Aviation Exam Records: Retention and Traceability for Training Organizations
Aviation exam records are everything a training organization keeps to show how an exam result came about: the paper or form, the sitting, the answers, the marks, the people involved and any later change. Retention is how long you keep them. Traceability is whether you can follow any result back through each of those steps.
The short answer on retention is that it depends on your approval. The sources we read give an unlimited period for Part-147 student examination records, three years after training for some flight crew records, a five-year default in guidance, and a school-set period for FAA Part 147. This guide gives a retention schedule template and a five-result traceability test.
It is for heads of training, quality managers and exam officers at Approved Training Organisations, Part-147 maintenance training organisations and FAA Part 147 schools. The rules were read in November 2026. This is not legal or airworthiness advice, and rules differ by country, so check your competent authority. Our post on how to map assessment results to aviation training records covers the field map between systems. This one covers the rest of the record set and how long to keep it.
Key takeaways
- Part-147, as read on the UK legislation site’s copy, says student examination records are kept “for an unlimited period”. Flight crew rules, FAA guidance and your own approved procedures give other periods, so the answer depends on your approval type.
- An exam record set has six layers, from question history to system logs. A good schedule says, line by line, what a source requires and what your organization chose.
- GDPR recitals accept keeping personal data where a legal obligation requires it, but expect time limits for the rest. Records kept only by choice need a stated reason and a review date.
- A result is traceable when you can show the paper version, question versions, identity check, assessor, rule applied and every change. Test five awkward results, not one clean pass.
What counts as an aviation exam record beyond the score?
An aviation exam record is any evidence of how an exam was prepared, delivered, marked and decided. Beyond the score, that means six layers: the exam material, the sitting, the marking, challenges, the people and the system. The rules we read name some of these directly and leave the rest to your procedures.
The table shows the six layers and the question each one answers.
| Layer | Typical contents | Question it answers |
|---|---|---|
| Exam material | Question versions, paper or form versions, answer keys, release log | What exactly could the candidate have seen? |
| The sitting | Candidate, identity check, room, invigilator, start and end times, equipment | Who sat it, where, and under whose supervision? |
| Marking and result | Responses, marks by part, pass mark applied, moderation notes, outcome, attempt number | How was the result reached? |
| Challenges | Incidents, disqualifications, appeals, complaints, accommodation requests | What was disputed, and what was decided? |
| People | Examiner, invigilator and assessor records with qualifications | Were the people involved qualified? |
| System | Access logs, change logs, exports, platform versions, backups | Who touched the record afterward? |
The last three layers are the easiest to lose, because they sit outside the exam itself: paper incident notes, people files held elsewhere, logs inside a vendor’s system.
How long do the rules say to keep aviation exam records?
No single period applies. As of November 2026, the sources we read give an unlimited period for Part-147 student examination records, a five-year default in EASA guidance for Part-ORA records, a school-set period for FAA Part 147, and four years for the authority’s own file on your approval.
The table separates requirements from guidance, because that line decides what you may change.
| Source | Applies to | What it says | Status |
|---|---|---|---|
| EASA Part-147, point 147.A.125 | Part-147 maintenance training organisations | “shall keep all student training, examination and assessment records for an unlimited period” (quoted) | Requirement in the text read |
| Part-147, point 147.A.100(h) | Same | “Secure storage facilities shall be provided for examination papers and training records”, with storage that keeps documents in good condition “for the retention period as specified in point 147.A.125” (quoted) | Requirement |
| Part-ORA, ORA.ATO.120 | Flight crew Approved Training Organisations | Training records kept for three years after the training is completed (our reading of the EASA text; confirm the wording) | Requirement |
| Part-ORA, ORA.GEN.220 and AMC1 | Organisations under Part-ORA | Records stored “in a manner that ensures protection from damage, alteration and theft”. AMC1: “In the absence of such indication, all records should be kept for a minimum period of 5 years” (both quoted) | Rule for ORA.GEN.220; acceptable means of compliance for the 5 years |
| FAA 14 CFR 147.23(b) and AC 147-3C, paragraph 3.5.1 | FAA Part 147 maintenance schools | The school must keep student records under “the procedures and retention timeframes described in their FAA-approved QC system” (quoted). The AC recommends at least 2 years after enrollment ends | Follow your own approved system; 2 years is a recommendation |
| Part-147, point 147.B.20(c) | The authority’s records of your approval | “The minimum retention period for the point (b) records shall be four years” (quoted) | Binds the authority, not you |
Sources and status: we read Part-147 on the UK legislation site’s copy of Annex IV to Regulation (EU) No 1321/2014, in the version dated 24 March 2020, because EUR-Lex was not readable to us. The ORA text comes from EASA’s June 2020 Easy Access Rules for Part-ORA. The FAA wording comes from FAA Advisory Circular 147-3C, dated March 22, 2022. Later amendments may differ, so confirm current text before relying on any line.
EASA’s February 2024 briefing slides on its Part-147 review list a proposed decrease from “unlimited” to 10 years for training records. The NPA page we read showed no outcome, so plan around the text in force. Our Part-147 examinations post covers the other proposals.
Which retention period should you follow when the numbers differ?
Follow the period that applies to your approval for each record class, and where more than one source applies, plan around the longest. The numbers differ because they bind different organizations, cover different records and carry different legal weight. Your competent authority or Flight Standards office decides which applies to you.
Three habits keep this manageable. List every approval you hold, since a Part-147 organization that also runs flight crew courses may fall under more than one rule set. Write the period and source per record class, marked as a requirement, a recommendation or your own choice. Take the longer period for shared records, and treat any move below a stated rule or approved procedure as a question for your authority.
Does GDPR cap an “unlimited” retention period?
No source we read says so, and the GDPR recitals point the other way for records a rule requires. Recital 65 says further retention is lawful where necessary “for compliance with a legal obligation”. For records kept only by choice, recital 39 expects time limits and periodic review.
We could read the recitals of Regulation (EU) 2016/679 on EUR-Lex, not the articles, so treat this as context for a conversation with your data protection officer, not legal advice. Recital 39 asks for a storage period “limited to a strict minimum” and “time limits” for “erasure or for a periodic review” (quoted). Records a rule requires have a stated basis. Extra data you collect for convenience, such as device logs, needs its own short period and reason.
What should an aviation exam records retention schedule contain?
A schedule lists each record class with its owner, period, the source of that period, when the clock starts and what happens at the end. The columns people leave blank are the source and the clock start, and those are the two an auditor or data protection officer asks about first.
The table is a starting template. Periods marked “our suggestion” are not requirements, and where no source we read sets a period, the row says so.
| Record class | What the sources we read say | Clock starts (our suggestion) | At the end |
|---|---|---|---|
| Student exam results and attempts | Part-147: unlimited (147.A.125). ORA.ATO.120: three years after training. FAA: set in the school’s QC system | Date of the result, or end of training | Apply your longest applicable period; confirm with the authority before destroying |
| Exam papers, forms and answer keys | Part-147: secure storage for examination papers (147.A.100(h)); staff “shall ensure the security of all questions” (147.A.135(a), quoted). No separate period read | Date the form was last used | Keep a reproducible copy while any result it produced is retained |
| Question item history | No source read sets a period | Date the item was retired | Keep while any result that used the item is retained |
| Identity and invigilation records | No separate period read. Our reading is that they form part of the “examination records” in 147.A.125 | Date of the sitting | Treat as part of the sitting record |
| Incidents and disqualifications | 147.A.135(b): a disqualified student “may not take any examination for at least 12 months” (quoted fragment) | Date of the decision | Keep at least until the ban and any appeal end |
| Appeals, complaints, accommodations | No aviation source read sets a period | Date the matter is closed | Exam administration outside aviation often ties retention to the end of any appeal; confirm for yours |
| Examiner and assessor records | 147.A.110: a record of all instructors, knowledge examiners and practical assessors, reflecting qualification and training history | Date the person leaves the role | Keep as long as results they marked or supervised |
| System, access and change logs | ORA.GEN.220: protection from alteration. AMC1: data stay accessible after hardware or software changes for the full period | Date of the logged event | Keep as long as the records they protect |
| Extra candidate data kept by choice | Required by no source read. GDPR recital 39 expects time limits | Date collected | Short period, stated reason, scheduled deletion |
Pro tip: Put The Basis And A Review Date Beside Every Period. Add two columns, one naming the basis (“147.A.125” or “our policy”) and one with a review date. When a rule changes, you edit the rows that cite it and leave the ones that rest on your own policy.
What is exam traceability, and where does the chain usually break?
Exam traceability is the ability to follow a result back to the paper, questions, candidate, assessor and rules behind it, and forward through every change. ORA.GEN.220 asks for a system that allows “reliable traceability” (quoted) for organizations under Part-ORA. The chain breaks wherever one link lives somewhere it cannot be matched.
The table gives seven links, the question an auditor would ask and a break worth testing for. The breaks are our analysis, not findings from any source.
| Link | Question to answer | Typical break |
|---|---|---|
| Result to attempt | Which attempt is this, and were there earlier ones? Part-147 Appendix II makes the organization or the authority responsible for checking attempt numbers, and AC 147-3C says records should “clearly distinguish between successful performance and unsuccessful performance” (quoted) | Only the latest pass is kept |
| Attempt to paper version | Which form did the candidate sit? | Items edited after the sitting, so the paper cannot be rebuilt |
| Paper to question versions and key | Which version of each item and answer key applied? | No item versioning; a key changed without a note |
| Candidate to identity check | Who confirmed identity, and how? | Check on a paper register, not linked to the attempt |
| Sitting to assessor | Who supervised or marked, and were they in the 147.A.110 record? | Assessor typed as free text |
| Result to rule applied | Which pass mark and syllabus version applied? | Pass mark changed and old results recalculated |
| Record to change history | Who changed what, when, and what was the old value? | Edits with no log, or logs deleted when a contract ends |
Our exam security post for approved training organizations shows why this chain matters when a question leaks.
How do you test traceability with five awkward results?
Pick five results that are awkward on purpose, have someone who was not there trace each one through the chain, and time it. A clean pass proves little. Awkward cases show where links are missing, and the test needs no special software.
Step 1: Choose five. Take a pass after a fail, a corrected score, a disqualified sitting, a result from a form last used more than two years ago, and a result marked by an assessor who has since left.
Step 2: Trace and time. Have someone outside the exam team work only from your written procedures. For each link in the table, note whether the evidence was found, where, and how many minutes it took.
Step 3: Log the gaps and repeat. Give each gap an owner and a date, then run the test again after any new system, vendor or revised schedule.
The sheet shows what findings can look like. The cases and results are invented for illustration, and no real exam content is used.
| Case | What the trace found | Fix |
|---|---|---|
| T1: pass after fail | Both attempts found within minutes | None needed |
| T2: corrected score | Old score found only in an email | Require a logged reason for every edit |
| T3: disqualified sitting | Incident note on paper, not linked to the result | Add a decision date field and link it |
| T4: form last used three years ago | Questions found, answer key version unknown | Version each key with its form |
| T5: assessor who left | Name in free text, no qualification record | Use an ID from the assessor record |
What should you ask a vendor about exam records?
Ask what the system stores, for how long, who can change or delete it and how you get it out. Then ask for a live demonstration using your five awkward results. A published page describing a feature is not evidence that it works for your approval, so treat answers as claims to test.
Put these requests to every vendor, in writing:
- Show each attempt, including failed ones, with the paper and question versions used.
- Show the change history for an edited score, with the old value and the person who changed it.
- Show what happens when someone tries to delete a record still inside its retention period.
- Export one year of sittings, with responses, versions and logs, in a format you can open without the vendor’s system.
- State where the data is stored and what happens to it when the contract ends.
- Confirm who owns the data and which retention period you can configure.
Pro tip: Treat A Platform Change As A Records Event. The Part-ORA guidance says that when hardware or software changes, “special care should be taken that all necessary data continues to be accessible” (quoted). Before you switch systems, export a full year, open it on a clean machine, and rerun the five-result test against the export, not the old system.
What should you do next?
Copy the retention table into a spreadsheet and fill the source and basis columns for your own approvals, marking each line as required, recommended or your choice. Then run the five-result test on last year’s exams, before you change software or retention periods, so you have a baseline.
If you are comparing systems, use the vendor questions above. SimpliAssess’s FAQ says you can export all test scores to a spreadsheet and that data ownership stays with the customer, and its features page names test management and analytics and reporting. Its published pages do not describe audit logs, content versioning or retention periods, so ask about those directly. SimpliTrain’s certification management page says certificate records are stored in SimpliTrain and shown in admin reports, and for data retention it tells you to contact SimpliTrain, so bring your schedule to that conversation.
Frequently asked questions
What are aviation exam records?
Aviation exam records are the evidence of how an exam was prepared, delivered, marked and decided. They include the paper or form version, the sitting details, responses and marks, incidents and appeals, the people involved and system logs. Part-147 refers to student examination and assessment records, so keep attempt-level detail, not only the final result.
How long must aviation exam records be kept?
It depends on your approval. The Part-147 text we read says student examination records are kept for an unlimited period. ORA.ATO.120 gives three years after training for flight crew records, and AC 147-3C leaves FAA schools to set the period in their approved QC system, recommending at least two years. Confirm with your competent authority.
Do exam papers and answer keys count as exam records?
Part-147 point 147.A.100(h) requires secure storage for examination papers and training records. We found no separate retention period for papers in the sources read. A sensible rule is to keep a reproducible copy for as long as the results it produced are retained, under restricted access, and confirm that with your authority.
Can aviation exam records be kept electronically?
The sources we read allow it, with conditions. The ORA.GEN.220 guidance says records may be kept on paper, electronically or both. AC 147-3C recommends that a school using electronic records follow AC 120-78 and says the FAA will issue OpSpec A025 to authorize digital recordkeeping. Check the arrangement with your authority.
Does GDPR require deleting aviation exam records?
No source we read says so. GDPR recital 65 treats further retention as lawful where necessary for compliance with a legal obligation, while recital 39 expects time limits and periodic review for other data. Separate records a rule requires from data kept by choice, and take advice from your data protection officer.
What makes an exam result traceable?
A result is traceable when you can show the attempt number, paper and question versions, identity check, assessor, pass mark applied and every change with its old value. ORA.GEN.220 asks organizations under Part-ORA for “reliable traceability”. Test it with awkward cases, such as a corrected score or a failed first attempt.
