FAA Still Lacks a General Certification Path for Airborne AI, Review Finds

Aircraft makers seeking approval for airborne artificial intelligence still have no published, general FAA means of compliance tailored to AI, according to a review of the agency’s guidance and certification materials. The FAA’s current public instruction is to coordinate with its Policy and Standards Division; a project may require a specific issue paper.

The FAA’s Roadmap for Artificial Intelligence Safety Assurance, Version I, frames the task as demonstrating the safety of AI in aircraft and related systems used in flight. It is a living roadmap, not an advisory circular or compliance checklist. The roadmap says an aircraft with an existing standard airworthiness certificate must be certified again to incorporate AI.

According to the roadmap, existing performance-based airworthiness regulations can apply to systems and equipment, requiring designers to show that equipment performs its intended function and that failures are mitigated to an acceptable level. But it also says current software and complex-hardware guidance does not adequately address learned AI, whose development through data complicates the traceability used for conventional software and hardware assurance.

The FAA’s Q3 2026 Small Airplane Issues List, dated Sept. 30, identifies artificial-intelligence software as an emerging technology. It tells applicants planning AI- or machine-learning-based technology to coordinate with the Policy and Standards Division and says a means-of-compliance issue paper may be needed. That is project-specific advice, not a general AI certification standard.

The roadmap’s milestone table had listed certification position papers for the first quarter of 2026, following several project-specific issue papers, while advisory circulars and an industry standard for learned AI were marked “TBD.” The review says it searched FAA materials on Oct. 14 and did not find a published AI/ML certification position paper or advisory circular. It does not establish whether the roadmap’s milestones were met through materials outside those pages.

The roadmap distinguishes static, or learned, systems from AI that continues to learn in operation. It says each new version of learned AI is subject to safety assurance, while methods for assuring continuously learning systems remain a lower-priority research topic. The FAA’s technical-discipline page describes research into measuring AI functionality and performance within the certification framework, rather than setting out a new approval route.

The review also notes that the roadmap excludes the ethical use of AI from its scope. Its findings describe the state of the cited FAA materials as of Oct. 14, 2026; they do not amount to an FAA determination that any particular AI-equipped aircraft cannot be certified.