AC 120-78B

Advisory circular · Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals

Approved
December 11, 2024
Last reviewed
December 12, 2024
Family
AC 120-78 · 5 versions
Revision
B
14 CFR parts
91, 117, 121, 125, 133, 135, 136, 142

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed November 22, 2025.

Show pages 13–24

4-2 information displayed at an authorized computer workstation or authorized portable device. Additionally, any information displayed should be easily traceable and comparable to the source document. The most important point is that the electronic manual content remains the same, regardless of the display format or device. Any displayed manual information should be identical in content for all users.

4.3 Electronic Manual Systems. An electronic system for delivering manual content must comply with regulatory requirements for currency, availability, accessibility, and distribution to the appropriate personnel. These requirements are set forth in 14 CFR § 91.1023, part 121 subpart G, part 125 subpart C, and § 135.21. Similar requirements are also contained in 14 CFR § 145.207. The following guidelines apply to electronic manual systems:

4.3.1 Ensures Manual Currency. The electronic manual system has a method of ensuring that each person (refer to 14 CFR part 1 for definition of “person”), to whom a manual or appropriate parts of it are furnished, keeps it up to date.

4.3.2 Provides Access, Availability, and Distribution to the Appropriate Personnel. The electronic manual system distributes, furnishes, and/or provides access to manual(s) by the appropriate personnel.

4.3.3 Access is Controlled. Access to the electronic manual system is controlled.

4.3.4 Electronic Access to the MEL—14 CFR Parts 91K, 121, 125, and 135. Where electronic MELs are concerned, there are additional regulatory requirements. Title 14 CFR §§ 91.1115(a)(2), 121.628(a)(2), 125.201(a)(2), and 135.179(a)(2) require certificate holders who conduct operations under 14 CFR part 91K, 121, 125, or 135 to provide flightcrews with direct access to the MEL through printed or other means approved by the Administrator. Electronic access to an MEL falls under the category of “other means approved by the Administrator.” Therefore, the use of an electronic MEL will require FAA approval in addition to FAA acceptance of the electronic manual system. Certificate holders that desire FAA approval to provide electronic access to their MEL will list each electronic MEL in the master manual or document that describes the electronic manual system. The master manual or document is discussed later in this chapter. Operations Specification (OpSpec) A025, Electronic Signatures, Electronic Recordkeeping Systems, and Electronic Manual Systems, requires each electronic MEL to be listed by aircraft M/M or make, model, and series (M/M/S), as specified by the MEL.

4.3.5 FAA Access—14 CFR Parts 91K, 121, 125, and 135. For 14 CFR parts 91K, 121, 125, and 135, each certificate holder must furnish copies of their manuals to appropriate FAA personnel. The FAA encourages certificate holders to provide access to the electronic manual system to the appropriate FAA representatives assigned to the certificate holder.

When providing such access, a certificate holder should provide the FAA’s representatives with instructions on how to access the system.

4.3.6 Functionality. The electronic manual system provides for storage and retrieval of electronic manual content and allows manual users to easily access manual content via

4-3 computer or comparable device. When appropriate or necessary, manual users should be able to print any information contained in an electronic manual. Once printed, however, content from an electronic manual could be less current than what is maintained on the electronic manual system.

4.3.7 Manual Revision Control. The electronic manual system provides revision control.

4.3.7.1 Manuals are Easy to Revise. Each manual distributed, furnished, or provided by the electronic manual system should be in a form that is easy to revise. For 14 CFR parts 91K, 121, 125, and 135, this is required.

4.3.7.2 Revision Status. Each manual accessed via the electronic manual system for 14 CFR parts 91K, 121, 125, and 135 must display the date of the last revision in a manner in which a person can immediately ascertain it (refer to 14 CFR §§ 91.1025, 121.135, 125.73, and 135.23). The intent is that the date of the last revision is readily accessible in the manual being used and that employees are able to quickly determine that they are using the most current version of the manual (refer to 88 FR 34437, Updating Manual Requirements to Accommodate Technology, dated May 30, 2023). The following are examples of how revision information could be displayed in an electronic manual:

4.3.7.2.1 Revision Status by Page. Electronic manuals that have individual pages should display the date of the latest revision for each particular page.

4.3.7.2.2 Revision Status Contained in Blocks of Information. Electronic manuals displayed in a continuous flow format, as opposed to page-by-page, should display the date of the latest revision in each section or block of information.

4.3.7.2.3 Revision Control Pages. Electronic manuals should contain a revision control page or section from which the user can readily determine whether the manual is current.

4.3.7.3 Communication of Revision Information. The electronic manual system should include a method of communicating revision information to manual users.

4.3.7.3.1 Revision information should provide the revision content, effective date, and any instructions required for ensuring that the revision is uploaded or incorporated into the electronic manual.

4.3.7.3.2 Revision information should allow the user the ability to compare the current revision to the previous version or it should explain the effect of the change.

4.3.7.3.3 Revised content should be readily apparent to the user.

4.3.7.3.4 Each electronic manual should contain a revision control page or section from which the user can readily determine whether the manual is current.

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4.3.8 Data Archiving. The electronic manual system has a method of archiving technical and procedural data superseded by revision. Earlier versions of manuals are archived and preserved to provide for future needs to duplicate, regenerate, or reconstruct instructions.

4.3.8.1 The Importance of Historical Data. Archived historical data is particularly important for the following reasons:

1. To trace aircraft repair information or reconstructing maintenance instructions.

2. To evaluate normal and abnormal flight deck (cockpit) checklist procedures.

3. For training purposes.

4. For investigation purposes in the event of an accident, incident, or occurrence.

4.3.9 Transferring Data to Another System. Technological hardware or software advances could make it desirable and/or necessary for a certificate holder to update their electronic manual system. When transferring manual data from one electronic system or application to another, the electronic manual system ensures that data integrity is maintained during transfer. This includes ensuring that archived information remains intact. This could entail running redundant systems for a brief period of time.

4.3.10 Information Technology (IT) System Maintenance and Support. The electronic manual system includes maintenance and support that can identify and resolve hardware, software, and network issues.

4.3.11 Backup Method. The electronic manual system has a backup method of maintaining, distributing, or otherwise providing access to manuals in case of system hardware, software, or network failure. The backup method may be a separate electronic system, a backup server to the authorized system, the use of backup media such as print or CD-ROM, or other methods acceptable to the FAA.

4.3.12 Master Manual for 14 CFR Parts 91K, 121, 125, and 135. The electronic manual system has a master manual. OpSpec A025 requires an electronic manual system used in operations under 14 CFR parts 91K, 121, 125, and 135 to include a master manual that describes the electronic manual system, contains the policies and procedures applicable to the electronic manuals system, and lists each manual maintained and distributed via the system. A025 requires the name of the master manual to be listed in the appropriate table of the OpSpec. (A 14 CFR part 135 certificate holder authorized by OpSpec A040 to be a single-pilot operator, who elects to have a manual and maintain/distribute it electronically, may list that manual as being the master manual for the purposes of OpSpec A025.)

4.3.13 Certificate Holders with Large and Complex Manual Systems. For a certificate holder with a large and complex manual system that contains numerous manuals, it is acceptable to list the kinds of manuals in the master manual, instead of listing each manual, provided

4-5 all of the particular kinds of manuals are maintained and distributed via the electronic manual system. For example, list “All Ground Operations Manuals,” “All Maintenance Manuals,” or “All Training Program Manuals.”

4.3.14 Description of the Electronic Manual—14 CFR Parts 133 and 145. For electronic manuals used in 14 CFR parts 133 and 145, a description of how each electronic manual is displayed, maintained, revised, and distributed should be included in the certificate holder’s manual system. The description should also include an explanation of the media by which manuals will be distributed to required personnel.

4.3.15 Policies and Procedures. Certificate holders with electronic manual systems should have policies and procedures that address the guidelines listed in this chapter. Policies and procedures should be documented in the certificate holder’s manual system. For 14 CFR parts 91K, 121, 125, and 135, documentation should be included in the master manual.

4.3.15.1 A Description of the Electronic Manual System. Policies and procedures should include a description of the electronic manual system. The description should include the methods for distribution and/or access to manual(s), including revision control.

4.3.15.2 Delivery Media. Policies and procedures should include an explanation of the media by which the manuals will be distributed to required personnel.

4.3.15.3 Personnel With Authority and Responsibility. Policies and procedures should list the certificate holder’s personnel who have the overall authority and responsibility for maintaining the electronic manual system.

4.3.15.4 Distribution of Electronic Manual Revisions to the FAA. Policies and procedures should include the certificate holder’s method of distributing electronic revisions to the FAA. When a particular manual requires FAA approval or acceptance, procedures should explain how the certificate holder will submit an electronic revision to the FAA for approval or acceptance of the revised content.

4.3.15.5 Changes to the Electronic Manual System. Policies and procedures should address how the certificate holder will submit electronic manual system changes to the FAA for acceptance, prior to implementation. For 14 CFR parts 91K, 121, 125, and 135, changes to the electronic manual system will typically necessitate a revision to the master manual.

4.3.16 Quality Control (QC) and Auditing. Policies and procedures should include QC and auditing measures that ensure the guidelines for electronic manual systems, continue to be met.

4.3.17 User Instructions and Training. The electronic manual system should include training and instructions necessary to ensure authorized users understand how to use the system.

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4.4 Electronic Manual Authorization.

4.4.1 Submit an Application. Certificate holders will submit their application for an electronic manual system to the responsible Flight Standards office in writing. The FAA will review the application package for accuracy and completeness and notify the certificate holder in writing of any application deficiencies. Before the responsible Flight Standards office accepts the application package, the certificate holder will be required to correct all of the deficiencies. A certificate holder’s application package for authorization to use an electronic manual or manual system should include the following:

4.4.1.1 Letter of Intent. The application should contain the certificate holder’s Letter of Intent to use an electronic manual system.

4.4.1.1.1 Estimated Date of Implementation. The letter should include the estimated date on which the certificate holder would like to implement the electronic manual system.

4.4.1.1.2 Primary Point of Contact (POC). The letter should include the certificate holder’s primary POC for the electronic manual system application process.

4.4.1.2 The Master Manual for 14 CFR Part 91K, 121, 125, or 135. An application to use an electronic manual system for 14 CFR part 91K, 121, 125, or 135 should include a copy of the master manual as described in paragraph 4.3 above. The manual is required by OpSpec A025 and should address the guidelines set forth in this AC, contain policies and procedures, and list each manual maintained and distributed by the electronic manual system. The FAA will not accept an application that does not include the master manual.

4.4.1.3 A Description of the Electronic Manual—14 CFR Parts 133 and 145. An application to use an electronic manual for 14 CFR parts 133 and 145 should include a description of the electronic manual as described in paragraph 4.3 above.

4.4.1.4 Manuals Included in the System. The application should state specifically which manuals the certificate holder intends to maintain and distribute electronically. All of the applicable manuals should be included. For example:

• Flight Operations Manuals (FOM) by title;

• Ground operations manuals by title;

• Maintenance manuals by title;

• Training program manuals by title;

• Electronic MELs;

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• General policy manuals by title; and

• User manuals (e.g., flight planning system and other hardware/software applications) by title.

4.4.1.5 How Electronic Manuals Will Be Provided to the FAA. The application should explain how electronic manuals will be furnished/provided to the responsible Flight Standards office, including an explanation of how revisions and future electronic manuals will be provided.

4.4.1.6 Electronic Access to an MEL. Title 14 CFR parts 91K, 121, 125, and 135 require a certificate holder or program manager to have FAA approval and OpSpec authority to provide access to an MEL via electronic means.

Certificate holders desiring to provide electronic access to an MEL must specify that in the application and include details on how electronic access will be provided.

4.4.2 Demonstration Phase. The FAA will require a certificate holder to demonstrate the electronic manual system. The items requiring demonstration will typically include at least the following:

4.4.2.1 System Functionality. The certificate holder should demonstrate how the electronic manual system works. Specifically, the demonstration should show how manuals are accessed. If access is different for certain users, the demonstration should include how information is accessed by each group.

4.4.2.2 Revision Status. For electronic manuals used in 14 CFR parts 91K, 121, 125, and 135 operations, the demonstration should show how each electronic manual displays the date of latest revision in a manner in which a person can immediately ascertain it (see paragraph 4.3.7 above). Additionally, the demonstration should show how revisions are posted to electronic manuals.

4.4.2.3 Security Protocols. The demonstration should include how the system prevents unauthorized access and/or unauthorized modifications to manual content.

4.4.2.4 QC Procedures. The demonstration should show how the QC and auditing procedures work.

4.4.3 Successful Completion of Application for Approval or Acceptance and Authorization.

When a certificate holder successfully completes the approval (applicable only to electronic access to an MEL) or acceptance process, the FAA will authorize the electronic manual system by signing and issuing OpSpec A025.

4.4.4 Unsuccessful Application. If the certificate holder fails to submit an acceptable application or fails to successfully demonstrate the manual system process, the responsible Flight Standards office will reject the application and provide an explanation to the certificate holder in writing.

5-1 CHAPTER 5. VOLUNTARY DISCONTINUANCE BY CERTIFICATE HOLDER

5.1 Voluntary Discontinuance. If a certificate holder elects to discontinue using electronic signatures, an electronic recordkeeping system, or an electronic manual system, they will inform the responsible Flight Standards office in writing. Once informed, the responsible Flight Standards office will amend the certificate holder’s OpSpec A025 to remove the authorization voluntarily discontinued. Certificate holders that voluntarily discontinue the use of electronic signatures, an electronic recordkeeping system, and/or an electronic manual system should include the following information in their discontinuance letter.

5.1.1 Letter of Discontinuance for Electronic Signatures.

5.1.1.1 The letter from the certificate holder should include the projected date the certificate holder intends to discontinue using the electronic signatures.

5.1.1.2 The letter should contain a description of how the certificate holder intends to transition from using electronic signatures to using pen-and-ink signatures.

5.1.1.3 The letter should contain a description of how electronically signed documents and records will be reproduced and retained in accordance with the requirements of 14 CFR in hardcopy form.

5.1.1.4 If an electronic signature is used in conjunction with an electronic recordkeeping system, the FAA will likely initiate procedures to withdraw authority to use the electronic recordkeeping system.

5.1.2 Letter of Discontinuance for an Electronic Recordkeeping System.

5.1.2.1 The letter from the certificate holder should include the projected date the certificate holder intends to discontinue using the electronic recordkeeping system.

5.1.2.2 The letter should contain a description of how the certificate holder intends to transition from electronic records to paper records. The description should include how the certificate holder intends to ensure the content of the paper records match the electronic content, including having the required signatures.

5.1.2.3 The letter should include the estimated date the paper records will be ready for FAA review.

5.1.3 Letter of Discontinuance for an Electronic Manual System.

5.1.3.1 The letter from the certificate holder should include the projected date the certificate holder intends to discontinue using the system and provide hardcopy manuals, if required by appropriate 14 CFR parts.

5.1.3.2 The letter should contain a description of how the certificate holder intends to transition from electronic manuals to paper manuals. The transition

5-2 description should include procedures for the certificate holder to audit the paper manuals by comparing them to the electronic manuals and reconcile any differences.

5.1.3.3 The letter should include the estimated date the hardcopy manuals will be provided to the responsible Flight Standards office.

6-1 CHAPTER 6. ADMINISTRATIVE

6.1 Questions About This Advisory Circular (AC). If you have questions about the material in this AC or would like to provide feedback, you may contact:

• The Air Transportation Division at Room # 834, 800 Independence Avenue, SW, Washington DC, 20591, or by phone at 202-267-8166; and/or

• The Aircraft Maintenance Division at 8th Floor, 800 Independence Avenue, SW, Washington, DC 20591, or by phone at 202-267-1675.

6.2 AC Feedback Form. For your convenience, the AC Feedback Form is the last page of this AC. Note any deficiencies found, clarifications needed, or suggested improvements regarding the contents of this AC on the Feedback Form.

6.3 Other Related Regulations, Guidance, and Reading Material (current editions).

6.3.1 Regulatory References:

• Public Law (PL) 104-13, Paperwork Reduction Act of 1995.

• PL 105-277, Government Paperwork Elimination Act.

• PL 106-229, Electronic Signatures in Global and National Commerce Act (E-Sign Act).

• Title 14 CFR Parts 43, 61, 65, 91, 119, 121, 125, 129, 133, 135, 137, 141, 142, 145, and 147.

• Office of Management and Budget (OMB) Circular A-130, Managing Information as a Strategic Resource.

6.3.2 FAA Order 8900.1, Flight Standards Information Management System. Certificate holders can find Order 8900.1 on the Dynamic Regulatory System (DRS) at https://drs.faa.gov.

6.3.2.1 Title 14 CFR Part 121 Dispatch and Flight Release Requirements— Electronic Signatures, Amendments, and Disposition. Information regarding electronic signatures on a dispatch or flight release, electronic amendments to a dispatch or flight release, and/or electronic recordkeeping of a dispatch or flight release is contained in Volume 3, Chapter 25, Section 1, Basic Requirements and Policy Applicable to All Air Carriers.

6.3.2.2 Title 14 CFR Part 121 En Route Communication Records. Information on the electronic retention of en route communication records in accordance with 14 CFR § 121.711 is contained in Volume 3, Chapter 25, Section 1.

6.3.2.3 Title 14 CFR Parts 121 and 135 Recordkeeping Systems Acceptance or Approval Process. Information and guidance to be used by PIs when accepting or approving certificate holder recordkeeping systems is contained

6-2 in Volume 3, Chapter 31, Section 2, Requirements for Approval, Acceptance, and Authorization.

6.3.2.4 Title 14 CFR Parts 121 and 135 Crewmember and Aircraft Dispatcher Records. Volume 3, Chapter 31, Section 3, Crewmember and Aircraft Dispatcher Records, contains detailed information regarding crewmember and aircraft dispatcher records in accordance with the requirements of 14 CFR parts 121 and 135, as applicable.

6.3.2.5 Title 14 CFR Parts 121 and §

135.411(a)(2) Maintenance Records.

Volume 20, Chapter 7, Maintenance Recordkeeping System, contains detailed information regarding the evaluation of an air carrier’s maintenance recordkeeping system.

6.3.2.6 Title 14 CFR Part 91K Non-CAMP Program Manager’s, 14 CFR § 125.247 Certificate Holder’s, and 14 CFR § 135.411(a)(1) Maintenance Records. Volume 3, Chapter 31, Section 6, Evaluate an Owner’s or Operator’s Maintenance Records as Required by § 91.417, contains information for Airworthiness inspectors on how to evaluate 14 CFR part 91K non-CAMP and 14 CFR part 135 maintenance records.

6.3.2.7 Title 14 CFR Part 145. Volume 6, Chapter 9, Section 6, Inspect a Repair Station’s Record System, contains detailed information on repair station electronic signatures and electronic recordkeeping.

6.3.2.8 Operations Specification (OpSpec) A025, Electronic Signatures, Electronic Recordkeeping Systems, and Electronic Manual Systems.

Information on how to issue OpSpec A025 is contained in Volume 3, Chapter 18, Section 3, Part A Operations Specifications—General, OpSpec/MSpec/TSpec/LOA A025.

6.3.2.9 OpSpec A061, Electronic Flight Bag (EFB) Program. Information related to authorization to use an EFB program is contained in Volume 3, Chapter 18, Section 3, OpSpec/MSpec/LOA A061.

6.3.3 FAA Order 8000.79, Use of Electronic Technology and Storage of Data.

6.3.4 Related ACs:

• AC 90-117, Data Link Communications.

• AC 91-78, Use of Electronic Flight Bags.

• AC 91.21-1, Use of Portable Electronic Devices Aboard Aircraft.

• AC 120-64, O perational Use and Modification of Electronic Checklists.

• AC 120-76, Authorization for Use of Electronic Flight Bags.

6.3.5 Other Reading Material:

• OMB Memorandum M-00-15, OMB Guidance on Implementing the Electronic Signatures in Global and National Commerce Act.

• Federal Information Processing Standards (FIPS) Publication 186-5, Digital Signature Standard (DSS) at https://doi.org/10.6028/NIST.FIPS.186-5.

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Appendix A A-1 APPENDIX A. SAMPLE LETTER OF INTENT Note: Certificate holders should use this AC to identify the various requirements for the Letter of Intent contents.

[Requester Letterhead] To: [Responsible Flight Standards office] From: [Requester] Date: [Date] Subject: Use of Electronic System – (Signatures/Recordkeeping/Manuals) This letter is to inform you that [requester] intends to use an electronic (signatures and/or recordkeeping and/or manual) system for [describe what the system will be used for]. This system has been established using the guidelines outlined in FAA Advisory Circular (AC) 120-78 (as amended).

Company facilities, equipment, and personnel are available for your review at [address] on [date]. Please contact [name] at [telephone] to arrange a visit to review the system and to discuss any FAA concerns.

Sincerely, [Requester]