The FAA's Diabetes Special Issuance Proposal and What It Means for Pilots Managing Type Two

The FAA has proposed a significant change to how pilots with non-insulin-dependent Type 2 diabetes obtain medical certificates. Under the proposal, qualified Aviation Medical Examiners (AMEs) would be able to issue certificates at the point of examination - eliminating the current requirement to route these cases through the FAA’s Civil Aerospace Medical Institute in Oklahoma City. For thousands of pilots, this would mean the end of a process that has cost many of them months of waiting, recurring documentation burdens, and sometimes their flying careers.

How the Special Issuance Process Works Today

When an AME encounters a pilot with certain medical conditions, they cannot issue a certificate on the spot. The case is deferred to the FAA in Oklahoma City for review. The agency may request additional evaluations, records from treating physicians, and specialist opinions before issuing an authorization that allows the AME to certify the pilot going forward.

For pilots with non-insulin-dependent diabetes, this process has historically meant months of waiting, recurring documentation requirements at every renewal cycle, and accumulating costs through specialist visits and records requests. Many pilots who are otherwise healthy and capable have chosen to stop flying rather than sustain this overhead indefinitely.

What the FAA Is Proposing to Change

The proposal would allow AMEs to issue medical certificates on the spot to pilots with non-insulin-dependent diabetes - meaning diabetes managed through oral medications, diet and exercise, or other non-insulin therapies - provided those pilots meet specific criteria the FAA would establish in the final rule and are otherwise medically qualified.

This is a meaningful clinical distinction. Non-insulin-dependent diabetes presents a materially different risk profile than insulin-dependent diabetes, which involves its own separate certification history and is not addressed by this proposal.

AOPA reported on this development on September 10, 2026, and characterized it as a meaningful step forward. The organization has been among the leading advocates for aligning certification standards with the current medical understanding of well-controlled Type 2 diabetes.

Why This Matters: A Shift in Presumption

The core of this change is not a lowering of safety standards - it is a shift in where the default presumption sits. Under the current framework, a non-insulin-dependent diabetes diagnosis triggers automatic deferral to Oklahoma City. Under the proposal, the default would become certification for pilots who meet the established criteria and are evaluated by a qualified AME.

The management of Type 2 diabetes has changed substantially over the past two decades. Better medications, improved monitoring tools, and a more precise understanding of how well-controlled blood glucose affects cognitive function and sustained attention have all advanced significantly. The FAA’s Special Issuance framework in this area was built for an earlier state of medical knowledge.

AMEs would still conduct full evaluations. Pilots would still need to meet specific parameters defined in the final rule. Ongoing condition management would still be part of the picture. What changes is the default pathway - from deferral to certification, for qualified pilots.

Where This Fits in the FAA’s Broader Direction

This proposal is not an isolated event. The FAA has been moving - gradually but with clear direction - toward a more evidence-based approach to aviation medicine for roughly a decade.

BasicMed, established in 2017, created a simplified certification pathway for private pilots operating certain aircraft, returning a meaningful number of pilots to legal flying status who had let their medicals lapse or found the standard process too burdensome.

More recently, the FAA updated the certification pathway for insulin-dependent diabetes, permitting some pilots managing the condition with insulin to obtain first and second class medical certificates under specific conditions - a significant marker that the agency was willing to review data, consult medical experts, and adjust long-static standards.

This proposal is the next step in that same trajectory.

What This Means Depending on Your Situation

If you are currently flying under a Special Issuance for non-insulin-dependent diabetes: The rulemaking process takes time. A public comment period, FAA review, potential revisions, and a final rule typically span a year or more. Continue following your existing authorization and working with your AME as you normally would. Watch for updates.

If you have been delaying your medical exam after a Type 2 diabetes diagnosis: Stay engaged with this rulemaking as it develops. In the meantime, connect with an AME who has experience with diabetes cases. AOPA’s Medical Certification Services team, available at aopa.org, can help you understand where you stand under the current rules now - not six months from now.

If you stopped flying because the Special Issuance process became too burdensome: This proposal signals that the system is moving in a direction that may eventually bring you back to the cockpit. Do not make major decisions based on a proposal that has not yet become a final rule. But stay engaged - this is a development worth following closely.

How to Engage With the Rulemaking Process

Rulemaking proposals do not always emerge unchanged. The formal mechanism for the aviation community to shape the outcome is the public comment period. Pilots, physicians, AMEs, aviation organizations, and anyone with relevant experience can submit comments that become part of the official record shaping the final rule.

Watch for the Notice of Proposed Rulemaking in the Federal Register. AOPA will also publish guidance on how to engage effectively through aopa.org. If this issue affects you, that comment period is your direct input into how the final rule is written.

Key Takeaways

The FAA has proposed allowing AMEs to issue medical certificates on the spot to pilots with well-controlled, non-insulin-dependent Type 2 diabetes, eliminating the current deferral to Oklahoma City.
This proposal does not address insulin-dependent diabetes, which falls under a separate certification framework.
The change represents a shift in default presumption - from deferral to certification for qualified pilots - not a reduction in safety standards or examination requirements.
Pilots currently flying under a Special Issuance should continue their existing process; the final rule is likely at least a year away.
The public comment period is the formal opportunity for pilots, physicians, and aviation organizations to shape the outcome - watch for the Notice of Proposed Rulemaking in the Federal Register.