MetabolicSpecial Issuance RequiredBasicMed Eligible

Type 2 Diabetes Certification

Last updated: 2026-09-12

Quick Facts

  • Diet-controlled diabetes: your AME can issue if you have no disqualifying complications
  • Any diabetes medication requires Special Issuance — the FAA decides your first certificate
  • Initial A1C target is below 9.0, measured within 90 days of your exam
  • Up to 3 non-insulin medications, only one from each FAA medication group
  • Observation after starting a new diabetes medication: 14 to 60 days depending on the drug
  • Insulin: 6 months stable; CGM protocol required for 1st and 2nd class
  • Prediabetes on one weight-loss medication (metformin, liraglutide, Wegovy, Zepbound) can be CACI if A1C is 6.4% or lower
  • After approval, your treating physician must evaluate you annually

Overview

How the FAA handles type 2 diabetes depends on how it's treated. Diabetes controlled by diet alone is the simplest case: you're eligible for all classes as long as you have no disqualifying heart, nerve, kidney, or eye complications, and your AME can issue. Once you take any medication for diabetes — pills, a GLP-1 injection, or insulin — you need an Authorization for Special Issuance, and the FAA makes the first decision. Your AME must defer your initial exam.

For diabetes treated with non-insulin medication, you'll submit either the FAA's Diabetes or Hyperglycemia on Medications Status Report or a detailed clinical progress note from your treating physician dated within 90 days of your exam. It must say whether you have any diabetes-related organ disease and whether you've had any low blood sugar episodes in the past year. You'll also need an A1C within 90 days of the exam and at least 30 days after any medication change. The FAA's initial targets are an A1C below 9.0 and an acceptable combination of medications: up to three non-insulin medications, no more than one from each FAA medication group, with an observation period after starting — 14 days for metformin alone, 30 days for most other groups, and 60 days for sulfonylureas or meglitinides. After approval, your AME can issue later certificates under the terms of your Authorization, and you'll need an annual follow-up evaluation from your treating physician.

Insulin-treated pilots can be certified in all classes, but only after being clinically stable on their current regimen for at least 6 months. First- and second-class applicants must use the FAA's continuous glucose monitoring (CGM) protocol; third-class applicants can choose the CGM protocol or a non-CGM option. After starting or adding insulin, the observation period is 90 days for third class and 180 days for first and second class. Insulin pumps are acceptable.

Weight-loss medication is a separate path. As of August 26, 2026, if you have prediabetes (not diabetes) and take a single medication — metformin, liraglutide, semaglutide (Wegovy), or tirzepatide (Zepbound) — your AME can issue under the CACI Prediabetes Worksheet, as long as your A1C is 6.4% or lower and has never been 6.5% or higher. If you have a diabetes diagnosis, the same medications fall under the diabetes Special Issuance process above.

FAA Requirements

Diet-Controlled
AME can issue if there is no disqualifying cardiovascular, neurological, renal, or eye disease
Non-Insulin Medication
Special Issuance — the AME must defer your first exam; the FAA decides
Documentation
Diabetes or Hyperglycemia on Medications Status Report, or a detailed clinical progress note no more than 90 days old
A1C
Within 90 days of the exam and at least 30 days after any medication change; initial target below 9.0
Medication Combinations
Up to 3 non-insulin medications, no more than one from each FAA group (A–G); meglitinides can't be combined with GLP-1/DPP-4 drugs
Observation After Starting
14 days (metformin only), 30 days (most other groups), 60 days (sulfonylureas/meglitinides); 48 hours after a dose change
Insulin
6 months clinically stable; CGM protocol required for 1st and 2nd class; 3rd class may use the non-CGM option; 90-day (3rd) or 180-day (1st/2nd) observation after starting insulin
Follow-Up
Annual treating physician evaluation; AME may issue subsequent certificates under your Authorization
Certificate Classes
All classes eligible, including insulin-treated pilots

Document Checklist

Gather these documents before your AME appointment to avoid delays and deferrals.

  • 1FAA Form 8500-8 (MedXPress) with full disclosure of your diabetes diagnosis and all medications
  • 2Diabetes or Hyperglycemia on Medications Status Report, or a detailed clinical progress note (within 90 days)
  • 3A1C lab result within 90 days of your exam and at least 30 days after any medication change
  • 4Current medication list with doses and start or change dates
  • 5Documentation of any low blood sugar episodes in the past year
  • 6Reports on any diabetes-related heart, nerve, eye, or kidney disease
  • 7Insulin-treated pilots: CGM data and the FAA insulin protocol documents for your certificate class
  • 8Prediabetes on weight-loss medication: clinical progress note and A1C within 90 days for the CACI worksheet

Related Medications

Use our medication checker to see the FAA status of each medication related to this condition.

Sources & References

Last verified: 2026-09-12

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Important Disclaimer

This guide provides FAA regulatory information for educational purposes only. It does not constitute medical advice, legal advice, or a guarantee of certification outcome. FAA policies are subject to change. Always consult with a qualified Aviation Medical Examiner (AME) and/or aviation attorney for guidance specific to your individual situation. ClearedMed is not affiliated with or endorsed by the FAA.