Maintaining Aircraft for RVSM Operations in 2026

August 2026

Aircraft operating in Reduced Vertical Separation Minimum, or RVSM, airspace must continue to meet precise airworthiness, equipment, maintenance, and altitude-keeping performance standards. Although the FAA no longer requires most operators to maintain a separately approved RVSM maintenance program, RVSM maintenance has not become optional or less important. The requirement has shifted from maintaining an FAA-approved standalone program to maintaining the aircraft in the configuration and condition established by its approved RVSM design and applicable Instructions for Continued Airworthiness.

Two RVSM Authorization Paths

There are two current ways in which an operator may be authorized to conduct RVSM operations.

ADS-B Out Under Appendix G, Section 9

Many operators no longer need to apply for a specific RVSM LOA (Letter of Authorization). Part 91 Appendix G, Section 9 provides authorization when the aircraft:

Has two operational and independent altitude-measurement systems
Has at least one compliant automatic altitude-control system
Has a compliant altitude-alerting system
Has an acceptable TCAS II installation, when TCAS II is installed
Has qualified ADS-B Out meeting § 91.227, unless otherwise authorized
Has its height-keeping performance monitored in a manner acceptable to the FAA; and
Does not exceed an altimetry system error of 200 feet while operating in RVSM airspace

An operator using this pathway does not submit an application solely to obtain an RVSM LOA. Authorization is established through compliance with Section 9 rather than through the issuance of a separate approval document.

FAA guidance states that the aircraft’s altitude-keeping performance must have been monitored within the preceding 24 months in airspace where the FAA can receive sufficient ADS-B data and must have been found compliant. If that requirement is not satisfied, the aircraft must be filed and operated as non-RVSM until the deficiency is resolved.

ADS-B Out Under Appendix G, Section 3

An OpSpec, MSpec, or LOA may still be required or desirable when:

The aircraft does not have qualified ADS-B Out
The aircraft is not routinely flown where the FAA can collect enough ADS-B data to evaluate its RVSM performance
A foreign state requires a specific documented RVSM approval, or
The operator otherwise chooses or is required to use the traditional authorization process

Under this pathway, Part 135 operators generally receive an OpSpec, fractional program managers receive an MSpec, and affected Part 91 operators receive a LOA. The person (see FAA definition of person) exercising operational control is normally the proper authorization holder.

An Approved RVSM Maintenance Program Is No Longer Required

Before 2016, an operator commonly had to create an RVSM maintenance program and obtain FAA approval of that document. That specific requirement was removed from Part 91 Appendix G.

A repair station or other authorized maintenance provider therefore does not need to obtain a customer’s separately FAA-approved RVSM maintenance program before performing RVSM-related maintenance. However, the work must still be accomplished using maintenance data appropriate to the aircraft and the work being performed.

Maintaining the Approved RVSM Configuration

Configuration control is one of the most important continuing RVSM responsibilities. The operator must ensure that the aircraft continues to conform to the design configuration under which its RVSM compliance was established.

This includes verifying the eligibility and configuration of instruments, avionics, and software on board the aircraft.

Substituting a different part number, loading new software, changing an air-data source, altering a static system, or installing equipment near a static-pressure source may affect the configuration upon which RVSM compliance was based.

Height-Keeping Performance Monitoring

RVSM height monitoring remains an ongoing requirement. It is not merely a one-time certification activity.

For aircraft operating through the ADS-B Out authorization provisions of Appendix G, Section 9, the FAA monitors altitude-keeping performance during normal operations when sufficient ADS-B surveillance data are available. The FAA tracks monitoring status by aircraft serial number. A change in registration or ownership does not automatically erase the monitoring status of a properly maintained aircraft.

Operators should verify that an acceptable monitoring result has been recorded for each aircraft rather than assume that routine flight through ADS-B airspace has satisfied the monitoring requirement. The FAA directs operators using the Part 91 Appendix G, Section 9 authorization to review the applicable NAARMO report, which lists aircraft and their most recent successful monitoring dates. NAARMO maintains records concerning RVSM airworthiness, operational approval, and height-monitoring status for operators and aircraft in the United States, Canada, and Mexico.

For operators using a traditional Section 3 authorization, the current June 2026 monitoring table divides aircraft into three broad categories:

Category 1 group aircraft: At least two aircraft in each monitoring group must be monitored every two years or 1,000 flight hours, whichever is longer. When the operator has only one aircraft in the group, that aircraft must be monitored.
Category 2 group aircraft: At least 60 percent of the aircraft in the group must be monitored every two years or 1,000 flight hours, whichever is longer.
Nongroup aircraft: Each aircraft must be monitored every two years or 1,000 flight hours, whichever is longer.

Aircraft classifications may change as additional performance data become available, so the current FAA/NAARMO table should be checked rather than relying on an older list.

Monitoring may be accomplished using qualified ADS-B data, an Aircraft Geometric Height Measurement Element ground station, an approved GPS-based monitoring unit, or another method accepted through the applicable regional monitoring agency.

Duncan Aviation’s Role

The principal question is no longer whether the customer possesses a separately approved RVSM maintenance program. The appropriate questions are:

Is the aircraft approved or otherwise eligible for RVSM operation?
What approved design or ICA establishes its RVSM configuration?
Does the proposed work affect an RVSM-critical system, component, software load or structural area?
Does the replacement equipment conform to the approved configuration?
Have all required inspections, tests and functional checks been completed?
Has the work been documented clearly enough to support continued airworthiness and configuration control?

The operator, rather than the maintenance provider, remains responsible for operational authorization, pilot qualification, flight-plan status, and continuing height-monitoring compliance. The maintenance provider is responsible for performing and documenting the maintenance correctly and for approving the aircraft for return to service only when it conforms to the applicable data.