What MOSAIC Changes

MOSAIC is not a minor regulatory update; it is a complete transformation of how light‑sport aircraft are designed, certified, manufactured, and operated in the United States. The new 14 CFR Part 22 defines what LSA must comply with, while the technical framework for how to demonstrate compliance is provided by FAA‑accepted ASTM standards, a system of consensus standards developed by Committee F37.

The entire system is built as a connected hierarchy, expressed by a simple but accurate chain:

Part 22 → Integration Standard → Functional Standards

Each link has a clearly defined role: the new 14 CFR Part 22 sets the regulatory requirements, the Integration Standard determines which Functional Standards apply to a given category, and the Functional Standards contain the actual technical requirements. MOSAIC has effectively reshaped the certification structure for the LSA category. At first glance, the change may not appear advantageous, but once understood, it reveals the intent of its creators: openness to emerging technologies and long‑term flexibility of the system.

Once this structure becomes clear, the entire MOSAIC framework starts to make sense — logical, consistent, and technically coherent.

One drawback is the abrupt transition: the change occurred without any transitional period. Aircraft manufactured in the U.S. (or imported into the U.S.) after July 23, 2026 must comply with the new regulation. Additionally, MOSAIC introduces a new Statement of Compliance, which may only be signed by a person who has successfully completed ASTM training.

Integration Standards: The Recipe for an Aircraft

Integration Standards form the key link between Part 22 and the individual ASTM Functional Standards. For each LSA type (fixed‑wing aircraft, gyroplanes, helicopters, etc.), there is exactly one Integration Standard. They are often described as a “recipe for an aircraft,” because they do not contain detailed technical requirements themselves. Instead, they bridge the regulation and the specific requirements found in the Functional Standards.

Their role is essential: the Integration Standard provides the structured framework that allows a manufacturer to assemble a complete compliance system. It also defines revision control — the newest version of a standard is not automatically valid; only the version formally accepted by the FAA is considered the FAA‑accepted revision.

Functional Standards: The Technical Core

Functional Standards contain the technical substance of the MOSAIC framework. While Integration Standards determine which Functional Standards apply, the Functional Standards define the specific technical and process requirements a manufacturer must meet. They cover a wide range of areas — structures, flight characteristics, performance, electrical systems, occupant safety, powerplants, landing gear, maintenance, IFR operations, electric propulsion, angle‑of‑attack systems, and indirect flight controls.

Each standard is a standalone building block that connects to Part 22 through the Integration Standard. Their combination forms the complete technical framework used for analyses, calculations, tests, and other activities required to demonstrate compliance. The result is a set of documents led by the Compliance Checklist — a table that demonstrates compliance with each of the thousands of requirements across the certification framework.

Compliance: The PEER Method

One of the topics covered in the training was the PEER method, which provides a structured and repeatable approach to managing the entire compliance process, from identifying requirements to producing final evidence. PEER divides the work into four clearly defined phases:

• Plan – identify all applicable Part 22 and ASTM requirements and determine how compliance will be demonstrated.
• Execute – perform the planned analyses, calculations, tests, and technical activities.
• Evaluate – compare the results with the requirements and verify compliance.
• Record – create objective, traceable, long‑term evidence documenting how compliance was demonstrated.

PEER emphasizes that compliance is not a one‑time certification file but a living documentation system, updated whenever the design, configuration, components, or standards change.

Quality Assurance: Ensuring Every Aircraft Matches the Design

ASTM F2972 defines the Quality Assurance System (QAS) — the system that ensures every manufactured aircraft matches the design for which compliance with Part 22 was demonstrated. While design compliance shows that the design meets the requirements, QAS ensures that this compliance is carried into production, from the first prototype to serial manufacturing.

QAS includes configuration and documentation control, supplier oversight, material inspection, calibration of measurement equipment, internal and external audits, and formal non‑conformance management. Every step must be documented so that any aircraft can be verified against the approved configuration.

Production Acceptance Testing (PAT)

Traceability is essential. A manufacturer must be able to demonstrate the complete origin of each aircraft: the configuration it was built to, the components and materials used, the inspections, measurements, and tests performed, and how any deviations were resolved.

Traceability is not just a list of parts — it includes serial‑number‑specific documentation, enabling full reconstruction of every step from material receipt through assembly operations to final PAT. This ensures that each aircraft matches the approved design, the correct standard revision, and the current configuration.

Continued Operational Safety: Compliance Does Not End at Delivery

ASTM F3198 defines Continued Operational Safety (COS) — a structured, ongoing system for monitoring the fleet after aircraft enter service. While QAS ensures compliance in production, COS focuses on real‑world operation, where new information, deviations, or failures may emerge.

Manufacturers must systematically collect operational reports, analyze failures, perform risk assessments, decide on corrective actions, communicate with owners and the FAA, and monitor the fleet long‑term. Even a small number of events may require immediate action if the potential consequences are severe.

COS ensures that compliance with Part 22 is not a one‑time achievement but a continuous, lifecycle‑long obligation.

Final Exam

The course concluded with a closed‑book exam of 50 questions, verifying whether participants truly understood all key elements of the MOSAIC framework — from the structure and development of ASTM standards, through Part 22 regulatory requirements, to practical areas such as compliance documentation, Integration vs. Functional Standards, Quality Assurance, Continued Operational Safety, initial airworthiness, and audit processes.

Passing required at least 80% correct answers, the level considered sufficient by both FAA and ASTM for independent work with the MOSAIC framework.

Why MOSAIC Matters for Orličan

For Orličan, MOSAIC is not just a regulatory change but a strategic opportunity — a chance to prepare for the new U.S. LSA framework at a time when most manufacturers are only beginning to study it. This allows us to strengthen our position for future export and understand a system that will shape light‑sport aviation in the United States for years to come.

The training provided a complete and practical understanding of the MOSAIC system: the relationship between Part 22 and ASTM standards, the structure of FAA compliance documentation, detailed insight into QAS and PAT, practical COS procedures, and the risk‑based decision‑making approach central to MOSAIC.

Participation in the first public run of the course — and the fact that we were the only European manufacturer from the existing SLSA category — allowed us to obtain information directly from the people who are creating MOSAIC and integrate it into our technical development, documentation, and future certification work.