The background: The growing challenge of communication
The FAA justifies the decision with the effort and challenges involved in sending time-critical mail to international addresses. The required deadlines for the delivery of important information and documents could often not be met, which led to communication problems for licence holders and authorities. The new address requirement means that a „US agent“ is needed to act as the official postal address and represent the licence holder in the USA.
Who can act as a „US agent“?
Under the regulation, a „US agent“ is a US citizen over the age of 18 who is willing and able to receive and forward mail for the licence holder. For international licence holders who do not have personal contacts in the US, there are numerous service providers who offer this service for an annual fee of 50 to 200 US dollars. This makes it easier for pilots worldwide to access a US address without having to rely on personal connections in the USA.
The details: requirements for licence holders and possible consequences
The FAA plans to publish an Advisor Circular (AC) in the near future that will contain details on the implementation of this new regulation. This will describe the exact requirements for how and where licence holders must provide their US address. For licence holders, this means Anyone who does not provide a valid US address by 7 July 2025 will lose the right to use the licence and therefore may not exercise the associated rights.
Some important points for European pilots:
- N-registered aircraftAnyone wishing to fly an aircraft with US registration (N-registration) outside the USA generally requires a US licence. However, there is one exception: holders of a national licence (e.g. EASA) can only fly N-registered aircraft in their licence issuing country without a US licence. For example, if a German pilot wishes to fly an N-registered aircraft within Germany, this is possible with a German EASA licence. In other European countries, however, a US licence is required.
- Validated licencesEuropean pilots who have had their licence validated in the USA are also affected by the new regulation. Such validated licences are based on the validity of the respective EASA licence and are only valid as long as the European licence is also valid. The FAA also expressly requires a valid US address for these licence types.
Reactions and challenges for international pilots
The new regulations pose logistical challenges for many European and international pilots, as they now have to use the services of a US agent in order to retain their US licence. Especially for pilots who regularly operate international flights with N-registered aircraft or use their licence in international air traffic, the US address requirement could mean additional effort and costs.
The European aviation community has been partly critical of the regulation, as it represents an additional organisational hurdle for many pilots who hold a US licence. Pilots who do not have direct US contacts are dependent on fee-based service providers, which entails additional costs and administrative obligations. Given these challenges, it remains to be seen whether European aviation associations will take steps to offer support to affected members or find alternative solutions.
Outlook: What does the regulation mean in the long term?
This change on the part of the FAA marks a significant change for international licence holders and reflects the growing demand for fast and reliable communication between the authority and the licence holder. In the coming months, the FAA will further concretise the practical aspects of implementation. Pilots should inform themselves in good time and, if necessary, take appropriate steps to be able to continue to exercise their licence rights after 7 July 2025.
Source references:
Aviation magazine