On January 17, 2025, the Federal Aviation Administration (FAA) published two new significant rules aimed at modernizing and streamlining the aircraft registration and recordation process under the purview of the Civil Aircraft Registration Branch located in Oklahoma City, Oklahoma (the “FAA Registry”).
These changes are part of the FAA’s broader effort to upgrade the registration system under the Civil Aviation Registry Electronic Services (CARES) initiative. Although the rules became effective upon publication in the Federal Register, the FAA Registry anticipates that the new policies and procedures will not be fully implemented until the fall of 2025.
I. Procedural Updates: Submission of Original Documents and Stamping
The FAA will be updating its procedures for submitting instruments related to aircraft registration, conveyances, and other supporting documentation that may be researched in the indices and records of the FAA Registry. For years, a key requirement for the FAA’s processing was the submission and acceptance of original documents. This generally required most documents to be executed and submitted in ink or with an authenticated digital signature. However, under the new rules, a certified true copy will be accepted in lieu of an original, except where an original is specifically required.
Additionally, the FAA has determined that its procedures for stamping documents will no longer be necessary for instruments submitted through the CARES system. Instead, the FAA Registry will digitally record the submission date and time, removing the need for physical date stamps.
II. Practical Updates: Electronic Issuance of Aircraft Registration and Dealer Certificates
Later this year, the FAA will also begin issuing aircraft registration and dealer registration certificates electronically, rather than printing and mailing physical paper copies. Historically, the FAA issued these certificates on a 4” x 9” document (colloquially known as “Hard Cards”), which were subsequently mailed to a registered owner or delivered to its representative in the FAA Registry’s Public Documents Room.
Moving forward, aircraft registration and dealer registration certificates will be primarily delivered electronically via e-mail or through other means. For those who prefer the traditional method, a Hard Card paper certificate may still be requested.
Aircraft owners will still be required to carry a copy of the electronically issued Certificate of Aircraft Registration on their aircraft. The FAA may eventually allow an electronic or digital version of this certificate to be onboard the aircraft as well.
Previously, owners were asked to return their Hard Cards to the FAA if their aircraft was sold, scrapped, or deregistered. For electronically issued certificates, this will no longer be a requirement. However, the owner must still provide notice to the FAA if any of these changes occur. Any printed copies of the registration certificate must be destroyed.
Conclusion: Gilchrist Aviation Law Is Primed and Positioned to Help
The FAA’s new rules may simplify certain aspects of aircraft registration and recordation, but they also introduce nuances that require careful attention. From ensuring consistent compliance with the most current document submission standards, to simplifying the complexities of the Federal Aviation Regulations for industry parties and clients, to understanding the unwritten course of practice necessary to achieve the best results when interacting with the FAA Registry, Gilchrist Aviation Law’s expertise and experience continue to deepen and remain an invaluable industry partner in navigating the evolving procedural and practical landscape regulated by the FAA.
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