What Is FAA Form 8110-3 and When Is It Required?

FAA Form 8110-3, “Determination of Compliance with Airworthiness Standards,” is the document a Designated Engineering Representative (DER) or an authorized Organization Designation Authorization (ODA) unit member uses to formally record that specific engineering data meets FAA airworthiness requirements.1Federal Aviation Administration. Form FAA 8110-3 – Determination of Compliance with Airworthiness Standards It is the only means by which a DER can approve or recommend approval of technical data, and a completed 8110-3 is a prerequisite to every type certificate, supplemental type certificate, and parts manufacturer approval the FAA issues.2Federal Aviation Administration. FAA Order 8110.37F – Designated Engineering Representative Guidance

When the Form Is Required

The form itself lists six project categories it supports.3Federal Aviation Administration. FAA Form 8110-3 – Determination of Compliance with Airworthiness Standards You need an 8110-3 when the project falls into one of these:

  • A Type Certificate or Amended Type Certificate for a new or modified aircraft, engine, or propeller design.
  • A Supplemental Type Certificate authorizing a major design change to a previously approved product, such as a new avionics suite or a wing modification.
  • A Parts Manufacturer Approval to produce replacement or modification parts for type-certificated products.
  • A major repair to a type-certificated product that requires new engineering data to show continued airworthiness.
  • A major alteration not covered by an STC that affects airworthiness.
  • An “Other” project that doesn’t fit the categories above, which the DER must explain on the form.

The form documents findings of compliance and nothing else. It doesn’t authorize production, grant operational approval, or function as a work order. A DER who approves data on an 8110-3 is confirming only that the listed data satisfies the cited airworthiness standards.4Federal Aviation Administration. Documenting Compliance Findings

What Goes on the Form

Form 8110-3 has eleven numbered blocks, and FAA Order 8110.37F prescribes exactly what belongs in each one.2Federal Aviation Administration. FAA Order 8110.37F – Designated Engineering Representative Guidance A few of them do the real work.

Blocks 1 through 5 identify the basics: signing date, product make and model as listed on the type certificate data sheet, description of the part or product type, and the applicant’s name. Getting the make and model wrong relative to the TC data sheet is a common error that stalls projects.

Blocks 6 and 7 list the specific engineering documents reviewed, by number, date, revision level, and title. Every test report, stress analysis, drawing, or flight test result the DER relied on has to appear here by name and revision. If a document isn’t listed, it isn’t approved, no matter what was discussed in meetings or emails.

Block 8 identifies the project type and project number. For an STC, that’s the STC project number the FAA assigned. For a major repair on a specific aircraft, the aircraft serial number goes here instead.

Block 9 is where the form earns its weight. The DER enters the exact regulatory paragraphs the listed data satisfies. If the data shows an emergency exit meets dimensional and accessibility requirements, the DER cites the specific paragraph of 14 CFR 25.807.5eCFR. 14 CFR 25.807 – Emergency Exits No regulation may appear in Block 9 unless the data listed in Blocks 6 and 7 actually supports it. This one-to-one traceability between data and regulation is the core function of the entire form.

Block 10 is the certification block, where the DER checks either “Approve these data” or “Recommend approval of these data.” Block 11 captures the signature, printed name, and DER number.

Who Can Sign the Form

Only two categories of people can sign an 8110-3: an individual DER, and an authorized member of an ODA holder.6Federal Aviation Administration. FAA Order 8110.103 – Alternative Procedures for ODA Unit Members

A DER is an individual engineer authorized by the FAA Administrator under 14 CFR Part 183 to approve or recommend approval of technical data within a defined specialty.7eCFR. 14 CFR 183.29 – Designated Engineering Representatives The recognized specialties include structural, powerplant, systems and equipment, radio, engine, propeller, flight analyst, flight test pilot, and acoustical engineering. Each DER is authorized only within the limits of that delegation. A structural DER cannot sign off on avionics compliance, and a powerplant DER cannot approve cabin interior data. The signature carries real weight: the DER is certifying that they personally reviewed the referenced data, verified it demonstrates compliance with the cited regulations, and are making that determination on behalf of the FAA.4Federal Aviation Administration. Documenting Compliance Findings

Many large manufacturers and certification organizations hold an ODA, which lets their qualified employees perform the same compliance-finding functions as individual DERs. An ODA unit member signs Form 8110-3 in the DER signature block, and that signature is a finding of compliance on behalf of the ODA holder.6Federal Aviation Administration. FAA Order 8110.103 – Alternative Procedures for ODA Unit Members Note that ODA unit members follow a separate set of form-completion instructions under Order 8110.103; using the standard DER instructions instead is a source of rejected forms.

Approve vs. Recommend

The two checkboxes in Block 10 look similar and behave very differently. When a DER checks “Approve these data,” the data is approved at that moment, subject to later FAA oversight. When a DER checks “Recommend approval of these data,” the FAA itself must review and separately approve the data before it takes effect.2Federal Aviation Administration. FAA Order 8110.37F – Designated Engineering Representative Guidance

A DER can only use the “Recommend” option when their letter of authorization limits them to recommending in that area, or when FAA policy requires recommendation for the particular project. A DER with full approval authority is expected to approve to the full extent of that authority. If the DER has concerns about the data, the right move is to contact the FAA project office, not to downgrade to a recommendation as a hedge.

For the applicant, the practical difference is timeline. An 8110-3 marked “Approve” moves the project forward immediately. One marked “Recommend” adds an FAA review cycle that can take weeks or months depending on the complexity of the data and the office’s workload.

Where the Signed Form Goes

Once signed, the 8110-3 becomes part of the applicant’s certification package. Design approval projects like TCs and STCs go to the FAA Certification Branch that has oversight of the project.8Federal Aviation Administration. Certification Branches (Formerly Aircraft Certification Offices/ACOs)

An FAA engineer assigned to the project reviews the submitted statements and the accompanying data. For forms marked “Approve,” the review is an oversight check to confirm the DER acted within their authority and the form was completed correctly. For forms marked “Recommend,” the review is substantive: the FAA engineer independently evaluates the compliance finding before deciding whether to accept it. Successful acceptance of every required 8110-3 is a prerequisite to the FAA issuing the final design approval document, whether that’s a type certificate, supplemental type certificate, PMA, or approved repair data.

Common Errors That Get Forms Rejected

A handful of mistakes recur often enough to be worth watching for. The most consequential is listing a regulation in Block 9 that the referenced data doesn’t actually support. That breaks the traceability the form exists to create, and an FAA reviewer will catch it.

Other frequent problems:

  • Referencing documents by outdated revision levels, so the data has moved on but the 8110-3 still lists the older revision.
  • Omitting attachment page counts in Block 10.
  • Failing to include the applicable amendment level of the regulation being cited. A regulation amended after the project’s certification basis was established may have different requirements, and the form needs to reflect which version applies.

Penalties for a False Statement

Because Form 8110-3 is a formal submission to a federal agency, anyone who knowingly makes a false statement on it faces prosecution under 18 U.S.C. § 1001. The statute covers falsifying a material fact, making a materially false statement, or using a document that contains false information. The maximum penalty is five years in federal prison and a fine of up to $250,000.9Office of the Law Revision Counsel. 18 USC 1001 – Statements or Entries Generally

Beyond criminal exposure, a DER who approves data they know to be noncompliant risks revocation of the designation under 14 CFR Part 183.10eCFR. 14 CFR Part 183 – Representatives of the Administrator Losing a DER designation ends the engineer’s ability to make independent compliance findings, which for many consultants means losing their livelihood. The certification block is a personal attestation with teeth, not a rubber stamp.