Many CFIs have questions about for what students a citizenship verification must be completed prior to beginning training.
The TSA has provided a great PDF document summarizing what is needed and how these requirements may affect you as a flight training provider or those for whom you provide training.
Click the graphic below to see a pdf document the TSA provided, “Flight Training Security Program – About the Regulation” to see some more details about this requirement and the regulation process relating to vetting of students who are U.S. citizens and for those who are non-U.S. citizens.
For CFIs who only provide training to U.S. citizens, the flight training provider must:
For most independent and contractor CFIs, the main application portions of this list include having a TSA provider account, validating your U.S. citizen training recipients documentation of citizenship (for 5 years), maintaining your initial and biennial security awareness training, and allowing the TSA to inspect and audit your records if requested.
These TSA Security Threat Assessments (citizenship validation and validation of training allowance for non-U.S. citizens is still required only for the following events:
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- Initial pilot certification (whether private, recreational, or a sport pilot certificate), which provides a pilot with basic piloting skills.
- Instrument rating, which enhances a pilot’s abilities to pilot an aircraft in bad weather or at night and enables a pilot to better understand the instruments and physiological experiences of flying without reference to visual cues outside the aircraft.
- Multi-engine rating, which provides a pilot with the skill to operate more complex, faster aircraft.
- Type rating, which is a specific certification a pilot obtains to operate a certain type of aircraft, because this training is required beyond the initial, multi-engine, and instrument certification.
- Recurrent training for type rating, which is required to maintain or renew a type rating already held by a pilot.
Other training events such as an addon sea-plane rating, commercial pilot training, CFI training, flight reviews, high performance, tailwheel or complex endorsements, add-on ratings or certificates, and other training outside this list do not require citizenship validation.
If you are working for a school or an FBO engaged in training as a more structured school, these requirements may be completed under a Security Coordinator for the school and tracked by school documentation processes. If you are providing independent instruction, you may need to conduct and track these efforts on your own. Be sure either this is the case or engage in doing so for yourself.