TSA's Alien Flight Training/Citizenship Validation Rule FAQ

FAQ Categories

General

Are introductory or "discovery" flights exempt from the requirements of the TSA rule?

Yes. TSA has stated through correspondence with AOPA that introductory, discovery or demonstration flights are exempt from the requirements of the TSA rule.  However, AOPA suggests that you not log the flight time in a logbook until the CFI can verify citizenship.  Click here to print a first flight certificate.

What is the definition of flight training as it pertains to this rule for the purposes of needing to undergo citizenship verification?

The TSA has further interpreted the definition of " flight training "for aircraft with a maximum certificated takeoff weight of 12,500 pounds or less to only apply to training for a recreational pilot, sport pilot, or private pilot certificate; multiengine rating (at any certificate level — i.e., does not apply to MEI); or instrument rating (does not include recurrent training).

Do the requirements for citizenship verification apply for flight reviews, aircraft checkouts, or instrument proficiency checks?

No, TSA has interpreted the definition of " recurrent training" to NOT include any flight review, proficiency check, or other check required by 14 CFR § 61.57 or § 61.58 whose purpose is to review rules, maneuvers, or procedures, or to demonstrate a pilot's existing skills. The TSA has further interpreted the definition of "flight training" for aircraft with a maximum certificated takeoff weight of 12,500 pounds or less to only apply to training for a recreational pilot, sport pilot, or private pilot certificate; multiengine rating (at any certificate level — i.e., does not apply to MEI); or instrument rating (does not include recurrent training).

Do the requirements for citizenship verification apply to flight training in airships, balloons, or gliders?

No, TSA has granted an exemption for those schools that provide, and individuals who apply for, instruction in the operation of airships, balloons, or gliders. This exemption also exempts schools that only provide instruction in airships, balloons, and gliders from the security awareness training requirement.

I was approved by the Department of Justice (DOJ) Flight Training Candidate Checks Program (FTCCP); do I have to go through the TSA background check?

The AFSP (Alien Flight Student Program) requires candidates to submit a request for each instance of flight training. Although some candidates have received final approval in the past through the DOJ's Flight Training Candidate Checks Program (FTCCP), they must submit a request for approval of new training through the AFSP Web site.

Please note that any user ID and password that was created for the FTCCP Web site will work on the AFSP Web site; you do not need to create a new account if you already have one from the FTCCP.

Aliens

What applicant category do I qualify for?

Aliens seeking flight training in an aircraft with a MTOW of 12,500 pounds or less qualify as a Category 3 candidate. A brief explanation of the four categories:

Category 1 - Candidates who seek flight training in the operation of aircraft with a maximum certificated takeoff weight (MTOW) greater than 12,500 pounds, but who do not fall into Category 2.

Category 2 - Candidates who seek flight training in the operation of aircraft with a maximum certificated takeoff weight (MTOW) greater than 12,500 pounds, and who: Are employed by a foreign air carrier that operates under 14 CFR part 1546;  Have unescorted access authority to a secured area of an airport under U.S.C 44936(a)(1)(A)(ii),49 CFR 1542.229;  Are a flight crew member who has successfully completed a criminal history records check in accordance with 49 CFR 1544.230; or Hold an airman's certificate that is recognized by the FAA or appropriate US military agency, with a type rating for a multi-engine aircraft that has a certificated takeoff weight of 12,500 pounds or more.

Category 3 - Candidates who seek flight training in the operation of aircraft with a maximum certificated takeoff weight of 12,500 pounds or less for the following training events:

  • Initial airman's certificate, including a private, recreational, or sport pilot certificate.
    -- If a private and/or commercial license is the candidate's initial FAA license, it is considered an initial airman's certificate and is not exempt.
  • Instrument Rating (IR)
  • Multi-Engine Rating (MEL)

Each of these training events requires a separate training request. Note: Category 3 Rotorcraft Requirements - Candidates who seek flight training in the operation of rotorcraft with a maximum certificated takeoff weight of 12,500 pounds or less are subject to the above Category 3 clarification. Candidates must obtain approval for the initial license, instrument rating or multi-engine rating if the pilot does not hold a fixed-wing equivalent.

Category 4 - Candidates who seek recurrent training in the operation of aircraft with a maximum certificated takeoff weight (MTOW) greater than 12,500 pounds, and are current and qualified on the aircraft for which they are requesting training. These training requests are submitted by the flight training providers.

Am I required to resubmit fingerprints for taking additional flight training?

No.  If done correctly the first time, additional flight training does not require resubmitting additional fingerprints. However, you must use the same account (pin) number that you used for your initial flight training request in order for this exemption to apply.

If I transfer to a different flight school, do I have to go through this entire process again?

Yes.  However, you should not need to submit fingerprints. You will have to pay the $130 processing fee again.  If you are training with an independent flight instructor who does not work for a flight school and want to fly with another independent flight instructor, you will need to file an additional training request.

I am pursuing a U.S. pilot certificate at a flight school located outside the United States. Do I need to comply with this rule?

Yes. The rule applies to the issuance of a U.S. airman certificate at any flight school located in or outside the United States that is providing flight training under 14 CFR.

I am pursuing a U.S. private pilot certificate based on my foreign license. Am I required to comply with the TSA rule?

TSA has clarified that getting a U.S. certificate based on a foreign license ( reference FAR 61.75) does not apply to the requirements of the rule.  However, if you choose to apply for a “stand-alone” FAA pilot certificate no longer based on your foreign license, you must comply with this rule. The TSA views this as receiving an initial FAA pilot certificate and qualifies under the TSA definition of flight training.

Can an alien candidate register without a passport?

You are generally required to have a passport, but there are some people with very special circumstances who cannot obtain a passport. TSA will handle these situations on a case-by-case basis.

Does the TSA have any international locations for processing fingerprints?

In March 2005, TSA announced that certain international locations have been selected to process fingerprints for alien candidates. A list of participating airports is available at www.tsc-csc.com/printoffices/.

How long will it take to get an answer on my training request?

There are factors that affect the amount of time between training request submission and response, including:

  • Response time of your flight training provider.
  • Accuracy and completeness of your training request.
  • Nature of the request.
  • Category of the candidate.

Once my flight training request has been approved, how long do I have before my approval expires?

 Once you have permission to train, you have 180 days to begin training and 365 days to complete the approved training. These time periods both start from the date you receive approval.  For example, if you begin flight training 30 days after you have been approved, you now have 335 days to finish.  If you do not finish, a new training request must be submitted.

What can I do if my request was returned for insufficient information?

If your training request contains insufficient information required to make a determination on your request, you will receive an e-mail notification. You may return to this Web site, select the training request for which you received the e-mail notification, and review the information you provided for its accuracy and completeness. Make any changes needed, and resubmit your training request. On a resubmission, the flight training provider DOES NOT need to validate your request again, and you DO NOT have to pay another $130 USD processing fee.

What if I need to cancel my flight training request?

You may now cancel a training request that is in the Draft status by going to Step 7 of the request, clicking on the Edit link for that request, and clicking the "Delete Training Request" button.

I am pursuing a U.S. pilot certificate at a flight school located outside the United States. Do I need to comply with this rule?

Yes. The rule applies to the issuance of a U.S. airman certificate at any flight school located in or outside the United States that is providing flight training under 14 CFR.

U.S. Citizens

Do I need to show my birth certificate to a CFI for a flight review or IPC?

No you do not.  Flight reviews and IPCs do not fall under the TSA definition of flight training.  TSA has also interpreted the definition of recurrent training to “not include any flight review, proficiency check, or other check to review rules, maneuvers, or procedures, or to demonstrate a pilot’s existing skills on aircraft with a MTOW of 12,500 pounds or less”.

It is my understanding that the logbook endorsement requirement for U.S. citizens should be done anytime an instructor/flight school is presented with a new student who received a logbook endorsement from a different school and/or location. But for students who remain at one flight school throughout their training, and are known by all the instructors, a recurring endorsement is not necessary. Is this correct?

Yes, this is a correct interpretation. Think of the endorsement as a replacement of the copy of the proof of citizenship. If you had a copy of my birth certificate from private training, and now I want to do an instrument rating, no need to run a new Xerox copy just because I'm doing a new rating.

Flight Training Provider

Are flight schools and flight instructors located outside the United States affected by this rule?

Yes. The rule applies to any flight school or flight instructor certificated under 14 CFR that provides instruction in the operation of any aircraft or aircraft simulator toward the issuance of a U.S. airman certificate. This includes any flight school or instructor located outside the United States that provides such instruction.

I am an active flight instructor and an alien . Am I required to do anything different than instructors who are U.S. citizens?

No, nothing special is required. The requirements of the rule for flight schools and flight instructors still apply to you. This requires registering with TSA if you are giving flight instruction to other aliens, verifying citizenship for U.S. citizens, and completing initial and recurrent TSA security awareness training.

How do flight training providers outside the United States verify their registration with TSA?

For providers outside the United States, you will need to validate with an international FSDO office (IFO). There are IFOs in New York, New York; San Francisco, California; and Miami, Florida. Please contact the nearest IFO to you and inquire whether that office can process your request for a provider account on AFSP. If you use the New York IFO, please select the New York IFO (EA29) as your FSDO option and "New York" for your state location. If you use the San Francisco IFO, please select the San Francisco IFO (WP03) as your FSDO option and "California" for your state location. If you use the Miami IFO, please select the Miami IFO (SO23) as your FSDO option and "Florida" for your state location. Once the IFO validates your request, you will be sent a password via e-mail.

How do I upload and submit a candidate photograph?

Candidate photographs must be taken when a candidate arrives for the first day of flight training. The provider, through the "Photograph Upload" link, should upload these photographs through the AFSP Web site. TSA guidelines for taking photographs are provided on the photograph upload page within the AFSP Web site.

What is a provider admin? What is a provider agent?

A provider admin is the administrator of a flight training provider account. Only one provider admin is allowed per flight training provider. The administrator user ID has access to all of the same screens and functionality as the provider agent but is also able to change flight training provider information, such as the telephone number of the school. Each school MUST have one provider admin.

A provider agent is the standard flight training provider account. This type of account allows the user to validate candidate requests, submit and review Category 4 candidate information, upload candidate photographs, and mark candidate training requests as completed. The provider agent account does not have access to change school information. A school may have any number of provider agents, including zero.

I am registered with a Part 141 (Part 142) school as a provider agent but teach part-time as a CFI (Part 61) provider. Do I register as a provider admin or agent?

Flight instructors who are registered with a Part 141 or Part 142 school should be registered as a provider agent for that school. The schools may have only one provider admin, which is generally an administrator at the school. By registering as a provider agent to the Part 141 or 142 school, flight instructors may validate candidate requests for their students at the school.

CFIs or Part 61 providers who do not have FAA school certification numbers must sign up as individual flight training providers. In this case, each instructor would sign up as a provider admin. For instructors who teach within a Part 141 (Part 142) school and also teach separately as a CFI (Part 61) provider, the instructor should sign up as a provider agent within the Part 141 or 142 school AND as a provider admin for instruction on a CFI (Part 61) basis. The instructor will validate candidate requests for the Part 141 (142) school separately from the CFI (Part 61) instruction.

What is the flight training provider's responsibility if a candidate is denied?

The flight training provider may not provide training to a candidate who has been denied by the AFSP. If the flight training provider has already initiated training for a candidate, and TSA notifies the flight training provider that the candidate poses a threat to aviation or national security, the flight training provider must stop the training immediately. TSA will contact the flight training provider both electronically (e-mail) and by telephone and provide further instructions.

It is my understanding that the logbook endorsement requirement for U.S. citizens should be done anytime an instructor/flight school is presented with a new student who received a logbook endorsement from a different school and/or location. But for students who remain at one flight school throughout their training, and are known by all the instructors, a recurring endorsement is not necessary. Is this correct?

Yes, this is a correct interpretation. Think of the endorsement as a replacement of the copy of the proof of citizenship. If you had a copy of my birth certificate from private training, and now I want to do an instrument rating, no need to run a new Xerox copy just because I'm doing a new rating.

Security Awareness Training

Does AOPA have a course that satisfies the requirement for initial and recurrent security awareness training?

Yes, AOPA worked with the TSA to create an online course for initial and recurrent security awareness training. If the course is used for recurrent training, you will need to review new security measures at your flight school, and any security incidents at the flight school and lessons learned as a result. Training can be completed the month before, during, or after it is due. Keep the certificate for your records and be able to produce it upon request.

TSA's security awareness training document is required to have a distinct identification number and also indicate whether or not the training is initial or recurrent. Neither of these is provided on the TSA security awareness training certificate. What should I do?

After rechecking the rule and with our Chief Counsel's Office, here's what we have regarding the identification number:

  • Under 1552.25(a), a flight school must issue a document to each flight school employee each time the employee receives training (initial and recurrent). Paragraph (a)(1) requires the document to contain the employee's name and a distinct identification number.
  • The purpose is for TSA auditors to be able to better track/identify employees who have received the training. TSA does not provide the identification number. The flight school should make up a numbering system for employees or use any employee numbering system that the school already uses to identify employees.
  • The school is also free to note initial or recurrent training on the certificate for their record-keeping purposes.

I am having a problem printing TSA's security awareness training certificate after I completed their online course; what should I do?

You may obtain a certificate from AOPA [independent CFI ( PDF document); CFI/employee of a flight school ( PDF document) and keep this for proof of complying with the security awareness training requirement. Be sure to include the information outlined under 49 CFR 1552.25(a)(1-7) on the certificate.  You may also elect to endorse your logbook or other permanent records with the wording provided on the certificate that applies to you.

I am a CFI only teaching ground school, do I need to meet the security awareness training requirements?

Yes, as an active ground school instructor who has direct contact with flight students, you are required to complete initial and yearly recurrent security awareness training. 

Is a flight instructor who is not actively instructing required to take the initial security awareness training, and then continually undertake the recurrent training if they remain inactive?

TSA has clarified the applicability of the security awareness training. Current and active instructors must take the training. However, current and inactive instructors are not required to take the training, but it is recommended. Expired instructors are not required to complete the training.

With regards to the security awareness training, can you please tell me if the TSA's online training can be used again for recurrent training?

It is not the intent of TSA for the initial training to be used repeatedly. The requirements for recurrent training differ greatly from initial (they are much less centered on the awareness portion, and more on actual security events or changes to procedures at the airport or facility), as laid out in 49 CFR 1552.23. There is nothing to prevent a training provider from using the initial program as part of recurrent, but completing that only would not fulfill the requirements for recurrent training under 1552.23 because of the difference in content requirements for initial and recurrent.