Medical Mondays: What Happens If the FAA Revokes Your Certificate?
In this edition of Medical Mondays, aviation attorney Matthew Bulow explains what happens when the FAA revokes an airman certificate and what pilots can expect if they want to return to flying. While certificate revocation is one of the FAA’s most serious enforcement actions, it does not necessarily mark the end of an aviation career. Understanding the process and taking the right steps early can make a significant difference in how quickly a pilot can become eligible to fly again.
This episode distinguishes revocation from suspension, explains the FAA’s appeal process and waiting periods, and outlines the requirements for earning certificates back after a revocation. Bulow also discusses why addressing the underlying issue that led to the enforcement action is just as important as completing the required testing and training.
Key Insights
- Revocation Is Different From Suspension: A suspension temporarily removes certificate privileges, while a revocation permanently cancels the certificate and requires the pilot to requalify from the beginning.
- Emergency Orders Require Immediate Action: Most FAA revocation orders are issued on an emergency basis, requiring pilots to surrender their certificates immediately unless they successfully challenge the emergency determination within a very short timeframe.
- Appeals Have Strict Deadlines: Pilots generally have the right to appeal a revocation to the National Transportation Safety Board (NTSB), but emergency appeals must often be initiated within two days of receiving the order.
- Most Revocations Include a Waiting Period: Before reapplying for pilot certificates issued under Part 61, applicants typically must wait about 12 months, although the FAA may impose shorter waiting periods in some cases.
- Medical Certificates Can Often Be Reapplied for Sooner: The waiting period generally does not apply to FAA medical certificates, allowing pilots to begin restoring their medical eligibility while waiting to reapply for pilot certificates.
- Recertification Usually Means Starting Over: Pilots should expect to meet current eligibility requirements and complete the required knowledge exams and practical tests again for each certificate or rating they wish to regain.
- Correcting the Underlying Issue Is Essential: The FAA evaluates not only a pilot’s technical qualifications but also whether the conduct, medical condition or other circumstances that led to the revocation have been fully addressed.
- Preparation Can Shorten the Return to Flying: Working with an instructor, Aviation Medical Examiner (AME) and, when appropriate, an aviation attorney can help pilots develop a strategy for recertification and avoid unnecessary delays.
- Revocation Does Not Have to End an Aviation Career: Although the process is demanding, pilots who demonstrate compliance, rehabilitation and qualification may be able to earn their certificates back and safely return to the flight deck.
