By Abid Farooqui, President and Founder, SilverLight Aviation. Abid has over 20 years of experience flying, designing, manufacturing, and supporting light sport aircraft. He has led FAA compliance processes and ASTM audits for multiple aircraft manufacturers, including Progressive Aerodyne, American Legend Cub, Evolution Trikes, Skyrunner, and Texas Aircraft Colt, and has worked directly with the FAA on the details of the MOSAIC rule. | Reviewed by Stacey Farooqui, MBA, Technical Writer and Content Strategist. Stacey has written technical documentation for aircraft and brings over a decade of aviation industry marketing experience.

Quick answer: Manufacturers currently certified under 14 CFR Part 23 or CS-VLA often expect the light-sport category to represent a lower-complexity compliance environment. Under MOSAIC, that assumption needs reexamination. 14 CFR Part 22 and the new ASTM F37 standards that govern it have a different architecture and different compliance demonstration requirements from what your team has built under Part 23. Your existing engineering rigor is an asset. Your existing compliance documentation is not a direct transfer. This article explains where the gap is and how to scope it accurately.

What the Light-Sport Category Looks Like Under MOSAIC

The FAA’s MOSAIC rule established 14 CFR Part 22 as a dedicated regulatory framework for light-sport category aircraft, with Phase 2 taking effect July 24, 2026. For light-sport category airplanes specifically, MOSAIC removed the previous 1,320-pound gross weight limit, raised the speed ceiling to 250 knots CAS, expanded seating to up to four occupants, and permitted retractable landing gear, constant-speed propellers, and electric or turbine powerplants. The category is no longer defined by a weight ceiling; it is defined by the compliance pathway.

For Part 23 and CS-VLA manufacturers, this expanded design space is commercially relevant. Aircraft designs that previously sat above the light-sport weight limit may now fall within it. Designs that were economically unattractive under the old limits may become viable. The market opportunity is real. What matters is understanding clearly that Part 22 compliance is not a subset of what you already do under Part 23. It is a different framework, built by a different standards body, for a different certification purpose.

The ASTM F37 Standards: A Different Architecture from What You Know

Under Part 23, compliance is demonstrated by reference to Federal Aviation Regulations, with supporting advisory circulars and accepted means of compliance. Under Part 22, the technical compliance pathway runs through the ASTM Committee F37 on Light Sport Aircraft, which produces the consensus standards the FAA accepts as the basis for Part 22 airworthiness certificates.

The architecture of those standards is modular. Each aircraft category has an integration standard that references a set of functional modular standards covering structural loads, occupant safety, landing gear, electrical systems, fuel containment, propulsion, propellers, systems and equipment, flight stability, performance and flight characteristics, aeroelastic behavior, and night flight, among others. Cross-cutting standards for Quality Assurance, Required Product Information, and Continued Operational Safety apply across all categories. Optional standards cover IMC flight and whole-plane parachute systems where applicable.

Standard selection is not automatic. Your engineering team must identify which modular standards apply to your aircraft’s category and configuration, and determine how each standard applies to your specific design. Selecting the wrong standards, or missing applicable ones, creates compliance gaps that surface at the worst possible time. This is one of the areas where direct experience inside the ASTM F37 standards development process makes a material difference to your program.

Where Your Existing Work Applies and Where It Does Not

Part 23 manufacturers bring genuine advantages to a Part 22 program. Structural engineering discipline, load calculation methodology, flight test planning experience, quality management systems, and documentation culture all transfer. The engineering rigor that Part 23 demands is the same rigor Part 22 requires. In fact, the structural loads are higher than Normal Category Part 23 load requirements. What does not transfer directly is the compliance documentation itself.

Your Part 23 type certificate data sheet, your FAA-approved flight manual, and your type design documentation were produced to satisfy FAA regulations and advisory circulars. The ASTM F37 standards require a different document set: design compliance reports structured to ASTM specifications, test plans and test reports organized by reference to the applicable modular standards, a Pilot Operating Handbook and Maintenance and Inspection Procedures built to the ASTM Required Product Information standard, a Quality Management System demonstrating compliance with the ASTM QA standard, and a Continued Operational Safety program meeting ASTM COS requirements.

The pre-MOSAIC ASTM consensus standards are no longer the accepted compliance basis for new light-sport category certifications after July 24, 2026. The new ASTM F37 standards have a different structure, and compliance documentation must be rebuilt to satisfy them. Existing Part 23 documentation informs that rebuild; it does not substitute for it.

Quality Systems and Required Product Information: Not a Simplified Version

One assumption we hear consistently from Part 23 manufacturers is that the ASTM QA and RPI standards will be simpler than what they already maintain. In practice, the ASTM F37 QA standard enumerates specific required elements: document change control, engineering change control, materials review, vendor qualification and audits, assembly travelers, quality inspections, first article inspection, configuration management, and record-keeping for the life of the aircraft model. These requirements are specific, auditable, and must be demonstrated in your production operation, not simply mapped from an existing system.

The Required Product Information standard governs your Pilot Operating Handbook, Flight Training Supplement, and Maintenance and Inspection Procedures. These are compliance documents with defined content and format requirements, not user guides produced to your own standard. If your existing manuals were written for Part 23 purposes, they need to be rebuilt to ASTM RPI specifications, not reformatted.

Continued Operational Safety: A Different Ongoing Obligation

Part 23 manufacturers operate under an FAA-regulated airworthiness directive and service bulletin framework for continued airworthiness. Part 22 uses a different mechanism: the ASTM Continued Operational Safety standard, which requires a formal customer feedback system, a Major Repair Authorization process, a service issue tracking system, and maintained records documenting the program’s operation over the life of the aircraft model.

The concepts are familiar. The implementation is not equivalent. Your existing continued airworthiness processes need to be evaluated relative to the ASTM COS standard specifically, and in most cases rebuilt to satisfy it. For manufacturers accustomed to the FAA-regulated Part 23 framework, this is often the area that requires more effort than expected.

How a Part 22 Entry Program Is Scoped and Managed

The right starting point for a Part 23 manufacturer entering the light-sport category is a structured gap assessment: a review of your existing engineering documentation, QMS, and product information relative to the applicable ASTM F37 standards to establish what exists, what needs to be adapted, and what needs to be built from scratch. That assessment produces an accurate project scope and timeline, which cannot be reliably estimated without it.

SilverLight Aviation manages Part 22 compliance projects using AGILE methodology structured around defined SPRINTs, each with specific deliverables at the end of the cycle. This keeps programs moving, surfaces blockers early, and gives management clear visibility into progress relative to the certification timeline. The approach is tracked in Jira, so every stakeholder knows what is complete, what is in progress, and what is coming next.

Services are scoped as a base consulting package, where your engineering and QA team executes the detailed work under expert guidance, or expanded to include direct engineering deliverables such as load calculations, test plan writing, manual authoring, and compliance flight test support. Most Part 23 manufacturers need a combination weighted toward guidance rather than direct engineering, because the internal capability already exists; what is needed is ASTM F37-specific direction.

Why Standards Development Experience Changes the Outcome

Abid Farooqui, President and Founder of SilverLight Aviation’s aviation engineering consultancy, has been directly involved in developing the new ASTM consensus standards that align with Part 22 requirements, including category-specific design standards and the cross-cutting QA, RPI, and COS standards. Understanding what the standards intend and how they were written makes a material difference when a compliance approach requires interpretation, when test results are borderline, or when an FAA auditor questions a methodology.

That involvement is combined with direct leadership of FAA compliance processes and ASTM audits for multiple aircraft manufacturers, and direct engagement with the FAA on the MOSAIC rule itself. For a Part 23 manufacturer entering a new compliance framework, the consultant’s depth of knowledge inside that framework determines how efficiently your existing engineering capability is directed toward certification.

SilverLight Aviation also manufactures the American Ranger 1 (AR-1) gyroplane and the Recon quick-build kit airplane to the same Part 22 and ASTM F37 standards we help other manufacturers navigate. The first factory-built AR-1 gyroplanes begin deliveries in October 2026.

READY TO SCOPE YOUR LIGHT-SPORT CATEGORY ENTRY?

SilverLight Aviation offers a discovery engagement to assess your Part 22 compliance gap and build a realistic project plan before production timelines are affected. If you are evaluating the light-sport category as a market entry, the right first step is understanding exactly where your existing certification work applies and where new compliance work begins.

FREQUENTLY ASKED QUESTIONS

Can a Part 23 type-certificated aircraft be re-certified as a light-sport category aircraft under Part 22?

No. A type-certificated aircraft certified under 14 CFR Part 23 and a light-sport category aircraft certificated under 14 CFR Part 22 are two separate regulatory classifications with different maintenance, airworthiness, and modification frameworks. Entering the light-sport category requires designing and certifying an aircraft to the ASTM F37 standards accepted under Part 22; it does not involve converting an existing type certificate. If you are a Part 23 manufacturer, your path into the light-sport category runs through a new aircraft program built to Part 22 from the start. The same model can be brought into Part 22 but no direct transfer can be made. Proper compliance evaluation and gap assessment is needed.

Does CS-VLA compliance provide any direct credit toward ASTM F37 compliance under Part 22?

CS-VLA is an EASA certification standard, not an FAA standard, and it does not provide direct regulatory credit toward Part 22 compliance. The ASTM F37 standards framework has a different architecture and different compliance demonstration requirements. A manufacturer with CS-VLA experience has engineering discipline, structural analysis capability, flight test experience, and quality system maturity that are all directly applicable to a Part 22 program. Those capabilities need to be directed toward the ASTM F37 standards specifically. A gap assessment is the right starting point.

What ASTM F37 standards apply to a light-sport category airplane entering the market under Part 22?

The applicable standards depend on your aircraft’s configuration, category, and optional features. The new ASTM F37 standards are modular: an integration standard for your aircraft category references functional modular standards covering structural loads, occupant safety, landing gear, electrical systems, fuel containment, propulsion, propellers, systems and equipment, flight stability, performance and flight characteristics, aeroelastic behavior, and night flight. Cross-cutting standards for Quality Assurance, Required Product Information, and Continued Operational Safety apply regardless of category. A Part 22 compliance specialist with direct standards development experience is the right resource for standard selection; errors at this stage affect the entire compliance program.

How long does a Part 22 market entry program take for a manufacturer with existing Part 23 experience?

Timeline depends on your engineering documentation maturity, the complexity of the aircraft, your internal staff capacity, and the number of applicable ASTM F37 standards. A structured discovery engagement for ASTM F37 compliance is the correct way to estimate scope and timeline accurately for your specific situation. AGILE project management with defined SPRINTs keeps complex compliance programs on schedule and surfaces resource constraints before they become deadline problems.

Is the ASTM F37 QA standard less demanding than what Part 23 manufacturers already maintain?

Not in the way most Part 23 manufacturers expect. The ASTM F37 QA standard enumerates specific required elements: document change control, engineering change control, materials review, vendor qualification, assembly travelers, first article inspection, configuration management, and life-of-model record-keeping, all of which must be demonstrated in your production operation. A Part 23 manufacturer’s existing QMS may cover many of these elements, but a gap assessment is required before any compliance claim can be made. Assuming equivalence without assessment is one of the most common errors in Part 22 market entry programs.

What is the difference between the base consulting package and additional engineering services for a Part 23 manufacturer?

The base consulting package assumes your engineering and QA resources execute the detailed compliance work under expert guidance from a consultant with direct ASTM F37 standards development experience. Additional services include direct engineering deliverables such as load calculations, test plan writing, manual authoring, and compliance flight test support. Most Part 23 manufacturers need the base package weighted toward standards interpretation and gap assessment, with targeted additional services where internal capacity is limited. The right scope is determined through a discovery engagement, not assumed in advance.

ABOUT THE AUTHOR

Abid Farooqui, President and Founder, SilverLight Aviation

Abid Farooqui is the President and Founder of SilverLight Aviation, the Zephyrhills, Florida-based manufacturer behind the award-winning American Ranger 1 (AR-1) gyroplane and the Recon quick-build kit airplane. Established in 2012, SilverLight Aviation has grown under Abid’s leadership into one of the most respected names in light sport aircraft manufacturing in the United States.

With over 20 years of experience flying, designing, manufacturing, and supporting light sport aircraft, Abid is a recognized expert in FAA airworthiness certification and ASTM compliance for light-sport aircraft. He has been directly involved in developing the new ASTM consensus standards that align with Part 22 requirements, including category-specific design standards and the cross-cutting QA, RPI, and COS standards. He has successfully led compliance processes and FAA audits for multiple aircraft manufacturers, including Progressive Aerodyne (SeaRey amphibian airplane), American Legend Cub (Super Legend), Evolution Trikes, Skyrunner, and Texas Aircraft Colt. Abid has also worked directly with the FAA on the details of the MOSAIC rule, giving him firsthand insight into the regulatory changes reshaping light sport aviation.

Abid’s expertise in the evolving MOSAIC regulatory landscape has led SilverLight Aviation to expand its aviation engineering consultancy services to include MOSAIC compliance guidance for aircraft manufacturers. He is a sought-after voice in the light sport aviation industry on topics including ASTM standards for light-sport aircraft certification, FAA certification, and the practical implications of the new light-sport category rules for both manufacturers and pilots.

Read more articles by Abid on the SilverLight Aviation blog.