Prior to 2010 the Federal Aviation Administration (FAA) did not require aircraft registration renewal. Once an aircraft was registered its registration remained valid until cancelled or revoked. Owners were required to report changes in registration such as the sale of an aircraft, death of an owner, change in mailing address, or destruction of an aircraft. However, reporting of such was done on a voluntary basis which, over time, led to tremendous inaccuracy in the FAA aircraft registration records. At one point in 2010 the FAA estimated that approximately one-third of the more than 350,000 FAA registration records contained an inaccuracy due to failure in voluntary reporting. This major lack of accuracy in registration records caused great concern for the FAA and other agencies as it created serious safety and security issues. These concerns led to a major change in registration rules for all FAA registered aircraft.
Effective October 1, 2010 the FAA amended its existing aircraft registration regulations to better and more accurately reflect current aircraft registration information. Under the amended registration rules, two major changes occurred. The first change caused all aircraft registered with the FAA prior to October 1, 2010 to be scheduled for registration termination staggered over a three-year period. This led to the owners of such aircraft, who were still alive and cared about registration of their aircraft, to update and re-submit current registration information to the FAA. This mass re-registration allowed the FAA to refresh its registration records for all aircraft owners who responded and to purge the registration information for all aircraft owners who didn’t, thus establishing an updated registration database.
The second major change involved the implementation of a three-year recurring registration expiration. Accordingly, any aircraft registered after October 1, 2010 will only be registered for three years. After three years, the aircraft need to be re-registered, at which point registration will be granted for another three years and so on. Under the registration regulations as amended, reporting is still required for changes in address and ownership, and the sale, scrapping, or destruction of an aircraft, just as they were before. However, the new tri-annual re-registration requirement will ensure that such changes, if not reported, do not go unnoticed for more than three years, thereby keeping the FAA’s newly updated aircraft registration records much more current. It is worth noting that the recent passage of the FAA Reauthorization Act of 2018 in Section 508, states that rulemaking will be initiated to increase the duration of aircraft registrations from every 3 years to every 10 years.
Under the amended registration regulations, initial registration for all new owners must be done via physical submission of registration documents to the FAA Aircraft Registration Branch in Oklahoma City. However, the tri-annual re-registration can be done online using the approved FAA form. Once registered, all aircraft will receive notice, sent to the last noted registration address, six months prior to registration expiration prompting re-registration. At that time is it important to promptly pursue re-registration, if desired, so that the FAA has enough time to process the request and issue the new Certificate of Registration before the previous one expires.
Aircraft registration under the FAA is a simple process in concept but can be tricky in practice. Additionally, the penalty for improper registration can be severe ranging from grounding of aircraft to steep fines or even legal action. If you find yourself contemplating aircraft registration or re-registration and have questions, give us a call and we will be glad to help.
