Who owns aircraft maintenance records, and what can an MRO license?

Who owns aircraft maintenance records, and what is left for the MRO?

The aircraft's maintenance records belong with the aircraft. As generally understood, FAA maintenance rules in 14 CFR Part 91 put the duty to keep them on the owner or operator and require them to be transferred to the buyer when the aircraft is sold; verify against the current regulation text. A repair station keeps a separate set: its own records of the work it performed, plus many working documents that never reach the customer's logbook.

That makes the objection sellers often hear, "the shop doesn't own the records, so there is nothing to license", only half right. The logbook entry a technician signs is the customer's record. The work order package, teardown worksheet, repair quote and quality investigation behind that entry are the shop's own working records, and they are what a data license would cover.

This page does not restate retention periods or the wording of individual FAA rules; read the current regulation and confirm with aviation counsel before relying on any detail. This is general information, not legal, tax or financial advice. Confirm with your own counsel, tax adviser or professional body before acting.

What is actually true: custody, contract and copyright

Ownership of an MRO's records runs on three tracks, and an archive only counts as a licensable asset when all three point the same way.

Custody is the regulatory track: who must keep which record. It puts aircraft and component records with the owner or operator, and evidence of the shop's own work with the shop.

Contract is the commercial track. General terms agreements with airlines, lessors and fleet operators often say who owns data generated during a repair, what is confidential and whether the shop may use it beyond the job. A restrictive clause can block a license even where the shop wrote every word.

Copyright is the authorship track. Text that employees write within the scope of their jobs is generally a work made for hire, so the employer is treated as its author and owner, as the Copyright Office explains in Circular 30 on works made for hire. Narratives written by contract mechanics from a staffing agency may not belong to the shop unless an agreement assigns them in writing. And because 17 U.S.C. 201 lets an owner transfer individual rights separately, a company can grant AI-training rights while keeping ownership of the records.

Which MRO records are candidates for a license?

Sort the data room by whose record each item is. Only the shop's own working records go forward.

Customer names, tail numbers, serial numbers and technician names are the usual redaction targets; the matrix of PII redaction by record type shows how those rules are set record by record. Redaction and de-identification requirements are agreed with the company before any work begins. A shop's internal hazard reports follow their own logic, covered in near-miss and safety incident reports.

Why the answer matters in an aviation services sale

The records question surfaces at three points in a sell-side process, and each one has an owner on the deal team.

• Structure. In a stock sale the company keeps its records and contracts under new ownership. In an asset sale the purchase agreement decides which archives transfer, so name the work order and quality archives, and the right to license them, in the schedules.
• Diligence. Buyers ask whether data has already been licensed. Licenses arranged through SourceX are typically exclusive for AI training for an agreed term, so a completed license belongs in the disclosure schedules.
• Timing. Some sellers prefer to finish a license before marketing the business; others leave it to the buyer. Agree the sequence with deal counsel before anyone contacts SourceX.

Long histories carry the value. A decade of teardown findings matched to later warranty returns says more than last year's work orders, for the same reason that git history matters more than a code snapshot.

How to answer the objection in a seller meeting

Agree with the part that is true, then move to what the shop does control.

If the buyer's counsel raises it later, the one-line version is: the license covers the company's own process records, excludes customer aircraft records, and is disclosed in the data room.

The 3C check before you introduce an MRO

Run these with the CEO or accountable manager in one meeting. A clear no on any line means park the idea for now.

• Custody: can the shop separate its own work order and quality records from copies of customer logbook entries and release documents?
• Contract: have the largest customer agreements been read for data ownership, confidentiality and use restrictions?
• Copyright: did employees write most narratives, or did contract mechanics write long stretches without a written assignment?
• Scale: does the business have 50+ full-time employees at peak (contractors excluded) and several years of documented work?
• Exportability: can someone still export the archive, including history from a retired maintenance system?
• Sponsor: will the owner, CEO, CFO or another authorized representative take the call?

The data inventory builder helps the shop list its systems and years of history without sharing any record, and who qualifies sets out the full company baseline.

When the objection is right

Sometimes there really is little to license:

• The shop works inside a customer's maintenance tracking system, so its history sits in the customer's environment.
• Customer agreements assign all repair data to the customer or bar any secondary use.
• Most of the archive is copies of customer records rather than the shop's own working documents.
• Export-controlled or defense work makes up most of the volume.
• A migration lost the old system's history, or nobody can export it.

In those cases, narrow the scope to internal quality and process records, ask the largest customers whether they would consent, or wait until a planned migration produces a complete export.

How the introduction and reward work for an advisor

1. Walk the owner through the 3C check and confirm they want to hear more.
2. Share your referral link, which takes the company to sourcex.si/apply with your code attached, or submit the company through the referral form.
3. SourceX reviews size, history, data breadth and rights directly with the sponsor.
4. The shop completes a data inventory, agrees price and terms, and buyers review the opportunity.
5. When the deal closes, the data is delivered under the agreed redaction rules and the company is paid.

Partners earn 25% of the eligible platform fees SourceX actually collects from the referred company's licensing deals, capped at $100,000 per referred company. Rewards are paid only after the buyer pays and SourceX receives its fee, and no reward is guaranteed. The reward comes out of SourceX's fee, never out of the seller's proceeds. Check your engagement letter and any rules that apply to your firm before accepting it; the page for M&A advisors covers the program from a sell-side view.

Next step

Take the 3C check into your next meeting with an aviation services client. If the shop's own records pass, register as a partner and make the introduction, or have the owner apply directly at sourcex.si/apply through your referral link.