The single most common compliance lapse among US Part 107 commercial drone pilots is letting aeronautical knowledge currency expire. Under 14 CFR § 107.65, a Part 107 Remote Pilot Certificate holder must complete an FAA recurrent training course every 24 calendar months to maintain operational privileges. As of 2026, the recurrent training is delivered exclusively through the FAA's free online course ALC-677, with no in-person test requirement.
This article delivers the current 2026 requirements, the cost implications of lapsed currency, and the step-by-step process to complete recurrent training without disruption to commercial operations.
1. The Statutory Basis — 14 CFR § 107.65
§ 107.65 establishes the recurrent training requirement. The full text is at https://www.ecfr.gov/current/title-14/chapter-I/subchapter-F/part-107/subpart-C/section-107.65.
The rule establishes that a person may not operate a small unmanned aircraft for commercial purposes under Part 107 unless that person has, within the previous 24 calendar months, either:
- Completed an initial aeronautical knowledge test (the UAG exam), OR
- Completed an FAA-approved online recurrent training course
The current FAA-approved online recurrent course is ALC-677, "Part 107 Small UAS Recurrent."
Key statutory point: the Remote Pilot Certificate itself does not expire. What expires is your aeronautical knowledge currency. Without current knowledge, the certificate exists but cannot be exercised for commercial flight.
2. The 2019 Reform — From In-Person Test to Free Online Course
Until April 2019, recurrent training required a Knowledge Testing Center visit and a $150 in-person test. On April 1, 2019, the FAA replaced this with the free online ALC-677 course, removing the cost and scheduling barrier. The 2021 night operations and operations-over-people updates further refreshed the curriculum.
FAA announcement: https://www.faa.gov/newsroom/recurrent-training-courses-drone-pilots-available-online
The change reflects the FAA's commitment to reducing the friction of regulatory compliance for the lowest-risk segment of the National Airspace System.
3. ALC-677 — Course Mechanics in 2026
Cost: Free. Format: Online, self-paced. Duration: Approximately 1.5 to 2 hours, depending on pace. Exam: None. The course includes embedded knowledge checks but no separate scoring exam. Certificate: Issued automatically upon completion.
Course content as of 2026:
- Updates to Part 107 since the operator's last course or initial test
- Operations Over People — Categories 1 through 4
- Night operations rules under § 107.29
- Remote ID compliance under 14 CFR Part 89
- LAANC airspace authorization workflow under § 107.41
- Crew resource management
- Aeronautical decision-making
- Emergency procedures
- Updates from the FAA Reauthorization Act of 2024
- BVLOS context (Part 108 NPRM published August 2025)
Platform: FAA Safety Team (FAASTeam) at https://www.faasafety.gov/.
4. Step-by-Step — Completing ALC-677
Step 1 — Create or Log In to FAASTeam Account
Visit https://www.faasafety.gov/. Account creation is free. The account links to your FAA Tracking Number (FTN) — the same number tied to your Remote Pilot Certificate.
Step 2 — Locate ALC-677
Search the course catalog for course code ALC-677 or "Part 107 Small UAS Recurrent." The course is listed under FAASTeam Online Courses.
Step 3 — Complete All Modules
Work through each module sequentially. Skipping is not permitted. Knowledge checks must be answered correctly to advance, but multiple attempts are permitted.
Step 4 — Generate Completion Certificate
On final module completion, FAASTeam generates a digital course completion certificate. Save this to your records.
Step 5 — Update IACRA Profile
Log in to IACRA at https://iacra.faa.gov/. Your currency date is automatically updated based on the FAASTeam ALC-677 completion. Verify the date in your IACRA profile.
Step 6 — Document the Completion
Retain the FAASTeam certificate, course completion email, and IACRA currency screenshot. This documentation is critical evidence in an FAA enforcement inquiry alleging operation while currency was lapsed.
5. Currency Lapse Consequences
Operating commercial Part 107 flights with lapsed currency is a violation of § 107.65 and § 107.12. Penalties include:
- Civil penalty up to $27,500 per violation under 49 U.S.C. § 46301
- Certificate suspension or revocation action by the FAA
- Insurance void — most commercial drone insurance policies require active currency as a condition of coverage. A claim filed during a lapse may be denied.
The FAA has investigated complaints alleging operation during lapse based on social media documentation, news coverage, and tip line reports.
6. Calculating Your Currency Date — 24 Calendar Months
The 24-calendar-month clock starts on your most recent completion of either the initial knowledge test or a recurrent course. Calendar month means the last day of the month, not 24 months from the exact date.
Example: Initial UAG test passed March 14, 2024. Currency expires March 31, 2026. ALC-677 must be completed by March 31, 2026 to maintain uninterrupted privilege. Complete it any earlier; the new currency date is calculated from the completion month.
Best practice: Set a calendar reminder 60 days before your currency expiration. Most operators discover lapses only when scheduling a flight — by which time it is too late to comply for that operation.
7. Common Misunderstandings — A Gyoseishoshi Compliance Lens
As MmowW Drone is operated by a licensed Gyoseishoshi (行政書士) office in Japan, we observe these recurring misunderstandings:
Misunderstanding 1: "My certificate doesn't have an expiration date, so it doesn't expire." The certificate is permanent; the knowledge currency expires.
Misunderstanding 2: "Recurrent training is annual." It is 24 calendar months, not annual.
Misunderstanding 3: "I have to take an exam at a testing center." Since April 2019, recurrent training is the free online ALC-677 course with no exam.
Misunderstanding 4: "If my currency lapsed, I have to retake the initial UAG test." For modest lapses, completing the recurrent ALC-677 course typically restores currency. For long lapses, the FAA may require the initial UAG test. Verify with FAA support if your lapse exceeds 24 months.
Misunderstanding 5: "Recurrent training covers state law." ALC-677 covers federal Part 107 rules and FAA-administered Part 89 Remote ID. State and local law is the operator's separate responsibility.
8. Special Pathway — Existing Part 61 Pilots
Pilots who hold a manned-aircraft Part 61 certificate (private, commercial, ATP) and a current flight review may complete an alternative streamlined recurrent training. The pathway is discussed in FAA guidance on the Become a Drone Pilot page at https://www.faa.gov/uas/commercial_operators/become_a_drone_pilot. The substantive curriculum is similar; the application pathway through IACRA is the same.
9. Industry-Specific Implications
- Real estate photography: Currency lapse on day of property shoot causes contract default risk. Schedule recurrent at least 30 days before any committed shoot.
- Film and cinematography: Production insurance and union contracts (IATSE) require active currency documentation. Lapsed pilots are removed from set call sheets.
- Infrastructure inspection: Government client contracts typically require current Part 107 certification; lapse triggers contract review.
- Agriculture: Seasonal scheduling means currency lapses tend to surface during peak season — schedule recurrent in the off-season.
10. The 2026 Best Practice Workflow
- Complete ALC-677 within 22 calendar months of last completion (2 months early).
- Save FAASTeam certificate to cloud storage.
- Verify IACRA currency date updates within 7 business days.
- Set next-cycle reminder at the new 22-month mark.
- Maintain a SaaS-based pilot certification tracker that surfaces currency expiry dates 60, 30, and 7 days in advance.
A SaaS like MmowW Drone tracks every operator's recurrent training currency and surfaces expiry warnings well in advance, eliminating the "I forgot" failure mode that drives FAA enforcement actions.
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Disclaimer
This article provides legal information, not legal advice. MmowW Drone is operated by a licensed Gyoseishoshi (行政書士) office in Japan. We are not US attorneys or licensed FAA legal counsel. For binding legal opinions on FAA compliance, consult a US-licensed aviation attorney.
Sources
- 14 CFR § 107.65 — Aeronautical knowledge recency — https://www.ecfr.gov/current/title-14/chapter-I/subchapter-F/part-107/subpart-C/section-107.65
- FAA FAQ — Recurrent training to renew currency — https://www.faa.gov/faq/after-part-107-pilot-completes-online-alc-training-course-renew-hisher-remote-pilot-currency
- FAA Newsroom — Recurrent Training Courses Available Online — https://www.faa.gov/newsroom/recurrent-training-courses-drone-pilots-available-online
- FAA Become a Drone Pilot — https://www.faa.gov/uas/commercial_operators/become_a_drone_pilot
- FAA Safety Team Online Courses — https://www.faasafety.gov/
- IACRA — Integrated Airman Certification and Rating Application — https://iacra.faa.gov/
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