Expert Report on the Certification and Compliance Framework for 14 CFR Part 107 Remote Pilots

TL;DR

14 CFR Part 107 requires commercial drone pilots to meet strict eligibility, knowledge, security, and currency standards. This authoritative report explains the full certification pipeline: foundational prerequisites, TSA background vetting, IACRA and FTN requirements, the UAG exam, the expedited pathway for Part 61 pilots, temporary vs. permanent certificate issuance, and recurrent training obligations. It also clarifies disqualifying offenses, administrative workflows, cost implications, and the regulatory philosophy behind the FAA’s shift to online recurrent training. The result is an end-to-end, legally grounded compliance roadmap for becoming—and remaining—a current, authorized Remote Pilot under Part 107.

I. Foundational Eligibility and Regulatory Context

1.1. The Scope of Part 107 and Core Personal Prerequisites

The Federal Aviation Administration (FAA) requires any individual operating a small Unmanned Aircraft System (sUAS) for commercial purposes to hold a Remote Pilot Certificate, governed by 14 Code of Federal Regulations (CFR) Part 107. This certification process begins with a series of mandatory personal and foundational prerequisites designed to ensure a minimal standard of capability and responsibility.

The fundamental age requirement mandates that an applicant must be a minimum of sixteen (16) years old to qualify for the certificate.1 This threshold is significantly lower than the requirements for most manned aviation licenses, reflecting the FAA’s assessment of the reduced complexity and operational risk profile associated with small, unmanned flight systems. In addition to age, the applicant must possess demonstrable English language proficiency, encompassing the ability to read, speak, write, and understand the language.1 This requirement is critical for maintaining safety standards, particularly for understanding complex regulatory documents, interpreting essential flight information such as Notices to Airmen (NOTAMs) and aviation charts, and communicating effectively if interaction with Air Traffic Control (ATC) is necessary for airspace authorizations.

A core operational prerequisite is the requirement that the applicant must be in a physical and mental condition that permits the safe operation of a drone.1 This is primarily a self-declaration requirement by the applicant, differentiating it from the stringent medical certification processes required under Part 61 for manned pilots. Finally, all initial applicants must satisfy the core knowledge requirement by passing the designated aeronautical knowledge exam, officially known as the “Unmanned Aircraft General – Small (UAG)”.1

1.2. The Necessity of Security Vetting: TSA Screening and Disqualification Criteria

While the FAA manages the procedural and knowledge aspects of the certification, the authority to issue the certificate ultimately relies upon the applicant successfully clearing a mandated security background check. This process is overseen by the Transportation Security Administration (TSA), and it is implicitly triggered when the applicant submits their final certificate application through the Integrated Airman Certification and Rating Application (IACRA) system.

The security vetting screens for a range of disqualifying criminal offenses. These offenses are categorized based on their severity and the duration of disqualification. Permanently disqualifying criminal offenses include high-level felonies related to threats against national security or acts of terrorism, for which a conviction, plea of guilty, or finding of not guilty by reason of insanity results in indefinite denial of the certificate, regardless of how long ago the event occurred.3

Conversely, the TSA also lists interim disqualifying criminal offenses. These include felonies such as arson, smuggling, various immigration violations, distribution or possession with intent to distribute controlled substances, robbery, and certain types of fraud.3 For these interim offenses, denial of the certificate typically applies if the conviction, plea, or finding occurred within a specified timeframe preceding the application date, generally understood to be five to seven years. Furthermore, any individual currently wanted, under warrant, or under indictment in any civilian or military jurisdiction for a listed felony (permanent or interim) will be disqualified until the status is resolved.3

This procedural structure dictates that applicants must first invest time and money—approximately $175 for the examination fee 4—to pass the aeronautical knowledge test before the final, mandatory security vetting is complete. Because the security check is initiated only upon submission of the IACRA application following a successful test, applicants carry the administrative and financial risk of potentially being denied certification weeks or months later due to a disqualifying conviction. The regulatory body places primary emphasis on ensuring the applicant meets the technical knowledge standard upfront, shifting the burden of administrative risk onto the individual pilot.

It is relevant to note that the security vetting is not a blanket prohibition against all criminal history. The evidence suggests the TSA primarily focuses on threats related to national security and terrorism.5 The existence of the “interim” categories and the focus on recent activities indicate that a risk-based assessment is employed, rather than an automatic denial based solely on an older criminal conviction that is not directly tied to a threat to transportation security. This approach allows for discretionary certification for individuals who may have older, non-violent felony records, as the ultimate objective is to mitigate immediate security risks.

Table I: Part 107 Basic Eligibility Requirements Checklist

Requirement CategoryStandardRegulatory Context
Minimum AgeAt least 16 years oldEntry-level commercial aviation standard
English ProficiencyRead, speak, write, and understand EnglishCommunication essential for safety and compliance
FitnessPhysical and mental condition to safely flySelf-assessment; grounds for revocation if violated
KnowledgeMust pass the initial UAG knowledge exam (or equivalent course)Demonstrated aeronautical knowledge foundation

II. The Standard Pathway: First-Time Remote Pilot Certification

The standard pathway applies to all applicants who do not currently hold a pilot certificate issued under 14 CFR Part 61 (manned aviation). This process is highly structured and requires strict adherence to administrative sequencing.

2.1. Administrative Prerequisites: The IACRA and FTN Requirement

The initial and mandatory administrative step requires the applicant to establish an official record within the FAA’s airman tracking system. This is accomplished by obtaining an FAA Tracking Number (FTN).1 The FTN is generated only after the applicant creates a profile within the Integrated Airman Certification and Rating Application (IACRA) system, which serves as the central electronic platform for all FAA airman certification and rating processes.1

The FTN is critical because it acts as the unique identifier that links the applicant’s personal record, test registration, and subsequent aeronautical knowledge test results. The FTN is printed on the resulting Airman Knowledge Test Report (AKTR).6 The regulatory procedure mandates that this FTN acquisition must occur prior to registering for the knowledge test.1 This sequence is not merely a formality; it is a critical regulatory gatekeeper. The FAA requires a pre-existing, standardized airman file before the test data can be accepted and validated. If an applicant bypasses this step and attempts to take the UAG exam without a pre-registered FTN, the resulting score may not be accurately indexed to their permanent record, potentially rendering the costly ($175) test result unusable for the final IACRA application.

2.2. Scheduling and Preparing for the Initial Aeronautical Knowledge Exam (UAG)

Once the FTN is secured, the applicant proceeds to schedule the required examination: the “Unmanned Aircraft General – Small (UAG)” test.1 Appointments must be made through an FAA-approved Knowledge Testing Center, such as those operated by approved testing service providers.1 The examination typically incurs a testing fee of approximately $175.4

On the day of the examination, stringent identification requirements must be met. Applicants must present a government-issued photo identification that is both valid and current. The identification document must contain all of the following essential details: a photo, the date of birth, a signature, and the applicant’s physical address.6

The content of the UAG exam is extensive, ensuring that the remote pilot possesses a strong foundational knowledge necessary for safe and compliant operation within the National Airspace System (NAS). Subject areas covered include: applicable regulations pertaining to small UAS privileges, limitations, and flight operation; airspace classification, operating requirements, and flight restrictions; aviation weather sources and the effects of weather on sUAS performance; small UAS loading, weight, and balance considerations; emergency procedures; crew resource management (CRM); and radio communication protocols.1 The composition of the test, with its heavy emphasis on regulatory compliance, airspace management, and environmental factors, confirms the FAA’s primary concern is the remote pilot’s cognitive understanding of the operational environment rather than hands-on, stick-and-rudder proficiency. This reliance solely on knowledge testing, without an equivalent to the practical checkride required for manned flight, demonstrates the FAA’s determination that operational safety for small UAS can be sufficiently maintained through intellectual mastery of the rules.

III. Comparative Pathways to Part 107 Certification

The FAA recognizes that individuals who already hold credentials in manned aviation possess significant foundational aeronautical knowledge. Consequently, the certification process is streamlined for current Part 61 certificate holders, creating a distinct, expedited pathway.

3.1. The Expedited Pathway for Existing Part 61 Pilots

Holders of a pilot certificate issued under 14 CFR Part 61 (e.g., Private Pilot, Commercial Pilot, Airline Transport Pilot) who seek Part 107 authority are granted a waiver for the standard, in-person UAG knowledge test. To qualify for this waiver, the Part 61 pilot must have completed a flight review within the preceding 24 calendar months.7 This requirement ensures their general aviation currency is active.

Instead of paying the ~$175 fee and scheduling the UAG exam 4, qualifying Part 61 pilots may complete a specific, free online training course. This course, designated ALC-451: Part 107 Small Unmanned Aircraft Systems, is available on the FAASafety.gov website.7 This online module focuses specifically on the unique rules and knowledge areas defined by Part 107 (such as operating restrictions, maintenance, and small UAS performance) that are not typically covered in detail during general manned pilot training.

The FAA affords this benefit because it recognizes that the core knowledge required for the UAG test—pertaining to weather, airspace communication, and navigation—is already contained within the Part 61 airman’s skillset. By only requiring the online supplemental training (ALC-451), the FAA avoids redundant knowledge assessment, promoting regulatory efficiency.

3.2. Mandatory Application and Dual Certification Requirements

It is critical to understand that even when a Part 61 certificate holder satisfies the knowledge requirement via the free online course, they are not automatically authorized to fly commercially under Part 107. The pilot must still formally apply for and obtain the separate Remote Pilot Certificate with a small UAS rating to conduct operations for business purposes.4 This application must be processed through the IACRA system, which necessitates the acquisition of an FTN, similar to the standard applicant process.

Although the initial process is significantly simpler and cheaper for the Part 61 pilot, eliminating the testing fee 4, the ongoing compliance obligation is nuanced. Part 61 pilots must remain cognizant of the currency requirements for both certificates. While the Part 61 status allows for the initial test substitution, maintaining the Part 107 authority requires adherence to the distinct 24-calendar-month recurrent training schedule specific to the drone operations environment.4

Table II: Comparative Pathways to Part 107 Remote Pilot Certification

CriteriaStandard Applicant (Non-Part 61)Part 61 Pilot (Current Flight Review)
Aeronautical Knowledge AssessmentRequired: Pass UAG Knowledge Test (In-person, fee required)Waived: Substitute free online training (ALC-451)
Mandatory Pre-Test StepFTN required via IACRAFTN creation required for final application (via IACRA)
Initial Cost (Exam/Training)~$175 Exam FeeFree (Online course is free)
Final RequirementApplication via IACRA using AKTRApplication via IACRA using Course Completion Certificate
Required Final DocumentationPart 107 Certificate (sUAS Rating)Part 107 Certificate (sUAS Rating)

IV. Post-Certification Procedures and Documentation

The culmination of the preparation and knowledge testing phase is the submission of the formal certificate application, leading to the security review and physical certificate issuance.

4.1. Application Submission and Review

Upon successfully passing the UAG knowledge test (for standard applicants) or completing the ALC-451 online course (for Part 61 pilots), the applicant must complete the official application for the Remote Pilot Certificate using the IACRA system.1 During this submission, the applicant’s FTN is linked to either the Airman Knowledge Test Report (AKTR) or the course completion certificate. This administrative action formalizes the application and simultaneously initiates the mandatory TSA background security screening process detailed in Section I.2.

4.2. Certificate Issuance Timeline

The FAA uses a two-step issuance process to expedite commercial operations authority while maintaining a secure process for producing the permanent document. The initial authorization takes the form of a temporary certificate, often issued via email shortly after the IACRA application has been processed and initial security checks have been performed.8 This temporary certificate immediately grants the remote pilot authority to begin legal commercial operations under Part 107. This separation of authorization (temporary) from physical card production (permanent) is a regulatory mechanism designed to minimize economic downtime for commercial pilots while the lengthy production phase for the permanent certificate is underway.

The permanent, hard-plastic certificate is subsequently processed and mailed by the FAA’s Airmen Certification Branch. The processing and mailing time typically spans between six (6) and ten (10) weeks from the date the temporary certificate was issued.8 Due to the reliance on physical mailing for this official document, the accuracy of the mailing address provided within the IACRA profile is essential. Any change of address during this several-month processing window must be updated immediately by the applicant to ensure timely receipt of the certificate. If the permanent certificate has not been received within the expected timeframe, generally after eight (8) weeks, the applicant is advised to contact the Airmen Certification Branch for inquiry.9

Table III: Part 107 Certificate Issuance Timeline and Milestones

Action/MilestoneTimelineSignificance
Successful UAG Exam Completion / ALC-451 CompletionDay 0Aeronautical Knowledge Requirement Met
IACRA Application Submission (Remote Pilot)Day 0 to Day 7FAA Processing and Security Vetting Begins
Temporary Certificate Issued (via email)Typically within 10 daysValid for immediate Part 107 operations
Permanent Certificate Processing6 to 10 weeks from temporary issuanceOfficial hard-copy document received

4.3. Documentation and Operational Requirements

Once the certificate is obtained, whether temporary or permanent, compliance dictates that the Remote Pilot Certificate must be easily accessible by the Remote Pilot in Command (PIC) during all small UAS operations.1 Furthermore, if the pilot is relying on a recently completed recurrent training course to maintain currency, the certificate of completion for that recurrent training must also be carried and presented upon request, along with the physical Part 107 certificate and a government-issued photo ID.10

V. Maintaining Recency and Aeronautical Knowledge (Currency)

Certification under Part 107 requires the proactive maintenance of aeronautical knowledge. The certificate is not issued in perpetuity; rather, pilots must comply with recurrent training mandates to ensure currency.

5.1. The 24-Calendar-Month Recurrent Training Mandate

To maintain authorization to operate commercially under Part 107, the certificate holder must complete recurrent training every 24 calendar months.1 This 24-month period is measured by calendar months, meaning currency is required by the last day of the 24th month following the month of the last issuance or recurrent completion. Maintaining this recency is a mandatory prerequisite for legal operation.

5.2. Recurrent Training Pathways for All Remote Pilots

A significant change in regulatory procedure has transitioned the requirement from a recurring, fee-based knowledge test to a free, mandatory online training course, substantially lowering the financial and logistical compliance burden.

For standard remote pilots (non-Part 61 holders), the recurrent requirement is satisfied by completing the designated online course, such as the module titled ALC-677: Part 107 Small UAS Recurrent, which is available on the FAASafety.gov platform.11 This course is designed specifically to update the pilot’s aeronautical knowledge base, focusing on any changes to regulations, operating requirements, and safety procedures over the preceding two years.11

For existing Part 61 certificate holders, the recurrent process also standardizes to this free online course every 24 calendar months, despite their alternative initial certification route.4 This means all Part 107 pilots, regardless of their background, utilize the same, simplified, no-cost method to maintain currency. This strategic shift from high-stakes testing to accessible regulatory education increases the likelihood of widespread compliance and exposure to crucial regulatory updates (e.g., changes related to night operations or Remote Identification).

Completion of this recurrent training course serves a dual function. Beyond merely updating knowledge, the required training covers safety protocols for specialized operations, which often includes the necessary knowledge required to operate at night under Part 107 regulations.10 Thus, compliance with the 24-month recurrent requirement is often implicitly tied to the continued authorization of expanded operational privileges, such as night flight. Upon successful completion, the pilot receives a certificate that must be retained and kept readily available during flight operations as proof of current training.10

Table IV: Part 107 Currency Requirements Summary

Pilot StatusRecurrence CycleMethod of RecurrenceCost Implication
Standard (Non-Part 61)Every 24 calendar monthsFAA Online Recurrent Training (e.g., ALC-677)Free
Part 61 PilotEvery 24 calendar monthsFAA Online Recurrent Training (e.g., ALC-677)Free

VI. Conclusions and Recommendations

The process for obtaining and maintaining the 14 CFR Part 107 Remote Pilot Certificate demonstrates a carefully calibrated regulatory approach that balances ease of entry with stringent compliance oversight. The FAA has established a clear, multi-stage procedure that prioritizes foundational knowledge assessment and preemptive security screening.

The primary differential in the process rests on whether the applicant holds a current Part 61 certificate. Standard applicants must complete the costly, formal UAG knowledge test, while current Part 61 certificate holders are granted a substantial waiver, allowing them to substitute the test with a free online course (ALC-451). This streamlined path acknowledges the transferability of core aviation principles. However, all applicants must follow the critical administrative sequence, commencing with the creation of the IACRA profile and the acquisition of the FTN prior to testing or training.

Following the aeronautical assessment, the security vetting performed by the TSA remains a non-negotiable gateway to certification. The design of this phase—where the security review is finalized after the knowledge requirement is met—places the risk of disqualification and sunk costs onto the applicant.

Finally, the shift in currency requirements from periodic recurrent testing to mandatory, free online training (ALC-677) every 24 calendar months represents a fundamental change in regulatory philosophy. This move emphasizes continuous education and universal exposure to updated safety standards and rules over procedural barriers, significantly improving compliance accessibility and reducing the financial burden for commercial remote pilots operating within the National Airspace System.

For prospective commercial operators, adherence to the specific procedural sequence (FTN first, then testing/training, followed by IACRA application) and meticulous documentation management (retaining recurrent training certificates and maintaining accurate mailing addresses) are mandatory requirements for successful compliance and continued operation.

Works cited

  1. Become a Certificated Remote Pilot | Federal Aviation Administration, accessed October 31, 2025, https://www.faa.gov/uas/commercial_operators/become_a_drone_pilot
  2. Can a Non-US Citizen Get A Part 107 Drone License? – Pilot Institute, accessed October 31, 2025, https://pilotinstitute.com/foreigner-drone-license/
  3. Disqualifying Offenses and Other Factors | Transportation Security Administration – TSA, accessed October 31, 2025, https://www.tsa.gov/disqualifying-offenses-factors
  4. FAA Part 61 vs. 107: Which Certification Path Should You Follow? – Leopard Aviation, accessed October 31, 2025, https://leopardaviation.com/faa-part-61-vs-107/
  5. What the TSA Checks During a Part 107 Application – Pilot Institute, accessed October 31, 2025, https://pilotinstitute.com/part-107-background-check/
  6. FAA Airman Knowledge Testing Matrix, accessed October 31, 2025, https://www.faa.gov/training_testing/testing/testing_matrix
  7. I already have a pilot certificate issued under Part 61. Do I need to obtain a remote pilot certificate to fly a UAS or drone under the Small UAS Rule (Part 107)?, accessed October 31, 2025, https://www.faa.gov/faq/i-already-have-pilot-certificate-issued-under-part-61-do-i-need-obtain-remote-pilot-certificate
  8. I completed the test for a remote pilot. I received a temporary certificate, but I never got my actual license? How should I go about getting this resolved? | Federal Aviation Administration, accessed October 31, 2025, https://www.faa.gov/faq/i-completed-test-remote-pilot-i-received-temporary-certificate-i-never-got-my-actual-license
  9. How long does it take the FAA to send out a permanent license (certificate)?, accessed October 31, 2025, https://www.faa.gov/faq/how-long-does-it-take-faa-send-out-permanent-license-certificate
  10. FAA Drone Pilot Recurrent Training & Testing, accessed October 31, 2025, https://www.dronepilotgroundschool.com/recurrent-knowledge-test-part-107/
  11. Part 107 Small UAS Recurrent – Activities, Courses, Seminars & Webinars – Course Overview – FAA – FAASTeam – FAASafety.gov, accessed October 31, 2025, https://www.faasafety.gov/gslac/ALC/CourseLanding.aspx?cID=677