![A wide range of light aircraft and the pilots that fly them will be positively affected by the implementation of MOSAIC. [Credit: Sling Aircraft]](https://flyingmag1.b-cdn.net/wp-content/uploads/sites/2/2024/04/IMG_1453-scaled-e16729530134661.jpg?width=1200&height=800)
The impact of the Modernization of Special Airworthiness Certification (MOSAIC) rule is generating a lot of discussion in the aviation community, as many flight schools and education professionals are anticipating 2026 will see more people heading out to the airport to seek sport pilot training.
However, many of us who were instructing in 2004 when the light sport aircraft (LSA) and sport pilot (SP) certificate became a thing are wondering if we’re going to have a “Lucy holds the football for Charlie Brown moment,” as the creation of the LSA/SP rule promised smaller, therefore less expensive airplanes. We heard about the possibility of new trainers that cost less than $100,000, but that did not happen for a variety of reasons—not the least of which were manufacturing and certification expenses.
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When the MOSAIC rule was released in July 2025, there was a cautious optimism among the instructor cadre. And although we’ve got a wait-and-see mindset, that doesn’t mean we’re not getting prepared.
In November the FAA released a 25-page Advisory Circular (AC) 61-65K that spells out how MOSAIC differs from the 2004 rule and provides guidance on the certification standards for sport pilots and sport pilot instructors.
MOSAIC was the topic of discussion at a Sunday evening seminar provided by the Society of Aviation and Flight Educators (SAFE). Over 1,000 people were online to discuss and learn what the information in AC 61-146 could mean to the aviation instructor community.
MOSAIC removes the weight and airspeed limitations on aircraft a sport pilot may operate in favor of performance limitations. The AC notes that the “FAA determined that performance-based standards are more appropriate based on the safety continuum concept, and the other existing performance and design characteristics provide appropriate limitations for sport pilot operations.”
Under MOSAIC, a sport pilot may operate an aircraft that has a “maximum stalling speed or minimum steady flight speed without the use of lift-enhancing devices (VS1) of not more than 45 [kcas], except for airplanes, which must have a VS1 speed of not more than 59 [kcas] at the aircraft’s maximum certificated takeoff weight and most critical center of gravity (CG) (14 CFR § 61.316(a)(1)).”
These changes are welcomed by those of us who were instructing in 2004 and have stories to tell about people coming to the flight school seeking sport pilot training only to learn that the school did not have a light sport aircraft, which was defined by a weight limitation of 1,320 pounds (or 1,430 pounds for aircraft equipped with floats), an airspeed limitation of 120 kcas and a single reciprocating engine. Another variation of this was when the training could not take place because, due to the applicant’s build even with the smallest CFI they were too large to fit in the LSA because of the weight limitation.
MOSAIC stipulates that existing legacy training aircraft such as Diamond DA-40s, Pipers, and Cessna 172s, 150s, and 152s, can be flown by sport pilots. In addition, a sport pilot can receive additional training and an endorsement to be able to operate an aircraft with a controllable pitch prop and retractable landing gear. No need to get a special airplane to take advantage of this new revenue stream, and if the school has a Cessna Cutlass or Cardinal that doesn’t see much action, this may be about to change.
Night flying privileges for a sport pilot are a little confusing. Under 14 CFR § 61.329, the sport pilot needs “additional night training, an authorized instructor qualifying endorsement, and additional medical qualifications,” which means the sport pilot must hold a valid medical certificate, although for daytime privileges they can legally fly with a valid driver’s license in lieu of an FAA-issued medical.
The training requirements for sport pilot night operations, per 14 CFR § 61.329(a), are three hours of night flight obtained from an authorized instructor, which includes one cross-country flight with a landing at an airport at least 25 nm from the departure airport, except for powered parachutes, and 10 takeoffs and 10 landings to a full stop at night.
The regulations go on to state that any night flight training done in pursuit of a “higher certificate”—for example, a private pilot certificate—may count toward the time required in 14 CFR § 61.329. provided the training was done in the same category and class of sport pilot night privileges sought. And you still need the endorsement from an instructor.
The new 14 CFR § 61.316 allows for the operation of aircraft with any powerplant types under sport pilot privileges. However, the FAA amended 14 CFR § 61.315 to specifically state a sport pilot may not act as PIC of an aircraft that requires a type rating “due to the complexity associated with operating those aircraft and the training footprint of sport pilots.”
Training and Check Ride Questions
As more aircraft are now sport pilot eligible, it is conceivable to think that flight schools may see an increase in pilot candidates.
However, during the SAFE seminar there was a great deal of discussion about whether the majority of Designated Pilot Examiners (DPEs) are able to administer the sport pilot check ride. DPEs have to gain FAA approval to add check rides to their offerings.
According to SAFE executive director and seminar host David St. George, if there is an increase in pilots training for sport pilot certificates, there will need to be an increase, perhaps a significant one, in the number of DPEs authorized to administer sport pilot—or new ones will need to be trained specifically for sport pilot, as so many DPEs are scheduled out weeks or even months in advance.
Sport Pilot Instructors
The experience requirements for sport pilot instructors also sparked some discussion because the minimum hours required to qualify for that rating are fewer than those required for the commercial pilot certificate—which is usually the precursor to the CFI rating for most pilots.
Under Part 141, an applicant can qualify for a commercial pilot certificate with 190 hours total time. If the training is done under Part 61, 250 hours is the minimum for a commercial certificate.
To be eligible for the sport pilot instructor certificate, the applicant must hold at least a sport pilot certificate with category and class ratings or privileges, as applicable, appropriate to the flight instructor privileges sought.
The applicant must have at least 150 hours total time and 100 hours of flight time as a PIC powered aircraft. That includes:
• 50 hours of flight time in a single-engine airplane
• 25 hours of cross-country time
• 10 hours of cross-country time in a single-engine airplane
• 15 hours of flight time as PIC in a single-engine airplane that meets the performance limits and design requirements of § 61.316
Several seminar attendees voiced concern about the manifestation of skill fade. DPEs have noted that in recent years the quality of private pilots trained by instructors with minimal experience who were also trained by instructors with minimal experience has resulted in a training culture in some places that is more focused on learning the check ride and getting the certificate to build hours and not necessarily building the experience to be a good teacher.
Compensation for CFIs With Sport Pilot Rating
Another confusing part of MOSAIC is that regulations state that sport pilots may not act as PICs of an aircraft carrying a passenger or property for compensation or hire or in furtherance of a business.
The exception is the flight instructor with a sport pilot rating who may receive compensation for providing flight training in accordance with 14 CFR Part 61 Subpart K.
