FAA Proposes Ending Special Issuance Requirement for Pilots With Non-Insulin-Dependent Diabetes

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The FAA published a notice of proposed rulemaking on September 4, 2026 that would let pilots whose diabetes is controlled without insulin receive first-, second-, or third-class medical certificates directly from an Aviation Medical Examiner — eliminating the automatic Special Issuance deferral that currently applies. The change hinges on a small edit: striking the phrase “or any other hypoglycemic drug” from §§ 67.113(a), 67.213(a), and 67.313(a). The FAA estimates the rule would allow AMEs to issue certificates at the time of examination in roughly 3,000 cases per year, with another 1,200 currently handled through Special Issuance transitioning to AME-managed certification. Requirements for insulin-treated diabetes would not change.

The comment period runs 30 days from publication.

What Changes

Under current regulations in 14 CFR part 67, diabetes requiring insulin or any other hypoglycemic drug for control is a specifically disqualifying condition.

Pilots managing diabetes with non-insulin medication can still hold a medical certificate — but the pathway runs through § 67.401, the Special Issuance provision. In practice, an AME must defer the application to the FAA, which reviews the case and decides whether to grant an Authorization for Special Issuance.

Removing four words from the regulation changes that pathway. Qualified applicants with non-insulin-dependent diabetes mellitus would instead be evaluated under the general medical standards, and the AME could issue the certificate at the same visit that currently ends in a deferral letter.

What Doesn’t Change

Two points worth being precise about, because the headline invites overstatement.

This is not automatic certification. Applicants would still be expected to provide documentation from their treating physician, relevant medical history, and an acceptable Hemoglobin A1C result. The AME would still evaluate the stability of the condition, the medication in use, potential side effects, and any evidence of diabetes-related complications. The scrutiny moves from the FAA’s desk to the examination room — it doesn’t disappear.

Insulin-treated diabetes is unaffected. Applicants requiring insulin would remain subject to the Special Issuance process. The proposal addresses non-insulin-dependent cases only.

Why the 64-Day Number Is the Point

The practical case for the rule sits in one figure from the FAA’s own analysis: initial applications deferred for a Special Issuance Authorization currently take an average of 64 days to process.

Pilots cannot exercise the privileges of a medical certificate during that window.

For a private pilot, that’s two months of not flying. For someone on an airline career timeline, it’s considerably worse — 64 days sits awkwardly against type rating courses, hiring windows, and training schedules, and a deferral can cascade into missed opportunities that have nothing to do with the applicant’s actual fitness to fly.

The FAA estimates the change would save applicants between $39.7 million and $80.2 million in labor costs over five years, alongside reduced processing burden on the agency and shorter backlogs for the cases that genuinely require FAA review.

The Medical Rationale

The FAA’s stated basis is that the science has moved and the regulation hasn’t.

The disqualifying standard dates to 1959. In the late 1980s, the agency began granting special issuances to individuals controlling diabetes through diet and oral hypoglycemic drugs — an acknowledgment even then that the blanket standard was too broad.

Since that time, non-insulin treatment options have expanded substantially, with medication classes that carry meaningfully different risk profiles than those available when the rule was written. The FAA’s position is that modern medical advancements have significantly improved the manageability of certain forms of diabetes, and that the certification process should reflect that.

The concern the original standard addressed — hypoglycemia in flight — remains legitimate. What’s changed is that the relationship between “takes medication for diabetes” and “at risk of an incapacitating hypoglycemic event” is far weaker with contemporary non-insulin treatments than the 1959 language assumes.

International Alignment

The proposal would also bring the FAA closer to ICAO standards. The United States currently files differences with ICAO on this point, and those filed differences would need adjustment if the rule is adopted.

That matters for pilots operating internationally and for the broader project of harmonizing U.S. medical standards with the rest of the world — an area where the FAA has historically been more restrictive than many peer authorities.

What Pilots Should Do

If you currently hold a Special Issuance for non-insulin-dependent diabetes: nothing changes yet. This is a proposal, not a final rule, and your existing authorization remains in effect. Continue following your current requirements.

If you’re facing a deferral now: the current process still applies. A proposed rule provides no relief until it’s finalized.

If you want to influence the outcome: the comment period is 30 days from the September 4 publication date, which is short. Comments can be submitted through the Federal Register docket for 2026-18162. Pilots, AMEs, and physicians with relevant experience are exactly the constituencies the FAA is asking to hear from.

In all cases, talk to an AME. Medical certification is individualized, and general reporting on a proposed rule is no substitute for a conversation with an aviation medical examiner about your specific circumstances. AMEs can also advise on documentation that would be useful under either the current or proposed process.

Watch for the final rule. Proposed rules can be adopted as written, modified, or withdrawn. The comment record will shape which.

The Bottom Line

The FAA is proposing to remove four words from three sections of Part 67, and the effect would be substantial: roughly 3,000 pilots a year receiving a medical certificate at their examination instead of waiting an average of 64 days for a Special Issuance authorization, and another 1,200 moving from FAA review to AME management.

The proposal keeps the medical scrutiny — physician documentation, A1C results, evaluation of stability and complications — while moving it to the point of care. It leaves insulin-treated diabetes untouched. And it updates a standard written in 1959 to reflect treatments that didn’t exist when it was drafted.

For pilots who have spent months grounded while paperwork moved through Oklahoma City for a condition their physician considers well controlled, it would be a meaningful change. The comment window is 30 days, and the docket is open.

Frequently Asked Questions

What is the FAA proposing to change about diabetes medical certification? The FAA published a notice of proposed rulemaking on September 4, 2026 that would remove the phrase “or any other hypoglycemic drug” from §§ 67.113(a), 67.213(a), and 67.313(a) of 14 CFR part 67. The effect would be to allow applicants whose diabetes is controlled with non-insulin medications to be evaluated under the general medical standards and receive a first-, second-, or third-class medical certificate directly from an Aviation Medical Examiner, rather than being deferred to the FAA for Special Issuance review.

Would pilots with diabetes still need medical documentation? Yes. The proposal is not automatic certification. Applicants would still be expected to provide documentation from their treating physician, relevant medical history, and an acceptable Hemoglobin A1C test. The AME would evaluate the stability of the condition, the medication being used, possible side effects, and any evidence of diabetes-related complications. The evaluation moves from FAA review to the examination room rather than being eliminated.

Does this proposal affect pilots who use insulin? No. The proposed rule addresses non-insulin-dependent diabetes mellitus only. Applicants whose diabetes requires insulin would remain subject to the FAA’s Special Issuance process under § 67.401. Since 2019, the FAA has issued first- and second-class certificates to pilots with insulin-treated diabetes under that special issuance framework.

How long does the current Special Issuance process take? According to the FAA’s analysis accompanying the proposal, initial applications deferred for a Special Issuance Authorization take an average of 64 days to process. Pilots cannot perform flight duties during that period. The agency estimates the proposed change would save applicants between $39.7 million and $80.2 million in labor costs over five years while reducing FAA processing burden and backlogs.

How can pilots comment on the proposed rule? The notice of proposed rulemaking was published in the Federal Register on September 4, 2026 under document number 2026-18162, with a 30-day comment period. Comments may be submitted through the Federal Register docket. Pilots, aviation medical examiners, and treating physicians with relevant experience are among the constituencies the FAA is seeking input from. Pilots should also consult an AME about how current or proposed requirements apply to their individual circumstances.

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