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Diabetes

Insulin

Insulin (Group A1)
Other names: Lantus, Humalog, Novolog, Tresiba, Basaglar, Levemir

FAA guidance

Special issuance required.

Wait

Your class of medical

180 days

when starting or adding insulin

first- and second-class pilots must use the CGM protocol

Source: FAA, Diabetes Mellitus – Insulin Treated. FAA date 9 March 2023. Checked by Crosscheck 14 October 2026

The FAA's diabetes disposition table says that for diabetes treated with any type of insulin the examiner should defer and submit the information to the FAA, and that the initial special issuance requires an FAA decision; first- and second-class pilots must use the CGM protocol, and third-class pilots may use it or the non-CGM third-class protocol.

Track your medications
Compare FAA documents: insulinWhat each of the six FAA documents says, in plain wordsOpen

The FAA's two insulin protocols, the CGM option and the non-CGM third-class option, say consideration is given to those who have been clinically stable on their current treatment regimen for 6 months or more, and that the FAA's policy permits the special issuance to some insulin treated applicants.

The FAA's chart of acceptable combinations of diabetes medications sets an observation time when starting insulin or adding insulin to an existing treatment plan of 90 days for third-class pilots and 180 days for first- or second-class pilots.

The FAA's insulin-treated diabetes page says insulin pumps are an acceptable form of treatment, and points to that chart for combining insulin with other medication.

The FAA's questions and answers for the insulin protocol say there is no ground time when a pilot already using a pump or CGM changes devices, and none when changing from an open-loop to a closed-loop system, and that a pilot who has never used a pump and starts one for the first time has a seven-day ground trial period.

The FAA's chart of acceptable combinations of diabetes medications lists an observation time of 7 days if transitioning between insulin injection to or from a pump, or for new insulin/CGM devices, and 7 days within Group A1 if adding a new type of insulin to the regimen, with a note that no time is needed for a minor dose change within the same drug class (short to short, long to long).

FAA rule for diabetes medication: The FAA makes the initial certification decision and the examiner must defer; combinations of up to three non-insulin medications, only one from each group, are considered acceptable, with an observation period when starting one. Each component in a combination medication is counted separately (for example, rosiglitazone + metformin counts as 2 medications), 4 or more medications may be considered on a case-by-case basis, and for unlisted medications the chart says to consult AMCD or RFS. Under medication adjustment, the chart lists 48 hours within Groups B to G, 7 days within Group A2, 7 days within Group A1 if a new type of insulin is added (with a note that no time is needed for a minor dose change within the same drug class), and 7 days if transitioning between insulin injection to or from a pump, or for new insulin/CGM devices. The FAA's diabetes disposition table says that for diabetes treated with one or more non-insulin diabetic medications the examiner should defer and submit the information to the FAA, and that the initial special issuance requires an FAA decision. The FAA's AME Assisted Special Issuance page for type II diabetes controlled by medication says that, once the FAA has granted the Authorization, examiners may re-issue a medical certificate under it, provided the applicant does not require insulin, remains on an acceptable oral medication therapy according to the chart of acceptable combinations, and provides the documents it lists. For insulin, the chart says to see Medical Certification Using Insulin, and for starting or adding insulin it gives separate lines for third-class pilots or agency ATCS and for first- or second-class pilots, who must use the CGM protocol; insulin has its own entry, which asks for the class of medical. FAA, Acceptable Combinations of Diabetes Medications

Show the FAA's words: insulinThe official FAA wording: seven passages, each with its document and dateOpen
FAA, Diabetes Mellitus – Insulin Treated · FAA date 9 March 2023
Insulin pumps are an acceptable form of treatment. Combination of insulin with other anti-diabetes medication(s): The chart of Acceptable Combinations of Diabetes Medications (PDF) summarizes the acceptable medications for both monotherapy and combination therapy.
FAA, Guide for Aviation Medical Examiners – Diabetes Mellitus, Insulin Treated (non-CGM, third-class option) · FAA date 9 March 2023
Consideration will be given only to those individuals who have been clinically stable on their current treatment regimen for a period of 6-months or more. The FAA has an established policy that permits the special issuance medical certification to some insulin treated applicants.
FAA, Diabetes Mellitus Disposition Table · FAA date 27 September 2023
C.
Treated with ANY type of insulin
1 st and 2 nd class must use: Diabetes Mellitus Type I or Type II - Insulin Treated - CGM Option Protocol
3 rd class may use the CGM protocol above OR the Insulin-Treated Diabetes Mellitus Non CGM – Third Class Option Protocol
DEFER
Submit the information to the FAA.
Initial Special Issuance – Requires FAA Decision
FAA, Guide for Aviation Medical Examiners – Diabetes Mellitus Type I or Type II, Insulin Treated (CGM option, all classes) · FAA date 30 September 2026
Consideration will be given to those individuals who have been clinically stable on their current treatment regimen for a period of 6-months or more. The FAA has an established policy that permits the special issuance medical certification to some insulin treated applicants.
FAA, Acceptable Combinations of Diabetes Medications · FAA date 30 September 2026
Insulin
When starting insulin or adding insulin to an existing treatment plan.
Adding/Starting Insulin Observation Time
Group A1 (insulin):
3rd class pilots or agency ATCS
1st or 2nd class pilots (must use CGM protocol)
90 days
180 days
FAA, ITDM – Frequently Asked Questions · FAA date 30 August 2023
20. Is there a required ground time if I change pumps or CGM devices?
If you are already using a pump or CGM device and you change devices, no there is no ground time.
If you have NEVER used a pump previously, and you start using a pump for the first time, there is a seven (7) day ground trial period.
There is no required ground time if changing from an “open loop” to a “closed loop” system.
FAA, Acceptable Combinations of Diabetes Medications · FAA date 30 September 2026
Medication Adjustment
When changing the dose, formulation (e.g., immediate vs. extended release), or switching to a different drug/device within the same class.
Adjusting Medication Observation Time
Within Group A1, if adding new type of insulin to regimen
7 days
*Note: no time is needed for minor dose change within the same drug class (short to short, long to long)
If transitioning between insulin injection to/from pump; or new insulin/CGM devices
7 days
Sources and dates: insulinSix FAA documents, with the FAA's date and when Crosscheck checked themOpen

See also

Medication guidance alone does not determine whether a pilot is medically qualified to fly. The underlying condition, dosage, side effects, medication combinations, and certification history may affect FAA eligibility.

For informational purposes only. Not legal or medical advice.