New Flight Plan Requirements in Effect

ICAO LogoA Nov. 15 transition to International Civil Aviation Organization (ICAO) flight plans triggered some confusion, with AOPA Pilot Information Center staff fielding calls from members concerned that a major shift in flight plan filing procedures had taken effect.

The date marked the completion of a long-planned transition from the FAA domestic flight plan format to an ICAO format for international and domestic IFR operations using performance-based navigation (PBN). General aviation IFR pilots can still use the older FAA domestic flight plan form that remains available through electronic flight planning applications for operations that do not utilize GPS-based procedures and routes.

The ICAO flight plan form has a much longer list of equipment options, a more detailed breakdown of on-board equipment that gives ATC a more detailed picture of an aircraft’s capabilities.

Domestic VFR flights, along with domestic IFR flights that do not utilize PBN equipment such as Wide Area Augmentation System-enabled GPS as the means of navigation, may still file using the FAA domestic form. IFR flights using WAAS GPS (the Garmin 430W or 530W, for example) are now required to use the ICAO flight plan form in order to utilize T-routes and GPS procedures, though the change may be relatively transparent. Most flight planning software automatically transitions equipment details to the ICAO form, provided that the aircraft profile created by the user correctly details on-board equipment. Pilots who file by phone will see no difference, because the briefer will enter the plan in the system using the appropriate format.

The ICAO equipment list includes items that should be familiar to users of the FAA domestic flight plan, such as a “G” for “GNSS/GPS” and a “D” for distance measuring equipment (DME). In addition, pilots are asked to specify capabilities such as ILS. Less familiar equipment specifications such as GBAS (ground based augmentation system) are also included, but will not apply to most GA aircraft. The operator is also asked to detail Automatic Dependent Surveillance-Broadcast (ADS-B) equipment. There is also an expanded list of codes pertaining to the medevac and other special mission flights, along with specifying what type of emergency radios and survival equipment is carried on board.


Any operator who filed an FAA domestic flight plan before Nov. 15 should still be able to do so, according to an FAA official contacted by AOPA.

“Our intent was not to change any of our rules with regard to who has to file ICAO (International Civil Aviation Organization) and who has to file domestic,” said Ray Ahlberg, flight planning lead with FAA operations support. “We did not intend to introduce any change.”

Any operator who filed an FAA domestic flight plan prior to Nov. 15, when the ICAO flight plan form was revised and the FAA updated its guidance on flight plan filing requirements, should still be able to do so, Ahlberg said.

International flights, including flights to Mexico and Canada and operations within oceanic airspace (regardless of departure or destination), are required to file ICAO flight plans, as they have been. Ahlberg said there is anecdotal evidence that controllers may have accepted FAA domestic flight plans to and from Canada in the recent past, but that is no longer the case.

In general, operators who are now required to file ICAO-format flight plans were already doing so, Ahlberg said, though there remains at least one “gray area” regarding flights that use reduced separation vertical separation minimum (RSVM), operations conducted exclusively above 29,000 feet, Ahlberg said. While the FAA’s website states that flights expecting routes based on performance based navigation (PBN) must file an ICAO flight plan, Ahlberg said that does not, in practice, apply to GA operators who use Wide Area Augmentation System-capable GPS for routes and procedures—devices that may or may not fall under the PBN definition as applied under ICAO flight planning requirements. While the ICAO flight plan is far more specific, using the alternative (FAA domestic) to file a plan that includes GPS procedures will not trigger rejection.

“There’s nothing changed in the computers,” Ahlberg said, noting that much of the more detailed data collected by the newly revised ICAO flight plan is not currently transmitted to ATC, anyway. GA operators “shouldn’t be denied a route or denied service” filing an FAA domestic flight plan, Ahlberg said.

Filing requirements relevant to GA operators may change in the future if it is deemed useful to provide controllers (and the computers used to issue IFR routes) with more detailed information about on-board equipment. Alhberg said he would suggest a simplified version of the ICAO form if it comes to that.

“The goal for us is to ask for the minimum information” required to complete the flight, Ahlberg said.

While the FAA states a preference for using the ICAO flight plan from now on, Ahlberg said he would not recommend GA operators switch for the sake of switching.

Ahlberg said he nonetheless recommends the status quo “if you’re filing a domestic flight plan today and not having any trouble getting your service.”

For example, an aircraft equipped with a Garmin 430W, mode C transponder, one or more VORs with glideslope capability, and DME would previously have selected the “G” designation on the FAA domestic flight plan. On the ICAO plan, the operator will now specify the GPS capability (box G), ILS capability, VOR (in a separate checkbox), DME, and also specify—in a separate box—the presence of the mode C transponder. ADS-B capability would be detailed in another section, if applicable. Other equipment coding options allow operators to detail more sophisticated types of equipment that are rarely used by GA aircraft.

The FAA “prefers” the use of ICAO-format flight plan forms by all users, and now requires it for flights using PBN routes and procedures (such as T-routes and GPS approaches), as well as for flights using ADS-B for traffic separation. Additional guidance on the changes has been posted online, and the FAA has also published a quick-reference brochure.

The ICAO flight plan incorporates an expanded equipment list allowing operators to detail on-board assets and systems, many of which are not widely used in GA cockpits, and is internationally standardized. That standardization, along with the more detailed equipment list, will allow controllers to understand fully what routes and procedures an aircraft is capable of utilizing.