1.3 Duration, Validity & Biennial Renewal Requirements
Key Takeaways
- Under 14 CFR 65.92(a), every Inspection Authorization expires on March 31 of each odd-numbered year, and privileges may be exercised only while the holder holds currently effective airframe and powerplant ratings.
- Under 14 CFR 65.92(b), an IA ceases to be effective whenever it is surrendered, suspended, or revoked, whenever the holder no longer has a fixed base of operation, or whenever the holder no longer has the equipment, facilities, and inspection data required by 65.91(c)(3) and (4).
- Under 14 CFR 65.93(a), renewal requires evidence presented during the month of March of each odd-numbered year that the applicant still meets 65.91(c)(1) through (4), plus completion of one of five listed activities in the first year of the cycle and one during the second year.
- The activity options are measured per 90 days of held authority, not per year: at least one annual inspection for each 90 days, or at least two major repairs or major alterations for each 90 days, or one progressive inspection performed or supervised and approved, or an 8-hour refresher course, or an oral test by an FAA inspector.
- Under 14 CFR 65.93(c), an IA holder who completes no listed activity by March 31 of the first year may not exercise IA privileges after that date and may resume only after passing an oral test given by an FAA inspector.
1.3 Duration, Validity & Biennial Renewal Requirements
[!WARNING] Two Deadlines, Not One: Most candidates memorize only the March 31 odd-year expiration. The current rule contains a second, earlier deadline. Since Amendment 65-65 (effective October 1, 2024), 14 CFR 65.93(a) requires one qualifying activity to be completed by March 31 of the first year of the two-year period and another during the second year. Miss the first-year deadline and 65.93(c) suspends your privileges on April 1 of that first year — eighteen months before the authorization itself expires.
The duration, validity standards, and renewal mechanics for an Inspection Authorization are codified in 14 CFR 65.92 (Inspection authorization: Duration) and 14 CFR 65.93 (Inspection authorization: Renewal). Unlike a mechanic certificate, which is issued without an expiration date and remains effective unless surrendered, suspended, or revoked, an Inspection Authorization is a renewable privilege tied to a fixed nationwide calendar. Every IAR candidate should read both sections in their current form, because the renewal section was rewritten in 2007 and amended again in 2018 and 2024, and a great deal of older study material still circulates with obsolete quotas in it.
Duration and Validity: 14 CFR 65.92
The Biennial Cycle and March 31 Expiration (65.92(a))
Under 14 CFR 65.92(a), each Inspection Authorization expires on March 31 of each odd-numbered year (for example March 31, 2025; March 31, 2027; March 31, 2029).
- Nationwide harmonization: every IA in the United States shares the same expiration date regardless of when it was issued. There is no rolling 24-month anniversary.
- Mid-cycle issuance: a mechanic who earns an IA in November of an even-numbered year holds an authorization that expires the following March 31 — an initial term of roughly five months. Section 65.93(b) provides relief for exactly this situation (below).
- Underlying certificate dependency: the second sentence of 65.92(a) states that the holder may exercise the privileges of the authorization only while holding a currently effective mechanic certificate with both a currently effective airframe rating and a currently effective powerplant rating. Suspend either rating and the IA card in the wallet becomes unusable even though its printed date has not passed.
Automatic Cessation Conditions (65.92(b))
An Inspection Authorization ceases to be effective — independently of the March 31 date — whenever any of three things happens:
- The authorization is surrendered, suspended, or revoked.
- The holder no longer has a fixed base of operation.
- The holder no longer has the equipment, facilities, and inspection data required by 65.91(c)(3) and (4) for issuance of the authorization.
Under 65.92(c), the holder of an authorization that is suspended or revoked must return it to the Administrator upon request. Note what is not on the cessation list: a change of address is not automatically disqualifying, but under 65.95(c) the holder may not exercise privileges at a new fixed base until the responsible Flight Standards office for the new area is notified in writing.
The Five Renewal Activities: 14 CFR 65.93(a)
To renew for a further 2-year period, an applicant must present evidence during the month of March of each odd-numbered year, at the responsible Flight Standards office, that they still meet 65.91(c)(1) through (4) — the ratings tenure, active engagement, fixed base, and equipment/data requirements. Note the deliberate omission of 65.91(c)(5): renewal never requires retaking the written test.
In addition, the applicant must show completion of one of the five activities below by March 31 of the first year of the 2-year period and completion of one of the five activities during the second year. Read the activity text carefully — three of the five are measured against 90-day blocks of held authority, not calendar years.
Activity 1 — Annual Inspections (65.93(a)(1))
Performed at least one annual inspection for each 90 days that the applicant held the current authority.
- A full year of held authority contains four 90-day blocks, so a full year works out to four annual inspections — but the legal test is the per-90-day distribution, not the annual sum. An applicant who performed all four annuals in one calendar quarter and none in the other three has not satisfied the wording.
- Evidence: maintenance record entries or an activity ledger showing registration marks, dates, and time in service.
Activity 2 — Major Repairs or Major Alterations (65.93(a)(2))
Performed at least two major repairs or major alterations for each 90 days that the applicant held the current authority.
- Two per 90 days is eight per year — this is the single most commonly misquoted number in IA study material, where it is often mis-stated as "two per year."
- Evidence: copies of the FAA Form 337s bearing the applicant's return-to-service signature in Item 7.
Activity 3 — Progressive Inspection (65.93(a)(3))
Performed or supervised and approved at least one progressive inspection in accordance with standards prescribed by the Administrator.
- Unlike Activities 1 and 2, this option carries no numeric quota and no 90-day distribution requirement — a single qualifying progressive inspection satisfies it. There is no "80 hours of progressive inspection" requirement anywhere in 65.93; that figure does not exist in the regulation.
Activity 4 — Refresher Course (65.93(a)(4))
Attended and successfully completed a refresher course, acceptable to the Administrator, of not less than 8 hours of instruction.
- The current text prescribes only the 8-hour minimum and acceptability to the Administrator. The timing is governed by the first-year/second-year structure in the lead-in paragraph of 65.93(a), so the course must fall inside the year for which it is being credited.
- Why most IAs use it: it is the only option with no dependence on shop volume, and it is available to a mechanic whose inspection work slowed for any reason.
Activity 5 — Oral Test (65.93(a)(5))
Passed an oral test by an FAA inspector to determine that the applicant's knowledge of applicable regulations and standards is current.
- This is both a renewal activity and, under 65.93(c), the sole route back to exercising privileges after a missed first-year deadline.
Summary of the Five Activities Under 14 CFR 65.93(a)
| Activity | Regulatory Text Standard | Worked Out Over a Full Year | Evidence Presented in March |
|---|---|---|---|
| 1. Annual inspections | At least one annual for each 90 days held | 4 annuals, distributed across the four 90-day blocks | Maintenance record entries / activity ledger |
| 2. Major repairs or alterations | At least two for each 90 days held | 8 per year, not two per year | Signed FAA Form 337s (Item 7) |
| 3. Progressive inspection | One performed or supervised and approved | One, no distribution requirement | Program records under the approved procedures |
| 4. Refresher course | Not less than 8 hours of instruction, acceptable to the Administrator | 8 hours | Course completion certificate |
| 5. Oral test | Passed an oral test by an FAA inspector | N/A | Inspector's determination at the FSDO/IFO |
The Two-Step Currency Structure and the 65.93(c) Trap
The lead-in sentence of 65.93(a) splits the two-year period into two independently policed years:
EVEN YEAR (Year 1) ODD YEAR (Year 2)
Apr 1 ---------------- Mar 31 | Apr 1 ---------------- Mar 31
[ one of activities (1)-(5) ] | [ one of activities (1)-(5) ]
| |
v v
MISSED? 65.93(c): privileges STOP MARCH: present evidence
after Mar 31 of Year 1 until an FAA at the responsible Flight
inspector oral test is passed Standards office; renewed
to Mar 31 of the next odd year
14 CFR 65.93(c) is the provision most study guides omit entirely. An IA holder who does not complete one of the five activities by March 31 of the first year of the two-year period:
- may not exercise inspection authorization privileges after March 31 of that first year; and
- may resume exercising them only after passing an oral test from an FAA inspector confirming that their knowledge of the applicable regulations and standards is current.
An IA holder who passes that oral test is deemed to have completed the 65.93(a)(1) through (5) requirement by March 31 of the first year, which repairs the record for renewal purposes. The authorization itself has not expired — but exercising its privileges in the interim is a violation.
Relief Provisions: Short Tenure (65.93(b)) and Reinstatement (65.93(d))
Short-Tenure Relief — 65.93(b)
Section 65.93(b) waives the activity requirement for holders whose authorization has been in effect only briefly:
- 65.93(b)(1): an authorization in effect less than 90 days before the expiration date need not comply with 65.93(a)(1) through (5) at all.
- 65.93(b)(2): an authorization in effect less than 90 days before March 31 of an even-numbered year need not comply with 65.93(a)(1) through (5) for the first year of the two-year period.
This is a regulatory provision, not a policy accommodation, and it is written in terms of held time before a date — not "prorated quotas." There is no half-quota anywhere in 65.93.
Reinstatement of an Expired Authorization — 65.93(d)
Section 65.93(d) provides the one path to renewing an expired IA: a person who qualifies for the relief prescribed in 14 CFR 61.40 is eligible to renew an expired inspection authorization under 65.93, provided the 61.40 requirements are met. Section 61.40 is the relief rule for airmen serving in the U.S. Armed Forces on active duty who could not meet a recency or renewal requirement.
Outside that narrow relief, an authorization that lapses past March 31 is gone: the mechanic must qualify again as an initial applicant under 65.91, which includes passing the IAR knowledge test a second time. There is no grace period, late fee, or administrative extension in Part 65.
Common Exam Traps & Regulatory Distinctions
- "Two per year" is wrong: 65.93(a)(2) requires two major repairs or major alterations for each 90 days, which is eight per year. Any answer offering "two per year" or "four over the cycle" is a distractor.
- "Four annuals per year" is a derived number, not the rule: the rule text is one annual for each 90 days. Prefer the answer that quotes the 90-day standard when both appear.
- There is no progressive-inspection hour quota: 65.93(a)(3) asks for one progressive inspection performed or supervised and approved. Hour figures such as "80 hours" or "160 hours" appear in no version of Part 65.
- The first-year deadline exists: under 65.93(c), missing a first-year activity stops privileges on April 1 of the first year and requires an FAA inspector oral test to resume — this is not the same thing as expiration.
- Renewal never requires the written test: 65.93(a) asks for continued compliance with 65.91(c)(1) through (4) only. The written test in 65.91(c)(5) returns only if the authorization actually lapses.
- Suspension of the underlying A&P: under 65.92(a), IA privileges may be exercised only while both ratings are currently effective, no matter what the card says.
On what calendar date does an FAA Inspection Authorization expire according to 14 CFR 65.92(a)?
An IA held the authorization continuously through both years of the cycle and intends to renew on inspection activity alone under 14 CFR 65.93(a)(2), using major repairs and major alterations. What does the regulation require?
An IA performed no annual inspections, no major repairs or alterations, no progressive inspection, took no refresher course, and passed no oral test during the first year of the two-year cycle. It is now April 10 of that first year — nearly a full year before the authorization's printed expiration date. What is the IA's status under 14 CFR 65.93?