Explainer
FAA Rules for Electronic Manuals
The Short Answer
Optional, but Accepted Through A025
No FAA rule makes a certificate holder go electronic. If a Part 121 or 135 operator, or a Part 145 repair station, chooses to, the FAA expects to accept the system first, and it records that acceptance in OpSpec A025. The guidance behind it is AC 120-78B, Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals, dated 11 December 2024, which cancelled AC 120-78A of 22 June 2016.
The AC is guidance. It states that it describes an acceptable means, not the only means, and that it does not have the force and effect of law. The binding text is in the regulations it points to. Read your own operations specifications and the rule text rather than relying on a summary, this page included.
Who Needs What
Approval, Acceptance, or Nothing
- Approval: the electronic MEL and Part 121 crewmember records
- The rules for flightcrew access to the MEL say printed or other means approved by the Administrator, so an electronic MEL needs FAA approval on top of acceptance of the manual system. Section 121.683(c) likewise allows a computerized crewmember and dispatcher recordkeeping system approved by the Administrator.
- Acceptance and OpSpec A025: Parts 91K, 121, 125, 133, 135, and 145
- Everything else these certificate holders move to electronic form needs FAA acceptance, and the FAA conveys it through OpSpec A025, Electronic Signatures, Electronic Recordkeeping Systems, and Electronic Manual Systems. Training providers under Parts 141, 142, and 147 get A025 too, for electronic records and the signatures on them.
- No formal action: Parts 61, 63, 65, 91 (except 91K), 129, and 137
- The AC says no approval, acceptance, or authorization is needed, and recommends following the guidance anyway. If an electronic record or manual lacks the key elements, the FAA may question its validity and notify the holder in writing to correct it.
The 2023 Rule
The Revision Date Must Be Easy to Find
On 30 May 2023 the FAA published "Updating Manual Requirements To Accommodate Technology" (88 FR 34437, effective 29 June 2023). It rewrote the manual rules so that paper and electronic copies are treated separately. Under 14 CFR 121.135(a), a manual accessed on paper shows the date of last revision on each page, and a manual accessed electronically shows it "in a manner in which a person can immediately ascertain it." Section 135.21 was amended in the same rule, and the AC cites the matching provisions for Parts 91K and 125.
The FAA's stated reason was revision control: there has to be a way to confirm that employees are using the current manual, and the date does that most simply while leaving the carrier free to choose where to show it. The AC gives three examples: a date on each page, a date on each block in a continuous-flow manual, or a revision control page. For a publications team the practical point is that the date has to travel with the content, not sit in a file name or a portal admin screen.
Inside the Manual
What the Manual Itself Should Show
AC 120-78B expects an electronic manual to give equivalent or better integrity, accuracy, and accessibility than the printed one, and to carry the elements a printed manual normally has:
- The manual title, and chapter and section numbers with topic headings.
- A revision control page or section from which the user can readily tell whether the manual is current.
- A list of effective pages.
- An indication of FAA approval (a signature or stamp) on any manual or section that needs it.
- Page numbers.
- The applicable aircraft, engine, propeller, appliance, component, or part make and model, where relevant to the MEL and to maintenance.
- The person with authority and responsibility for the manual content.
The system around the manual has its own checklist: controlled access, a way to keep every holder of a copy current, FAA access to the manuals, an archive of superseded revisions, backup, and a master manual that describes the system and lists the manuals on it. For Parts 91K, 121, 125, and 135 the master manual is named in A025, and the FAA will not take an application without it. A repair station under Part 145 describes how each electronic manual is displayed, maintained, revised, and distributed in its own manual system, and 14 CFR 145.207 requires the repair station manual itself to reach the FAA in a format the FAA accepts. What that manual and the quality control manual each have to contain is covered in repair station manual vs quality control manual.
Signatures and Records
Electronic Signatures and Recordkeeping
Maintenance records, training records, dispatch and flight releases, and airworthiness releases are the typical records, and a signature on any of them in electronic form needs an accepted recordkeeping system behind it. The AC lists what a valid electronic signature has: it is unique to the signer, identifies and authenticates the signer, stays under the signer's sole control, is applied with intent and by deliberate action, prevents the signer denying it, and is permanent, so a signed record cannot be edited without a new signature.
For the record itself, the AC wants the type of event, when and where it took place, who was involved, the certification or authentication required by regulation, and for maintenance records the make and model of the aircraft, engine, propeller, appliance, component, or part. The system needs controlled access, protection against corruption, backup, and a software revision control process. For Parts 91K, 121, 125, and 135 that process must notify the responsible Flight Standards office when a software revision affects record entry, display, access, or data quality.
Each electronic signature process is listed in A025, together with the manual that describes it. The FAA asks for a letter of intent and a live demonstration before it signs. Our revision-currency explainer covers keeping maintenance data current across a fleet.
Flight Deck
How the EFB Rules Differ
An electronic flight bag is authorized separately. An operator under Parts 91K, 121, 125, or 135 that wants to replace required paper information on a tablet or installed equipment seeks OpSpec, MSpec, or LOA A061, Electronic Flight Bag Program, under AC 120-76E, Authorization for Use of Electronic Flight Bags (12 June 2024). Installation of EFB components on the aircraft is covered by AC 20-173.
The two instruments meet in one place. AC 120-78B says manual, recordkeeping, and signature functions may sit on an EFB, provided the holder already has authority for them in A025. The revision test then looks different on the flight deck: AC 120-76E expects a procedure that lets crewmembers confirm the revision numbers or dates of the databases and software on their unit for each flight, and for cycle-based data it should be evident which cycle is loaded. Our flight operations library guide describes the shelf an EFB carries, and the AFM and QRH explainer and minimum equipment list guide cover two documents where electronic access has its own conditions.
For Publications Teams
What Your Content Has to Make Possible
The acceptance is the operator's or repair station's, not the supplier's. What a publications team controls is whether the content and its delivery make the operator's application easy or hard. Working from AC 120-78B, an operator will need these from you:
- A visible last-revision date on every page, or on every block for continuous-flow content, plus a revision control page. This is the part the 2023 rule made explicit.
- Revision notices that state what changed, the effective date, and what the user must do to load the revision, with a way to compare against the prior version or an explanation of the effect.
- Changed content that is readily apparent to the reader.
- Identical content on every authorized device. The AC allows the layout to differ between a flight deck tablet and a workstation, but not the content.
- A way to trace any displayed passage back to its source document.
- Superseded revisions archived, so earlier instructions can be reconstructed for repair tracing, training, or investigation.
- Data integrity preserved when content moves from one system to another, with the archive intact.
- A backup path to the manuals if the system, software, or network fails.
Most of this is revision discipline applied to delivery, the subject of effective-dated publishing. For the platform view, see the field guide to aviation technical publication systems, and for how flight operations data is packaged between manufacturers and operators, the ATA Spec 2300 standard page.
FAQ
Questions We Hear
Does the FAA require electronic manuals to be approved?
Mostly it asks for acceptance, not approval. For Parts 91K, 121, 125, 133, 135, and 145, AC 120-78B says FAA acceptance is required, conveyed through OpSpec A025. Approval is reserved for specific items, notably an electronic MEL. Use of electronic systems is optional, and the AC describes an acceptable means, not the only means.
What is OpSpec A025?
It is the operations specification through which the FAA authorizes electronic signatures, electronic recordkeeping systems, and electronic manual systems. For Parts 91K, 121, 125, and 135 the AC says it also lists the master manual that describes the electronic manual system, and each electronic MEL by aircraft make and model. The template name varies by regulatory part.
What did the 2023 rule change about manuals?
The final rule at 88 FR 34437, published 30 May 2023 and effective 29 June 2023, updated manual requirements to accommodate technology. In 14 CFR 121.135(a), paper manuals still show the date of last revision on each page, and electronic manuals must show it in a manner in which a person can immediately ascertain it. The FAA left the placement of the date to the carrier.
Which version of the advisory circular is current?
AC 120-78B, dated 11 December 2024. It cancelled AC 120-78A of 22 June 2016. Check the FAA advisory circular index before you cite either one, since a revision letter is the first thing a stale proposal gets wrong.
Does an electronic flight bag need A025 as well?
An EFB program is authorized through OpSpec, MSpec, or LOA A061. The AC says manuals, recordkeeping, and signature functions may live on an EFB only if the holder also has authority for them in A025. EFB program guidance is in AC 120-76E, dated 12 June 2024.
Does AC 120-78B apply to the manufacturer's own manuals?
Not as written. The AC is aimed at entities regulated by Flight Standards, and it says it is not meant for the signature, recordkeeping, and manual requirements that Aircraft Certification sets for design and production approval holders. The operator or repair station carries the A025 authorization for the copies it uses, which is why the manufacturer's content has to be easy to fit into it.
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Revision Dates That Show Themselves
If your manuals need a visible revision date, a change summary, and a clean archive before an operator can put them on a tablet, send us a sample set and we will look at how they are built.