SFAR Grants Relief for Expired Medical Certificates and Recency Requirements

In response to the COVID-19 pandemic, the FAA has issued a Special Federal Aviation Regulation (SFAR) the extends the duration of medical certificates to all pilots.  It also provides relief from recent flight experience requirements, but only to certain pilots and operations. The FAA emphasizes that apart from the limited relief provided by the SFAR, pilots must continue to comply with all FARs applicable to their flights.


Airmen with any class of medical certificate that expires between March 31, 2020 through May 31, 2020 is now valid through June 30, 2020.

This is an important change from the previous statement in which the FAA announced that it would not take enforcement action against pilots who operate aircraft with a recently expired medical certificate.  That placed the pilot in jeopardy of not having insurance coverage if their policies specifically required a valid medical certificate as a condition of coverage.

Now, this is no longer a concern because the SFAR explicitly states that the medical certificates remain valid during this period.


  1. The FAA has granted some relief from recency requirements to, “. . . flight[s] to transport essential goods and medical supplies to support public health needs”.

This appears to apply whether or not the pilot is flying at the request of a volunteer pilot organization (VPO), however, the pilot must meet the following requirements:

(iii) The person has at least 500 hours of total time as a pilot, that includes at least 400 hours as a pilot in command and at least 50 hours that were accrued within the preceding 12 calendar months, and the person is conducting one of the following operations consistent with the compensation or hire prohibitions specified in § 61.113.

  1. With respect to other charitable flights, only to pilots conducting a charitable medical flight on behalf of a volunteer pilot organization that has been issued an exemption allowing fuel reimbursement.  The flight must also be conducted in accordance with the requirements of that exemption.

Please check with your VPO as they have their own requirements for pilots and may or may not allow non-current pilots to accept missions, despite the FAA’s dispensations.

There are detailed requirements for each aspect of recent flight experience.  Therefore, please consult the SFAR to address your specific situation.

Although Air Care Alliance cannot give specific legal advice, we would gladly address your general questions. Email us at info@aircarealliance.org.