FAA Order 8900.1 Change 1062 clarifies Corporate ASAP, rejected reports, and ASAP’s role in an SMS.

On September 24, 2026, the FAA issued Change 1062 to FAA Order 8900.1, revising Volume 11, Chapter 2, Section 1, the inspector guidance for the Aviation Safety Action Program (ASAP). The change moves the Corporate ASAP (C-ASAP) policy first published in Notice 8900.765 in January into the permanent order, along with clarifications on rejected reports and on how ASAP connects to a safety management system (SMS).

Under the new guidance, a C-ASAP lets an aviation organization operate under a single memorandum of understanding (MOU) that covers its defined employee groups, including multiple organizations owned by the same parent company and overseen by one responsible Flight Standards office. The order also states plainly that a Part 91 flight department does not need an FAA-issued operating certificate to participate. On report handling, the FAA representative decides acceptance whenever the event review committee (ERC) cannot reach consensus on an apparent violation or a medical issue; a closed report can be reopened when new evidence surfaces; and timeliness remains a factor the ERC weighs against the best interest of safety, though it does not apply to sole-source reports.

The SMS paragraph is the one many operators will read twice. It names ASAP as a viable way to meet the confidential employee reporting requirement in 14 CFR 5.71 and calls for de-identified ASAP data to feed the organization’s safety assurance and safety risk management processes. With Part 135 certificate holders working toward the May 28, 2027 Part 5 compliance date, and many Part 91 operators running voluntary SMS programs, that link gives a business aviation organization one more scalable option for a reporting system it can build to fit its size.

For an operator building or maturing an SMS, the change invites a practical question: “could one ASAP agreement cover every employee group we have, and serve as our confidential reporting channel under Part 5?” The answer depends on the operation and its Flight Standards office, and the revised order now lays out a clear path for having that conversation.

We updated our Aviation Safety Action Program courses for line employees and for safety managers to match the new guidance, covering Corporate ASAP, Part 91 eligibility, the handling of rejected and reopened reports, ERC attendance, and the SMS connection, and we refreshed review questions where the guidance changed the answer, so crews and ERC members train on current policy.

The full text is FAA Order 8900.1, Volume 11, Chapter 2, Section 1, Change 1062, available through the FAA Dynamic Regulatory System. If you want to see how your ASAP training lines up with it, we’d love to hear from you.