Ask a room full of aircraft owners what they are allowed to do to their own aeroplane and most will give you the same number. Thirty-two jobs, they will say. It is on the list, in Appendix A.

Count them. There are thirty-one.

The thirty-second was struck out on 28 January 2013, and the reason it went is a better story than the job itself. It is also the perfect way into a piece of regulation that almost every pilot half-knows and almost nobody has actually read: the closed list of work that a certificated pilot may legally carry out on their own aircraft, sign off themselves, and fly away.

The list is longer than most owners think and narrower than most owners hope. Here is all of it, who may use it, and where it stops.

Legally, it is not maintenance at all

Start with the definitions in 14 CFR 1.1, because they set up everything that follows and they are quietly strange.

Preventive maintenance is defined as “simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations.” Fine. But look at the entry immediately above it. Maintenance means “inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.”

Read that again. In the Federal Aviation Regulations, preventive maintenance is not a subset of maintenance. It is carved out of it. The two are legally separate categories, which is precisely why a pilot with no mechanic certificate can lawfully touch an aircraft at all, and why the boundary between the two matters so much. Cross it and you are doing maintenance, and maintenance needs an A&P.

Appendix A to Part 43 is where that boundary is drawn. Paragraph (a) lists major alterations, paragraph (b) lists major repairs, and paragraph (c) lists preventive maintenance. Paragraph (c) opens with a qualifier that owners skip over at their peril: the work is permitted “provided it does not involve complex assembly operations.” Every one of the thirty-one items is subject to that condition.

Free Pilot Training’s PPL lesson on maintenance basics is the clearest plain-English walk through the Part 43 and Part 91 recordkeeping framework that sits around the list.

Doing the work and signing it off are two different privileges

This is the part that trips people up, and it trips them up because the two halves live in different sections of the same rule.

Section 43.3(g) governs who may faire the work: “Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135 of this chapter.” Sport pilots get their own sentence immediately after, limited to aircraft holding a special airworthiness certificate in the light-sport category.

Note what 43.3(g) does pas say. It does not say private pilot. Any Part 61 pilot certificate will do, which on a plain reading includes a student pilot and a recreational pilot.

Then turn to 43.7. Section 43.7(f) is the one that matters: “A person holding at least a private pilot certificate may approve an aircraft for return to service after performing preventive maintenance under the provisions of 43.3(g).” Section 43.7(h) gives the equivalent privilege to sport pilots, again only on light-sport category aircraft.

So a student pilot who owns an aeroplane may lawfully change its tyres. What that student pilot may not do is sign the aircraft back into service afterwards, and without that signature the work is not approved for return to service at all. The practical answer to “can a student pilot perform preventive maintenance?” is therefore yes, and it does them no good on their own: somebody with at least a private certificate, or an A&P, has to make the entry.

Kallio’s point is the second constraint and it is easy to miss while staring at the list. The privilege attaches to the aircraft, not to the type. It covers an aircraft that the pilot owns or operates. The identical aeroplane parked in the next row, belonging to somebody else, is not theirs to work on, and a flying club member whose club rents them an aircraft is on far shakier ground than an owner is. “Operated by” is doing real work in that sentence, and it is worth a conversation with the club before anyone reaches for a screwdriver.

What is actually on the list

Read paragraph (c) end to end and the shape of it becomes obvious. This is a list written for a 1960s light aeroplane, extended piecemeal ever since, and it is dominated by the undercarriage and by fluids.

Landing gear takes the largest share: tyres, elastic shock absorber cords, servicing shock struts with oil or air, cleaning and greasing wheel bearings, and replacing wheels and skis where no weight and balance computation is involved. Fluids and filters take the same number: hydraulic reservoir top-ups, hose connections except hydraulic ones, prefabricated fuel lines, fuel and oil strainers or filter elements, and the fitting of anti-misfuelling devices that reduce the diameter of a tank filler opening.

Then the cabin: upholstery and decorative furnishings, side windows, safety belts, and seats or seat parts, provided no primary structure or operating system is disassembled. The powerplant gets three entries and no more — cowlings that do not require removing the propeller or disconnecting flight controls, spark plugs including setting the gap, and removing, checking and replacing magnetic chip detectors.

And two items on a thirty-one-item list are about hot air balloons: cleaning burner pilot and main nozzles to the manufacturer’s instructions, and interchanging baskets and burners where the type certificate data designates them as interchangeable. Balloons get a mention inside two more items as well. For a list that most people meet in the context of a Cessna, the balloon community is remarkably well represented.

Two entries sit outside that pattern. Item 30 covers inspection and maintenance tasks specifically identified as preventive maintenance in an approved special inspection programme for a primary category aircraft, and it is hedged with conditions: the pilot must hold at least a private certificate, must be the registered owner, and must hold a certificate of competency for that aircraft issued either by the production certificate holder under an approved training programme or by another entity with a course approved by the Administrator. It is the only item on the list that requires the owner to have been trained on the specific type.

Item 31 is the modern one. It permits removing and replacing self-contained, front instrument panel-mounted navigation and communication devices that use tray-mounted connectors, explicitly excluding automatic flight control systems, transponders and microwave frequency DME. The unit has to be designed to be readily and repeatedly removed and replaced, instructions have to be provided, and an operational check has to be carried out before the unit is used.

The thirty-second job, and why it vanished

Item 31 has a missing twin. Until January 2013 the list ran to thirty-two, and the last entry covered updating the navigation database in exactly the sort of panel-mounted box that item 31 lets you pull out of its tray.

It had been there since 1 May 1996, when the FAA first categorised pilot-performed database updates as preventive maintenance. That decision had an awkward side effect. Pilots flying under Parts 121, 129 and 135 are not permitted to perform preventive maintenance at all, so by classifying the task that way the FAA had quietly made it illegal for an airline or charter pilot to swap an SD card — while the pilot of an identical aeroplane with identical avionics, flying under Part 91, could do it every month. The agency spent the next fifteen years receiving petitions for exemption from operators who wanted out of that trap.

By 2011 the technology had moved on far enough that the distinction had stopped meaning anything. Boeing 787s and Airbus A380s were rolling out with Gatelink, updating themselves wirelessly. The FAA’s own summary of the problem is blunt about it.

The fix, published as Amendment 43-45 and effective on 28 January 2013, did two things at once. It deleted the item: in the agency’s own words, “We have removed paragraph (c)(32) of Appendix A to part 43, which pertains to updating navigation databases of certain equipment installed on aircraft operated under non-restricted operating regulations.” And it replaced it with a new paragraph 43.3(k) which opens with a sentence worth memorising: “Updates of databases in installed avionics meeting the conditions of this paragraph are not considered maintenance and may be performed by pilots.”

Not reclassified as easier maintenance. Not maintenance. The conditions are tight — the upload must be initiated from the flight deck, performed without disassembling the avionics unit, and performed without tools or special equipment — and the FAA was careful to say that anything falling outside them stays maintenance: “Performing database updates on avionics systems that require tools or special equipment to accomplish the data transfer continues to be maintenance and requires that approved personnel perform the update.”

So the thirty-second job did not become harder. It escaped the regulation entirely. Which is why the list is thirty-one, and why so much of the internet still says thirty-two.

The ACS Library’s short on PA.I.B.K2, the airman certification standards knowledge element that makes pilot-performed preventive maintenance an examinable subject on the private pilot checkride.

The entry is the job

Doing the work is the easy half. The part owners get wrong is the record, and the record is not optional: under 43.5, no person may approve an aircraft for return to service unless the maintenance record entry required by 43.9 has been made.

Section 43.9(a) sets out exactly four things the entry must contain. A description of the work performed, or a reference to data acceptable to the Administrator. The date the work was completed. The name of the person who did the work, if that is somebody other than the person signing. And the signature, certificate number and kind of certificate held by the person approving the work.

That last clause carries a sting in its tail which is printed in the regulation and routinely ignored: “The signature constitutes the approval for return to service only for the work performed.” Signing a tyre change does not bless anything else about the aeroplane, and it is not a statement that the aircraft is airworthy in the round. It covers the tyre.

The current guidance on all of this is AC 43-9D, Maintenance Records and FAA Form 8130-3 Return to Service, dated 22 September 2025 and editorially updated on 30 April 2026. It replaced AC 43-9C, which had been the reference for four decades and which an industry coalition had told the FAA in 2017 was no longer current.

FreedomFixer works through Part 43 from the mechanic’s side of the fence: who may legally work on an aircraft, and under whose supervision.

The oil change that is not on the list

Here is a small thing that catches people out. Search the thirty-one items for the words “oil change” and you will not find them. The list never uses the phrase.

What it does contain is item 6, lubrication not requiring disassembly other than the removal of non-structural items such as cover plates, cowlings and fairings; and item 23, cleaning or replacing fuel and oil strainers or filter elements. Those two are what the common practice rests on, and they are not the same thing as a blanket permission to drain and refill an engine. Owners who do their own oil are relying on an interpretation of a list that does not name the task, which is a reasonable place to be and a good reason to agree the scope with your mechanic in advance rather than afterwards.

Where the list stops applying at all

One last boundary, and it is the one that catches owners of interesting aeroplanes. Section 43.1(b)(1) says Part 43 does not apply to any aircraft for which the FAA has issued an experimental airworthiness certificate, unless a different kind of airworthiness certificate had previously been issued for that aircraft.

That sweeps in most of the privately owned ex-military jet fleet. An L-39 Albatros on the US register typically flies on an experimental exhibition certificate, and with it the whole architecture described above falls away: there is no Appendix A list, because Appendix A is part of a regulation that does not reach the aircraft. What governs instead are the operating limitations issued with that certificate, which are specific to the airframe and frequently stricter than Part 43 would have been.

So the thirty-one items are a general aviation rule, for aircraft holding standard or most special airworthiness certificates, owned or operated by the pilot doing the work. Inside that boundary the list is generous. Outside it, it does not exist.

It is a short list, written for a simpler fleet, patched eleven times in sixty years and shortened once. It is also the only part of the maintenance regulations where the pilot gets to be the mechanic, and the number is thirty-one.

Sources: 14 CFR 1.1, 43.1, 43.3, 43.5, 43.7, 43.9 and Appendix A to Part 43, as published on eCFR; FAA final rule “Pilot Loading of Aeronautical Database Updates,” Amendment 43-45, Docket FAA-2011-0763, 77 FR 71089, 29 November 2012; FAA Advisory Circular 43-9D, Maintenance Records and FAA Form 8130-3 Return to Service, 22 September 2025, editorially updated 30 April 2026; Eric Kallio, AOPA Pilot Protection Services, 1 August 2022; Aeronautical Repair Station Association, on the 2017 industry rewrite of AC 43-9C.