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Record retention period for a modifier who submits a declaration of compliance

Remote Pilot (Part 107) practice question 11 of 19 on Regulations / Operations Over People. ACS element UA.I.E.K13 · difficulty: applied. Want to answer it in a timed quiz? Use the Remote Pilot (Part 107) practice mode.

Question bank updated 2026-09-22

QUESTIONAn applicant who modified a small unmanned aircraft, but does not produce it, submitted a declaration of compliance for Category 2 on March 1, 2022; the FAA accepted the declaration on April 15, 2022. Under § 107.165, until what date must the applicant retain the supporting information used to show compliance?

  1. AMarch 1, 2024
  2. BApril 15, 2024
  3. CTwo years after production of the aircraft stops
Show the answer and explanation

Correct answer: A. March 1, 2024

  • A — correct § 107.165(a)(2)(ii) requires a person who designs or modifies the aircraft to retain the supporting information for two years after the person submitted the declaration of compliance. Two years after March 1, 2022 is March 1, 2024.
  • B — incorrect The two-year period runs from the date the declaration was submitted, not the date the FAA accepted it.
  • C — incorrect The retention period tied to cessation of production applies only to a person who produces the aircraft under § 107.165(a)(2)(i); this applicant only modified it.

BACKGROUND

Section 107.165 sets record retention duties for people who submit a declaration of compliance (DoC) or a means of compliance (MoC). A DoC submitter must retain, and make available to the Administrator on request, all supporting information used to show the aircraft meets § 107.120(a) for Category 2 or § 107.130(a) for Category 3. The retention period depends on the applicant's role: a producer must keep the information for two years after production of that system ceases, while a person who designs or modifies the aircraft must keep it for two years after submitting the declaration. A MoC submitter must retain the detailed description and justification for as long as the means of compliance remains accepted.

STUDY TIP

First decide whether the applicant produced, designed or modified the aircraft; then apply the matching trigger date and add two years.

KEY POINTS

  • Producers retain DoC supporting information for two years after production ceases.
  • Designers and modifiers retain it for two years after submitting the declaration.
  • The clock starts at submission, not FAA acceptance.

SOURCES

  • 14 CFR 107.165(a)(2)
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SkyDrill is not affiliated with the FAA. This is an original practice item based on 14 CFR part 107, 14 CFR part 89, and the FAA Remote Pilot – Small UAS Study Guide (FAA-G-8082-22). Regulations and handbooks are revised; confirm details against the current edition.