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Overview
How to Apply for a Section 927 Waiver
High Seas Operations
Frequently Asked Questions

Overview

Section 927 of the Reauthorization Act of 2024 (Pub. L. 118–63) authorizes the FAA to enable unmanned aircraft operations through waivers to applicable federal aviation regulations instead of initiating a rulemaking or requiring operators to seek an exemption under Title 14 Code of Federal Regulations (CFR) part 11. A waiver is an official document issued by the FAA which approves certain operations of aircraft outside the limitations of a regulation.

The Section 927 waiver authority provides an additional tool to complement—not replace—the exemption process under 14 CFR part 11. However, not all regulatory relief will be eligible for a Section 927 waiver. The FAA recommends reviewing the Notice that it published in the Federal Register on April 1, 2026, which explains how the FAA will implement the Section 927 waiver authority (hereinafter, referred to as the Notice). The Notice describes the process the FAA uses when evaluating whether a Section 927 waiver or a traditional exemption is the appropriate tool for granting regulatory relief. The Notice is available at the following link: Federal Register :: Implementing Section 927 Waiver Process for Certain Unmanned Aircraft Operations.

As explained in the Notice, the FAA uses the same safety standard for Section 927 waivers as it uses for exemptions: a Section 927 waiver request must show that the operations under the waiver would not adversely affect safety or would provide a level of safety equal to the rule from which relief is sought. However, a practical difference between the two options is that the FAA may grant regulatory relief through a Section 927 waiver without requiring that the requested relief is in the public interest. 

How to Apply for a Section 927 Waiver

Step 1: Determine the regulatory relief you need.

The first step is to determine the regulatory relief you will need to conduct your proposed operation. To do this, you should identify what you intend to do, how you will conduct the operation, and what CFR parts and regulatory sections apply to your operation. After you identify this information, you should evaluate the applicable regulations to determine which requirements your operation needs relief from. 

To determine what regulations you require relief from, it may help to consider the following questions:

• How much does your UAS weigh? And what CFR part do you plan to operate under?
• What type of flying do you intend to do? [e.g., agricultural (14 CFR part 137), aerial filming/imagery, research/development, or testing (14 CFR part 91), package delivery (14 CFR part 135)]
• Where do you intend to operate your UA, and what airspace? (e.g., sparsely populated areas, rural-controlled-access property, uncontrolled airspace, over people, near airports) 
• Will you operate within visual line of sight (VLOS) or beyond visual line of sight (BVLOS)?
• Will your remote pilots hold any pilot qualifications?
• How high will you fly your aircraft (i.e., maximum altitude above ground level)?
• How fast will you operate your aircraft? 
• Will your operation involve the carriage of property for compensation or hire?
• What equipment will your UAS use? (e.g., ADS-B In/Out, geofencing, GPS, INS, RADAR, LIDAR, DAA)
• Will your operation involve the carriage of hazardous materials (HAZMAT)?
• Will your operation consist of operating a UA that is equipped or armed with a dangerous weapon?

Step 2: Consider your options for requesting regulatory relief. 

Not all requests for regulatory relief will be eligible for a Section 927 waiver. When deciding which pathway to pursue, the FAA refers you to the Notice discussed above, which describes the process the FAA uses to determine if the requested relief is eligible for a waiver under Section 927. 

As explained in the Notice, the FAA identified four criteria that it will use to determine whether the Section 927 waiver process is the appropriate path for relief. Some proposed operations will align with all four criteria, while others may align with only one. The four criteria are briefly described in the table below.  

If you are interested in pursuing a Section 927 waiver, you should evaluate your proposed operation using the four eligibility criteria. The Notice thoroughly explains the criteria and provides questions for you to consider when evaluating whether your proposed operation meets the criteria. If you determine that your proposed operation aligns with one or more of the eligibility criteria for a Section 927 waiver, you may request a Section 927 waiver. 

Step 3: Write the waiver request.

To request a Section 927 waiver, provide a robust explanation of why the request for regulatory relief is eligible for the Section 927 waiver process. The request should explain how the proposed operation meets one or more of the eligibility criteria and include facts, data, or examples that support eligibility. Identify the specific regulations from which you seek relief and provide a well-documented safety case to support your request. 

To avoid delays in processing, the request should include the following: 

• The specific federal aviation regulation(s) from which you are seeking relief.
• The extent of relief requested, and the reason you seek the relief.
• The reasons why granting the waiver would not adversely affect safety or how it provides a level of safety equal to the rule from which you seek relief.
• The reasons why the request meets the requirements of § 44807(b), including how such unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, operation over people, and operation within or beyond the visual line of sight, or operation during the day or night, do not create a hazard to users of the national airspace system or the public.

In addition, before submitting the waiver request, ensure your request contains the following information, if relevant: 

• Concept of Operations 
• Operations Manual 
• Emergency Procedures 
• Checklists 
• Maintenance Manual 
• Training Program 
• Flight History (flight hours, cycles, accidents, etc.) 
• ¹Safety Risk Analysis for the specific operations to be conducted

¹ FAA Order 8040.6A may be helpful: https://www.faa.gov/documentLibrary/media/Order/Order_8040.6A.pdf

Step 4: Submit the waiver request. 

Upon completing your waiver request, you should submit it via email directly to 927waivers@faa.gov. You can expect an initial response informing you whether the FAA agrees that your request is appropriate for the Section 927 waiver pathway. The FAA evaluation team may contact you for further information as needed. If at any point in the evaluation process, the FAA determines the request is not eligible for a Section 927 waiver, the FAA will redirect you to an appropriate pathway to request regulatory relief. If the FAA determines the request is eligible for a Section 927 waiver, the FAA will conduct a safety evaluation and provide a final decision (approval or denial).

High Seas Operations

The FAA is considering concepts to enable near-term operational approvals for certain UAS operations over the high seas. FAA will utilize the Section 927 process as the mechanism for the intake and consideration of UAS operations beyond 12 nautical miles of the United States.

If your UAS operation will take place beyond 12 nautical miles from the United States AND does not cross into the territorial airspace of another State AND meets the Section 927 eligibility criteria, then you may be eligible for a Section 927 waiver to facilitate UAS high seas operations.

We recommend contacting FAA’s Emerging Technologies Division (9-AVS-FS-AFS-700-Correspondence@faa.gov) before submitting a Section 927 waiver request for high seas operations. Once you have established that your intended high seas operation is appropriately scoped for this near-term approval pathway, then follow the Section 927 waiver process as outlined above.

Frequently Asked Questions

1. May I apply for an exemption and for a Section 927 waiver at the same time to see which pathway provides a decision more quickly?
   No, you must select either the exemption pathway or the Section 927 waiver.
    
2. If I have already applied for an exemption, may I withdraw my petition for exemption and apply for a Section 927 waiver instead?
   Yes; however, applicants enter the Section 927 waiver process on a first-come, first-served basis and would not receive priority or expedited treatment.
    
3. Will the FAA conduct an abbreviated safety analysis for Section 927 waivers?
   No, the safety analysis conducted for exemptions and for Section 927 waivers will remain identical.
    
4. Will both pathways provide similar types of relief, i.e., will the operational Conditions and Limitations posed by an exemption versus a Section 927 waiver be similar? 
   Yes, both pathways—irrespective of whether an exemption or Section 927 waiver—will provide regulatory relief based on the safety case. The safety analysis and resulting operational parameters, including Conditions and Limitations, would not depend on the pathway for regulatory relief.