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MOSAIC Simplified

By Jamie Beckett · April 23, 2026 · 15 Comments

(Graphic by Dan Johnson)

When you were a child it’s entirely possible that you played a game with friends called “telephone.” The object of the game was for the first player to whisper a simple message to the second player. The second player would whisper the message to the third player and so on until the last player had received the message.

Not surprisingly, when the last player announced the message they’d received, it had little in common with the original message sent. This is because each player put a slight modification into the message, altering it just a bit. Little by little, the original message was completely lost as it was incrementally modified, then replaced by one that was virtually unrecognizable.

This is why it is so critical to go to the source when trying to understand information that has an impact on legality or safety of operations, especially in aviation.

The introduction of the MOSAIC rule (Modernization of Special Airworthiness Certification) from the FAA has suffered from the same fate as the messages sent through that children’s game all those years ago. Slight misunderstandings have exploded into massive misconceptions about what MOSAIC is, what it isn’t, and how each of us can work within its framework.

Considering the final rule for MOSAIC clocks in at more than 700 pages, few of us actually sit down and read the whole thing. Yet if we hold an FAA certificate, we may find it beneficial to understand the rule as it was passed down to us. It offers tremendous privileges, but also comes with some very specific limitations.

In the interest of clarity, let’s simplify a bit.

MOSAIC involves four distinct areas of general aviation. They are, in no particular order:

  1. Sport Pilots
  2. Light Sport Category Aircraft
  3. Maintenance and Repairmen (limited to Light Sport Category Aircraft)
  4. Operations

In the interest of brevity and clarity, we will limit our scope here to pilots and aircraft. Maintenance and Repairmen deserve sufficient space of their own to spell out the changes. Operations can best be handled as a separate topic as well. Look for more on those in upcoming posts.

Sport Pilots

Individuals who hold an existing pilot certificate have been mightily confused about if they can or how they might operate as a Sport Pilot should they choose to take that route. The process is actually quite simple. In fact, it shares a great deal of commonality with pilot privileges that existed prior to MOSAIC coming into effect.

Consider this example. You are a current commercial pilot or an ATP. One day you invite your spouse or a friend to fly off to an airport 75 nautical miles distant to have lunch at a favorite restaurant. You choose to rent a single-engine airplane from the local FBO, a Piper Warrior perhaps. That’s entirely legal.

A Piper Warrior aircraft takes off at Delaware Airpark in Cheswold, Delaware. (U.S. Air Force Photo by Roland Balik)

As you fulfill your PIC duties on this flight, you are not acting as a commercial pilot or an ATP. Rather, you are exercising the private pilot privileges that exist under your commercial or ATP certificate. You do not need a first or second class medical certificate to conduct the flight, because private pilots are not required to hold a first or second class medical. You’re good to go with a third class or even as a participant in BasicMed.

That same principle is in effect for pilots who hold a private, commercial, or ATP certificate but wish to operate as a Sport Pilot on a given flight. They can act as PIC of a qualifying aircraft with no medical at all, because Sport Pilot requirements do not mandate pilots hold a medical. All you need to do is be current, hold a Sport Pilot certificate or higher, and self-certify your medical fitness by carrying your state issued driver’s license.

The caveat to this is that your medical certificate must not have been denied or revoked. If your first class medical lapsed and reverted to a second class, then a third class, then expired entirely, you can still operate as a Sport Pilot in good standing. You only have to limit yourself to operating aircraft that a Sport Pilot certificate would qualify you to fly. 

Light Sport Category Aircraft

While we may have become accustomed to the term LSA, which translates to Light Sport Aircraft, there is now a new term for us to consider: Light Sport Category Aircraft.

MOSAIC removes many of the restrictions on these aircraft, updating and expanding them considerably. The old weight limit of 1,320 pounds is gone. The limitation that restricts aircraft to just two seats is similarly out the window. And, believe it or not, Light Sport Category Aircraft now includes rotorcraft and powered-lift vehicles, as well as airplanes, weight shift control aircraft, and gliders.

This is where things can get confusing, but they don’t have to. Specifics matter and in the realm of Light Sport Category Aircraft and Sport Pilots, knowing what’s acceptable and what’s not makes a world of difference.

As a Sport Pilot, or a higher-level certificated pilot who wishes to exercise the Sport Pilot privileges of their certificate, the limitations on what they can fly has been expanded dramatically, but not without limits.

There is no longer a weight limit or a speed limitation for the aircraft Sport Pilots can fly. Rather, there are performance limitations. Vs1, the stall speed in a clean configuration, must be 59 knots calibrated airspeed or less. The Sport Pilot is still limited to carrying just one passenger, but the aircraft may have up to four seats.

With additional training and appropriate endorsements, the Sport Pilot may fly aircraft with a controllable pitch propeller and retractable landing gear. Even electrically powered aircraft are now included in the mix.

This means popular aircraft such as the Cessna 152, C-172, Piper Cherokee, and Warrior are available to Sport Pilots now. The C-182 and some Beechcraft Bonanzas may qualify. Simply verify the clean stall speed in CAS (calibrated air speed) as 59 knots or less and off you go.

Under MOSAIC, Sport Pilots can now fly Cessna 172 Skyhawks. (Photo by Hayman Tam)

For pilots with higher level certificates who wish to operate as Sport Pilots on a full-time basis, or just occasionally, the freedom this option presents is tremendous. There are no additional tests to take. The FAA doesn’t require any special notification to be made or unique record-keeping files to be maintained.

For pilots who hold a Sport Pilot certificate, the number and variety of aircraft available to them has expanded beyond what was rumored or anticipated.

However, one common misunderstanding of MOSAIC is that Sport Pilots will be able to fly multi-engine airplanes. That is not the case. Multi-engine aircraft are mentioned specifically in the MOSAIC document. However, that reference is to eVTOL and powered-lift aircraft, not multi-engine airplanes. 

Beyond Sport Pilot

The general aviation pilot population can celebrate with enthusiasm that Sport Pilots can fly a wide assortment of aircraft under MOSAIC. However — and it’s a big however — there is a wrinkle in the definitions and limitations that must be understood to stay on the sunny side of the FAA.

While Sport Pilots, or pilots with higher level certifications who wish to operate as Sport Pilots, can fly airplanes with a clean stall speed of up to 59 knots CAS, not all Light Sport Category Aircraft will be limited to that number.

This presents a potential challenge to those who operate as Sport Pilots.

On July 24, 2026, the term “Light Sport Aircraft” will be removed from the definitions section of the FARs. It will be replaced with the term “Light Sport Category Aircraft.”

Light Sport Category Aircraft may be certified with a Vso (dirty stall speed) of up to 61 knots CAS. That means that while Sport Pilots and those acting as Sport Pilots can fly Light Sport Category Aircraft, they cannot fly all Light Sport Category Aircraft. Those with a clean stall speed greater than 59 knots CAS will require a private pilot certificate or higher to act as PIC. 

The Upshot

All in all, MOSAIC has brought us a remarkable gift: Fewer limitations, enhanced privileges, and a far wider selection of aircraft for pilots to choose from. Earning a Sport Pilot certificate is significantly less time-consuming and far less expensive than obtaining a private pilot certificate — a fact that should bring a great many new pilots into the industry in the coming years.

These liberties will also make it possible for experienced pilots, also known as old folks, to remain in the left seat with less expense and fewer hassles. This makes it possible and even desirable for aircraft owners and renters to remain active as long as they fly appropriate aircraft and carry no more than one passenger at a time.

Of course, there are a great many nuances to the rule beyond those expressed here. For those you may wish to curl up on the couch, grab a favorite beverage, and plow through the full 700 plus pages of the ruling yourself. Or you could just verify the simplified version presented here and conduct yourself accordingly.

You can read the full ruling at FAA.gov.

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. Robert Russell says

    April 24, 2026 at 8:43 am

    Over the months since the implementation of the Regulations. I have been contacting and visiting Flight Schools and Flying Clubs in northern NV. Have a Private Pilot Certificate. Instrument Rating. Medical not current. Some were unaware of MOSAIC. Some did not even want to discuss anyone flying under MOSAIC. Citing insurance issues. At least one Flight School at Reno-Tahoe International spoke with their insurance carrier. I can take lessons with them in their fleet of Pipers. But I cannot rent and fly solo.

    I have spoken with folks at EAA and AOPA regarding the matter. They noted the problem appears to be in certain regions of the U.S. That eventually insurance carriers will come around. Same occurred with implementing Basic Med. My take is during all the discussions between the parties to establish MOSAIC. The insurance industry might not have had a seat at the table.

    Reply
  2. iTerk. (Terk Williams) says

    April 24, 2026 at 6:45 am

    MOSAIC has brought about some excellent opportunities. There are, as you pointed out, some minor wrinkles. I recently was made aware of one of those “wrinkles”. As a current CFI, If I use just my drivers license as my medical, any instruction where I am PIC the pilot under instruction can only log sport pilot time , i.e. what was intended to be private pilot instruction. If I’m giving a flight review with a certificated pilot but one with lapsed medical I become PIC. That puts the level of that review for the PUI at the sport pilot level? and the mud thickens…. Excellent program, just with a few wrinkles we need to be cautious of.

    Reply
    • Carlos Rodriguez-Botet says

      April 24, 2026 at 1:03 pm

      Please explain what you mean by “sport pilot time” because all flight time is flight time. When they created the sport pilot certificate back in the day, they even let you claim all ultralight flight time toward your total flight time, and ultralights weren’t even aircraft.

      Reply
      • Jamie Beckett says

        April 25, 2026 at 10:39 am

        Ultralights definitely meet the FAA definition of an aircraft. A device that is used or intended to be used for flight in the air.

        Reply
  3. rwyerosk says

    April 24, 2026 at 5:44 am

    I would like to add that the above situation happened to me on my 28th Flight review with a CFI-S Flight instructor.

    Fortunately for me I have only flew for currency and have not instructed anyone……

    All those other instructors out there are in violation of issuing FRs, IPC and Certificate and Ratings that are now invalid ……and in violation…..

    Add an accident to the mix and now there are legal problems for everyone involved…..

    WHAT DO YOU THINK JAMIE………………????

    Reply
  4. rwyerosk says

    April 24, 2026 at 5:34 am

    I. wonder how many CFI-A(h) instructors did not realize that if they flew with a CFI-S light sport flight instructors for the Flight Review is a problem???

    A CFI-A would then not be authorized to instruct above a Light Sport Aircraft Certificate.

    So, if the CFI-A was unaware of this, he/she would be in violation …..

    I wonder how many CFI-A instructor realize this.

    Ironically no one would know this until there is a problem, like an accident or FAR violation.

    Currently FAA requires only a log book entry for a FR or IPC…..A DPE would not know the issuing instructor for a Private or Commercial is not qualified ?

    Sound confusing???

    No one knows how many CFI-A instructors have take a FR with a CFI-S instructor….

    Confusing? A problem?……..??

    Reply
    • Jamie Beckett says

      April 24, 2026 at 8:05 am

      This is new territory but I’m not sure it’s as complex or confusing as you might think. A private pilot or commercial pilot can participate in a Flight Review while exercising the Sport Pilot privileges of their higher level certificate, provided they fly in an appropriate aircraft. Just as a commercial pilot has always had the ability to participate in a Flight Review while exercising the private pilot privileges of their commercial (or ATP) certificate.

      You are correct that a Flight Instructor with a Sport Pilot rating cannot provide a flight review to a private or higher certificate level pilot in an airplane that does not meet the sport pilot aircraft options, but the flight instructor never had that option, so it’s not really much of a change in that case.

      Reply
      • John Hunt Weber says

        April 24, 2026 at 12:46 pm

        Hi Jamie. There is confusion. I have a CFI-Sport. I gave a flight review to a regular CFI a few months ago. Now someone I give a flight review to can only exercise sport pilot privileges. If he is am MEI, then he would need an additional flight review before he could legally instruct. Previously it was believed that a flight review was a flight review and good for all aspects, like an ATP getting a flight review in a J-3 cub and being good for whatever. No longer the case.

        Reply
  5. John Hunt Weber says

    April 24, 2026 at 5:19 am

    And still many flight schools want NOTHING to do with Sport Pilots. Some claim insurance reasons, some look down on Sport Pilots as not real pilots. Personally, I think this is a major revenue source for a flight school if they pursue it. I think a large percentage of students want training just to fly-not necessarily to make it a career.

    Reply
    • rwyerosk says

      April 24, 2026 at 5:49 am

      John

      As An ATP,CFI/A&P/IA I cannot understand why the FAA does not allow CFI-S instructors to do Flight reviews……

      I am also a former FAA inspector and this situation is not acceptable and FAA needs to fix it …….

      Light Sport CFIs under go a lot of training to be an instructor to teach flying and solo students. IMO they should be authorized to issue a FR to anyone…..
      Regards….

      Reply
  6. Douglas says

    April 24, 2026 at 5:14 am

    Jamie,
    The last paragraph under “Beyond Sport Pilot” should state that a private pilot or higher needs a current medical to fly an aircraft with a CAS of over 59 knots.

    Reply
    • Darrell Hay says

      April 24, 2026 at 7:11 am

      Or Basic Med, which technically is not a “Medical”. Or if it is a glider……seems like this is never easy is it?

      Reply
  7. Gary Schaffer says

    April 24, 2026 at 4:30 am

    Unfortunately, the insurance companies seem to have a lot to say about who can and cannot operate under the MOSAIC rule.

    Reply
    • John Hunt Weber says

      April 24, 2026 at 5:20 am

      I feel insurance companies have a good chance of “strangling” MOSAIC.

      Reply
      • ET says

        April 24, 2026 at 8:48 am

        Similar to how they are ‘strangling’ everything else?

        Reply

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