Original publication date: December 3, 2022
Last Updated: February 9, 2024
Author: Max Skyler
Topic: Flight Physiology
Number of Comments: 0
Diabetes management is a contentious issue when it comes to physical fitness for flight. By virtue of its regulatory authority, the Federal Aviation Administration (FAA) painstakingly seeks to push the envelope in terms of enforcing and upholding the highest standards of aviation safety. Bearing the interests of the safety of the general public in mind, pilots are thus beholden to the rigors of meticulous medical scrutiny. Consequently, diabetes among those conditions that are demonstrably in the crosshairs of the FAA.
Being diagnosed with diabetes does not, in and of itself, result in automatic disqualification from exercising the privileges of a pilot license. By demonstrating to the FAA that your diabetes is under control and does not pose a safety risk, you can be granted permission to operate an aircraft.
In the given context, this begets the following questions: Under what circumstances can the FAA ground you with respect to diabetes? Under what circumstances can the FAA permit you to fly? And are there any limitations imposed upon you with respect to what kind of flight operations are you allowed to perform? Let’s examine what the FAA has to say about diabetes.
What are the medical exam certification standards for pilots?
All pilots are required to undergo a medical exam in order to demonstrate their fitness for flight. However, not all pilots are subject to the same medical standards. The type of pilot’s license you intend to pursue dictates what medical standards you are beholden to.
There are 4 classes of medical certification, each with graduating degrees of strictness with respect to your health and your physical and mental fitness to operate an aircraft safely.
Diabetes is addressed in each of these 4 medical certification classes, with varying degrees of tolerance for its severity, and varying degrees of strictness in terms of your ability to demonstrate effective control over this disease.
| Medical Certification Class | Purpose / Privileges |
| 1st Class Medical Certificate | Required in order to carry a Airline Transport Pilot license. This allows you to fly for the major airlines, cargo jets, and jet airplanes. Valid for 6 months if over 40 years of age. Valid for 12 months if under 40 years of age. |
| 2nd Class Medical Certificate | Required in order to carry a Commercial Pilot license. This allows you to fly for compensation or hire for any type of commercial operations, other than for those requiring a 1st class medical certificate. Valid for 12 months. |
| 3rd Class Medical Certificate | Required in order to carry a Private Pilot license. This allows you to fly for general aviation, non-commercial purposes only. Valid for 2 years if over 40 years of age. Valid for 5 years if under 40 years of age. |
| BasicMed | May be used as an alternative to the 3rd class medical certificate. Limits the type of aircraft you can fly and your destination to the continental USA only. Valid for 4 years. |
Is diabetes a disqualifying condition according to the FAA?
The FAA maintains a list enumerating what it describes as “specifically disqualifying medical conditions” which would preclude an individual from being able to obtain the requisite medical certificate needed in order to obtain a pilot license.
The FAA specifically calls out diabetes in the Federal Aviation Regulations for each of the aforementioned classes of medical certificates, with the exception of BasicMed:
| Medical Certification Class | Federal Aviation Regulation Citing Diabetes As A Disqualifying Condition |
| 1st Class | 14 CFR 67.113(a) |
| 2nd Class | 14 CFR 67.213(a) |
| 3rd Class | 14 CFR 67.313(a) |
| BasicMed | Not Applicable |
Having said that, the FARs make a provision, in 14 CFR 67.401(a), to allow for the discretionary authority for “Special Issuance” medical certificates, which is covered in detail later in this publication.
How does diabetes affect general aviation?
If you are seeking a pilot’s license for recreational purposes only, and have no intention of flying commercially for compensation or hire, then the requirements for diabetes control are less restrictive. Note here that the operative phrase is “less restrictive”, not “absent” or “more lenient”.
The FAA takes diabetes seriously, no matter whether you seek to fly for business or for pleasure.
If you intend to fly simple general aviation aircraft only, that too of the four-seater or six-seater variety, then you can opt to fly under the provisions of a medical program called BasicMed.
Unlike the other three classes of medical certification, BasicMed does not require you to be seen by an AME. You need only to be examined by a general physician, once every four years, who conducts a general physical exam and fills out a form, attesting to your general fitness to fly.
BasicMed does not explicitly call out any medical conditions that would disqualify you from exercising the role of pilot-in-command of an aircraft. Instead, it relies on the subjective evaluation of the general physician to assess your fitness for flight, given the evidence and the information disclosed on the FAA BasicMed form.
If the general physician can objectively determine that you are successfully keeping your diabetes under control, and that you are able to do so during flight, then they may clear you for flight. If, on the other hand, they determine that your diabetes poses a legitimate safety risk, then they may indicate otherwise, during your general physical exam.
BasicMed vs 3rd Class: Which is better for diabetic pilots?
When it comes to general aviation, as shown in the chart above, private pilots have two options in terms of medical certification: BasicMed or the 3rd class medical certificate.
While it is true that BasicMed is the most hassle-free way for diabetic pilots to get medically certified to fly, there may be some situations that justify or warrant you obtaining a 3rd class medical certificate instead.
| BasicMed | Third Class Medical Certificate |
| You cannot carry more than 5 passengers (with yourself being the 6th). | There is no restriction on the number of passengers you can carry, subject to the physical limitations of the aircraft. |
| You can not fly at or above an altitude of 18,000 feet above sea level. | You may fly above 18,000 feet with a 3rd class medical certificate only if you also have an Instrument Rating. |
| You cannot fly faster than 250 knots. | There is no airspeed restriction, except as imposed by certain categories of airspace. |
| The weight of the aircraft cannot exceed 6,000 pounds at the time of takeoff. | There is no weight limit for the aircraft. |
| You cannot fly for compensation or hire. | You can fly for compensation or hire with a 1st or 2nd class medical certificate, not with a 3rd class medical certificate. |
| You may only fly within the United States or in countries that accept BasicMed (which are Mexico and the Bahamas, as of this writing). | You can fly anywhere in the world that a United States pilot license is permitted. |
| You need to take an online medical course and pass a quiz every 2 years. | No online medical course is required. |
| You must be seen by a general physician every 4 years. | You must be seen by an Aviation Medical Examiner (AME) every 5 years if you are under the age of 40, or every 2 years if you are age 40 or older. |
3rd Class Medical Certification For Diabetic Pilots
Based on the chart shown above, the FAA has imposed restrictions on what a general aviation private pilot can do under BasicMed. But what if you wish to fly faster, more high-performance, and complex aircraft?
What if, as a diabetic general aviation pilot, you wish to fly a multi-engine aircraft, or an aircraft capable of flying faster than 250 knots, or carry more than 6 passengers?
In this case, your only recourse is to opt for obtaining a 3rd class medical certificate instead.
Unlike BasicMed, which only requires a physical exam by a general physician, the 3rd class medical exam must be administered by an FAA-licensed Aviation Medical Examiner (AME). The exam itself will be more comprehensive and will be focused specifically on ensuring fitness for flight.
Prediabetics With A Low A1C Can Be Medically Cleared To Fly
Prediabetics who take a blood test whose results show an A1C of less than 6.5 can be cleared for flying by an Aviation Medical Examiner (AME). This is true for all classes of medical certification.
Furthermore, A1C control using diabetes treatment medication such as metformin is allowed.
Can Pilots Who Take Insulin Be Medically Cleared To Fly?
Under current FAA regulations, if you require the use of insulin and / or other oral medication (other than metformin) in order to keep your blood-sugar level under control, then the FAA cannot automatically grant you a 3rd class medical certificate. You would need to apply for what is known as a Special Issuance medical certificate.
The silver lining is that you would not need to undergo any type of continuous glucose monitoring (CGM). You would need only to periodically demonstrate that your A1C is being kept within acceptable limits.
Special Issuance Medical Certification For Diabetics
Unlike the standard 1st, 2nd, or 3rd class medical certifications, a Special Issuance medical certificate must be issued to diabetic pilots. This is true for both Type 1 and Type 2 diabetes.
The difference between a standard medical certificate and a special issuance medical certificate is that the latter requires a higher level of scrutiny and monitoring than any of the former.
You may be required to submit further evidence documenting that your diabetes is under control and that it is not a debilitating condition that could potentially pose a risk to the safe operation of an aircraft. It may take longer to get a special issuance certificate. And the period of time for a special issuance certificate may be shortened, at the discretion of the FAA. Thus you may be required to renew your special issuance certificate more frequently, relative to the validity timelines of a standard medical certificate.
The length of time the special issuance is valid for, and the level of documentation required, will vary individually on a case-by-case basis.
Unlike a standard medical certificate that is wholly administered and issued by an AME, consideration for a special issuance certificate requires that your case be reviewed directly by the FAA, before it can be granted.
Can I become a commercial pilot with diabetes?
On November 7th, 2019, the FAA issued a groundbreaking new directive that went into effect, ushering in a pathway for insulin-dependent diabetic individuals to pursue a Commercial or Airline Transport Pilot license.
Diabetes is no longer a barrier to becoming a commercial pilot.
This directive is now part of the Federal Register.
According to this directive, new risk mitigation protocols have been put into place to allow AMEs to better evaluate and assess an individual’s diabetes management regimen in light of their fitness to be able to safely operate an aircraft.
With advances in modern medical technology, this is now possible.
Nonetheless, diabetic individuals seeking to become commercial pilots must still apply for a Special Issuance medical certificate. This means that your diabetes must still be closely monitored and kept under control, in order for you to maintain your Special Issuance status.
However, the former process that was more case-by-case oriented and required greater scrutiny, and one in which it might have been construed as the decks being stacked against aspiring pilots who suffer from diabetes, the floodgates have now been opened, greatly simplifying the path toward qualifying to earn this medical certificate.
FAA Requirements For 1st or 2nd Class Special Issuance
According to The American Diabetic Association, pilots are required to use a Continuous Glucose Monitoring (CGM) device, if applying for a 1st class or 2nd class medical certificate (which are required for commercial flying).
The FAA has published the requirements for consideration for a special issuance 1st or 2nd class medical certificate:
- Pilots must undergo an initial comprehensive clinical consultation from the endocrinologist who is treating you.
- You will need to submit an Initial/Annual lab comprehensive panel.
- You will need to submit 12 months of CGM data using an FAA-approved CGM device, in which the measurements fall within the parameters as defined in their requirements publication.
- You will need to undergo an eye exam administered by a board-certified ophthalmologist (not optometrist).
- You must undergo a Cardiac Risk Evaluation administered by a board-certified cardiologist.
The aforementioned information has also been encapsulated in this concise checklist, to make it easier for pilots to ensure all of the above are completed, documented, and submitted properly.
The FAA has published a Guide For Aviation Medical Examiners for how to evaluate a pilot’s diabetes management in consideration for a medical certificate.
In some circumstances, a Statement of Demonstrated Ability (SODA) may also be required.
FAA Requirements For 3rd Class Special Issuance
If you are only seeking special issuance for a 3rd class medical certificate, which is sufficient for general aviation flying, the requirements are less stringent.
Unlike for a commercial certificate, you are not required to use a CGM or submit CGM data.
The FAA requirements for a 3rd class special issuance medical certificate for diabetics are as follows:
- No recurrent episodes (2 or more) of hypoglycemia in the past 5 years.
- No episodes of hypoglycemia within the past 1 year, that resulted in unconsciousness, seizures, impaired cognitive function.
- The pilot must provide medical records as well as any accident records as they pertain to their history with diabetes.
- A complete medical examination administered by a physician (preferably one who specializes in diabetes treatment) within the previous 90 days. The results of the examination should be documented using the FAA-published requirements for an Initial Comprehensive Report.
As with the 1st or 2nd class special issuance certificates, there may also be circumstances that warrant a Statement of Demonstrated Ability (SODA) for 3rd class special issuances as well.