What are Part 108 Requirements?
Part 108 requirements encompass the personnel qualifications, aircraft standards, operational procedures, and documentation needed to conduct beyond visual line of sight (BVLOS) drone operations under the FAA's proposed regulatory framework. These requirements include designated Operations Supervisors and Flight Coordinators, airworthiness acceptance for aircraft, Safety Management Systems for certificated operations, and TSA security assessments for covered personnel.
The FAA released its Notice of Proposed Rulemaking (NPRM) for Part 108 on August 7, 2025, establishing the most comprehensive framework for commercial BVLOS operations since Part 107 launched in 2016. With over 3,000 public comments received and a final rule expected by early 2026, operators need to understand the specific requirements and begin preparation now.
This guide breaks down every Part 108 requirement category, provides the current implementation timeline, and delivers a practical compliance checklist for organizations planning BVLOS operations.
Table of contents
- Part 108 implementation timeline
- Two-tier authorization system
- Personnel requirements
- Aircraft requirements
- Documentation and SMS requirements
- Operational area requirements
- Security requirements
- Compliance preparation checklist
- Frequently Asked Questions
- Implementation considerations
- In summary
Part 108 implementation timeline
Understanding the regulatory timeline helps organizations plan their compliance preparation effectively. The Part 108 vs Part 107 transition represents a fundamental shift in how BVLOS operations will be authorized.
| Milestone | Date | Status |
|---|---|---|
| Executive Order 14307 | June 6, 2025 | Complete |
| NPRM Published | August 7, 2025 | Complete |
| Comment Period Closed | October 6, 2025 | Complete |
| Comments Received | 3,000+ | Under Review |
| Expected Final Rule | February-April 2026 | Pending |
| Implementation Period | Late 2026-Early 2027 | Projected |
Executive Order 14307, signed June 6, 2025, mandates publication of a final rule within 240 days. This aggressive timeline suggests the FAA will finalize Part 108 by early February 2026, though industry observers anticipate potential delays pushing finalization to March or April 2026.
Following final rule publication, operators should expect a 6-12 month implementation period before requirements become enforceable. Organizations beginning preparation now will be positioned to operate immediately when the rule takes effect.
Two-tier authorization system
Part 108 establishes two distinct pathways for BVLOS authorization: Operating Permits and Operating Certificates. The pathway determines fleet limits, operational areas, and oversight requirements.
Operating permits
Permits cover lower-risk operations with streamlined approval processes. Eight permit categories address specific use cases:
| Category | Fleet Limit | Max Weight | Population Density |
|---|---|---|---|
| Package Delivery | 100 aircraft | 55 lbs | Category 3 or less |
| Agriculture | 10 aircraft | 1,320 lbs | Category 1 only |
| Aerial Surveying | 25 aircraft | 110 lbs | Category 3 or less |
| Civic Interest | 25 aircraft | 110 lbs | Category 3 or less |
| Training | 10 aircraft | 1,320 lbs | Category 1 only |
| Demonstrations | 50 aircraft | 110 lbs | Category 2 or less |
| Flight Testing | Unlimited | Varies | Very sparse areas |
| Recreation | 1 aircraft | 55 lbs | Category 3 or less |
Permits remain valid for 24 months and require less intensive FAA oversight. Utilities and energy sector operations conducting routine inspections may find permits sufficient for many applications.
Operating certificates
Certificates enable larger-scale operations in more complex environments. Four certificate categories mirror the commercial permit categories: package delivery, agriculture, aerial surveying, and civic interest.
Certificated operations require:
- No fleet size limits
- Operations in populated areas (Category 4-5)
- Safety Management System implementation
- Enhanced FAA oversight and reporting
- Formal maintenance and records programs
Construction and infrastructure operations requiring flexibility across diverse project sites may need certificates to operate without permit restrictions.
Personnel requirements
Part 108 introduces two new roles that shift responsibility from individual pilots to organizational accountability. Neither role requires an FAA-issued airman certificate, representing a significant departure from Part 107 certification requirements.
Operations supervisor (SS108.35)
The Operations Supervisor holds final authority for safe and secure operations across all Part 108 activities. This role serves as the organization's primary FAA contact and maintains authority over training and credentialing.
Qualification pathways (one required):
- Completion of FAA-approved training program
- Demonstrated operational experience
- Recognized subject matter expertise
Key responsibilities:
- Ensuring operations meet all regulatory requirements
- Verifying personnel training and qualifications
- Maintaining operational limitations compliance
- Serving as FAA point of contact
- Final authority on safety decisions
Tracking pilot qualifications and training becomes essential as organizations designate Operations Supervisors and document their qualification pathway.
Flight coordinator (SS108.310)
Flight Coordinators provide tactical oversight during operations, functioning similarly to traditional pilot-in-command roles but with focus on automated systems supervision rather than direct flight control.
Experience requirements:
- Minimum 5 hours operating experience on specific make and model
- Experience obtained under qualified coordinator or Operations Supervisor supervision
- Professional training programs can accelerate qualification
Currency requirements:
- 5 hours flight time on specific aircraft within preceding 12 calendar months
- Currency maintained through operational experience or supervised training
Flight Coordinators may supervise multiple aircraft simultaneously when manufacturer specifications permit. This enables scalable operations where a single coordinator monitors fleet-wide autonomous missions.
Aircraft requirements
Part 108 establishes aircraft requirements across three weight categories, each with distinct operational implications.
Weight categories
| Category | Maximum Weight | Typical Applications |
|---|---|---|
| Small UAS | 55 lbs | Delivery, surveying, inspection |
| Medium UAS | 110 lbs | Agriculture, heavy-lift inspection |
| Large UAS | 1,320 lbs | Agricultural spraying, cargo |
The 1,320-pound maximum aligns with recommendations from the FAA's BVLOS Aviation Rulemaking Committee (ARC).
Airworthiness acceptance
Part 108 replaces traditional airworthiness certificates with a streamlined Airworthiness Acceptance process. Manufacturers submit a Means of Compliance demonstrating adherence to industry consensus standards. Upon approval, manufacturers receive a Declaration of Compliance.
Manufacturer requirements:
- Documented safety bulletin program
- Implemented safety management program
- Unrestricted FAA access to facilities, data, and documentation
- Compliance with ASTM or equivalent standards
Operators must ensure aircraft have received Airworthiness Acceptance before Part 108 operations. Equipment management systems should track acceptance status for each fleet aircraft.
Mandatory equipment
All Part 108 aircraft require:
- Remote ID broadcast - Remote ID compliance enables airspace awareness
- Position lighting - Visibility during operations
- Communication systems - Reliable command and control links
Detect and avoid systems
Detect and Avoid (DAA) requirements vary by operational environment:
- Category 5 areas (2,500+ people within 0.5 miles): DAA required for all aircraft, including detection of non-cooperative targets
- Controlled airspace: Strategic deconfliction and conformance monitoring required
- Lower density areas: DAA requirements scale with population density
DAA systems must detect both cooperative aircraft (ADS-B equipped) and non-cooperative aircraft using optical, radar, or hybrid sensing technologies.
Documentation and SMS requirements
Documentation requirements differ significantly between permitted and certificated operations. Organizations pursuing certificates face comprehensive Safety Management System mandates.
Operations manual requirements
All Part 108 operators must maintain operations manuals covering:
- Equipment specifications and testing procedures
- Maintenance schedules and procedures
- Personnel roles and responsibilities
- Emergency procedures
- Flight planning protocols
Safety Management System (SMS)
Certificated operators must implement formal SMS programs with four core components:
1. Safety Policy
- Documented commitment signed by senior management
- Safety established as organizational core value
- Clear accountability structure
2. Safety Risk Management
- Systematic hazard identification processes
- Risk assessment before, during, and after operations
- Control measures for identified hazards
3. Safety Assurance
- Regular audits and performance reviews
- Incident investigation procedures
- Continuous improvement mechanisms
4. Safety Promotion
- Ongoing safety training programs
- Safety communication throughout organization
- Culture development initiatives
Drone compliance platforms that integrate SMS documentation streamline the certification process and ongoing compliance maintenance.
Recordkeeping requirements
Part 108 mandates detailed recordkeeping including:
- Flight logs and telemetry data
- Pre-flight inspection records
- Maintenance and repair documentation
- Personnel training and qualification records
- Incident and occurrence reports
Operational area requirements
Before conducting Part 108 operations, organizations must obtain FAA approval for intended operational areas.
Area approval elements
Applications must specify:
- Geographic boundaries of operational area
- Approximate number of daily operations
- Takeoff, landing, and loading locations
- Communications coverage verification
- Lost link procedures
Population density categories
Part 108 defines five population density categories that determine operational restrictions:
| Category | Description | Permit Operations | Certificate Operations |
|---|---|---|---|
| 1 | Very sparse | Permitted | Permitted |
| 2 | Sparse | Permitted | Permitted |
| 3 | Suburban | Permitted | Permitted |
| 4 | Urban | Not permitted | Permitted |
| 5 | Dense urban (2,500+ per 0.5 mi) | Not permitted | Permitted with DAA |
Controlled airspace operations
Operations up to 400 feet AGL are permitted in Class B, C, D, and surface-area Class E airspace with appropriate authorization. Airspace authorization processes will integrate with Part 108 area approvals.
Automated Data Service Providers (ADSPs)
Part 108 introduces ADSPs as third-party entities providing services to maintain separation between BVLOS drones and other aircraft. The FAA will approve and regulate ADSPs, which may offer:
- Traffic deconfliction services
- Airspace management support
- Communication relay capabilities
Security requirements
TSA requirements apply to all Part 108 personnel in covered positions.
Security threat assessments
Operations Supervisors, Flight Coordinators, and other covered personnel must complete TSA security threat assessments up to Level 3, which may include:
- Watchlist verification
- Immigration status check
- Fingerprint-based criminal history records check
Organizations should initiate security clearance processes early, as assessment completion can take several months.
Facility security
Operations involving sensitive areas or cargo may require additional security protocols beyond personnel assessments.
Compliance preparation checklist
Organizations can begin Part 108 preparation now, even before the final rule publishes. This checklist prioritizes actions by implementation timeline.
Immediate actions (now)
- Designate prospective Operations Supervisor
- Identify Flight Coordinator candidates
- Inventory current fleet for airworthiness acceptance eligibility
- Assess operational areas and population density categories
- Review current drone operations software for SMS support
Short-term actions (Q1 2026)
- Develop draft operations manual
- Create personnel training programs
- Establish flight logging and documentation systems
- Initiate TSA security assessment applications
- Contact aircraft manufacturers regarding airworthiness acceptance status
Pre-implementation actions (Q2-Q3 2026)
- Finalize Operations Supervisor qualification documentation
- Complete Flight Coordinator experience requirements
- Implement Safety Management System (if pursuing certificate)
- Submit operational area approval applications
- Conduct staff training on Part 108 procedures
Go-live preparation (late 2026)
- Verify all personnel qualifications and currency
- Confirm aircraft airworthiness acceptance
- Complete FAA application submission
- Test operational procedures
- Establish incident reporting workflows
Drone fleet management platforms that track personnel qualifications, aircraft status, and documentation centralize compliance management.
Frequently Asked Questions
Do Part 108 personnel need FAA pilot certificates?
No. Neither Operations Supervisors nor Flight Coordinators require FAA-issued airman or remote pilot certificates under Part 108. However, both roles require documented qualifications through training, experience, or expertise pathways. Existing Part 107 certifications remain valuable for demonstrating aviation knowledge but are not mandatory for Part 108 roles.
What happens to existing Part 107 BVLOS waivers?
The Part 108 NPRM proposes eliminating the ability to obtain new Part 107 BVLOS waivers once the final rule takes effect. Industry associations have urged the FAA to create a grandfathering pathway for operators with existing waivers, but this remains unresolved in the current proposal. Operators with active waivers should monitor the final rule for transition guidance.
Can Flight Coordinators supervise multiple drones simultaneously?
Yes, when manufacturer specifications permit. Part 108 allows Flight Coordinators to supervise multiple aircraft concurrently based on the specific UAS manufacturer's operational guidelines. This enables scalable operations where automation handles routine flight tasks while coordinators provide tactical oversight across fleets.
When will Part 108 take effect?
Based on Executive Order 14307's 240-day mandate from June 6, 2025, the final rule should publish by early February 2026. Industry observers anticipate possible delays pushing finalization to March or April 2026. Following publication, a 6-12 month implementation period will allow operators to complete compliance preparation before requirements become enforceable.
Implementation considerations
Organizations should evaluate their operational profile against Part 108's two-tier structure. Permits offer faster approval and simpler compliance for operations within fleet and geographic limits. Certificates provide flexibility but require substantial SMS investment.
Current BVLOS waiver holders should continue monitoring FAA announcements regarding transition provisions. The final rule may include pathways that leverage existing waiver experience toward Part 108 authorization.
Technology investments should align with Part 108 requirements. Aircraft manufacturers are actively pursuing airworthiness acceptance, and operators should verify their fleet's eligibility. Comprehensive feature sets in operations platforms should support SMS documentation, personnel tracking, and compliance reporting.
Personnel development represents the most time-intensive preparation element. Identifying and qualifying Operations Supervisors and Flight Coordinators requires documented training or experience that cannot be accelerated once final rules publish.
In summary
Part 108 requirements establish a comprehensive framework for scaling BVLOS operations beyond the current waiver system. The two-tier authorization structure accommodates operations ranging from single recreational aircraft to large commercial fleets operating in populated areas.
Personnel requirements shift accountability from individual pilots to organizational roles. Operations Supervisors maintain overall safety authority while Flight Coordinators provide tactical oversight scaled to automation capabilities. Neither role requires traditional FAA certification, enabling organizations to develop internal expertise.
Aircraft requirements emphasize manufacturer compliance through airworthiness acceptance rather than individual certification. Remote ID, lighting, and detect-and-avoid systems ensure operational safety across diverse environments.
Organizations beginning preparation now will be positioned to operate when Part 108 takes effect. The compliance checklist provides a structured approach to personnel qualification, documentation development, and system implementation that can proceed in parallel with final rule development.
Ready to Prepare for Part 108 Compliance?
Part 108 represents the most significant opportunity for commercial BVLOS operations since Part 107 launched. Organizations that begin compliance preparation now will gain competitive advantage when the final rule takes effect.
Start your free trial today - no credit card required.
Or book a demo to see how DroneBundle helps teams track personnel qualifications and maintain regulatory compliance across BVLOS operations.
