TSA AFSP Compliance for Flight Schools: Requirements and Record-Keeping

If your flight school trains non-U.S. citizen student pilots, you are required by federal law to participate in the TSA's Alien Flight Student Program (AFSP). This applies regardless of whether you're a Part 61 or Part 141 school, and regardless of the student's visa status or country of origin.

Failure to comply — including training a student before TSA approval is received — can result in significant civil penalties and, in some cases, criminal liability. This guide explains what the AFSP requires, how the approval process works, and how to track compliance across your student roster.

What Is AFSP?

The Alien Flight Student Program is administered by the TSA under 49 CFR Part 1552. It requires flight schools (called "flight training providers" in the regulation) to:

1. Verify that any non-U.S. citizen seeking flight training has received TSA approval before training begins
2. Submit the student's information to TSA for a security threat assessment (STA)
3. Maintain records of the approval and keep them available for inspection

The regulation distinguishes between two categories of flight training:

• Category 1: Training in aircraft over 12,500 lbs MTOW, or training to fly aircraft with a turbine engine — requires full background check before training begins
• Category 2: All other training (most general aviation instruction) — requires expedited check, but the approval must still be received before training begins

Who Must Comply

The regulation applies to any non-U.S. citizen seeking flight training in the United States. U.S. citizens and U.S. nationals are exempt.

"Non-U.S. citizen" includes:

• Foreign nationals on student visas (F-1, M-1)
• Permanent residents (green card holders) — they are not exempt
• Any other lawfully admitted non-citizen

This surprises many flight schools. Green card holders are not considered U.S. citizens under the AFSP and must complete the approval process.

The Approval Process

The student applies through TSAFlightStudent.com. The basic process:

1. Student creates an account and submits personal information and training request
2. TSA conducts the security threat assessment
3. Approval (or denial) is issued, with an expiration date
4. Flight school receives confirmation of approval before training begins

The critical detail: the flight school receives confirmation separately through their AFSP account. The student's copy is not sufficient. You must have the school-side confirmation in your records.

What You Must Track

For each non-citizen student, your records should include:

• Citizenship status — the basis for determining whether AFSP applies
• TSA case number — assigned when the application is submitted
• Approval date — when the TSA issued approval
• Approval expiration date — AFSP approvals expire and must be renewed for continued training
• Training category — Category 1 or Category 2

The regulation requires you to retain these records for five years after the training is completed.

Approval Expiration and Renewal

AFSP approvals are not permanent. They expire, and training must pause until a renewal is approved. Many schools run into compliance issues not at initial approval but at renewal: a student continues training after their approval lapses because no one was tracking the expiry date.

This is exactly the kind of gap that a spreadsheet doesn't reliably catch. If the expiry date isn't being actively monitored with alerts, it falls through the cracks.

Good compliance tracking means:

1. Expiry dates are recorded in the system when approval is received
2. Alerts fire automatically 30–60 days before expiry
3. Scheduling is blocked for the student if their approval has lapsed

Aloft360's TSA compliance tracking includes all three of these: fields for citizenship status, case number, approval status, approval date, and expiry, with admin alerts before expiry.

Training Before Approval: The Risk

The regulation is unambiguous: you may not provide flight training to a non-U.S. citizen before receiving TSA approval. The civil penalty for providing training without prior approval is up to $10,000 per violation.

The TSA has pursued enforcement actions against schools that trained students before approval was received, even when it was inadvertent. "We didn't have a tracking system" is not a defense.

Practical Steps for Your School

If you're not currently tracking AFSP:

1. Audit your current non-citizen students — do you have confirmation of AFSP approval for all of them?
2. Identify any approvals with upcoming expiry dates
3. Establish a process: before any non-U.S. citizen student begins flight training, the AFSP approval is confirmed and recorded

Ongoing tracking:

• Add citizenship status as a required field in your student enrollment process
• Track TSA case number, approval date, and expiry date per student
• Set alerts 60 days before expiry so you have time to prompt the student to renew
• Block scheduling for students with expired or missing approvals

Beyond AFSP: Related Compliance Areas

Flight schools training foreign national students should also be aware of:

• SEVIS reporting requirements for schools with F-1 or M-1 visa students (administered by DHS, separate from AFSP)
• State licensing requirements for flight schools, which vary by state
• Aircraft insurance requirements that may include clauses about non-citizen pilots

The AFSP is a federal minimum. Your insurance carrier may have additional requirements.

Summary

TSA/AFSP compliance for flight schools comes down to three requirements: verify approval before training begins, track the approval and its expiration, and maintain records for five years. The practical challenge is doing this systematically across every non-citizen student on your roster without letting anything slip through.

For related reading, see our guide on FAA Part 61 record-keeping requirements and our overview of the best flight school management software for keeping compliance automated.