An individual with diabetes can obtain a pilot’s license, but the process requires demonstrating exceptional medical control and strict adherence to specific Federal Aviation Administration (FAA) protocols. Certification is governed by a rigorous medical review designed to ensure the condition does not pose a risk of pilot incapacitation during flight. Advancements in diabetes management technology have allowed the FAA to evolve its policies, opening the door for pilots who manage their condition responsibly. This opportunity demands a high level of discipline and a commitment to ongoing medical documentation to satisfy safety standards.
Understanding Medical Certification Classes
The privileges a pilot may exercise are tied directly to the class of medical certificate they hold, which establishes the regulatory framework for all aviators.
The Third Class medical certificate is the entry-level standard, required primarily for private pilots who fly for recreation and are not compensated. This certificate generally has the lowest medical scrutiny.
A Second Class medical certificate is required for commercial pilots who fly for hire, such as corporate pilots or flight instructors, but who are not operating as an Airline Transport Pilot (ATP). The First Class medical certificate represents the highest standard of health and is mandatory for those who wish to serve as an ATP, including captains and first officers for major commercial airlines. As the certificate class increases, the medical requirements become progressively more stringent, reflecting the greater public safety responsibility associated with those operations.
The FAA’s Stance on Diabetes and Flying
The FAA’s initial stance on diabetes depends on the treatment method used to maintain blood glucose levels. Standard FAA regulations, outlined in 14 CFR Part 67, generally consider insulin-treated diabetes mellitus (ITDM), which typically includes Type 1 diabetes, to be a medically disqualifying condition. This disqualification stems from the concern that insulin treatment carries a risk of acute hypoglycemia, or dangerously low blood sugar, which could lead to pilot incapacitation during a flight.
In contrast, non-insulin-dependent diabetes managed solely through diet, exercise, or acceptable oral medications does not typically require the same level of intervention. For these cases, an Aviation Medical Examiner (AME) can often issue a medical certificate directly. The applicant must demonstrate stable control of their blood sugar levels, show they have not experienced any significant hypoglycemic episodes, and confirm there are no progressive complications affecting organs like the eyes or heart.
Navigating the Special Issuance Process
Pilots with insulin-treated diabetes must obtain a waiver known as an Authorization for Special Issuance (SI), granted under 14 CFR § 67.401. This process allows the Federal Air Surgeon to issue a medical certificate to an applicant whose condition is otherwise disqualifying.
The procedural steps begin when an Aviation Medical Examiner defers the application to the FAA for review. The applicant must submit extensive documentation demonstrating a history of excellent diabetes control, often covering at least six months of clinical stability.
Required Documentation
Required medical reports include:
A detailed diabetes history from a treating endocrinologist.
A comprehensive eye examination by an ophthalmologist.
A cardiovascular assessment.
The FAA reviews this evidence to determine if the individual can safely perform pilot duties without endangering public safety. This review can take a significant amount of time and depends heavily on the quality of the submitted medical data. The initial Special Issuance is not permanent and requires ongoing monitoring for renewal.
Required Monitoring and Documentation for Diabetics
Maintaining a Special Issuance medical certificate requires strict adherence to a protocol of continuous monitoring and documentation. For those seeking a First or Second Class medical certificate, the mandatory use of a Continuous Glucose Monitoring (CGM) system is a core requirement.
The CGM data must show that the pilot maintains blood glucose levels within a tight range, often requiring 70% or greater time-in-range (e.g., between 80 to 180 mg/dL).
Pilots must submit a detailed status report to the FAA every three to six months for renewal. This report must include the raw CGM data and a current Hemoglobin A1C test performed no more than 90 days before the renewal exam. During flight, pilots must carry a glucometer and rapidly absorbable glucose, and they are required to log blood glucose readings at specific intervals, including before and during flight.
Differences Between Private and Commercial Piloting
The medical certification process differs significantly depending on whether the pilot is pursuing private or commercial privileges. Since 1996, the FAA has allowed pilots with insulin-treated diabetes to obtain a Third Class medical certificate for private flying, acknowledging the lower public risk involved. For a Third Class SI, the pilot can elect to use a protocol relying on finger-stick glucose testing during flight, though the CGM-based protocol is also an option.
Securing a First or Second Class medical certificate for commercial operations, permitted since 2019, involves much higher scrutiny and mandatory requirements. The commercial certification protocol necessitates the use of a CGM, reflecting the FAA’s need for continuous, real-time data to authorize a pilot to fly for hire. Regulations may also impose operational limitations for commercial pilots, such as requiring multi-pilot crews, to enhance safety further.
Resources and Next Steps
Individuals beginning the medical certification journey should seek an Aviation Medical Examiner (AME) experienced in handling complex medical cases, as not all AMEs are familiar with Special Issuance protocols. Specialized examiners can provide guidance on the necessary paperwork and testing requirements to prevent application delays.
Pilot advocacy groups, such as the Aircraft Owners and Pilots Association (AOPA), maintain resources to help pilots navigate the FAA medical system. Prospective pilots should also be aware that medical requirements of international aviation authorities, such as the European Union Aviation Safety Agency (EASA), may differ from the FAA, requiring separate research if international flight operations are a goal.

