FAR Part 3 Subpart C Impacts
FAR Part 3 Subpart C requires international FAA certificate holders without a U.S. address to designate an agent by specific deadlines, adding compliance costs but aiming to streamline FAA communications and reduce processing delays.
Impacts of FAR Part 3 Subpart C
October 8thof 2024 added another level of complexity to international holders of FAA certificates. This is due to the release of FAR Part 3 Subpart C, which requires anyone who does not have a U.S. address on file with the FAA to designate an agent to represent them. Compliance with this regulation is mandatory to keep a valid certificate, and agents must be designated by April 2nd for new applicants and July 7th for current certificate holders.
As of July 2022, there were about 115,000 certificate holders worldwide that would be required to designate an agent on their behalf. With new applications received daily, that number has steadily increased since then, with the FAA estimating about 4,500 new international certificate holders added to that total every year. This represents about 8% of all active FAA certificates held. The FAA proposes that this regulation will cost each certificate holder up to $200 per year to comply with this regulation.
The FAA brought this regulation into effect to streamline communications and servicing to international certificate holders. Providing these services requires compliance with international service laws, including the many treaties between various countries worldwide. This significantly delayed the processing and delivery times of documents, sometimes taking over a year. Additionally, these international services were creating extra costs for the department, both financially and timely, causing delays in other areas in the FAA. As a solution to this problem, the FAA created FAR Part 3 Subpart C.
This regulation creates a large impact for international FAA certificate holders. It adds additional costs and levels of compliance to maintain valid FAA certificates outside of the United States. But with the assistance of FAA Designated Agencies, compliance is simplified, ensuring that certificate holders receive the full representation they deserve and overcoming these challenges together while continuing to operate legally.
