The rule changes implemented Oct. 22, 2025, by MOSAIC, known as Sport Pilot 2.0, included a condition inspection option for owners of experimental amateur-built (E-AB) aircraft.
According to officials with the Experimental Aircraft Association (EAA), E-AB builders with repairman certificates and certificated FAA mechanics, as well as holders of light-sport aircraft repairman certificates with an inspection (LSRI) or maintenance (LSRM) rating may now perform condition inspections on E-ABs.
“Contrary to what the names of these certificates may suggest, these privileges apply to all E-ABs, whether or not they meet the updated parameters for light-sport category aircraft,” EAA officials said.
The LSRI certificate can be obtained through a 16-hour course and applies to aircraft the holder owns. The LSRM certificate, which can be earned through a three-week course, grants commercial maintenance and inspection privileges for any aircraft certificated in the light-sport category, as well as any E-AB.
“These are welcome options for many E-AB owners who, unlike experimental light-sport aircraft (E-LSA) owners, cannot obtain inspection privileges for their own aircraft if they were not the original, primary builder,” association officials said. “EAA has long advocated for these privileges and was pleased to see them included in the final MOSAIC rule.”
A Barrier Remains
One barrier remains for many E-AB owners: Operating limitations.
No matter what the regulation provides, experimental aircraft operating limitations take priority and have the force of regulation under 14 CFR 91.319(i), according to EAA officials.
Most aircraft certificated after, at the latest, 1994 have an operating limitation stating that condition inspections may only be performed by amateur-built repairmen, an FAA-certificated mechanic, and in some cases repair stations. LSRI and LSRM do not fall into these categories, EAA officials noted.
“Carefully review your aircraft’s unique set of operating limitations, as there can be significant variation from aircraft to aircraft, particularly older aircraft certificated when standardized limitations were less common,” officials said.
In cases where this operating limitation exists, E-AB owners will need to obtain new operating limitations to take advantage of the new LSRI and LSRM rules. This is a paperwork exercise with either the owner’s local FSDO or a designated airworthiness representative (DAR).
“Complicating the matter, however, is that the document detailing these new operating limitations is yet to be published due to the ongoing shutdown of the federal government,” EAA officials said. “Order 8130.2L will contain this new guidance to inspectors and designees, but it is not officially an active document. We anticipate this being resolved shortly after the shutdown ends.”
EAA officials recognize that many owners of experimental aircraft are wary of updating their operating limitations.
“This is understandable, as standard operating limitations change from year to year,” they said.
EAA recently compared operating limitations issued in FAA Order 8130.2C (1994-1999) to 8130.2K (2024-present) and found that for most aircraft there was little fundamental difference. Some special cases, such as turbine aircraft, may have more restrictions in newer versions, while some operating limitations have actually become more flexible in newer versions, they said.
“EAA is exploring other methods for enabling LSRI and LSRM to perform inspections on E-ABs. For the foreseeable future, however, an operating limitation update is necessary if the restriction exists.”
“For owners concerned about updating to the latest version of operating limitations, EAA highly recommends carefully comparing the aircraft’s operating limitations to those found in the current revision of Order 8130.2, and the new version when released, before deciding,” they concluded.
For more information: EAA.org/EAA/MOSAIC-Aircraft-Certificate
As an “old school” A&PIA and former part 147 DOE (Director Of Education) I am looking forward to this program. The similar Canadian owner maint program appears to have been successful I do have a few qualms, until I see the content and depth of the two training courses. An A&P program under part 147 requires a mandatory 1,820 hrs of pretty heavy duty training. I’m somewhat skeptical that the ‘average’…. Owner, non builder, can become that ‘good’ in sixteen hours or three weeks in the case of a commercially viable inspector. Still, I have faith in the program. It should make flying more affordable and get folks more invested in their aircraft, both are great pluses.
I’ll see if I can address Terk’s comment with some “north of the border” perspective.
Owners of Amateur-Built aircraft in Canada are and have been responsible for maintenance of their aircraft. In this respect MOSAIC is much more like the Canadian A-B rule set than the Owner Maintenance category.
I’m deeply involved in both the A-B and certified aircraft worlds, holding a Canadian Aircraft Maintenance Engineer license as well as holding delegation from Transport Canada in a role very much like the FAA DAR as well as being an EAA Tech Counselor.
In working with many, many aircraft owners I’m seeing a consistent trend. Owners want to be more involved. They want to be better educated. They want to be the engine that drives safety into their flight operations.
The frequency with which I receive requests for maintenance assistance is encouraging. Everything from “will you let me watch you do your annual” to “will you come guide me through my annual inspection” is featured in the request list. Often times I’ll get a simple text message asking a simple technical question. This is what I see as a vital flow of information – from those with knowledge and experience to those who acknowledge they lack that knowledge and experience.
No matter the regulatory backdrop, we will always see a broad spectrum of human behaviors. We have seen the one extreme in terms of maintenance in commercial operations. We see homebuilts that look like they were prepped with the rigors of NASA for space flight. We see everything in between. I’m personally encouraged by the level of responsibility which I see many Canadian aircraft owners taking in maintaining their aircraft. With this in mind I’m certain MOSAIC will bring huge benefits to US aircraft owners.
As a sidebar conversation, wouldn’t it be a treat if we were able to inspire some cross-border reciprocity such that Canadian aircraft in the Owner Maintenance category might be able to fly in US airspace?
The new MOSAIC rules. will be good for G/A and allow the costs for obtaining a Pilot Certificate or performing maintnenance and inspections on light sport aircraft by the owner to be more affordable..
So let all get out there and go to an FBO and start that light sport certificate or get the training to be able to work on their own aircraft……
Our legacy aircraft will still need an FAA certificated A&P as well as an IA to annual them, however those aircraft owners can still perform preventive maintnenance on these aircraft….
All I can add is to bad the FAA did not do this 20 years ago when light sport aircraft first hit the market. However, that is another story….