Drone Flight Log Requirements, Remote ID, and Records Audits

There is no federally mandated flight log for Part 107 operations. Nothing in Part 107 requires you to record a takeoff time, a battery serial, a location, or a mission type. This surprises nearly everyone who comes to drones from a manned aviation background, and it is the single fact that most distorts how agencies build their programs.

What the FAA requires is different in kind. Outside a few narrow triggers, the obligation is almost never "submit something on a schedule." It is "maintain a record and produce it when asked." Reporting duties are event-driven and rare; retention duties are continuous and broad. Programs do not fail audits because they broke a rule. They fail because a rule was probably followed and they cannot prove it.

This guide covers what the regulations actually require you to keep, how Remote ID compliance works and where its two broadcast paths diverge operationally, why public aircraft operations shift the evidentiary burden onto your own files, who will ask, and what a defensible program can produce on demand.

What the FAA actually requires you to keep

The requirements split into three buckets by authority. Most public-safety programs sit in two at once: Part 107 for some pilots and missions, a Part 91.113 Certificate of Waiver / Authorization for the rest. The obligations do not merge. They stack.

Part 107 operations

Three things are mandatory and everything else is discretionary.

Safety event reporting under 107.9. Report to the FAA within 10 calendar days any operation resulting in serious injury to any person, any loss of consciousness, or damage to property other than the aircraft, unless the cost of repair or the fair market value of the property is $500 or less. That is the entire routine reporting obligation. Note the trap in the threshold: $500 is a low bar in 2026, and damage to a parked vehicle or a storefront window clears it easily.

Registration and marking. Every aircraft flown under Part 107 is registered individually, regardless of weight, at $5 for three years. The number must be visible on the exterior before flight and proof of registration available. A drone registered under the recreational exception cannot be flown under Part 107 without re-registering it — see the Part 107 guide.

Currency under 107.65. Aeronautical knowledge recency every 24 calendar months, satisfied by a free online course (ALC-677, or ALC-515 for current Part 61 airmen). The certificate never expires; currency does, on the last day of the calendar month 24 months out. There is no grace period. Keep the FAASafety.gov completion certificate — it is the only artifact proving the date.

Three more sections shape what you should keep without demanding a log: 107.7 (certificate readily accessible, presented on request to the FAA, NTSB, TSA, or law enforcement; aircraft subject to inspection), 107.15 (condition for safe operation, preflight check before every flight), and 107.49 (preflight duties). None say "write it down." All are far easier to defend if you did.

The trap. No flight log requirement is not permission to operate without records. It means the FAA has not told you what your records must look like, so when an inspector, a plaintiff's attorney, or your city council asks what happened on a given date, whatever you produce is the whole of the evidence. Silence is not neutral.

Public aircraft operations under a 91.113 CoW/A

The April 2025 expedited Part 91.113 CoW/A removed the two burdens agencies complained about most: no NOTAM requirement and no monthly reporting. What survives is retention and on-request production, and it is substantial.

• NTSB reporting under 49 CFR Part 830 is expressly not waived. Immediate notification under 830.5 goes to the NTSB Response Operations Center by the most expeditious means available; an accident report follows within 10 days on Board Form 6120.1, and incident reports are filed only on NTSB request. Under 830.10 you preserve wreckage and related records until the Board releases them — so your video-purge cycle has to be suspendable.
• 500-foot proximity events. Report any event in which the unmanned aircraft came within 500 feet vertically or horizontally of another aircraft, with closest-point-of-approach measurements. Measurements, not estimates. If your flight-data logging does not capture position at sufficient resolution to reconstruct a CPA, you cannot satisfy this condition after the fact.
• Loss-of-control events must be reported.
• All flight times, including monthly totals, available to the Administrator on request. This is the flight log requirement Part 107 lacks. It is not a submission; it is a standing production obligation with no notice period.
• Pilot Records Database, 14 CFR Part 111, which expressly reaches entities conducting public aircraft operations as defined in 49 U.S.C. § 40102(a)(41), other than military and National Guard entities, with compliance required since 9 September 2024.
• Current pilot and aircraft lists available for inspection. Rosters go stale faster than anything else in a drone program.

Your ConOps is a record too. The application becomes part of the certificate. Whatever you wrote about launch sites, call types, crew composition, and altitudes is a binding condition, and an audit compares your flight records against your own words. See the Part 91 COA and waiver guide for what goes into the package.

Legacy blanket and jurisdictional COAs

A blanket or jurisdictional COA still carries NOTAMs and monthly reporting, and both are VLOS-only with terms of no more than 24 months. Where the 91.113 CoW/A covers the same missions with neither burden, letting a legacy COA lapse is a recordkeeping decision as much as an operational one.

Everything else you will actually be asked for

None of the above is what most audits turn on. The real requests are for training and currency files by pilot, maintenance and self-certification evidence by tail number, equipment custody records, proof that operations conformed to the ConOps, and signed policy acknowledgments. None carry a CFR citation. All are asked for first.

Remote ID compliance and the difference between the two broadcast paths

Remote ID under 14 CFR Part 89 applies to every drone that requires registration — recreational, commercial, and public-safety aircraft alike. Manufacturer compliance was due 16 September 2022 and operator compliance 16 September 2023; the FAA's enforcement discretion ended 16 March 2024 and Part 89 has been fully enforced since, with no amendment in 2025 or 2026. There are three compliance paths, and the choice between the first two has real operational consequences.

The difference that matters operationally is the control-station position. Standard Remote ID broadcasts your operator location continuously and publicly; anyone with a receiver app can see where the crew is standing. A broadcast module broadcasts only the fixed take-off point — a different privacy exposure, and also why a module cannot support BVLOS. The Part 91.113 CoW/A requires Standard Remote ID for BVLOS unless the FAA authorizes otherwise, so a retrofitted aircraft is not a BVLOS aircraft.

The third path is a FRIA, an FAA-Recognized Identification Area where non-equipped aircraft may be flown within visual line of sight. FRIA authorizations run 48 months and are renewable, and sponsors are limited to community-based organizations, educational institutions, trade schools, colleges, and universities. A police department cannot sponsor one for itself.

The registration field that trips everyone. The Remote ID serial number you enter at registration is not the drone's serial number. It is a separate identifier assigned to the Remote ID equipment, and you get it from the manufacturer. Entering the airframe serial produces a registration that looks complete and is wrong.

Part 89 does provide a narrow route for law enforcement and other government entities to obtain temporary authorization not to broadcast where operational security genuinely requires it. Treat it as narrow: routine categories such as search and rescue, training, and firefighting generally do not qualify, and it is not a blanket agency exemption. That characterization comes from secondary sources rather than FAA text, so check 14 CFR 89.510 and 89.520 and the FAA public-safety toolkit before planning around it.

Self-certification under public aircraft operations means the records are the standard

AC 00-1.1B states that public aircraft operators "may self-certify standards for unmanned aircraft (UA) airworthiness as well as pilot certification, qualification, and medical standards," and that such operations "create a significant transfer of responsibility to the contracting government entity, and that most FAA oversight ceases."

Read that as a records mandate. When you certify your own standards there is no external certificate to point to, so the written standard and the evidence of compliance with it are the standard. A defensible PAO program has four artifacts:

1. A written pilot qualification standard — what a pilot must hold, demonstrate, and complete before flying agency aircraft, adopted by the agency, not inherited from a vendor slide deck.
2. Per-pilot evidence that each individual meets it: initial qualification, evaluation records, mission-type sign-offs, and any medical or fitness attestations your standard requires.
3. A maintenance program — inspection intervals, who may perform work, component life limits, firmware baselines, and a per-aircraft history that survives reassignment between units.
4. A defensible currency definition. Public aircraft status does not import 107.65, so you define currency yourself and then track it. "Three flights in 90 days" is defensible. "Our pilots fly constantly" is not.

Public aircraft status is determined flight by flight, not once at program launch, so the record that a given flight was a governmental function under 49 U.S.C. § 40125 lives in your mission log. Cost recovery from another agency can nullify public aircraft status for that flight, which makes mutual-aid billing records aviation records whether your finance office thinks so or not.

Three audiences who will ask for your records

The FAA. Narrow and specific: waiver conditions and safety events. Flight times and monthly totals, pilot and aircraft lists, proximity and loss-of-control reports, Remote ID equipage, and whether operations matched the ConOps you filed. An FAA drone audit is usually reconstructive — it starts from one event and works outward.

A public records request, a defense attorney, or a journalist. The broadest ask, and it lands at flight-by-flight granularity: date, time, duration, location, mission type, call number, pilot, aircraft, and whether video exists. Expect questions about sensors carried, whether footage was retained, who accessed it, and what policy applied. If you run a DFR program, expect the EFF's critique — that deployments concentrate on low-risk calls rather than emergencies — to be tested against your own call-type data. Eighteen states require a warrant before drone deployment for surveillance or evidence-gathering, with exigency and rescue exceptions; there, the warrant or exigency justification is part of the flight record.

Your governing body. Aggregate, not granular: how the equipment was used and for what purposes, complaints received, internal audit results and violations, total annual cost by category including funding sources, quantity possessed, and what you intend to acquire next year. In California that is not optional — Cal. Gov. Code § 7072 requires exactly that report annually, followed within 30 days by a community engagement meeting. The AB 481 transparency guide has the full list.

How long to keep flight data and video

The honest answer: federal aviation rules mostly do not set video or flight-data retention periods. Part 107 sets none. The 91.113 CoW/A requires flight-time records without stating a purge date. Part 830 requires preservation only after a reportable event.

What governs retention is your state records retention schedule, your state's evidence rules, and your own policy. Practice varies widely, and the commonly cited figures come from published agency policies rather than any federal floor: Montgomery County at about 180 days for non-evidentiary footage, New York City at 30 days, and Chula Vista at 90 days unless flagged as evidence. Pick a period, write it into policy, and make the evidence flag something an operator triggers at end of mission, not a task that depends on someone remembering next week.

Two rules regardless of the number you pick. Flight records outlive video — they are cheap, and they are what reconstructs a closest-point-of-approach measurement two years later. And any retention clock must be suspendable the moment litigation, a Part 830 event, or a records request touches a flight.

A records readiness checklist

Judge your program by response time, not by whether the data exists somewhere.

Within one hour: the flight record for any date and time — pilot, aircraft, duration, location, mission type; the pilot roster with each pilot's currency status and expiration date; the aircraft list with registration numbers and Remote ID equipage; and the signed waiver, COA, or authorization with its expiration.

Within one business day: all flight times for any month with a total; every flight by a named pilot or aircraft over a stated period; maintenance history including firmware for any aircraft; training and qualification files for any pilot; and whether video exists for a given flight and is still within retention.

Within one week: an aggregate use report by mission type and outcome for a fiscal year; program cost by category with funding sources; complaints and their dispositions; audit results and policy violations with actions taken; and a full reconstruction of one incident from flight data, video, the policy in force that day, and the authority the flight was conducted under.

If the one-week list is the only one you can meet, you have a data collection, not a records system.

Common failure modes

• Paper logs and spreadsheets that do not reconcile. The unit binder, the vendor's cloud flight history, and the CAD entry disagree, with no rule for which wins. Name the system of record in writing.
• Currency tracked in someone's head. It works until that sergeant transfers, and it is indefensible the moment a lapsed pilot flies. Currency needs an expiration date field and an alert, not institutional memory.
• Missing maintenance history on a self-certified aircraft. Under public aircraft operations the maintenance record is the airworthiness argument. An aircraft with no history has, evidentially, no airworthiness basis.
• No audit trail on edits. A flight log that can be changed after the fact without recording who changed it and when is worth little in litigation. Editability is fine; untracked editability is not.
• Video retained inconsistently across units. Patrol keeps 90 days, SWAT keeps everything, the fire side keeps nothing. One request spanning all three exposes it, and it reads as bad faith even when it is only drift.

Frequently asked questions

Is a drone flight log required by the FAA?

Not under Part 107. No section of Part 107 requires one, which is why many programs run for years without a log. It is required under a Part 91.113 Certificate of Waiver / Authorization, where a standing condition requires retention of all flight times including monthly totals, available to the Administrator on request. Legacy blanket and jurisdictional COAs require monthly reporting, which no one can produce without a log.

How long do I have to report a drone accident to the FAA?

Ten calendar days, under 14 CFR 107.9, for any operation causing serious injury, loss of consciousness, or damage to property other than the aircraft where repair cost or fair market value exceeds $500. Separately, 49 CFR Part 830 requires immediate NTSB notification of a reportable accident and a written report within 10 days on Board Form 6120.1. Part 830 is not waived by a Part 91.113 waiver.

Does Remote ID apply to public safety drones?

Yes. 14 CFR Part 89 applies to every drone that requires registration, including public-safety aircraft, and has been fully enforced since the FAA ended enforcement discretion on 16 March 2024. Part 89 provides a narrow authorization for law enforcement and government entities not to broadcast where operational security requires it, but routine categories such as search and rescue, training, and firefighting generally do not qualify.

What is the difference between Standard Remote ID and a broadcast module?

Standard Remote ID is built into the aircraft and broadcasts the aircraft ID, its position and velocity, the live control station position, an emergency status field, and a time mark. A broadcast module is a retrofit broadcasting the module's serial number, the aircraft's position and velocity, the fixed take-off location, and a time mark, with no emergency status field. A module is visual-line-of-sight only and cannot support BVLOS.

How long should a police department keep drone video?

Federal aviation regulations do not set a retention period for drone video. State records retention schedules, evidence rules, and agency policy do. Published agency practice ranges widely: Montgomery County retains non-evidentiary footage roughly 180 days, New York City 30 days, and Chula Vista 90 days unless flagged as evidence. Whatever period you adopt, it must be suspendable when litigation, a reportable safety event, or a records request touches a flight.

Who tracks pilot currency for a public aircraft operation?

You do. Public aircraft operators self-certify pilot certification, qualification, and medical standards under AC 00-1.1B, so 107.65's 24-calendar-month knowledge recency does not automatically govern agency flights. The agency must write its own currency definition, apply it consistently, and hold per-pilot evidence that each individual meets it. Because the standard is self-certified, the records are the only proof it exists.

Where this leaves you

Write down which authority each of your missions flies under, map the obligations in the first table onto your actual files, and mark every gap. Most programs find the same three: no reconciled flight log, currency tracked informally, and maintenance history that does not follow the aircraft.

Then set the two policies the FAA has not written for you — a retention period for flight data and video with a working evidence flag and litigation hold, and a pilot qualification and currency standard specific enough that a stranger could audit against it — and confirm your Remote ID posture aircraft by aircraft, including whether each registration carries the equipment serial rather than the airframe serial. Flight records, currency tracking, and incident documentation have to live in one system of record with an audit trail, whether that is software you buy or a process you build.