Part 108 Doesn’t Require a Pilot’s License. Here’s What It Requires Instead.

For twenty years the first question in commercial drones has been “do I need a pilot’s license for this?” Under Part 107 the answer is yes: you study, you pay PSI $175, you pass a 60-question test, you carry the card. The FAA’s proposed Part 108 rule, the framework for routine beyond visual line of sight (BVLOS) flying, flips that question on its head.

Quick answer: the proposed Part 108 rule does not require anyone at your company to hold an FAA pilot certificate. Instead, it puts legal responsibility on the operator, meaning the business rather than any one person, and requires two named roles: an operations supervisor who holds final authority over every flight, and flight coordinators who watch individual aircraft and step in when something looks wrong. The operator writes its own training program, keeps the records, and answers to the FAA when things go sideways.

Same caveat as every article in this series: this is the proposed rule, published August 7, 2025, and the final text is still being written as of this writing. Details can shift. But the operator-responsibility model comes straight from the statute. Congress gave the FAA explicit authority to skip airman certificates for these operations in 49 U.S.C. 44807, so the shape of this is very likely to hold. For the bigger picture, start with our Part 108 overview, and for the side-by-side with today’s rules, see Part 107 vs the proposed Part 108.

Why the FAA skipped pilot licenses

The logic is simpler than people expect. A Part 108 aircraft spends most of its life flying itself. The automation handles the stick-and-rudder work, the navigation, the lost-link behavior. There is no one aboard to save, and the human involved is sitting at a console watching a screen, often monitoring more than one aircraft at a time.

When the human’s job is supervision instead of flying, the FAA’s usual tool stops fitting. You cannot test an individual, issue a certificate, and revoke it if they misbehave when the individual barely touches the controls. The safety-critical decisions move up a level: which routes are acceptable, what the training covers, when an aircraft is airworthy enough to dispatch, who is on duty and for how long. Those are company decisions. So the rule regulates the company.

The operations supervisor: the name on the hook

Every Part 108 operator has to designate at least one operations supervisor. Under proposed section 108.305, this person is directly responsible for, and the final authority over, the operation of every aircraft the company flies. They are also the FAA’s point of contact, the aviation equivalent of a director of operations at an airline. If a flight should not go out (weather, equipment, a coordinator who is not fit for duty), the operations supervisor is the one expected to kill it, and the FAA will treat it as their call to make.

Who qualifies? The proposal says training, experience, or other expertise, and it names examples like military UAS experience or an academic background. There is no certificate to earn and no test at a testing center, but the bar is real: the supervisor has to know the company’s policies and procedures cold, understand aviation safety standards and safe operating practices, and understand Part 108 itself. The operator also has to tell the FAA within 10 days whenever the person in the role changes.

This is a genuine accountability shift. Under Part 107, the remote pilot in command carries the personal risk. Under Part 108, the operation’s chain of command carries it, and the operations supervisor sits at the top of that chain. If you run a small shop, that person is probably you, the owner. Read the role description before you sign up for it.

Flight coordinators: the humans in the loop

Flight coordinators are the people watching flights in real time. The FAA picked the word “coordinator” on purpose, to drive home that this is not a pilot. Direct manual control of the aircraft, a handheld joystick, is not permitted under the proposal at all. Any command the human sends, a change in airspeed, altitude, or heading, goes through an automated control system. Think dispatcher rather than pilot: the coordinator is the layer of human judgment between the automation and the public.

The mechanics: the operator designates a flight coordinator before each flight where the manufacturer’s operating instructions require one. The coordinator keeps situational awareness of the aircraft and acts, within the limits of its design, to keep it from endangering people, aircraft, or property. Operators need handoff procedures for transferring a flight between coordinators mid-flight, and one coordinator can monitor several aircraft at once when the FAA approves the operation for it.

Here is where most coverage gets the details wrong, so be careful. There is no flight coordinator certificate, and no knowledge test at a testing center. But “no license” does not mean “no experience requirement.” Proposed section 108.310 requires a minimum of 5 hours of initial supervised flight experience on the specific make and model of aircraft, plus recency within the previous 12 calendar months, before someone can serve as a coordinator. The 5 hours mirrors the requirement for flight engineers in manned aviation, and it can be logged in training scenarios rather than live commercial flights, which is how a brand-new operator would qualify its first group of coordinators.

Beyond that floor, whether a coordinator is qualified is the operator’s call to make and the operator’s problem to document. The FAA deliberately left the role flexible: a fully autonomous aircraft may need only occasional oversight, while a less automated design needs a coordinator watching continuously.

Training becomes your program, not the FAA’s test

Section 108.315 is where the weight lands. The operator has to make sure each person in an operations role has the knowledge and skills their duties require, with initial and recurrent training, and keep the records to prove it. The FAA does not hand you a syllabus, and it prescribes no hours and no format. It lists subject areas, from airspace and flight rules to emergency procedures and security, and expects you to train people on the ones their job touches. You can hire an outside course, but the responsibility for whether it works stays with you.

One distinction matters here. Certificate holders, the larger and more complex operations, have to build a formal training program under section 108.540 and submit it with their certificate application. Permit holders, the smaller end of the rule, do not have to submit a program for FAA approval, though the duty to train and keep records is identical. For a two-person inspection shop this is lighter than it sounds: a written program, documented sessions, a records folder. For a delivery company running a hundred aircraft it is a genuine training department. Either way, the era of “everyone just go pass the same 60-question test” ends for BVLOS work.

The rest of the personnel rulebook

The remainder of subpart C covers the ground you would expect once the FAA regulates the operator instead of the pilot:

Medical condition (108.320): no part 67 medical certificate is required, but nobody serves in an operations role with a physical or mental condition that would interfere with the job. The standard follows the person, not a piece of paper.

Alcohol and drugs (108.325): the familiar rules follow you into the control room. No serving within 8 hours of drinking, no serving while under the influence or at a blood alcohol concentration of 0.04 or higher, and you must submit to testing on request from law enforcement and hand certain test results to the FAA.

Duty and rest (108.330): a 14-hour maximum duty day, a 50-hour maximum duty week, at least 10 consecutive hours of rest in the 24 hours before you report, and one full day free of all work responsibility each week you are scheduled. Fatigue management matters when one person monitors aircraft for hours, and these limits do not apply to recreational permit holders.

Security threat assessments (108.335): supervisors, coordinators, and anyone with unescorted access to the aircraft, its cargo, or its control and flightpath need a TSA security threat assessment, up to Level 3, which runs criminal history, immigration, and intelligence checks. Let it lapse and the operator has to pull the person from the role or risk the permit or certificate.

What this changes if you sell to drone businesses

Here is the part I think most coverage misses. Part 107 created a market of individual pilots, and a whole industry grew up selling to them: test prep, checklists, insurance, gear. Part 108 creates a market of operators. The buyer is no longer a pilot studying for a test. It is a manager building a compliance program: training records, duty schedules, maintenance logs, security assessments.

That is a different sale, a different budget, and a much longer relationship. The companies that understand the operator-responsibility model early will be the ones these businesses call when the final rule arrives.

Common questions

Do I need a Part 107 license to fly under Part 108?

No. The proposal requires no airman certificate for Part 108 operations. The operator designates an operations supervisor and flight coordinators and trains them under its own program, with 5 hours of supervised flight experience on the specific aircraft for coordinators.

What is an operations supervisor under Part 108?

The person who is directly responsible for, and the final authority over, every flight the operator runs. They are the FAA’s point of contact, they own the go/no-go call, and the operator must notify the FAA within 10 days when the person in the role changes.

What does a flight coordinator do?

Monitors individual aircraft in real time and intervenes within the limits of the automated control system when needed. Coordinators supervise the automation rather than hand-fly the aircraft, and they need 5 hours of supervised experience on the specific make and model plus recency within the previous 12 calendar months.

Does Part 108 replace Part 107?

No. Part 107 stays in place for visual line of sight flying, and it remains the certificate to earn for today’s commercial work. Part 108 is the proposed framework for routine beyond visual line of sight operations, and many companies will eventually operate under both.

Source: FAA NPRM, “Normalizing Unmanned Aircraft Systems Beyond Visual Line of Sight Operations,” 90 FR 38212 (August 7, 2025), proposed sections 108.305 through 108.335, and 49 U.S.C. 44807. This article describes the proposed rule; the final rule may differ.