New FAA Rule Requires U.S. Agents for Individuals with Foreign Addresses
FAA Implements New Requirement in 2025
Beginning in 2025, individuals with foreign addresses must designate U.S. agents for service of FAA documents. This change will impact thousands of certificate holders and new applicants. For example, the FAA’s most recent data recorded approximately 115,000 individuals who would be required to designate a US agent.
Previous U.S. Agent Requirements and the 2024 Rule Change
Prior to the issuance of the new rule in 2024, only U.S. air carriers, foreign air carriers and foreign persons operating a U.S.-registered aircraft in common carriage exclusively outside the United States were required to designate a U.S. agent. However, due to cost burdens, time constraints, and complex international service requirements, the FAA promulgated a new rule requiring individuals with i) a foreign address and ii) no U.S. physical address on record with the FAA to designate a U.S. agent for service. The requirement applies to individuals holding or applying for a certificate, rating, or authorization under 14 C.F.R. parts 47, 61, 63, 65, 67, or 107.
Compliance Deadlines for New and Existing Certificate Holders
New applicants under the affected parts must designate a U.S. agent at the time of application. Whereas current certificate holders have until July 7, 2025, to comply. Furthermore, any changes to the designated U.S. agent or their contact information must be reported to the FAA within 30 days.
Who Can Serve as a Designated U.S. Agent?
The rule gives affected individuals discretion in choosing a designated agent. An individual may appoint an entity or an adult over 18 with a US address to be their agent. Acceptable examples include registered agent service companies, friends, relatives, or associates. The only true requirement is that the agent must have a U.S. address.
- If the U.S. agent is an entity, the address must be the U.S. agent’s office address.
- If the agent is an individual, the address must be the U.S. agent’s usual place of residence or, if applicable, the individual’s U.S. military office address.
U.S. address is defined as, “[a]n address in the States of the United States, the District of Columbia, or any U.S. territory or possession, but excludes post office boxes, military post office boxes, mail drop boxes, and commercial addresses that are not also residential addresses.” (14 C.F.R. § 3.302).
Importance of Choosing a Reliable U.S. Agent
Despite the flexible requirements for U.S. agents, individuals should exercise caution when selecting an agent. The agent will be responsible for collecting and forwarding all documents from the FAA. Since the FAA treats service on a U.S. agent as identical to serving the individual directly, the individual remains legally responsible for answering and complying with any FAA documents delivered to their agent.
Because the documents may include letters of investigation, enforcement notices, and similar time-sensitive communications, individuals should only pick a reliable person as their designated agent. If you make your brother your agent, you should check in with him periodically to make sure he hasn’t forgotten to forward mail from the FAA.
FAA Launches Online Portal for U.S. Agent Designations
Fortunately, the FAA has created an online system dedicated exclusively to quickly processing assignments of U.S. agents for service. The new portal, the U.S. Agent for Service System (USAS), is available at https://usas.faa.gov.
Through the online system the individual must provide the following information about their agent:
- the U.S. agent’s full name
- the type of U.S. agent
- the U.S. agent address
- the U.S. agent’s email address
The applicant or holder must also certify that the agent has accepted responsibility for service. Impacted parties must provide their basic personal details and contact information. Additional information may be needed depending on the individual’s role.
- Airmen must provide their date of birth, certificate number, FAA tracking number, and applicant ID (medical)
- Aircraft owners or applicants under part 47 must include their aircraft’s registration number, make, model, and serial number
Penalties for Noncompliance: Why You Must Act Now
Ultimately, it is crucial to address this new requirement without delay, as the penalties for noncompliance are strict and there is minimal room for leniency if deadlines are missed.
- Pilots and mechanics who fail to designate a U.S. agent will be unable to exercise the privileges of their certificates, ratings, or authorizations under parts 47, 61, 63, 65, 67, or 107.
- Aircraft owners who do not comply will have their registration certificates deemed ineffective.
- Applicants for certificates, ratings, or authorizations will not receive approval without a designated U.S. agent.
Act Now to Ensure FAA Compliance
With the July 7, 2025 deadline approaching for existing certificate holders, it is essential to designate a trusted U.S. agent as soon as possible. To avoid disruptions to your FAA certification, complete your designation process today at https://usas.faa.gov.