FAA Publishes MOSAIC Fact Sheet, Clarifies Operating Limitation Requirements for New Light-Sport Repairman Privileges

The FAA released a fact sheet on the Modernization of Special Airworthiness Certification (MOSAIC) rule. While summarizing both the reforms to the sport pilot certificate and the light-sport aircraft category, the fact sheet also contained a note that clarifies the FAA position on light-sport repairman certificates and experimental operating limitations.

MOSAIC created new privileges for light-sport repairmen to perform condition inspections on experimental amateur-built (E-AB) aircraft. Despite the name of the certificate, this is true for all E-ABs regardless of size or performance. However, as EAA reported recently, many E-ABs will need new operating limitations to take advantage of these expanded privileges. This reflected EAA discussions with FAA, in which EAA advocated against the need for this requirement. However, the FAA was firm in its position that most operating limitations specify who may perform these inspections, and unless light-sport repairmen are listed they may not perform the inspections regardless of the new rule.

Some in the E-AB community have pointed out that the operating limitation uses non-specific language that could imply that others not specifically listed in the operating limitation may perform inspections. Following up on these questions, EAA has asked for clarification from FAA and is awaiting a written response. In the meantime, however, the FAA’s new MOSAIC fact sheet contains the following statement:

NOTE: EAB aircraft with operating limitations issued prior to Oct. 22, 2025, must obtain revised operating limitations that permit a light-sport repairman to perform the annual condition inspection.

EAA contends that this is not fully accurate for some aircraft with very old operating limitations that are silent on who may perform inspections, but otherwise this note is consistent with previous statements made by FAA. EAA has advocated against E-AB owners requiring new operating limitations to access the new repairman certification rules, but has to date received no indication that the FAA can accept any alternative.