Is there a Part 108 drone license?
No. Under the FAA's proposed Part 108 rule for beyond visual line of sight (BVLOS) flights, crew members would not need an FAA airman or remote pilot certificate, and the proposal includes no FAA knowledge test. Instead, the operator holds an FAA operating permit or certificate, and it qualifies its own operations supervisors and flight coordinators through training, experience and logged hours. As of October 4, 2026, Part 108 is still a proposal and is not in effect.
People search for a "Part 108 drone license" because Part 107 taught them that drone rules come with a card: pass the knowledge test, get the Remote Pilot Certificate. Part 108 breaks that pattern. The proposal moves the license from the person to the operator.
That has real consequences for hiring, training budgets and how you document your crew. This guide explains what the FAA's proposed Part 108 rule actually requires of people, using only the proposed rule and its preamble published in the Federal Register on August 7, 2025 (90 FR 38212), the FAA's own BVLOS fact sheet, and the current Part 107 rules. Section numbers (§108.x) refer to the proposal and can change in the final rule.
For the full rule, read our FAA Part 108 explainer. For where the rule stands, see the Part 108 NPRM tracker.
Is there a Part 108 drone license?
No personal FAA license exists in the Part 108 proposal. The FAA states it plainly in the preamble: "FAA anticipates that both permitted and certificated operations could be safely conducted without an airman certificate" (90 FR 38252). The FAA's fact sheet says the same about the two named crew roles: "Neither position would require holding an FAA-issued airman or remote pilot certificate."
The proposed regulatory text for Part 108 contains no FAA knowledge test, no FAA practical test and no minimum age for crew. That is a deliberate break from Part 107, which the FAA built around an individual Remote Pilot Certificate with a small UAS rating. Testing moves to the operator instead: each training record must include a certification showing the person completed a test satisfactorily (§108.40(e)(1)(vi)).
The FAA explains why. Most Part 107 flyers are hobbyists and individuals, so a test is how the FAA verifies they know the rules (90 FR 38252). Operators flying under exemptions told the FAA that the Part 107 knowledge test "only covers basic concepts," so they had to train crews on operation-specific knowledge anyway (90 FR 38251). For Part 108, the FAA "anticipates that each company will tailor the training to fit their particular operational profile" (90 FR 38253).
Status check: Part 108 is not in effect. Until a final rule takes effect, BVLOS flights need a Part 107 BVLOS waiver, a Section 44807 exemption, or a Section 927 waiver. Part 107 waiver flights still need a certificated remote pilot in command (§107.12(b)), and exemptions and 927 waivers set their own crew conditions.
What gets licensed instead: the operator
Under Part 108, the FAA would authorize the operator, whether a company or an individual, instead of certificating each crew member. Every operation needs either an operating permit or an operating certificate (§108.100). The permitted operations guide covers the eight permit types and four certificate types in detail.
| Part 107 today | Part 108 as proposed |
|---|---|
| The person holds a Remote Pilot Certificate | The operator holds a permit or certificate |
| FAA knowledge test before certification | No FAA test for crew |
| Remote pilot in command is the final authority (§107.19) | Operations supervisor has final authority (§108.120(d)) |
| Recurrent training every 24 calendar months (§107.65) | Operator-run training, refreshed every 24 calendar months (§108.315(d)) |
| FAA keeps the airman record | Operator keeps qualification records (§108.40(b)) |
The practical result is that "being licensed" under Part 108 means being on the roster of an operator who holds an FAA permit or certificate, with your qualifications on file. The qualification records are the operator's, kept under §108.40, not an FAA record that follows you.
Operations supervisor qualifications
Every operator would need one or more operations supervisors (§108.305(a)). Recreational permits are the only exception (§108.475(f)).
How they qualify. An operations supervisor must be "qualified through training, experience, or expertise" (§108.305(a)). There is no FAA test and no FAA-approved course requirement. The preamble gives drone experience in the military and an academic background as examples of expertise (90 FR 38253).
What they must know. The supervisor must be knowledgeable of the company's policies and procedures. To the extent of their responsibilities, they must also have a full understanding of aviation safety standards and safe operating practices, practices for keeping facilities and operating areas secure, and the regulatory requirements of Part 108 (§108.305(c)).
What they are responsible for. The supervisor has final authority for the safe operation (§108.120(d)). The FAA's fact sheet adds that the role includes "ensuring all personnel are properly trained and knowledgeable." The operator must tell the FAA within 10 days whenever the person in the role changes (§108.305(b)).
The proposal requires personnel records showing each person's "qualifications in sufficient detail to determine their ability" to take part in operations (§108.40(b)(2)). Whether the basis is training, years of BVLOS waiver operations, or military experience, write down how you decided this person qualifies.
Flight coordinator qualifications
A flight coordinator monitors an aircraft in flight and can send commands or start emergency actions (§108.5). The aircraft flies itself; the design rules require automated flight controls "without manual flight control being necessary or available" (§108.810(a)). The coordinator must take appropriate action to keep the aircraft from posing an undue hazard to people, aircraft or property (§108.310(d)), which is where the proposal's right-of-way and electronic conspicuity rules come in.
When you need one. You must designate a flight coordinator before each flight when the manufacturer's operating instructions require one (§108.310(a)). Anyone who directs an aircraft in flight must be qualified and authorized by the operator as a flight coordinator, except a trainee gaining supervised experience (§108.310(b)).
Initial experience. At least 5 hours of operating experience in the specific make and model to be flown, gained under the direct supervision of a fully qualified flight coordinator, an operations supervisor, or another person the operator designates (§108.310(e)).
Currency. At least 5 hours as a flight coordinator in that make and model within the preceding 12 calendar months (§108.310(f)). If currency lapses, the operator must requalify the person (§108.310(g)). Recreational permits are the exception: they skip these experience rules (§108.475(f)(2)) and the duty and rest limits (§108.475(f)(6)).
Multiple aircraft. The default is one aircraft per flight coordinator. A higher ratio needs a method acceptable to the FAA and cannot exceed the ratio in the manufacturer's instructions (§108.210).
Those hours are tracked per make and model, so a coordinator current on one aircraft is not automatically current on another. Tracking flight hours by pilot and aircraft lets you show currency on demand, and automated flight logs make the numbers trustworthy.
Training every crew member needs
Training replaces the license. The operator must ensure all operations personnel have completed the required training and have the knowledge and skills for their duties (§108.315(a)).
General training. All operations personnel need training relevant to their areas of responsibility, drawn from 19 subject areas as applicable to their role (§108.315(b)). These include regulations, airspace and flight restrictions, aviation weather, crew resource management, communication procedures, strategic deconfliction and conformance monitoring, drugs and alcohol, aeronautical decision-making, night operations, transfer of control, multi-aircraft operations, command and control links, contingency management, and population density.
Make-and-model training. Personnel also need training on the specific aircraft, including maintenance and inspection, preflight procedures, navigation systems, detect and avoid procedures, lost link procedures, and operating multiple aircraft (§108.315(c)).
Refresh cycle. The training must have been completed within the previous 24 calendar months for a person to serve (§108.315(d)).
Certificate holders. Operators with a Part 108 certificate need a formal training program acceptable to the FAA (§108.540). It must include initial and recurrent training, and the operator must designate a person who certifies each crew member's proficiency, with that certification kept in the person's record. Training can be delivered by contracted personnel or services (§108.540(c)).
Operation-specific training. Package delivery operators would also need hazardous materials recognition training for people who handle cargo (§108.440(b)), and agricultural operators need a training program covering chemical handling and safety (§108.445(i)).
Existing UAS pilot training programs can supply much of this content, but the operator remains responsible for mapping it to the §108.315 subject list.
Medical, alcohol, duty and security rules
Part 108 adds person-level rules that look more like crewed aviation than Part 107.
| Rule | Requirement | Section |
|---|---|---|
| Medical condition | No one may serve if they or the operator know of a physical or mental condition that would interfere with safe operation | §108.320 |
| Alcohol | No duty within 8 hours of drinking, or at an alcohol concentration of 0.04 or more | §108.325 |
| Duty limits | Maximum 14-hour duty day and 50-hour duty week | §108.330(a) |
| Rest | At least 10 hours of continuous rest within the 24 hours before duty, and one full day off per week | §108.330(b)-(c) |
| Security | TSA security threat assessment for covered persons before they perform those duties | §108.335 |
| Multiple roles | No one may perform several roles at once if it could affect safety | §108.300(b) |
There is no FAA medical certificate. The medical rule uses a "knows or has reason to know" standard, similar in spirit to Part 107's §107.17.
The TSA security threat assessment applies to covered persons, which include operations supervisors, flight coordinators, and staff with unescorted access to the aircraft or its cargo, or access to its controls or flight path. The NPRM describes it as a check of criminal history, immigration, and intelligence-related databases and watchlists (90 FR 38262). It is not a license, and there is no Part 108 threat assessment requirement until a final rule takes effect. A person who already holds an STA or security clearance TSA deems comparable would not need a new one (§108.335(a)).
Do you still need a Part 107 certificate?
For Part 108 operations, no. The proposal does not require a Remote Pilot Certificate for any Part 108 role. Our Part 108 vs Part 107 comparison covers the two frameworks side by side.
For everything else, yes. A Remote Pilot Certificate remains required for commercial flights within visual line of sight under Part 107, which Part 108 would not replace (§108.1(b)(1)). It is also what you need today for any BVLOS flight under a Part 107 waiver, since Part 108 is not yet in effect. Our FAA drone license guide and license cost breakdown cover how to get one.
Once you have one, our Part 107 renewal guide covers keeping it current.
An operator could run both: Part 107 remote pilots for visual line of sight jobs, and a Part 108 permit or certificate for BVLOS work. A crew member can hold a Remote Pilot Certificate and also serve as a Part 108 flight coordinator.
Part 108 certification, tests and courses: what they mean
Searches for "Part 108 certification," "Part 108 test" and "Part 108 training" point at three different things. Only one of them is an FAA credential.
Part 108 certification. The only FAA certificate in the proposal is the operator's operating certificate under Subpart E. The FAA issues it to an operator after evaluating its application, which includes its training program, safety management system, and risk assessments (§§108.505, 108.515). Individual crew members get a training or proficiency certification from their operator, not from the FAA (§§108.40(e), 108.540(d)).
Part 108 test. There is no FAA test for Part 108 crew in the proposal. Each operator's training records must include a certification showing the person completed a test satisfactorily (§108.40(e)(1)(vi)), so expect a test at the end of your employer's training. Certificate applicants also run validation tests to show the FAA their operation works as described (§108.545).
Part 108 training. Training is required, but it is delivered by or on behalf of the operator against the §108.315 subject list, not by the FAA. Any course or certificate sold as a "Part 108 license" is a private credential, not an FAA certificate. It may help an operator document a person's training or expertise, but the FAA would not issue it, and the rule is not final.
How to prepare your crew now
The personnel side of Part 108 takes the longest to build, though these requirements could still change: the FAA asked, for example, whether the 5-hour experience requirement is enough (90 FR 38254). You can start today without betting on the final rule.
- Name your operations supervisor candidates and write down how each one qualifies: training, experience, or expertise.
- Log flight hours by make and model for anyone who would serve as a flight coordinator. The proposed bar is 5 supervised hours to qualify and 5 hours in the past 12 calendar months to stay current.
- Map your current training against the 19 general subjects in §108.315(b) and list the gaps.
- Set a 24-month refresh calendar for each person, the same cycle Part 107 already uses.
- Track duty and rest for everyone who would serve, since the limits apply to all operations personnel outside recreational permits (§108.330). Certificate holders must also keep shift and rest records for 3 months (§108.40(b)(5), (f)(2)).
- List your covered persons for future TSA security threat assessments.
- Keep Part 107 certificates current for all visual line of sight work and for BVLOS waiver flights until Part 108 takes effect.
A system that tracks pilot certifications and currency turns this list into a report you can hand an inspector. The Part 108 requirements checklist covers the rest of the operator obligations.
Frequently asked questions
Do I need a license to fly under Part 108?
No personal FAA license is required in the proposal. The operator needs an FAA operating permit or certificate, and crew must meet the operator's qualification and training requirements (§§108.305 to 108.315). Part 108 is not yet in effect, so today BVLOS needs a Part 107 waiver flown by a certificated remote pilot, a Section 44807 exemption, or a Section 927 waiver.
Is there a Part 108 test?
Not from the FAA. The proposed Part 108 rule includes no FAA knowledge test or practical test for crew. Your operator's training would end in a test, recorded in your training file (§108.40(e)(1)(vi)). Flight coordinators also need 5 hours of supervised experience on the make and model, and training in the applicable general subjects refreshed every 24 calendar months.
Can I get Part 108 certified as an individual?
Not as a crew member. Permits and certificates go to the operator, which can be a company or an individual, and there is no personal crew credential (§§108.400, 108.515). An individual qualifies as an operations supervisor or flight coordinator with a specific operator. If you run a one-person business, you would apply as the operator, but your first 5 hours on a make and model must be under another qualified person's direct supervision (§108.310(e)), and §108.300(b) limits combining roles.
Will my Part 107 certificate count toward Part 108?
The proposal does not give Part 107 certificates any formal credit. Your Part 107 knowledge and flight experience can still support an operator's decision that you are qualified through training, experience or expertise, but hours count toward the 5-hour flight coordinator experience only if flown under the direct supervision §108.310(e) requires. Solo Part 107 hours would not meet that.
Ready to keep your crew qualified for Part 108?
Under Part 108, the license is your records: who is qualified, on which aircraft, with how many recent hours, and when their training expires. DroneBundle tracks pilot certifications, flight hours by aircraft, and training dates across your team, so currency gaps surface before a flight rather than during an inspection.
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Sources and references
Official documents this guide is based on:
