The National Flight Training Alliance (NFTA) submitted a 471-page report of industry recommendations to the Federal Aviation Administration’s (FAA) Part 141 modernization docket on April 1, 2026. Among its recommendations is a significant expansion of the role that flight simulation and other training technologies could play in Part 141 programs, potentially changing how much training students can complete in a simulator, which kinds of devices can receive credit, and how those devices are approved.
Before going further, one fact should be stated plainly and early: this is not a rule. It is not a Notice of Proposed Rulemaking (NPRM). It carries no regulatory force. For any of it to become policy, the FAA would need to review the recommendations, decide what it wants to pursue, draft an NPRM, run a public comment period, and issue a final rule. There is no fixed timeline for that process, and an overhaul of this scope could take years. The comment period on the report itself closed May 11, 2026.
With that established, here is what the report actually proposes, and why it should matter to anyone who owns, uses, or instructs in a flight simulator.
The NFTA report is the consolidated output of a year of public meetings, running from March 2025 through March 2026, involving representatives from across the flight training industry. Its eight main recommendations are as follows:
Standing up a new Central Management Office (CMO) within the FAA to centralize school certification and oversight;
Implementing safety and quality management systems at Part 141 schools;
Modernizing school documentation and management procedures;
Developing consensus standards;
Reforming examining authority;
Expanding simulation and technology credit;
Updating course appendices; and
Creating a new “Registered Pilot School” designation for smaller operators that currently have no viable on-ramp to Part 141 certification.
The final two-thirds of the document is draft and redline regulatory language for every section of Part 141. The simulation piece, Recommendation 6, is arguably where the report lands hardest for anyone reading these pages.
The structure of the existing rules governing the use of Flight Simulation Training Devices (FSTDs) in Part 141 programs traces back to a 1997 revision. That revision predates the current generation of high-fidelity simulation hardware by roughly two decades. Under current regulations, an Advanced Aviation Training Device (AATD) can be credited for up to 40% of the flight training requirements in a Part 141 instrument rating course (for example), subject to the applicable course and device limitations, a limit that was itself an improvement when the FAA established it in 2016, coming off a period when the agency had to walk back informal Letter of Authorization (LOA)-based allowances that exceeded what the Code of Federal Regulations (CFR) actually permitted.
The report proposes a new device category, the Enhanced Advanced Aviation Training Device (EAATD). To qualify, a device would need a 210-degree field-of-view visual system and a flight deck layout mirroring a specific aircraft make and model, not just category and class. The report positions the training value of an EAATD as roughly equivalent to a current Flight Training Device (FTD) Level 5. The administrative structure would work similarly to existing AATDs: the device would be authorized under an FAA Letter of Authorization, allowing a school to use its approved capabilities without seeking separate local Flight Standards District Office (FSDO) approval for each curriculum element.
The proposed credit percentages represent a meaningful departure from current limits. Under the table in Recommendation 6, an EAATD would be eligible to receive credit for up to 50% of the applicable private pilot flight training hours, 60% of the applicable instrument rating flight training hours, and 40% of the applicable commercial pilot flight training hours. AATDs, under the same proposal, would receive credit for up to 25% for private, 40% for instrument, and 30% for commercial training. Basic Aviation Training Devices (BATDs) would receive credit for up to 15%, 25%, and 15%, respectively. For context, the current maximum combined FTD/AATD credit for an instrument rating in a Part 141 program is 40% of the applicable flight training hours. The proposal would raise that ceiling to 60% with an EAATD.
The research the report cites provides evidence for that argument.
A 2015 study found that learners in intensive simulator-based programs earned private certificates in approximately 39% fewer aircraft hours than those trained conventionally.
A 2006 study using a Level 6 FTD demonstrated positive transfer in 33 of 34 evaluated tasks.
The report also formally introduces Extended Reality (XR), encompassing virtual, augmented, and mixed reality, as a formal category within the proposed Part 141 framework. Credit allowances for XR would run at roughly 10% toward private and 15% toward instrument.
One structural change in the report that deserves specific attention is the proposal to centralize the approval process for adding tasks and maneuvers to a device’s LOA. Currently, that process runs through local FSDO interpretation, which the report argues can lead to inconsistent approvals across regions for identical hardware. Under the proposed CMO model, a flight school submits a standardized Device Effectiveness Report to the national office, a FSDO inspector conducts an on-site evaluation, and the CMO makes the final call, applying that authorization consistently across all schools using that device configuration. The report frames it as an Aviation Training Device (ATD) equivalent of the T001A process that already governs Full Flight Simulator (FFS) and FTD qualification under Part 60.
This one is easy to miss in a 471-page document, but it matters.
Currently, a certified flight instructor (CFI) who spends hours instructing in an FTD cannot use that instructional time as aeronautical experience toward the ATP/Restricted ATP experience requirements. The same device that earns a learner credit toward their certificate earns the instructor nothing toward theirs.
Additional Recommendation 12 proposes allowing CFIs to log instructional time conducted in an approved Part 141 or 142 FTD at a rate of one hour of credited aeronautical experience for every two hours of qualifying FTD instruction, up to the 100-hour cap already in place under § 61.159(a)(6). The device would need dual controls, and the CFI would operate from a functional pilot station. The analogy drawn in the report is to § 61.159(d), which already allows commercial pilots to credit flight engineer time toward total time at a 1:3 ratio for up to 500 hours. The FAA has long recognized that certain non-traditional aeronautical experience has legitimate value. The question is whether CFI instructional time in a qualified simulator qualifies.
For learners in a Part 141 program, the most direct effect is cost. Simulator time can cost substantially less per hour than aircraft rental and operation. Shifting up to 60% of an instrument course's creditable training hours into a high-fidelity simulator, at EAATD credit levels, could meaningfully reduce the aircraft time—and potentially the overall cost—required to complete a rating.
For flight instructors, the centralized LOA approval process addresses a genuine and long-standing problem. An instructor who moves between schools in different FSDO regions can encounter differences in how identical device capabilities are interpreted and authorized. The proposed standardized national approval process is intended to eliminate that inconsistency. If Additional Recommendation 12 becomes a rule, instructors building toward an ATP through sim-heavy teaching programs would be able to count that time, which could change the calculus on building flight school career tracks considerably.
For flight schools that choose to take advantage of the higher proposed credit limits, the potential business case is straightforward. Higher FSTD credit percentages could reduce the amount of aircraft utilization required to move the same number of learners through a program. Greater use of simulation could reduce exposure to fuel, maintenance, and weather-related scheduling constraints. A school with a training device qualified to EAATD standards under the proposed framework could absorb weather delays without losing training days, complete substantially more instrument approaches per session, and run scenarios that a live airplane cannot safely replicate: engine failures, system malfunctions, decision-making under compounding pressure. The throughput argument compounds that advantage; a simulator can run multiple sessions daily without the fuel turnaround, maintenance downtime, and scheduling friction of an aircraft. Schools that have had Part 141 throughput constrained by limited fleet availability have a structural alternative here.
The next step belongs to the FAA. The agency will review public comments, conduct its own analysis, and decide what, if anything, to take to an NPRM. That process will take time, probably measured in years rather than months. It will likely go in some different directions than the NFTA recommendations suggest, as rulemaking invariably does.
What is already true, regardless of what the rulemaking produces: Modern simulation hardware has capabilities that the NFTA argues are not fully reflected in current credit limits. An AATD with a modern visual system can deliver instructional outcomes that an earlier generation of devices simply could not. Whether the FAA agrees will be one of the central questions in the rulemaking that follows.