Ron Levy said:
The FAA is not limited in requiring you to prove that the airplane was legally airworthy for just the most recent flight. They could require you to prove that the database was current for an IFR flight made two months ago or even two years ago, and without your log of database updates, you couldn't prove that.
The FAA via the FARs requires:
§ 91.417 Maintenance records.
(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
(1)
Records of the maintenance,
preventive maintenance , and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include -
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completion of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for return to service.
...
(b) The owner or operator shall retain the following records for the periods prescribed:
(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.
(emphasis added)
The FAA cannot demand that an owner/operator produce a record that the owner operator is not required to have kept. Your "please prove it was an IFR legal aircraft two years ago" example will not happen without some solid records falling into the FAA's hands.
As to your irrelevant stale complaint tangent, since you opened that can of worms, the task of proving non-compliance falls upon the FAA. The FAA must prove that the pilot did indeed violate the regulations via records the FAA can locate. The FAA is not allowed to convict based on records the FAA does not have. The stale complaint issue only relates to when the clock starts, not whether or not the FAA can demand records the FARs don't require the pilot to keep. If the FAA starts the clock, you can be darn certain some piece of evidence set it ticking.
As Tom Downey is fond of saying, "A mechanic's best legal defense is bad handwriting."
Within that context an owner/operator's best legal defense is a sharp shredder.
Enough said.