At the 2026 NBAA Business Aviation Convention & Exhibition (NBAA-BACE), experts from the association’s Regulatory Issues Advisory Group examined key developments affecting business aviation, from tariffs and international sanctions to evolving FAA requirements and the growing risks associated with inaccurate regulatory filings.
Tariffs and International Operations
Jonathan M. Epstein, a partner in the Washington, DC, office of Holland & Knight, addressed the changing U.S. tariff environment, which since has created significant uncertainty for aircraft operators, manufacturers and buyers over the past two years.
In early 2025, the United States began imposing substantial tariffs on products from countries around the world, including aircraft and aircraft parts. The measures relied on the International Emergency Economic Powers Act (IEEPA) of 1977, which grants the president certain powers to regulate international commerce during national emergencies.
The tariffs had unforeseen consequences for business aviation, particularly given the long-standing international Agreement on Trade in Civil Aircraft, established in 1980. In February 2026, the Supreme Court ruled that the president lacked authority to impose the tariffs under IEEPA.
As of July 9, 2026, no IEEPA tariffs were in effect, although the ever-changing policies and litigation highlighted the importance of monitoring trade policy.
Epstein also discussed the operational implications of changing international restrictions. Venezuela has become more accessible for U.S. flights, while Syria has eased certain flight restrictions even though export controls remain in place. Conversely, Cuba presents challenges involving potential secondary sanctions and fuel shortages, while the United States has suspended authorizations for temporary sojourns by foreign-registered aircraft to Iran and for overflights.
Epstein also highlighted the need for robust due diligence in aircraft transactions, noting that the Office of Foreign Assets Control recently sanctioned more than 600 additional entities and individuals, with new designations occurring regularly. Under OFAC’s 50% ownership rule, restrictions can extend to entities owned, directly or indirectly, at least 50% by sanctioned persons.
“Contract clauses are not due diligence,” Epstein cautioned, emphasizing that operators should maintain contemporaneous evidence of risk-based due diligence, particularly when conducting business involving higher-risk regions.
Regulatory Changes Require Advance Planning
Jason Maddux, a shareholder at GGH Air Law, reviewed several pending and upcoming regulatory issues.
A proposed passenger-rights document stemming from the 2018 FAA Reauthorization Act remains under review. The requirement addresses matters including delays, diversions, cancellations, mishandled baggage and denied boarding. However, uncertainty remains over the definition of a “covered air carrier,” which could potentially encompass Part 135 operators, charter brokers and cargo carriers. The compliance deadline would be 90 days after approval, but the timing remains uncertain, Maddux explained.
Another significant issue is the FAA’s radio altimeter compliance deadline for Parts 91 and 135 operations, set for Oct. 31, 2034. Although operators have years to prepare, Maddux warned against delaying equipment upgrades. Supply-chain constraints and maintenance, repair and overhaul backlogs could intensify as the deadline approaches.
“We have an eight-year runway here. Don’t wait until the last minute,” said Maddux. “We can expect supply chain shortages and MRO backlogs as we get closer to the deadline.”
Other developments include the FAA’s rescission of a single-pilot exemption for certain Cessna aircraft over safety concerns and widespread noncompliance, as well as ongoing issues involving pilot duty and rest, restricted-category aircraft used for wildfire suppression, and pilot oxygen requirements.
FAA Broadens Scope of Falsification Approach
Greg Reigel, an aviation attorney and partner at Shackelford, McKinley & Norton LLP in Dallas, warned that the FAA’s recently revised approach to falsification of records, applications and other statements has broad implications.
Rules addressing false statements and omissions apply to information submitted in contexts ranging from medical certification and maintenance records to aircraft documentation and other compliance filings.
Reigel emphasized that the scope extends beyond intentional fraud to potentially include information a person knows or should know is false, or omitting information.
In the past, certificate revocation has been a common consequence of falsification findings. Civil penalties may also become a consideration, particularly in cases involving inaccurate submissions by a noncertificated entity, in which case certificate revocation would not apply
The evolving enforcement landscape makes accuracy and documentation essential. As Reigel advised, anyone submitting information to the FAA should ensure it is correct.
“If you’re giving any information to the FAA, make sure it’s right,” said Reigel. “Anything you submit to the FAA has to be accurate because now the FAA has this broad brush.”
The developments shared by the experts reinforce a central message for business aviation: regulatory compliance requires continuous monitoring, documented due diligence and proactive planning—not simply reacting when a deadline or enforcement action arrives.