Hiring a pilot is not the same as hiring any other employee, and the records review is not optional or left to an employer’s discretion. Congress built a specific, federally mandated records check into the hiring process for pilots after a string of accidents involving pilots whose past performance problems had never been shared between employers. That mandate started as the Pilot Records Improvement Act of 1996 and has since moved almost entirely into an electronic system called the Pilot Records Database, or PRD. If your operation hires flight crewmembers, understanding what this check covers, who has to run it, and how it fits alongside a standard employment background check is part of getting the hire right.
Who has to check a pilot’s records
The requirement applies to a defined set of aviation employers, not to every company that touches an airplane. Under 14 CFR Part 111, the operators required to query and evaluate a pilot’s records before letting that person begin service as a required flight crewmember include certificate holders operating under 14 CFR parts 121 and 135, fractional ownership programs under part 91K, certain part 125 operators, air tour operators holding a letter of authorization under 14 CFR 91.147, and governmental entities conducting public aircraft operations. The Federal Aviation Administration refers to these as “reviewing entities,” and they are legally barred from allowing a pilot to fly for them until the review is complete and the pilot has consented to it, according to the final rule published in the Federal Register.
Corporate flight departments and operators conducting public aircraft operations have some discretion over how they use the review side of the system, but they are still required to report records on the pilots they employ, so the obligation runs in both directions for most of the industry.
From PRIA to the Pilot Records Database
The Pilot Records Improvement Act of 1996 originally required a hiring air carrier to request records directly from three sources before letting a newly hired pilot fly: the pilot’s current and former employers, the FAA, and the National Driver Register. That paper and fax based process worked, but it was slow, inconsistent, and easy to have gaps in, since it depended on every prior employer responding accurately and on time.
Congress replaced that model with the Pilot Records Database, an FAA-run electronic system built under 14 CFR Part 111. The transition happened in stages rather than all at once. The FAA required reviewing entities to start pulling FAA-held records through the PRD on December 7, 2021. Employer-reported, non-FAA records started populating the system on June 10, 2022. Operators were required to keep running PRIA requests in parallel with PRD use through September 8, 2024, and PRIA formally stopped being an effective compliance method the next day, under 14 CFR 111.5(b), as confirmed on the FAA’s own Pilot Records Improvement Act page. In practice, that means a hiring air carrier today is complying through the PRD, not through the old PRIA paper request.
What a PRD pull actually contains
The PRD pulls together records from two broad sources: the FAA itself, and every employer that has reported records on that pilot since the reporting requirement took effect.
FAA-held records available in the PRD include the pilot’s current certificate and medical certificate information, associated type ratings and any limitations on those certificates, records of any failed attempt to pass a practical test for a certificate or rating under 14 CFR part 61, enforcement actions that resulted in a finding against the pilot that was not later overturned, and records tied to the pilot serving as pilot in command or second in command during an accident or incident. The FAA also enters a pilot’s pre-employment drug and alcohol testing history and other Department of Transportation drug and alcohol records reported by past employers, though those specific records belong to the reporting employer rather than to the FAA itself, per the rule’s preamble.
Employer-reported records, submitted by every reporting entity that has employed the pilot, cover drug and alcohol testing records maintained under 14 CFR part 120 where applicable, training, qualification, and proficiency records, final disciplinary action records, records concerning separation from employment, verification that a motor vehicle driving record search was completed, and other historical records tied to that pilot’s employment. Most of these must be reported to the PRD on an ongoing basis, generally within a set window the FAA describes as contemporaneous reporting, though certain smaller operators such as corporate flight departments and public aircraft operators can hold records until a reviewing entity requests them, unless the record involves a permanent removal from flying duties or a termination.
PRIA versus the PRD, side by side
| Feature | Legacy PRIA process | Pilot Records Database (PRD) |
|---|---|---|
| Legal basis | Pilot Records Improvement Act of 1996, 49 U.S.C. 44703 | 14 CFR Part 111, implementing the Pilot Records Database Act of 2016 |
| How records move | Written or faxed requests sent directly to each prior employer, the FAA, and the NDR | Centralized FAA electronic database that reporting entities populate and reviewing entities query |
| What gets shared | Full records exchanged in their entirety between employers | Specific, defined data elements only, intended to limit unnecessary disclosure |
| Current status | Ceased to be an effective compliance method on September 9, 2024 | The required compliance method for FAA and employer-reported pilot records |
| Motor vehicle records | NDR request bundled into the same records package | NDR query remains a separate step tied to written pilot consent, not stored inside the PRD itself |
Pilot consent is not a formality
A reviewing entity cannot simply look up any pilot in the PRD. A pilot has to grant specific, time-limited written consent before an operator can view that pilot’s records, and the pilot decides how long that consent window stays open, up to 60 days per release, and can revoke it. A separate written consent is required before an operator can query the National Driver Register for a pilot’s motor vehicle driving history, since that check runs through the state licensing system rather than through the PRD itself, according to the Federal Register rule discussion.
Because the statute anticipated pilots refusing to cooperate, 49 U.S.C. 44703(i) allows a hiring employer to require a pilot to sign a release from liability tied to proper use of the PRD, and it allows the employer to decline to hire a pilot who will not consent to the records review, without exposing the employer to a legal claim over that refusal. Reviewing entities are also expected to compare the employment history a pilot lists going back five years against what actually shows up in the PRD, so a gap or a mismatched employer is something a hiring team should expect to have to run down before moving forward.
How long the records stick around
Pilot records entered into the PRD are not purged on a normal business retention schedule. Under the rule, the FAA retains a pilot’s records for the life of that pilot, removing them only after notification of death or after 99 years have passed since the pilot’s date of birth. That is a marked change from the FAA’s prior practice of expunging some enforcement records after a period of years, a practice the agency suspended once the PRD’s statutory retention requirement took effect. Reporting entities, meaning the employers submitting records, are separately expected to retain the underlying source records they are required to report, so a hiring team should not assume an employer’s own retention window can run shorter than what the PRD framework anticipates.
Where PRIA and PRD checks stop, and an FCRA background check picks up
It is worth being precise about what the PRD and the old PRIA process actually cover, because it is not a full background check in the way most employers use that term. The PRD is a federal aviation safety mechanism built around FAA certificate history, aviation employer records, and driving history. It is not a consumer report, and it is not governed by the Fair Credit Reporting Act. A hiring air carrier still has an independent obligation, confirmed directly by the FAA, to obtain drug and alcohol testing records from a pilot’s prior DOT-regulated employers under 49 CFR 40.25, since the PRD does not substitute for that specific requirement, as stated in the FAA’s own guidance on PRD and drug and alcohol records.
What the PRD does not touch at all is the kind of screening most employers run on every other hire: criminal history checks, verification of prior non-aviation employment, education verification, and identity checks. Those fall under a standard employment background check, which operates under a completely separate legal framework built on consumer report disclosure, authorization, and adverse action notice requirements. Aviation employers that hire pilots, dispatchers, mechanics, and ground personnel typically need both tracks running side by side: the FAA-mandated PRD and drug and alcohol review for the flight crew, and a standard FCRA-governed background check covering criminal history and employment and education verification for the broader workforce. Carriers building out a transportation hiring program often coordinate this alongside driver-specific screening, which is covered in more detail on our transportation background check page and in our overview of MVR background screening for employers. For the non-flight-specific portions of a pilot’s history, such as prior employment outside of aviation, a standard employment verification process still applies the same way it would for any other candidate.
Building this into a hiring workflow
A practical hiring sequence generally starts with confirming which category of reviewing entity applies to your operation, since a part 135 charter operator, a fractional program, and a corporate flight department each have slightly different reporting obligations even though all of them must review records before a pilot begins flying. From there, obtain the pilot’s written consent early, since the PRD query and the separate NDR request both depend on it and delays here are one of the most common bottlenecks in pilot onboarding. Run the drug and alcohol history request under 49 CFR part 40 in parallel rather than assuming the PRD covers it, and cross check the employment history the pilot provides against what actually appears in the database rather than taking a resume at face value. Finally, treat the FAA-mandated review as one track of the hire and the standard background check as a separate, parallel track, since combining them into a single step is where gaps tend to appear.
Frequently asked questions
Does the PRD replace a standard background check for pilots?
No. The PRD is a federal aviation safety database covering FAA certificate history, employer-reported training and disciplinary records, and drug and alcohol testing history. It does not cover criminal history, non-aviation employment verification, or education verification, which still require a separate background check process.
Who is required to query the PRD before hiring a pilot?
Operators certificated under 14 CFR parts 121 and 135, fractional ownership programs under part 91K, certain part 125 operators, air tour operators holding a letter of authorization under 91.147, and government entities conducting public aircraft operations must review a pilot’s PRD records before that pilot begins service as a required flight crewmember.
What happens if a pilot refuses to consent to a PRD records release?
An operator cannot view a pilot’s PRD records without the pilot’s written, time-limited consent. Federal law permits a hiring employer to decline to hire a pilot who will not provide that consent, and it shields the employer from liability for making that decision.
How long are pilot records kept in the PRD?
Records generally remain in the PRD for the life of the pilot. They are removed only after the FAA receives notification of the pilot’s death or after 99 years have passed since the pilot’s date of birth.
Is the PRIA process still used?
No. PRIA requests were required in parallel with PRD use through September 8, 2024. As of September 9, 2024, PRIA ceased to be an effective compliance method under 14 CFR 111.5(b), and the PRD is the required system for these checks.
This article is general information, not legal advice. Aviation employers should confirm current requirements directly with the FAA and consult qualified aviation counsel before building or changing a pilot records compliance program.
