew.

A Part 61 school that keeps its own lesson record (date, aircraft, instructor, what was covered, how it went, signed by the instructor) can answer all four. It also gives you a place to keep citizenship verification records for TSA, which have their own retention rule. Our guide to the TSA Flight Training Security Program covers that one.

Part 141: the school's training record

Section 141.101(a) requires each pilot school to keep a current and accurate record of each student enrolled in an approved course, including:

  1. The date the student enrolled in the approved course
  2. A chronological log of the student's course attendance, subjects, and flight operations covered, and the names and grades of any tests taken
  3. The date the student graduated, terminated training, or transferred to another school

Then:

  • The logbook isn't enough (141.101(b)).
  • The chief instructor certifies the record when the student graduates, terminates, or transfers (141.101(c)). Under 141.85(a)(1), the chief instructor is responsible for certifying each student's training record, graduation certificate, stage check and end-of-course test reports, and recommendation for course completion, unless those duties are delegated to an assistant chief instructor or recommending instructor.
  • Keep it at least 1 year from the date the student graduates, terminates enrollment, or transfers (141.101(d)).
  • Give the student a copy on request (141.101(e)).

Two neighboring sections feed the record. At enrollment, 141.93 requires the school to give the student a certificate of enrollment with the course name and enrollment date, a copy of the training syllabus, and a copy of the school's safety procedures. At graduation, 141.95 lists what the graduation certificate must contain, including a statement of the cross-country training the student received and the chief instructor's certification.

Why a logbook alone isn't enough under Part 141

The logbook is the pilot's record of flight time. The 141 record is the school's record of a course. They answer different questions.

A logbook entry says the student flew 1.3 hours of dual in N12345 on a Tuesday. The school's record has to show that this was the student's attendance at Stage 2, Lesson 9, what subjects and maneuvers it covered, how the student did, and how it fits in the chronology of everything else in the course, including ground lessons that never appear in a logbook. It also has to show the stage checks and end-of-course tests by name and grade.

An inspector reviewing a 141 school can compare these records against the approved training course outline. If lessons were flown out of order, or a stage check is missing a grade, or a ground lesson has no record, the logbook can't fill the gap. In practice, a 141 school with a solid record has every lesson tied to a syllabus item, every grade entered the day of the lesson, and every completed record certified by the chief instructor or a delegate.

Part 141 students still keep logbooks, because 61.51 still governs how they document their aeronautical experience. A 141 school simply keeps both.

Running Part 61 and Part 141 side by side

Many schools hold a Part 141 certificate and also train under Part 61, with the same aircraft and often the same instructors. That works if the records never blur:

  • Enroll each student in a specific course, and label every lesson with the course it counts toward.
  • Don't put a Part 61 student's lessons in a 141 record until they've actually enrolled in the course, and record the enrollment date.
  • When a student switches from 61 to 141, document the credit decision in their training record, with the kind and amount of previous training, within the limits in 141.77(c).
  • Keep instructor records under 61.189 for everyone, whatever the course.

Electronic records: get acceptance in writing

Nothing in 61.51 or 141.101 requires paper. Part 61 asks for records in a manner acceptable to the FAA, and electronic logbooks are common. The FAA's guidance on electronic signatures and electronic recordkeeping is AC 120-78B, issued in December 2024. Like any advisory circular, it describes an acceptable means, not the only means.

For a Part 141 school, treat a move to electronic records as something to coordinate with your principal operations inspector before you switch, not after. Be ready to describe how records are created, how instructors and the chief instructor sign them, how they're stored and backed up, and how you'd produce a student's complete record during an inspection. Get the acceptance in writing, and keep it with your training course outline file. Then keep using the old system until you have it.

Electronic records also make the 141.101 chronology easier to keep honest. In Sky Schedule's flight training records software, each program is set up as Part 61 or Part 141, lessons are logged from the booking with a 1 to 5 grade on each item, students countersign their entries, and you can export a student's training record as a PDF when they or an inspector ask for it. Instructor signatures, chief instructor certification, and your POI's acceptance are still your school's responsibility, and the help article on creating a training program covers the setup.

A records checklist by part

Every school (Part 61 or 141):

  • Instructor endorsement records under 61.189, kept at least 3 years
  • Training entries with description, length, signature, certificate number, and expiration or recent experience end date
  • Citizenship verification records for TSA, kept on their own schedule
  • A school-level lesson record, even where Part 61 doesn't require one

Part 141 schools, add:

  • Enrollment date and a copy of the certificate of enrollment
  • Chronological log of attendance, subjects, and flight operations for each student
  • Stage check and end-of-course test names and grades
  • Graduation, termination, or transfer date, certified by the chief instructor or a delegate
  • Retention of at least 1 year after the student leaves the course
  • Written POI acceptance of your electronic records system, if you use one

For the document side of compliance (medicals, IDs, and expiration dates), see our page on flight school compliance.

Your next step

Pull three student files: one current Part 61 student, one Part 141 graduate, and one student who quit. Check each against the checklist above. If the 141 graduate's record has a lesson with no grade, or the student who quit has no termination date certified by the chief instructor, fix the process before the next inspection finds it.

Last reviewed October 8, 2026, against the eCFR text current as of October 6, 2026.

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