What records must I keep, and for how long?

Keep the two records an owner is required to keep, for the two different periods the Regulations set, and know the two things that happen to them — a request from the Minister, and a sale.

Record-keeping is the obligation that outlives the flight. It is also the one where the periods differ, which is why "keep everything for two years" is not a safe shortcut. CAR 901.48

• You know whether you are the owner of the system, because 901.48 puts these duties on the owner rather than on the pilot. CAR 901.48
• You know whether you are an RPAS operator under Division VI, because an operator has a wider set of records under section 901.223. CAR 901.223
• You know your aircraft's maintenance and modification history, because that is the content of the second record. CAR 901.48

Every owner of a remotely piloted aircraft system shall keep: a record of the names of the pilots and other crew members involved in each flight and, in respect of the system, the time of each flight or series of flights; and a record of the particulars of any mandatory action and any other maintenance action, modification or repair performed on the system. CAR 901.48

The retention periods are not the same, and the section states them separately:

Record	Retained for
Pilots, crew and flight times — 901.48(1)(a)	12 months after the day it is created CAR 901.48
Maintenance, modification, repair — 901.48(1)(b)	24 months after the day it is created CAR 901.48

Both records must also be made available to the Minister on request. CAR 901.48

The second record is the detailed one. For any mandatory action and any other maintenance action, modification or repair performed on the system, it must include: the names of the persons who performed the work; the dates they were undertaken; in the case of a modification, the manufacturer, model and a description of the part or equipment installed to modify the system; and, if applicable, any instructions provided to complete the work. CAR 901.48

That list is worth reading as a chain of custody. It is not enough to write "propellers replaced"; the record has to say who, when, with what, and under whose instructions. CAR 901.48

An owner who transfers ownership of the system to another person shall, at the time of transfer, also deliver to that person all of the records referred to in paragraph (1)(b) — the maintenance, modification and repair records. CAR 901.48

Note what is not in that sentence: the flight-and-crew record is not handed over. The maintenance history follows the aircraft, because the next owner inherits the obligation to know what was done to it. CAR 901.48

Recording systems, including computer records and microfiche, that are not paper entries may be used to comply with the record-keeping requirements if measures are taken to ensure the records are protected, by electronic or other means, against inadvertent loss or destruction and against tampering; and a copy of the records can be printed on paper and provided to the Minister on reasonable notice. CAR 103.04

Both conditions are about the same thing: a record that can be lost, altered without trace, or not produced, is not a record. A spreadsheet on a laptop with no backup and no tamper protection fails the first condition even if it is perfectly accurate. CAR 103.04

Every RPAS operator shall keep records of: pilots, pilots-in-command and other crew members involved in each flight, and flight times; the names of the operator's employees, agents, mandataries and representatives; the names of everyone who has received training from the operator and the nature of it; the registration numbers of all remotely piloted aircraft it operates; and the same maintenance particulars as 901.48(1)(b). CAR 901.223

The retention split repeats: 12 months for the crew, personnel and training records, and 24 months for the registration-number and maintenance records. CAR 901.223

Who	What they keep	Where
The owner	Flight/crew names and times; maintenance and modification history	901.48 CAR 901.48
An RPAS operator	The above plus personnel, training and registration numbers	901.223 CAR 901.223
A pilot, for recency	A record of the activities relied on for recency, with dates	901.56(2) CAR 901.56

The pilot's recency record is a condition of operating at all, and it is the pilot's to keep; the owner's records are the owner's. Being one does not discharge the other. CAR 901.56 CAR 901.48

Your record-keeping is compliant only when all of the following hold:

• The flight, crew and time record exists, and is kept for 12 months CAR 901.48
• The maintenance, modification and repair record exists, with who, when, what part, and what instructions, and is kept for 24 months CAR 901.48
• Both are available to the Minister on request CAR 901.48
• On a sale, the maintenance records are delivered to the new owner at the time of transfer CAR 901.48
• Any electronic system protects against loss and tampering, and can be printed CAR 103.04
• If you are an operator, the personnel, training and registration-number records are kept as well CAR 901.223

Warning The two periods are 12 months and 24 months, and they apply to different records. "Keep everything for two years" is compliant, but "keep everything for one year" is not — and a maintenance record that has been discarded before its 24 months cannot be produced on request or delivered on a sale. CAR 901.48

Symptom	Likely cause	What to do
You kept the flight record for 18 months and discarded the maintenance record at 12	The periods differ: 12 months and 24 months	Retain each for its own period CAR 901.48
You sold the aircraft and kept the maintenance file	The records follow the aircraft on transfer	Deliver them at the time of transfer CAR 901.48
Your records are in a spreadsheet with no backup or audit trail	103.04 requires protection against loss and tampering	Add both, and the ability to print CAR 103.04
The Minister asks for the records and you cannot print them	The second condition of 103.04	Keep a means of producing paper copies CAR 103.04
You are an operator and kept only the flight records	901.223 adds personnel, training and registration numbers	Keep all five categories CAR 901.223
You are a pilot and relied on the owner's records for your recency	The recency record is the pilot's own duty	Keep your own dated record CAR 901.56

Practise: Owner and operator records

Practise: RPAS operator records

• CAR 103.04 — Record Keeping
• CAR 901.48 — Records
• CAR 901.56 — Recency Requirements
• CAR 901.223 — Records
• AIM RPA 3.2.36 — Records
• Consolidation: CARs current to 2026-09-21