MOSAIC Rule Explained: New Sport Pilot Privileges and LSA Standards

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In July, 2025, the long-awaited MOSAIC final rule was introduced with a phased implementation schedule. Regulatory changes related to Sport Pilots were planned to go into effect 90 days after publication in the Federal Register (effective October 22, 2025). Changes related to Light Sport Aircraft (LSA) were planned to become effective 365 days after publication (effective July 24, 2026). Regulation links within this post may go to placeholders until their effective date. Refer to the final rule linked above for details, if it is before the effective dates.

One of the key provisions of the change is essentially splitting the Sport Pilot certificate requirements and privileges from the Light Sport Aircraft requirements. Previously, they used the same criteria for both.

The 1320-pound limitation was removed from the definition of LSAs (July, 2026) and Sport Pilot eligible (October, 2025) aircraft. The new rule shifts to a performance-based standard for both LSAs and Sport Pilots, though the criteria for both are not the same.

skyhawk

The 1320-pound limitation was removed from the definition of LSAs (July, 2026) and Sport Pilot eligible (October, 2025) aircraft.


Sport Pilots and Privileges

Effective October 22, 2025, for Sport Pilots, the maximum stalling speed for airplanes in the clean configuration (VS1) was raised from 45 KCAS to 59 KCAS. Seating limitations for airplanes were raised from 2 seats to 4 seats as long as no more than 1 passenger is carried by the Sport Pilot. This redefinition of the limitations adds most 4-seat trainers to the Sport Pilot’s arsenal of available airplanes.

Beyond the performance criteria, retractable landing gear, controllable pitch propellers, and night flights are also allowed with the proper training and endorsements.

Other criteria are covered in the new 14 CFR §61.316 What are the performance limits and design requirements for the aircraft that a sport pilot may operate?

Sport pilots are not permitted to operate any aircraft that requires a type rating.

Sport and higher-level pilots operating under sport privileges can still operate using a driver’s license as a medical for most operations. Night flying requires an FAA medical or BasicMed.

Effective October 22, 2025, Sport Pilot applicants may now obtain up to 2.5 hours of training credit in a category and class qualified flight simulation training device / aviation training device.

Adding a new category or class rating at the sport level to an existing pilot certificate was permitted without the use of a practical exam prior to MOSAIC. This has changed for adding an airplane single-engine land or sea or adding a rotorcraft-helicopter rating. These additions now require a practical exam with a pilot examiner. Adding other categories and classes may still be completed with a flight instructor proficiency check from a different instructor than the one that completed the training for the addition. All of these additions require the proper training and endorsement from an authorized instructor prior to the practical exam or proficiency check.

The previous version of the Sport Pilot rules did not allow helicopters to be built as light sport aircraft or flown by Sport Pilots. The new regulations have provisions for helicopters certified with simplified flight controls. As noted in 14 CFR §61.9, flight time acquired while flying an airplane or helicopter with simplified flight controls may not be used for certain solo/PIC aeronautical experience requirements for a private, commercial, or airline transport pilot certificate.

Effective July 24, 2026, 14 CFR §22.180 defines what the simplified flight control certification requires. Pilots are required to have model specific training and an endorsement for all simplified flight control aircraft that they fly. Instructors will need this endorsement as well in order to teach in this type of aircraft unless they fall under an “initial cadre” designation as indicated in 61.195(n). If the practical exam for a category and class is completed in a simplified flight control model of aircraft, the pilot will be limited to this model until they obtain additional training, endorsement(s), and/or a practical exam.

Traffic Pattern

Night flying requires an FAA medical or BasicMed.


Sport Pilot Instructors

There were a few minor changes for Sport Pilot Instructors. These were mostly related to needing training and endorsements of their own to teach in retractable landing gear, controllable pitch propeller, and simplified flight control aircraft. Training and endorsements are also needed for teaching night flying. Requirements for adding rotorcraft category and helicopter class with a simplified flight controls designation to a Sport Pilot Instructor certificate were also added.

The new rule also clarifies that Sport Pilot Instructors may charge for their instructional services.


Light Sport Category Aircraft

The MOSAIC rule adds a new Part 22 to 14 CFR. Part 22 covers the Design, Production, and Airworthiness Requirements for Non-Type Certificated Aircraft. This is one of the rule changes being introduced in July, 2026. While SLSAs will still be designed and conform to an industry consensus standard, Part 22 lays down some ground rules for the aircraft produced to these standards. As of this writing, it only provides the guidance found in Subpart B—Light-Sport Category Aircraft.

Part 22 is where you will find the criteria that defines the eligibility requirements for an aircraft to be considered an LSA that will be produced by a manufacturer. The previous definition is being removed from Part 1 and moved to 21.181(a)(3)(iv) to cover LSAs certified prior to July 24, 2026. The new 14 CFR §22.100 will define new LSA eligibility as:

(a) To be eligible for a special airworthiness certificate in the light-sport category issued under §21.190 of this chapter, an aircraft must—

(1) Except for an airplane, have a maximum seating capacity of not more than two persons, including the pilot.(2) For an airplane, have a maximum seating capacity of not more than four persons, including the pilot.

(3) Have a maximum stalling speed or minimum steady flight speed at the aircraft’s maximum takeoff weight and most critical center of gravity of 61 knots CAS VS0 for an airplane, 45 knots CAS VS0 for a glider, or 45 knots CAS without the use of lift-enhancing devices, VS1, for a weight-shift-control aircraft.

(4) Have a maximum speed of 250 knots CAS in level flight with maximum continuous power (VH) under standard atmospheric conditions at sea level.

(5) Have a non-pressurized cabin, if equipped with a cabin.

(6) Not have been previously issued a standard, primary, restricted, limited, or provisional airworthiness certificate, or an equivalent airworthiness certificate by a foreign civil aviation authority.

(7) Meet the design, production, and airworthiness requirements specified in this subpart using a means of compliance consisting of consensus standards accepted or approved by the Federal Aviation Administration (FAA).

(8) Be inspected by the FAA and found to be in a condition for safe operation.

(b) For aircraft manufactured outside the United States, an applicant must also provide the FAA evidence that—

(1) The aircraft was manufactured in a country with which the United States has a Bilateral Airworthiness Agreement concerning airplanes or Bilateral Aviation Safety Agreement with associated Implementation Procedures for Airworthiness concerning airplanes, or an equivalent airworthiness agreement; and(2) The aircraft is eligible for an airworthiness certificate, flight authorization, or other similar certification in its country of manufacture.

You may note that there is a difference between the LSA Airplane stalling speed with high-lift devices (generally flaps) used for approval as an LSA and the clean configuration stall speed limitation for Sport Pilots. It is possible that a manufacturer could produce an LSA that a Sport Pilot would not be permitted to fly. This is a function of the LSA and Sport Pilot information being analyzed and approved separately whereas they were previously tied more closely together. Airplanes with a VS1 greater than 59 KCAS could still be approved under the simpler LSA consensus standards if their VS0 is 61 KCAS or less. Pilots would likely need a Private pilot certificate or higher to fly any airplanes in this narrow band of limitation differences. Recreational pilots would likely get caught by other power related limitations.

Part 22 also removes the single-reciprocating engine requirement that limited the use of electric motors and other technologies in the LSA category. This also allows the development of LSA multiengine airplanes and other aircraft provided that the propulsion systems, “Be designed so that the failure of any product or article does not prevent continued safe flight and landing or, if continued safe flight and landing cannot be ensured, the hazard has been minimized;” Traditional light, 4-seat twins with lower stall speeds would not be flyable by Sport Pilots due to the 61.316(a)(5) requirement, “For powered aircraft other than balloons or airships, the loss of partial power would not adversely affect directional control of the aircraft and the aircraft design must allow the pilot the capability of establishing a controlled descent in the event of a partial or total powerplant failure.” and the lack of a Sport Pilot Airplane Multiengine class rating.


Other MOSAIC Changes

Some other miscellaneous changes incorporated in the final rule include:

  • A number of other changes were made to Part 21 to clarify and expand the issuance of restricted airworthiness certificates for various aircraft. Experimental airworthiness certificates issued to manufacturers for testing new designs will now be good for 3 years rather than 1 year.
  • Part 36 is related to noise standards. The final rule amends this to provide a voluntary means for aircraft owners and manufacturers of aircraft that do not conform to a type certificate to demonstrate compliance with Part 36 noise levels for their aircraft. This rule permits the use of industry consensus standards as a means of compliance with Part 36 for the first time and permits the use of a statement of compliance (SOC) as a method of showing compliance. This change does not create new noise limits, nor does it apply to aircraft that conform to a type certificate.
  • Courses for Repairman with Light Sport Inspection or Light Sport Maintenance became less prescriptive in terms of hours in favor of more performance-based criteria.
  • Privileges for these Light Sport Aircraft Repairman certificate holders were also expanded to include working on Experimental-Amateur Built aircraft even if they were not the original builder. Inspector Rating holders can still only sign-off on a condition inspection if they own the aircraft. Maintenance Rating holders may charge for their services. Both can only work on aircraft category and classes for which they have been trained. Repairman changes are effective as of October 22, 2025.
  • 14 CFR 91.327(a)(3) allows LSAs to be used for compensation or hire “To conduct any aerial work operations specified in the aircraft’s pilot operating handbook or operating limitations, as applicable, and specified in the manufacturer’s statement of compliance for the aircraft, in accordance with §21.190 of this chapter.” This will likely only apply to newly approved aircraft and is effective July 24, 2026.

Conclusion

Numerous groups, organizations, and individuals have been working with the FAA for years to bring about these rule changes. Now that they are here, only time will tell if they will bring about the desired growth and opportunities in aviation while not compromising our improving safety record. If nothing else, the changes should allow some older pilots to return to aviation and allow new pilots to train as sport pilots without needed to find a flight school with an elusive LSA based on the old definition. We all hope that there are some manufacturers out there that are ready to jump on the new LSA bandwagon, but it will be at least July, 2026, before we see any of those designs come to fruition.

Fly and stay safe!

Paul Jurgens
2 replies
  1. Randy Warner says:

    I have been following the progress and catching several webinars regarding MOSAIC, I just want to be clear on a couple things. I would like to teach as a Sport Pilot (CFIS) at some point. If I own an E-LSA, I can teach in it, but when the student is ready for solo I cannot rent them the E-LSA, they can only rent an S-LSA. Can I let them solo and log XC time in the E-LSA and just not charge them to rent it? Is there a Deviation applicable that would allow to rent the E-LSA for this purpose?
    As far as getting the 16 hour course so that I can do my own condition inspections, the LSR-I certification. I live in CA, are there any LSR-I training locations within 1000 miles? If so, I have not found one that has responded to my inquiries. How long is the certification good for? Does it need to be renewed?
    Clarification will be appreciated
    R. Warner

    Reply

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