Part 108 Requirements: Timeline and Compliance Checklist

What are Part 108 Requirements?

Part 108 requirements are the personnel, aircraft, operational, security and record-keeping rules the FAA has proposed for beyond visual line of sight (BVLOS) drone operations. They include a designated operations supervisor and qualified flight coordinators, airworthiness acceptance for aircraft, a safety management system for certificated operators, and TSA security threat assessments for covered personnel. As of October 7, 2026, these are proposed requirements. No final rule has been published.

The FAA published its proposed Part 108 rule on August 7, 2025 (90 FR 38212). It drew approximately 3,100 public comments, and the draft final rule has been under White House review since July 10, 2026.

This guide breaks down every Part 108 requirement category using the proposed rule text, cites the section (§108.x) for each one, and ends with a compliance checklist you can start on now. Section numbers refer to the proposal and can change in the final rule.

Part 108 implementation timeline

The regulatory timeline decides when any of this becomes enforceable. The Part 108 vs Part 107 transition depends entirely on when a final rule publishes and what effective date it sets.

Executive Order 14307 told the FAA to publish a final rule within 240 days "as appropriate," which was February 1, 2026. The FAA's agenda lists January 16, 2026 as the Section 930 deadline, although the statute itself counts 16 months from the proposal's publication, which would be December 7, 2026. The executive order date and the agenda date have both passed. The Office of Information and Regulatory Affairs (OIRA) received the final rule on July 10, 2026, and its public list of rules under review still showed it as "Pending Review" on October 7, 2026.

No official source gives an implementation period. The NPRM says certain operations now flown under waivers or exemptions, "such as agricultural, package delivery, aerial surveying, photography, and flight testing," would transition "when their exemptions expire, and a reasonable transition can occur" (90 FR 38225). Operations that would not fit Part 108 could continue under their existing approvals.

Until a final rule takes effect, civil BVLOS flights need a Part 107 waiver, a Section 44807 exemption, or a Section 927 waiver.

Our Part 108 NPRM tracker follows each step.

Two-tier authorization system

Every Part 108 operation would need either an operating permit or an operating certificate (§108.100). The pathway determines fleet size, aircraft weight, where you can fly, and how much the FAA oversees you. Our Part 108 permitted operations guide compares the two in depth.

Operating permits

Permits cover lower-risk operations. The proposal lists eight permit types (§108.400(a)):

Sources: §§108.440 to 108.475. Training and demonstration fleets can exceed these numbers with FAA authorization. Only qualified aircraft manufacturers and accredited educational institutions can hold a flight test permit (§108.470(b)).

A permit lasts 24 months (§108.410(a)), and you can apply for the next one up to 120 days before the current one expires (§108.410(c)). Each permit covers one operation type, and you cannot hold two permits of the same type to double a fleet cap (§108.400(e)). Inspection work for utilities and energy operators falls under the aerial surveying permit.

Operating certificates

Certificates cover larger operations. There are four types: package delivery, agriculture, aerial surveying and civic interest (§108.500(a)). One certificate can cover several types (§108.515(d)).

Certificated operations:

• Have no fleet size cap
• Are required to fly over Category 4 or 5 areas (§108.185(d)(4)), unless the FAA authorizes otherwise or a civic interest flight goes over them to the extent necessary to safeguard lives under imminent threat (§§108.185(a), 108.455(f))
• Still have limits by type: package delivery up to 110 lbs (§108.565(c)), agriculture up to Category 3 unless the FAA authorizes otherwise (§108.575(c)), and surveying or civic interest flights over 110 lbs up to Category 4 unless the FAA authorizes otherwise (§§108.580(b), 108.585(c)), with civic interest flights allowed further to the extent necessary to safeguard lives under imminent threat (§108.585(d))
• Need a safety management system (§108.560)
• Need an accepted training program (§108.540), validation tests (§108.545), and communication and ground risk assessments (§108.550)
• Need FAA authorization to resume any operation type not flown in the preceding 12 calendar months (§108.530)
• Must file service difficulty reports with the manufacturer within 7 days (§108.45(d), (h))

Maintenance rules and record-keeping apply to permit holders as well, so they do not separate the two tiers. Construction and infrastructure operations that need dense urban sites would need a certificate.

Personnel requirements

Part 108 would shift responsibility from individual pilots to the operator. Neither required role needs an FAA airman or remote pilot certificate, a clear break from Part 107 certification. The FAA's BVLOS fact sheet states this directly.

Our Part 108 drone license guide covers the crew rules in depth.

Operations supervisor (§108.305)

The operations supervisor is responsible for the overall safety of the operation and has final authority over it (§108.120(d)). The FAA's fact sheet adds that this includes "ensuring all personnel are properly trained and knowledgeable."

Qualification (one of three):

• Training
• Experience
• Other expertise, such as military drone experience or an academic background (90 FR 38253)

There is no requirement for an FAA-approved course, but the supervisor must still complete the §108.315 training that applies to the role (90 FR 38253).

Key obligations:

• Overall safety of the operation and final authority for it
• Making sure personnel are properly trained and knowledgeable
• Compliance with the permit or certificate limits

The operator, not the supervisor, must notify the FAA within 10 days when the person in the role changes (§108.305(b)).

Recreational permits do not need an operations supervisor (§108.475(f)). Tracking qualifications and flight hours gives you the documentation an inspector would ask for.

Flight coordinator (§108.310)

A flight coordinator monitors the flight and can send commands or start emergency actions (§108.5). The aircraft flies itself; the proposal requires automated flight controls "without manual flight control being necessary or available" (§108.810(a)). The FAA chose "flight coordinator" over "pilot" to show the role "would not share the exact same roles" (90 FR 38254).

You must designate a flight coordinator before each flight when the manufacturer's operating instructions require one (§108.310(a)). Anyone directing an aircraft in flight must be a qualified flight coordinator, except a trainee gaining supervised experience (§108.310(b)).

Experience requirements:

• At least 5 hours of operating experience in the specific make and model (§108.310(e))
• Gained under the direct supervision of a qualified flight coordinator, an operations supervisor, or another person the operator designates

Currency requirements:

• 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 skip both the experience and currency rules (§108.475(f)(2)).

Training: Operations personnel need general training in whichever of the 19 listed subject areas apply to their duties, from airspace and weather to multi-aircraft operations (§108.315(b)), plus make-and-model training. Training must have been completed within the previous 24 calendar months (§108.315(d)). Structured training programs make that refresh cycle easy to document.

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). Certificate holders also need a validation test for it (§108.545).

Duty, rest and alcohol limits

• Maximum 14-hour duty day and 50-hour duty week (§108.330(a))
• At least 10 hours of continuous rest within the 24 hours before duty (§108.330(b))
• At least one full day off each week you are scheduled (§108.330(c))
• Recreational permits are exempt from the duty and rest rules (§108.475(f)(6))
• No duty within 8 hours of drinking alcohol, while under the influence of alcohol, while using a drug that affects faculties in a way contrary to safety, or at an alcohol concentration of 0.04 or more, measured in grams per deciliter of blood or per 210 liters of breath (§108.325(a))

Aircraft requirements

Part 108 aircraft would need FAA airworthiness acceptance, except under a flight test permit (§108.105(b)), and must meet the design requirements in Subpart H.

Weight categories

The proposal uses three weight limits "depending on the type of operation" (90 FR 38270). The terms "small," "medium" and "large" are not FAA categories.

Unless the FAA authorizes otherwise, every aircraft is also limited to a 25-foot span and 87 knots ground speed (§108.805). The FAA bases the 1,320-pound maximum on the BVLOS Aviation Rulemaking Committee's recommendations and JARUS kinetic-energy limits (90 FR 38270).

Airworthiness acceptance

Part 108 replaces traditional airworthiness certificates with airworthiness acceptance (90 FR 38232). The steps run in this order: standards bodies submit consensus standards to the FAA for acceptance as a means of compliance (§108.705). The manufacturer then submits a declaration of compliance, and FAA acceptance of that declaration is the airworthiness acceptance (§108.715).

Manufacturer requirements:

• A quality assurance system (§108.730)
• A continued operational safety program, including safety bulletins and notice of safety issues to the FAA and owners (§108.740)
• Inspection and testing of each aircraft produced (§108.735)
• FAA access for inspections and audits (§108.745)
• Design to an FAA-accepted means of compliance (§108.710); the proposal names no specific standards body

Only aircraft made in the U.S. or in a country with a qualifying bilateral agreement are eligible (§108.700(b)(1)). Outside flight test permits, operators must use aircraft with airworthiness acceptance, and equipment management should track that status per aircraft once acceptances exist.

Mandatory equipment

All Part 108 aircraft require:

• Anti-collision lighting. Visible at least 3 statute miles at night and used on all flights, unless the flight coordinator dims or turns it off for safety (§§108.110, 108.830)
• Standard Remote ID. Built into the aircraft, plus a beyond visual line of sight status, a no-flight-coordinator status where that applies, and the takeoff location (§108.200(a)(3)). See our Remote ID guide
• Flight data recorder. Captures data from power-up to shutdown in a format the FAA and NTSB can read (§108.900)
• Lost-link behavior. A safe preset action when the control link is lost (§108.815(b))

Aircraft with a span of 96 inches or more need position lights unless their operating instructions prohibit night flight (§108.835). Unless the FAA authorizes otherwise, ADS-B Out and transponders must not transmit during Part 108 operations (§108.160).

Detect and avoid systems

Detect and avoid requirements depend on where you fly:

• All Part 108 aircraft must be able to yield to aircraft departing from or arriving at an airport or heliport, and to aircraft broadcasting ADS-B Out or qualifying electronic conspicuity, except in shielded areas (§108.195(a); design requirement §108.825)
• Category 5 areas (within 0.5 statute mile of a cell of 2,500 people or more, using LandScan USA data): must also detect and avoid aircraft not broadcasting their location (§108.185(d)(5)(ii))
• Class B and C airspace: the same requirement for non-broadcasting aircraft (§108.180(b))
• Category 3 and above: strategic deconfliction required (§108.185(d)(3))

The proposal does not mandate a sensor type. Radar, cameras and ADS-B In appear in the preamble only as examples of systems operators have used (90 FR 38246). The FAA reopened comment on these right-of-way and electronic conspicuity provisions in January 2026 after substantial public comment.

Documentation and SMS requirements

Some documentation applies to every operator. The safety management system applies only to certificate holders.

Operations manual requirements

Every operator except recreational permit holders must keep a company operations manual (§108.135; §108.475(f)). Its required contents (§108.135(g)) include:

• Personnel roles and the number of each required
• Preflight procedures
• Weight and balance
• Accident notification
• Records and reports
• Maintenance procedures and access
• Emergency procedures
• Recovery of aircraft that fail to return
• Loading procedures and hazardous materials recognition

Safety Management System (SMS)

Certificated operators must keep a safety management system that meets 14 CFR Part 5 (§108.560(a)). Part 5 has four components:

1. Safety Policy

• Safety objectives and the commitment to meet them
• A safety reporting policy and an emergency response plan
• Signed by the accountable executive (14 CFR 5.21(b))

2. Safety Risk Management

• Hazard identification
• Risk analysis and assessment
• Risk controls for identified hazards

3. Safety Assurance

• Monitoring and measuring safety performance
• Investigating incidents and hazards
• Continuous improvement

4. Safety Promotion

• Safety training
• Safety communication across the organization

Organizations where one person performs all operational functions are exempt from some Part 5 provisions (§108.560(b)). Compliance records that tie hazards, incidents and fixes together give the SMS real evidence to sit on.

Recordkeeping requirements

Section 108.40 sets what to keep and for how long:

Package delivery records also include pickup and delivery points. Agricultural records include each customer, date, and material dispensed. Automated flight logging covers most of the flight record list.

Reporting requirements

Reports under §108.45 have their own deadlines: aggregate flight data at least monthly, interruption summaries by the 10th of the following month, security-related occurrences within 96 hours, emergency deviations within 10 days, event reports (damage over $500 to any property other than the drone itself, or a system malfunction or failure that leads into an unauthorized area) within 10 days (§108.45(g)), and the aircraft registration list at least every 12 months.

Operational area requirements

Before conducting Part 108 operations, operators would need FAA approval for each operating area (§108.165).

Area approval elements

According to the proposal and the FAA's fact sheet, an operating area request includes:

• Geographic boundaries of the operating area
• Approximate number of daily operations
• Takeoff, landing, and loading locations
• Communications coverage for the area
• Lost-link procedures

Operations must launch from pre-designated, access-controlled locations (§108.150(a)), and flight planning records should match the approved area.

Population density categories

Part 108 defines five population density categories using LandScan USA data as of August 1 each year, with day or night data as appropriate. Requirements follow the highest category an operation flies over, and each category excludes areas that qualify for a higher one (§108.185(c)):

Agriculture, training and flight test permits stay in Category 1 unless the FAA authorizes otherwise (§§108.445(e), 108.460(d), 108.470(c)). The one built-in exception: civic interest flights may go over any population density to the extent necessary to safeguard lives under imminent threat (§108.455(f)).

Controlled airspace operations

Flights are allowed in Class B, C and D airspace and the Class E surface area at an airport, at or below 400 feet, using an approved method of strategic deconfliction and conformance monitoring (§108.180(a)). A separate FAA authorization is needed only in airspace the FAA designates for it (§108.180(c)-(d)). The proposal does not tie Part 108 to LAANC.

Automated Data Service Providers (ADSPs)

ADSPs come from a new Part 146 in the same proposal. They would provide strategic deconfliction and conformance monitoring (§108.190(e)). They do not have to be outside companies: the FAA's fact sheet says "a BVLOS operator could be its own data service provider or contract with another company." The FAA would certify and oversee them.

Security requirements

TSA requirements apply to covered persons, not every employee.

Security threat assessments

Under §108.335, covered persons include operations supervisors, flight coordinators, and staff with unescorted access to the aircraft or its cargo, or access to its controls or flight path. They must complete a TSA security threat assessment before performing those duties. The assessment can include:

• Watchlist verification
• Immigration status check
• Fingerprint-based criminal history records check

A security threat assessment is not a security clearance. There is no Part 108 threat assessment requirement until a final rule takes effect, and the NPRM says applicants would likely visit a TSA enrollment center (90 FR 38262).

Facility and cyber security

• Physical security policies to prevent unauthorized access to operating facilities (§108.150(c))
• Cybersecurity policies for permit and certificate holders, except recreational permits (§§108.435, 108.535, 108.475(f)(5))
• All flights monitored and controlled from a location inside the United States (§108.150(b))
• Package delivery operators need a TSA limited security program (§§108.440(i), 108.565(f))

Part 108 requirements checklist

You can prepare now, even before a final rule publishes. Some steps, such as FAA applications and TSA assessments, cannot start until the final rule takes effect and the processes open.

Now

• Designate a prospective operations supervisor and document how they qualify
• Identify flight coordinator candidates and start logging hours by make and model
• Inventory your fleet and ask each manufacturer about plans for a declaration of compliance
• Map your usual operating areas to the five population density categories
• Match each operation to a Part 108 operation type and check its limits
• Review your drone operations software against the §108.40 record list

After the final rule publishes

• Compare the final text with this checklist, especially right-of-way and detect and avoid
• Note the effective date and any compliance dates
• Finish the company operations manual against the final §108.135 list
• Build training programs covering the final subject list
• Start the SMS if you plan to seek a certificate
• Complete TSA security threat assessments for covered persons before you apply, since the application must declare them (§108.335(c))
• Choose a data service provider, or plan to become one

Before your first Part 108 flight

• Confirm each operations supervisor and flight coordinator is qualified and current
• Confirm each aircraft has airworthiness acceptance (not required under a flight test permit)
• Get FAA approval for each operating area
• Receive your operating permit or certificate
• Set up reporting workflows for the §108.45 deadlines

Drone fleet management platforms that track personnel qualifications, aircraft status, and documentation keep these items in one place.

Frequently Asked Questions

Do Part 108 personnel need FAA pilot certificates?

No. Neither operations supervisors nor flight coordinators would need FAA-issued airman or remote pilot certificates. The operations supervisor qualifies through training, experience, or expertise (§108.305). Outside recreational permits, a flight coordinator needs 5 hours of supervised experience on the make and model, and all operations personnel need training (§§108.310, 108.315, 108.475(f)(2)). Part 107 certification remains useful but is not required.

What happens to existing Part 107 BVLOS waivers?

The NPRM would amend §107.1 so Part 107 no longer covers BVLOS, and says "it no longer makes sense to provide waivers to the part 107 rules for this type of activity" (90 FR 38319). For current holders, it expects certain operations, such as agricultural, package delivery, aerial surveying, photography and flight testing, to "transition to the operations under part 108 when their exemptions expire, and a reasonable transition can occur" (90 FR 38225). The NPRM sets no specific date. Keep your waiver current until the final rule says otherwise.

Can Flight Coordinators supervise multiple drones simultaneously?

Yes, with limits. The default is one aircraft per flight coordinator. A higher ratio needs a method the FAA accepts and cannot exceed the ratio in the manufacturer's instructions (§108.210). Certificate holders must also run a validation test for multi-aircraft operations (§108.545).

When will Part 108 take effect?

There is no official date. Executive Order 14307's 240-day target passed on February 1, 2026, and the final rule has been under OIRA review since July 10, 2026. The final rule will set the effective date and any compliance dates. Until then, BVLOS flights need a Part 107 waiver, a Section 44807 exemption, or a Section 927 waiver.

Implementation considerations

Start by matching each operation to its Part 108 type. Permits are simpler but come with fleet, weight and population caps. Certificates remove the fleet cap but add an SMS, a training program, validation tests and risk assessments.

Current BVLOS waiver holders should keep their waivers current. Waiver history and flight records are the evidence every authorization path asks for, whether a waiver, a Section 927 request, or a future Part 108 application.

No aircraft can hold Part 108 airworthiness acceptance until a final rule takes effect and the FAA accepts a means of compliance. Ask your manufacturer about its plans, and check the made-in eligibility rule against your current fleet. Operations platforms with a full feature set for personnel, aircraft and records reduce the paperwork either way.

In summary

Part 108 would replace BVLOS waivers with operating permits and certificates. Permits cover eight operation types with set limits on weight and population density, plus fleet caps for six of them. Certificates cover four types without a fleet cap, with more obligations.

The required roles are an operations supervisor, except under a recreational permit, and a flight coordinator wherever the manufacturer requires one. Neither needs an FAA certificate, but both need documented qualifications, and outside recreational permits, coordinators need make-and-model hours and currency.

Aircraft would rely on manufacturer declarations against FAA-accepted standards. Every aircraft needs anti-collision lighting, standard Remote ID, a flight data recorder and defined lost-link behavior.

Until the final rule is published, everything here is a proposal. The organizational pieces, such as people, records and procedures, are the safest place to start.

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