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The MOSAIC Loophole That Isn’t

By Jamie Beckett · February 24, 2026 · 12 Comments

A flight review in a Cessna 152 is different under the new MOSAIC rule. (Photo by Acroterion via Wikimedia)

In October 2025 something wonderful happened in aviation. The MOSAIC rule went into effect. The new Modernization of Special Airworthiness Certification rule, which is, in truth, a broad collection of regulatory changes, is arguably the most profoundly sweeping development in general aviation over the five decades I’ve been involved.

This is big stuff. Really big. And almost entirely positive from my perspective.

Yet big changes require some time to filter down through the various entities involved in any endeavor. That’s certainly proving to be true of MOSAIC.

Let me give you an example that might be pertinent to your life and aeronautical pursuits.

While spending time in the high school aero club’s hangar here at my home base, I met a young flight instructor. He’s sharp. He’s committed. The man has ambition and drive and a real dedication to procedure and establishing a culture of safety. I like all that. He’s also new to the game. And like all of us who are new to anything, there are some fuzzy spots in his understanding of the big picture.

That’s okay. He’s trying. He’s learning. As he should.

We chatted amicably in the hangar. Surrounding us was a collection of teenagers taking their best shot at re-covering a Piper Cub or riveting together the various components of their two Zenith 750 projects. As they worked and we oversaw their efforts, we got on the topic of flight reviews.

Flight reviews have always been a favorite activity of mine, both as a client and as an instructor. They appeal to me for a variety of reasons. Every pilot is different. They have different goals. Their areas of expertise vary, as do their areas of ignorance. We can all benefit from gaining a new perspective or learning a new skill. And the opportunity to fly with folks I’ve never flown with in a wide assortment of aircraft has never gotten old for me. I suspect it never will.

“I’ve got a client who wants to get his flight review done,” my young friend said. “But he needs to get his medical renewed first.”

“What kind of airplane are you going to be flying?” I queried.

“The 152,” he replied, indicating the pristine Cessna resting in the corner of the hangar.

Seeing an opportunity to shed a little light on a new and often misunderstood rule, I offered.

“He doesn’t need a medical to do a flight review with you in that. The MOSAIC rule allows a sport pilot to fly a Cessna 152 without a medical. All he needs is his FAA certificate and his driver’s license.”

The young CFI looked at me with an expression suggesting he’d just realized how monumentally dumb the ancient boomer in front of him truly was.

“The problem is,” he said, “my client isn’t a sport pilot. He’s a private pilot.”

And there it was. Disconnect complete. My new young friend was fully certificated, highly motivated, perfectly professional in his demeanor and outlook. Yet he was not connecting the dots of the regulations he’s committed to complying with.

I explained that even an ATP can choose to exercise the sport pilot privileges of his or her ATP certificate. Any one of us has that option. In fact, many of his peer group, commercially rated CFIs with an eye on being picked up to fill a seat in an airliner, do this self-downgrade without even realizing it.

Like my young friend, I too am a commercially rated CFI. But when I launch off in a single-engine, piston-powered fun machine with my wife by my side, I’m not operating as a commercial pilot. I’m choosing to exercise the private pilot privileges of my commercial certificate. I only need a third-class medical to make that flight. Or I can choose to operate under BasicMed. Or since I’m only carrying one passenger and flying an airplane that stalls at 59 knots or less (which includes a significant portion of the GA fleet), I can opt to take the sport pilot route.

When flying with my wife, or one of my kids, or a friend who wants to experience general aviation for themselves, I don’t need the second-class medical required of a commercial pilot. The simple reason is because I’m not acting as a commercial pilot. I can fly if I meet the private pilot or sport pilot standards. Yippee!

It’s not a loophole. It’s a regulation. MOSAIC has given us a whole new lease on personal flying adventures.

The truth is we enjoy such incredible freedom to fly as we choose, to the destinations we wish, in the aircraft we opt to pilot, it’s actually difficult for some of us to recognize the full breadth of our bounty. That was very much the case with my new young friend — as it is with a large percentage of the pilots I engage with.

Fortunately, my new CFI friend picked up on the nuance of the situation quickly. He’s now locked in and ready to roll with valuable information he can use to market his services. I suspect there are a good number of mom and pop flight schools and rental operators that could benefit from recognizing their good fortune, too.

Better yet, now you have some rock solid information to throw in your own flight bag — something to consider for future flights.

The rules are always changing. Sometimes those changes irk us. More often than not they make us safer — or at least that’s the intent of the new rules.

In the case of MOSAIC, the new order brings us privileges we’ve always enjoyed with fewer limitations than we’ve ever had. This is a good thing. No, it’s a great thing.

May the Sport be with you. Now and forevermore. Even if you sometimes captain a widebody transport across oceans and continents. It’s the FAA’s gift to all of us.

About Jamie Beckett

Jamie Beckett is the AOPA Foundation’s High School Aero Club Liaison. A dedicated aviation advocate, you can reach him at: [email protected]

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Comments

  1. James Craig says

    March 1, 2026 at 7:20 am

    It seems the snag is with the insurance companies whose policy requires a valid medical certificate—the driver’s license medical is NOT a medical certificate and they may not cover the aircraft. I am a retired, highly experienced ATP rated pilot who used Basic Med to continue to fly, but let that expire as I thought my recreational flying was now allowed under the sport pilot rules. A flight school in southern Illinois would not rent an Archer as they did not believe their insurance would cover the flight.

    Reply
  2. Jeff Edwards says

    February 28, 2026 at 5:38 am

    Get Basic Med now… you can hold both an FAA medical and Basic Med. If you ever have a medical concern in the future or are on special issuance now and it gets harder to maintain SI then let your FAA medical expire and continue on Basic Med.

    Reply
  3. Eric Taylor says

    February 25, 2026 at 7:54 am

    I am surprised how many pilots and even CFI’s do not understand BasicMed, even though those rules have been in place since 2017. Specifically, several people I’ve talked to about it think they just need to have a doctor fill out the BasicMed exam form, and they’re good to go– they don’t understand that taking an online quiz after the exam (and again after two years) is also required.

    Reply
    • Jerry says

      February 25, 2026 at 5:41 pm

      Hi Eric
      Go to Rainbow Aviation website and read the link that is the LSRIA that is for an LSA Repairman Inspector course. This is not the full 15 day Repairman Course but an 2 day inspector authorization. That will explain the new MOSAIC rule that will add the E-AB you own but not built to the LSA Inspector Authorization. That would include a Lancair Legacy you bought for example. The FAA is lagging a little in paperwork update but as of Oct 22/2025, it was effective.

      Reply
  4. Joe Reid says

    February 25, 2026 at 6:44 am

    Ok I am a little confused. I understand the whole 3rd class when not for hire and even ferrying a 135 aircraft under 91 rules, but I do have to ask about this sport pilot thing. I am a commercial instrument amel, asel, rotorcraft helicopter rated pilot and most of my career has been as a 135 pilot. Yes I came up through the ranks starting with private. I understand with the private in the past I can choose to operate as a private not as a commercial pilot. But if I never had a sport pilot rating and in my retirement years I am just flying for pleasure can I still operate as a sport pilot having never had that rating when I take my biannual check ride? And will it still count if I decide to go back to work flying as a PIC?

    Reply
    • Rich says

      February 25, 2026 at 7:03 am

      Yes, that was the whole point of this article.
      In fact I am 99% certain the would be “student” in the article doesn’t need a medical at all to take a BFR in a almost any single engine aircraft because he isn’t acting as pilot in command, the CFI would be, Yes?

      Reply
    • Jamie Beckett says

      February 25, 2026 at 8:04 am

      Yes, Joe. As the article says, a pilot with a private, commercial, or ATP certificate can choose to operate using the privileges provided by a lower certificate. This means a commercial pilot can operate as a private or a sport pilot if they choose to. However, when operating as a private pilot or sport pilot you are bound by the limitations those certificates come with. It’s an easy downgrade for anyone who wishes to temporarily or permanently utilize the benefits of sport or private privileges.

      Reply
  5. jerry says

    February 25, 2026 at 5:03 am

    I agree. I am astounded as to how misunderstood the key elements of MOSAIC really are.
    Another one is that with a 16 hr course you can do your own annual “Condition Inspections” on any E-AB aircraft you own, even if you did not build it.
    Here is the disappointing capper though. The insurance companies will be the ones to control who flies under MOSAIC without a medical and if you are gray beard, brace yourself for a future requirement to have a non FAA physical exam. I received a letter from my insurance carrier NOT to assume that I can continue as normal with my flying and let my current medical lapse assuming I am okay with the FAA under MOSAIC.
    They will decide. Citing the use of a medical in lawsuits when settling a claim is a requirement for them. I could see this coming a mile away years back. There is no free lunch.

    Reply
    • Barbara Fioravanti says

      February 25, 2026 at 5:57 am

      Absolutely true. I used to fly my Lake Amphibian under BasicMed. then I turned 80. My old aircraft insurance company would only cover me (even for liability only) if I was accompanied at all times by a pilot meeting their standards. The only company that would cover me at all requires an FAA Clas III medical every year. Never mind that it provides no additional level of safety based on actual statistics. So all these wonderful (and they truly are) advances in reality-based regulations are moot if you want to insure your airplane.

      Reply
    • Eric Taylor says

      February 25, 2026 at 10:36 am

      Jerry- it was my understanding that taking the repairman course authorized you to inspect an E-LSA, but not an E-AB. Apparently that has changed. Can you provide a link to the new reg that you cited? Thanks.

      Reply
  6. ET says

    February 24, 2026 at 7:16 pm

    Great reminder for all of us, Jamie. Thank you!

    Reply
  7. Jason Blair says

    February 24, 2026 at 7:14 pm

    A great scenario question would be future CFIs might want to brush up on for CFI checkrides now that MOSAIC is fully implemented. Just saying! 🙂

    Thanks for sharing this point!

    Reply

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