Part 135 operators using iPads or other Electronic Flight Bags often assume that OpSpec A061 gives them authority to carry everything digitally, including company manuals. That assumption creates a common compliance gap.
A061 authorizes the EFB program. It does not, by itself, authorize electronic manuals, electronic recordkeeping, or electronic signatures.
FAA AC 120-78B separates those functions clearly. The AC identifies OpSpec A025 as the authorization used for electronic signatures, electronic recordkeeping systems, and electronic manual systems. It also states that electronic manual functions may be displayed on an EFB only when the certificate holder has authority to use those items under A025.
OpSpec A061 addresses the operator’s Electronic Flight Bag program. This includes the EFB hardware, software applications, backup procedures, data currency controls, battery management, and related EFB operating procedures authorized under the operator’s EFB program.
OpSpec A025 addresses a different authority. It is used when the certificate holder wants to maintain, access, distribute, sign, or store required manuals, records, or signatures electronically.
That distinction matters because the same iPad may be used for both functions, but the FAA authority is not the same.
An operator may have an approved EFB program under A061 and still lack authority to use that device as the approved source for electronic manuals unless A025 has also been issued.
AC 120-78B recognizes that electronic manual functions may co-reside on, or be displayed through, an EFB, provided the certificate holder also has A025 authority.
In practical terms, a Part 135 operator cannot assume that manuals are authorized for iPad carriage just because the device is approved under the EFB program. The operator needs to confirm that its OpSpecs authorize both sides of the operation:
This distinction is especially important when the iPad is used to access required manuals or MEL information, because those functions must be supported by the correct OpSpec authority and manual procedures.
If the operator uses iPads for charts, performance tools, or other EFB functions, A061 may be the correct authority. If the operator also uses the iPad to carry or access required company manuals, A025 must be addressed separately.
Because A061 and A025 cover different authorities, they should not be collapsed into one generic iPad procedure.
Part 135 operators should address these functions in separate manual sections or separate GOM chapters. The A061 section should describe the EFB program and how the device is used operationally. The A025 section should describe the electronic manual system, including access, currency control, revision tracking, user responsibilities, and any applicable electronic signature or recordkeeping procedures.
This separation helps prevent a common inspection issue: the operator has an EFB program, but the manual system does not clearly show authority for required manuals to be maintained or accessed electronically.
The compliance question is not whether the manual can physically be opened on the iPad. The question is whether the certificate holder has the correct OpSpec authority and manual procedures to support that use.
Part 135 operators using iPads for both EFB functions and manual access should confirm that their OpSpecs, GOM chapters, and electronic manual procedures clearly separate A061 authority from A025 authority. Sky Safety Solutions can review those sections before FAA inspection or manual revision to ensure the authorization structure is properly reflected.