The Federal Aviation Administration (FAA) has issued a Notice of Proposed Rulemaking (NPRM) replacing the mechanic Inspection Authorization (IA) with a non-expiring Inspection Rating (IR) on the mechanic certificate. The proposal would reduce biennial renewal paperwork, but it would also shift more responsibility to mechanics and maintenance organizations to track recent experience and prove eligibility on request. A link to the full NPRM is here, and comments are due August 31, 2026.
The NPRM would move the current IA into the mechanic certificate as a new IR, carrying the same core privileges and limitations but without an expiration date or biennial renewal cycle. Instead of presenting renewal evidence to the FAA every March of each odd-numbered year, mechanics would need qualifying recent experience within the prior 12 calendar months and would be required to retain records for at least two years. The five current IA renewal options (annual inspections, major repairs or major alterations, progressive inspections, an acceptable eight-hour refresher course, or an FAA oral test) would carry over as recent experience options unchanged. A mechanic who falls out of recent experience could reestablish IR privileges through refresher training or an FAA oral test, which would satisfy the requirement for the next 12 calendar months.
Current IA holders would not need to act immediately. A mechanic with a valid IA on the final rule's effective date could exercise IR privileges using the existing IA for up to 24 months, with a six-month grace period before the new recent experience requirement applies. Within that window, the mechanic would need to request a replacement certificate showing the IR.
The FAA says safety would not decrease because eligibility requirements would remain, and Flight Standards District Office (FSDO) and International Field Office (IFO) surveillance would continue.
The practical question under this proposal is not whether a mechanic holds the IR, but whether the mechanic is current and eligible to exercise IR privileges on the date of a given inspection or return-to-service approval. Compliance would depend on self-maintained records produced on request, shifting the FAA from proactive review to reactive enforcement. Personnel qualification files and vendor audit procedures would become more important. At a minimum, organizations should determine who verifies IR currency and how internal systems will block assignments to non-current personnel.
Next Steps
- Current IA holders should map existing IA renewal records to the proposed 12-month recent experience and two-year retention framework.
- Maintenance organizations should confirm by August 22, 2026, that personnel systems can flag IR currency before assigning inspection-privileged work.
- Owners and operators should look at implementing processes to update diligence checklists to request and maintain evidence of current IR eligibility.
- Stakeholders should review the NPRM and submit comments by August 31, 2026.
This alert provides a brief overview of FAA's NPRM and is not intended to be comprehensive. If you or your company have questions about the proposed IR framework, IA transition planning, aircraft maintenance documentation, or aviation regulatory compliance, please contact Jim Janaitis or another member of Baker Donelson's Aviation and Aerospace Team.