FAA Form 8100-9: Signing, Submission, and Common Errors

FAA Form 8100-9, the Statement of Compliance with Airworthiness Standards, is the single-page document an Organization Designation Authorization (ODA) engineering unit member signs to certify that specific design data meets the airworthiness requirements in Title 14 of the Code of Federal Regulations.¹ Each form records one compliance finding: the signer has examined the listed drawings, analyses, and test reports, and found them to satisfy the cited regulations. The form travels with type certificate projects, supplemental type certificates, parts manufacturer approvals, and major design changes, and small mistakes on it — wrong signer, wrong approval box, missing data reference — are what stall otherwise finished certification work.

When You Need to File One

Form 8100-9 is the vehicle for documenting a compliance finding whenever an applicant has to prove that technical data conforms to FAA airworthiness standards. The situations that call for it include:

Type certificate projects for a new aircraft, engine, or propeller, where ODA engineering unit members document findings on the 8100-9 throughout the program.
Supplemental type certificates, where the form certifies that altered design data still meets airworthiness requirements.²
Parts manufacturer approval projects, where the form certifies that a replacement part’s design data meets the same standards as the original type design.²
Major repairs and alterations approved by an ODA holder using its own delegated authority.

The regulatory hook is 14 CFR 21.20, which requires every TC, amended TC, and STC applicant to show compliance with all applicable requirements and to give the FAA the means by which compliance was demonstrated.³ The 8100-9 is how delegated organizations meet that obligation finding by finding.

Not every design change requires the form. Under 14 CFR 21.93, a minor change is one with no appreciable effect on weight, balance, structural strength, reliability, or operational characteristics affecting airworthiness; everything else is a major change and requires a formal compliance demonstration.⁴ Major changes are where the 8100-9 lives.

What Goes on the Form

The form is one page, but it has to tie together the data, the product, and the standard. The top block identifies the aircraft or component by make, model number, and product type — aircraft, engine, propeller, or other — along with the applicant’s name or the delegated organization’s authorization number.¹

The main body is a “List of Data” table. Each row identifies one document being certified by its identification number, title, and purpose. Typical entries are engineering drawings with revision levels, stress analyses, test reports, and specification documents. The form also requires a clear listing of the applicable airworthiness requirements by specific section of 14 CFR (Part 23, 25, 27, 29, 33, or 35, among others). If the data package runs longer than one sheet, note the number of attached continuation sheets.¹ Each 8100-9 also has to identify the ODA certification project it supports.²

Who Can Sign It

The signature is a personal certification that the listed data was examined under established procedures and found to comply with the cited standards, so only individuals with specific delegated authority can sign.¹ The 8100-9 is the form ODA engineering unit members use.

A Designated Engineering Representative acting individually — not through an ODA — uses a different form for the same function: FAA Form 8110-3, which shares the same title. The 8110-3 is a DER’s only means of approving technical data when making a compliance finding. A DER who also serves as an ODA unit member generally does not issue an 8110-3 for ODA projects; the exception is a type certificate holder’s DER supporting a major repair, alteration, and airworthiness ODA.⁵

Management DERs cannot sign either form. Their role is non-technical project management, not compliance finding.⁵

Approve or Recommend Approval

The certification block offers two choices: “Approve these data” or “Recommend approval of these data.” Picking the wrong one is one of the most common administrative errors on the form.

Choose “Approve” when the finding falls within the authority the FAA has delegated to the ODA. That approval takes effect immediately, with no further FAA review. Choose “Recommend approval” when the FAA has reserved the final determination on that particular finding. These reserved areas, called “specific findings,” typically involve regulatory interpretations, novel or unusual design features, or compliance showings for noise and emissions standards.²

When you recommend approval, submit the supporting technical data with the form so the FAA can conduct its own review. The agency’s direction at the start of a certification project generally identifies which findings it has reserved for itself.²

Submission and FAA Review

Once signed, the 8100-9 becomes part of the larger certification package. Engineering or flight test representatives within the ODA unit approve the form as part of documenting compliance for the project.² The original goes to the FAA’s oversight management team (OMT), which confirms that the delegated authority acted within the scope of its authorization and that the technical data supports the required safety level.

The FAA does not publish a standard turnaround for OMT review of individual 8100-9 submissions. Actual timing depends on the complexity of the finding, agency workload, and whether the form uses “approve” or “recommend approval.” When the form supports a foreign authority’s request, the completed 8100-9 serves as evidence of FAA approval of the repair or alteration procedure.

Common Errors That Get the Form Rejected

The FAA’s oversight evaluation process classifies the kinds of discrepancies that invalidate compliance findings. Watch for these:

Technical discrepancies: math errors, inadequate compliance determinations, or relying on engineering analysis when the regulation actually requires a physical test.⁶
Procedures manual violations: the organization did not follow its own FAA-approved internal procedures when making the determination.⁶
Regulatory noncompliance separate from the airworthiness standard itself. A classic example: failing to submit the names of authorized staff to the FAA before they started approving data.⁶
Wrong approval status: selecting “Approve” on findings the FAA reserved for itself, or “Recommend approval” unnecessarily, which routes routine findings through the OMT and delays the project.⁶
Ignoring relevant FAA orders, notices, policy memos, or handbook bulletins that apply to the finding.⁶

The technical discrepancies tend to be the most consequential because they go to the substance of the safety finding. An incomplete stress analysis, or a compliance showing built on analysis when the rule demands a test, can unravel months of certification work.

Penalties for False Statements

Because the 8100-9 is a legal certification of safety compliance, inaccurate statements carry heavy consequences. Under 14 CFR 3.403, no person may make a fraudulent or intentionally false statement in any document used to show compliance with FAA requirements, and no person may knowingly omit a material fact from such a document.⁷

The financial exposure is substantial. For a production certificate holder that knowingly presents a nonconforming aircraft for an initial airworthiness certificate, the maximum civil penalty is $1,212,278 per violation under the most recent adjustment. The same ceiling applies to knowingly failing to submit safety-critical information or omitting it from a flight manual. General regulatory violations by organizations can reach $75,000 per occurrence.⁸

Beyond fines, the FAA can deny, suspend, or revoke any certificate, approval, or designation held by the person or organization responsible.⁷ For an ODA holder, losing the delegation effectively ends the ability to approve its own design data, which is usually the core of the business.

Records and Digital Signatures

The ODA holder keeps copies of every executed 8100-9 along with the supporting technical data, and those records have to be readily available for FAA audits, maintenance actions, and continuing airworthiness reviews. Under 14 CFR 91.417, maintenance and alteration records generally must be kept until the work is repeated or superseded, or for one year, whichever is longer, and records tied to the aircraft’s ongoing airworthiness status transfer with the aircraft when it is sold.⁹ In practice, most organizations keep 8100-9 forms and their associated data for the product’s entire service life, since the form documents the original finding that the design met airworthiness standards.

Digital signatures are permitted if they meet authentication standards. Under AC 120-78B, a digital electronic signature must use Public Key Infrastructure cryptography and a digital certificate issued by a trusted certificate authority, and the private signing key must remain under the sole custody of the signer at all times, with system controls preventing unauthorized use.¹⁰ Organizations moving to electronic workflows should confirm their signature technology aligns with Federal Information Processing Standards Publication 186-5, the Digital Signature Standard. A signature that fails those requirements can undermine the legal validity of the compliance finding on the form.

1
Federal Aviation Administration. FAA Form 8100-9 – Statement of Compliance with Airworthiness Standards
2
Federal Aviation Administration. FAA Order 8100.15 – Organization Designation Authorization Procedures
3
eCFR. 14 CFR 21.20 – Compliance With Applicable Requirements
4
eCFR. 14 CFR 21.93 – Classification of Changes in Type Design
5
Federal Aviation Administration. FAA Order 8110.37F – Designated Engineering Representative (DER) Handbook
6
Federal Aviation Administration. FAA Order 8100.9A – DAS, DOA, and SFAR 36 Authorization Procedures
7
eCFR. 14 CFR 3.403 – Falsification, Reproduction, Alteration, or Omission
8
Federal Register. Revisions to Civil Penalty Amounts, 2025
9
Federal Aviation Administration. AC 43-9D – Advisory Circular: Maintenance Records
10
Federal Aviation Administration. AC 120-78B – Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals