Who released the flight, and what was checked.
The pack starts from the dispatch record: aircraft, crew, route, findings, and the accountable person.
Part 108 recordkeeping software
Part 108 recordkeeping software for the proposed record you keep today.
Part 108 is proposed, not in effect. The NPRM is 90 FR 38212, Docket FAA-2025-1908. The final rule package is still at OIRA. Ledger is Part 108 recordkeeping software for BVLOS waiver operators flying under current authority: it maps proposed §108.40 record families to objects you can keep now, runs those checks in shadow mode, and assembles a §108.45 evidence pack from the same source records. The dispatch release lives on the BVLOS compliance software page. Map a Part 107 BVLOS waiver to Part 108 in the transition brief.
Proposed §108.40
Proposed §108.40 record families map to objects you can keep before the rule is final.
As drafted, proposed §108.40 covers the record families a Part 108 operator would keep: flight operations, aircraft configuration, maintenance, personnel qualifications, and operating documents. Ledger maps those proposed families to connected objects. This is Part 108 recordkeeping software, not a generic flight log. The families below are the NPRM draft, not a current legal duty.
Proposed record family
What it covers (as drafted)
Ledger object
Flight operations
Mission intent, route, times, crew assignments, operational state
Mission record + release decision
Aircraft configuration
Accepted system, installed components, firmware, serial numbers
Aircraft + configuration snapshot
Maintenance
Inspections, repairs, component replacements, return to service
Maintenance entries + work orders
Personnel and training
Qualifications, currency, role assignments, training completion
Personnel records + training events
Operations manual
Procedures, limitations, checklists, operational guidance
Document library + version control
Flight record
+
Aircraft state
+
Crew currency
+
Procedures
=
Release proof
Proposed §108.45
The §108.45 evidence pack is the reporting record, not a folder hunt.
As drafted, proposed §108.45 covers the reports and evidence an operator would produce. Ledger builds that pack from the same objects that fed the dispatch release: the release decision, source records, cited rules, and the change history. You generate it when a reviewer asks. You do not reconstruct it from drives and inboxes.
Each fact links back to the object that supported it.
Flight, configuration, maintenance, training, and procedure records stay connected to the decision.
Findings name the proposed section or the waiver provision.
A reviewer can see which check ran and which record triggered it.
Edits create versions. The original entry stays.
The pack includes the change history so a later review can replay what was true at release.
Release gate
Records alone are not proof. The dispatch release connects them.
A folder of logs does not answer whether you were allowed to fly that mission on that day. The BVLOS compliance software release gate checks aircraft readiness, crew currency, route authorization, open findings, and applicable procedures before dispatch. The release decision references the source records this page is built to keep.
- What was checked Aircraft, personnel, route, findings, procedures
- Who released Accountable person and timestamp
- What evidence exists Links to source records behind the decision
Waiver special provisions
Waiver special provisions are today's dispatch envelope under §107.7.
A Part 107 BVLOS waiver includes special provisions. Those provisions are the operating envelope: airspace limits, altitude restrictions, time-of-day constraints, equipment requirements, crew roles. Each flight must stay inside that envelope. Under §107.7, you must produce those records on request. Ledger tracks waiver special provisions as rules and checks each mission against them before release. See the Part 107 BVLOS waiver to Part 108 transition brief for how existing waivers may be treated under three possible paths.
Waiver provisions checked
Finding open if outside limits
Release blocked or documented override
AC 120-78B design guidance
AC 120-78B is electronic-record design guidance: integrity, attribution, retrievability. It is not a UAS mandate.
Advisory Circular 120-78B (issued December 2024) describes acceptable means for electronic signatures, record integrity, attribution, and retrievability. The AC historically addressed Part 121, 135, and 145 certificate holders. Part 107 and proposed Part 108 are not in its stated audience. Ledger uses those three qualities as design guidance for Part 108 recordkeeping software. It does not claim that Part 107 or proposed Part 108 operators are 120-78B certificate holders.
Records must be protected from undetected alteration.
Ledger keeps an immutable change history. Each edit creates a new version. The original entry is preserved.
Records must identify who created or approved them.
Ledger captures the authenticated user, timestamp, and action for each record and release decision.
Records must be available for the required retention period.
Ledger stores records in durable cloud infrastructure and generates evidence packs for review.
Use the familiar framework without claiming certificate-holder status.
Ledger applies AC 120-78B principles as design guidance. It does not claim that Part 107 or Part 108 operators are 120-78B certificate holders.
AC 120-78B is FAA guidance for electronic records in aviation. It does not create a mandate for Part 107 or Part 108 operators.
Shadow mode
Run proposed Part 108 recordkeeping checks beside current Part 107, Part 135, or waiver authority.
Part 108 is not in effect. The NPRM was published August 2025, and the final rule package is still pending at OIRA. Ledger runs proposed recordkeeping checks in shadow mode under current Part 107, Part 135, or waiver authority: each check executes, each finding opens, but nothing blocks release until you choose to enforce it. The history is a rehearsal record under today's authority, not a legal status under the proposal.
Proposed checks run but do not block.
See findings without stopping operations. Use the gap list to plan improvements.
Each gap is tracked as a finding.
Findings cite the proposed rule section and the record that triggered them.
Promote checks to blocking when you are ready.
Move from shadow to enforced on your schedule, not the rule's publication date.
Promote the same objects into a §108.45 pack when a reviewer asks.
Shadow-mode findings stay attached to the source records. The proposed §108.45 evidence pack is generated from that history, not assembled after the fact.
What Ledger covers
One record system for the proposed Part 108 evidence categories.
- Dispatch release
- Flight operations records
- Aircraft configuration snapshots
- Maintenance entries
- Personnel and training
- Operations manual versioning
- Findings and corrective actions
- Evidence packs
- Auditor portal
- Change history and audit journal