Records must be protected from undetected alteration.
Ledger keeps an immutable change history. Each edit creates a new version. The original entry is preserved.
For BVLOS waiver holders preparing for proposed Part 108
Keep the record today. Run proposed checks in shadow. Produce the evidence pack later.
Part 108 is proposed, not in effect. The final rule is still at OIRA. Ledger is BVLOS compliance software for the dispatch release, with proposed Part 108 recordkeeping checks in shadow mode. Flight records, maintenance logs, training evidence, and operations documents stay connected to each release decision.
Proposed record families
As drafted, Part 108 expands what operators must keep and produce.
The NPRM discusses recordkeeping at proposed §108.40 and reporting at proposed §108.45. These sections cover flight operations, aircraft configuration, maintenance, personnel qualifications, and operating documents. Ledger maps those proposed record families to objects you can build and check before the rule is final.
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
The release decision
Records alone are not proof. The dispatch gate connects them.
A folder of logs does not answer whether you were allowed to fly that mission on that day. Ledger runs a release gate before each flight. The gate checks aircraft readiness, crew currency, route authorization, open findings, and applicable procedures. The release decision references the source records it evaluated.
- What was checked Aircraft, personnel, route, findings, procedures
- Who released Accountable person and timestamp
- What evidence exists Links to source records behind the decision
Today's waiver compliance
Your Certificate of Waiver already defines a dispatch gate.
A BVLOS waiver under Part 107 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 records on request. Ledger tracks waiver 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 scenarios.
Waiver provisions checked
Finding open if outside limits
Release blocked or documented override
Electronic records guidance
AC 120-78B is the FAA's playbook for electronic records. It is not a Part 107 mandate, but it is the standard FSDOs recognize.
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. But when an inspector asks how your electronic records work, AC 120-78B is the vocabulary they know.
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 checks beside your current operations.
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: each check executes, each finding opens, but nothing blocks release until you choose to enforce it. When the final rule is published, you will have a history of how your operations would have performed.
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.
Generate a fixed record set for any reviewer.
Evidence packs include the release decision, source records, applicable rules, and audit history. Use them for internal review, insurer diligence, or regulatory inquiry.
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