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FAA - Law Update Updated 2026-05-02

FAA Part 107 Recurrent Training 2026: Latest Requirements

Quick Answer: The single most common compliance lapse among US Part 107 commercial drone pilots is letting aeronautical knowledge currency expire. Under 14 CFR §. § 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.
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Law Update FAA - 14 CFR Part 107 Updated: 2026-05-02 Approx. 1750 words

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:

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:

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:

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.


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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


10. The 2026 Best Practice Workflow

  1. Complete ALC-677 within 22 calendar months of last completion (2 months early).
  2. Save FAASTeam certificate to cloud storage.
  3. Verify IACRA currency date updates within 7 business days.
  4. Set next-cycle reminder at the new 22-month mark.
  5. 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

  1. 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
  2. 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
  3. FAA Newsroom — Recurrent Training Courses Available Online — https://www.faa.gov/newsroom/recurrent-training-courses-drone-pilots-available-online
  4. FAA Become a Drone Pilot — https://www.faa.gov/uas/commercial_operators/become_a_drone_pilot
  5. FAA Safety Team Online Courses — https://www.faasafety.gov/
  6. IACRA — Integrated Airman Certification and Rating Application — https://iacra.faa.gov/

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Takayuki Sawai — Gyoseishoshi

Licensed Gyoseishoshi (Administrative Scrivener) and founder of MmowW. Delivering accurate drone regulation guidance for operators worldwide.

⚠️ This article is for informational purposes only and does not constitute legal advice. Always verify current regulations with Federal Aviation Administration (FAA) before operating your drone.

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