By Ciaran Doyle – Waterford Aero Club
In October 2024, the U.S. Federal Aviation Administration (FAA) introduced a significant change affecting foreign pilots and aircraft owners: the requirement for individuals with foreign addresses to designate a U.S.-based “Agent for Service.” This new mandate, detailed in Advisory Circular AC 3-1, has important implications for Irish aviators who hold or are applying for FAA certificates, ratings, or authorisations.
What Is an ‘Agent for Service’?
An Agent for Service is a U.S.-based individual or entity authorised to receive official FAA documents on behalf of a foreign certificate holder or applicant. This role ensures that critical communications, such as enforcement actions or medical certificate denials, are promptly and reliably delivered.
Who Needs to Designate an Agent?
The requirement applies to individuals who:
- Have a foreign address and no U.S. physical address on record with the FAA.
- Hold or are applying for certificates, ratings, or authorisations under parts 47, 61, 63, 65, 67, or 107 of Title 14 of the Code of Federal Regulations.
This includes private pilots, flight instructors, aircraft mechanics, and drone operators residing in Ireland.
Why the Change?
The FAA’s decision addresses challenges in delivering time-sensitive documents internationally. Traditional international service methods can delay communication by months and increase costs. By mandating a U.S.-based agent, the FAA aims to streamline the delivery process, ensuring timely and efficient communication.
Responsibilities of the Agent
Designated agents must:
- Be at least 18 years old and have a physical address in the U.S. (P.O. boxes or mail drop services are not acceptable).
- Be available to receive FAA documents and promptly forward them to the certificate holder.
- Notify the certificate holder of any changes in their contact information.
It’s crucial to choose a reliable and responsive agent, as failure to receive or respond to FAA communications can have serious consequences. So, whilst you can nominate a friend in the US as your agent, if they receive correspondence from the FAA and are away on vacation or just forget to pass it on to you, then this is still deemed as delivered by the FAA.
Designating an Agent
Once you have decided on an agent, you must create a record on the U.S. Agent for Service System (USAS) website at: https://usas.faa.gov. You’ll need your FTN number to complete this step, which you can get from either IACRA or the MedExpress systems.
There are multiple companies offering the service with prices ranging from $35 per year to many hundreds of dollars per year. Some examples (these are not recommendations!) include:
- https://faausagentforservice.com/ $75
- https://www.floridaregisteredagent.com/ $35 (not FAA specific)
- AOPA’s service: https://www.aoparegisteredagent.com/ $79/$99
Deadlines and Compliance
Current certificate holders had nine months from the rule’s publication (until July 2025) to designate an agent. Failure to comply by this deadline may result in the suspension of certificate privileges. New applicants, including applications wishing to renew an FAA medical, must designate an agent at the time of that application.
Implications for Irish Pilots
For Irish pilots operating under FAA certificates, this change necessitates prompt action:
- Identify a suitable U.S.-based agent, such as a trusted friend, family member, or professional service.
- Ensure the agent understands their responsibilities and is committed to timely communication.
- Use the USAS platform to officially designate the agent and keep their information current.
As a reminder, any pilot who resides in the EU must hold an EASA Part FCL licence when flying any aircraft other than those defined in Annex I of the EU Basic Regulation (Regulation (EU) 2018/1139) e.g. gyroplanes, ex-military, homebuilt and certain historic aircraft, and microlight aeroplanes. As an EU resident, you can not fly, e.g. a C172 or SR22 in Ireland on an FAA license. (See article here)
You can contact Waterford Aero Club at info@waterfordaeroclub.com for more information on obtaining an EASA license based on your FAA license without having to sit written exams etc.)
For further information, refer to the full Advisory Circular AC 3-1 available on the FAA’s website here.
