Safety

Pilot mental health and your medical in 2026: what has changed

March 27, 2026Updated October 1, 202610 min readFor pilots

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In this article

The 2024 rulemaking committee
What the FAA has changed since
What pilots must report
Peer support and HIMS
Legislation: where it stands
How Europe does it
Practical guidance
If you need help now

For years, many pilots have treated the medical application as a reason to stay out of a therapist's office. The FAA's own rulemaking committee said so in 2024. Since then the FAA has changed a long list of policies, mostly quietly, through monthly updates to its examiner guide, and Congress has moved legislation through both chambers. The changes are real. So are the rules that have not moved, and a pilot needs to know both.

This article covers what has been published and decided as of late September 2026. It is not medical or legal advice. Your AME, a HIMS AME, your union's aeromedical resources or an aviation attorney can speak to your own case.

The 2024 rulemaking committee

The FAA set up the Mental Health and Aviation Medical Clearances Aviation Rulemaking Committee (ARC) in December 2023, covering both pilots and air traffic controllers. Its recommendation report is dated April 1, 2024 and contains 24 recommendations. The committee put the core problem plainly: "Current data suggest that fear, anxiety, and avoidance in seeking health care is due to the fear of loss of medical certification/clearance."

The main recommendations were:

Let pilots and controllers attend talk therapy without having to disclose it during aeromedical screening (REC1).
Create a non-punitive pathway for reporting previously undisclosed mental health conditions, treatments or medications (REC2).
Expand peer support programs and make clear that using them does not have to be disclosed (REC3 and REC4).
Limit neurocognitive testing to clinically indicated cases, and revise the requirements for depression, anxiety, ADHD and PTSD (REC5 to REC8).

The report also noted that FAA observation times for antidepressants were longer than those of most other civil aviation authorities it reviewed.

What the FAA has changed since

Most of the FAA's changes have come through the Guide for Aviation Medical Examiners. The dates below come from the guide's own change log.

Date	Change
April 24, 2024	Three SNRIs (duloxetine, venlafaxine, desvenlafaxine) added to the antidepressants the FAA will consider; the SSRI protocol is renamed the Antidepressant Protocol
May 29, 2024	New table lets AMEs issue for up to two uncomplicated anxiety, depression and related conditions
August 27, 2025	Vilazodone (Viibryd) moved to conditionally acceptable
December 3, 2025	Required time on a stable antidepressant dose cut from 6 months to 3 months
May 27, 2026	New therapy and counseling information page, FAQs for pilots and controllers, and guidance for psychotherapists
July 29, 2026	New AME Assisted Special Issuance (AASI) for anxiety, depression and related conditions
August 26, 2026	Chief pilot report requirement removed from the antidepressant program

Since May 2024, an AME can issue a medical in the office, without deferring to the FAA, for up to two listed conditions. These include generalized, social, situational and unspecified anxiety; postpartum, situational and unspecified depression; OCD; PTSD; and life-event codes such as uncomplicated bereavement or relationship distress. Any amount of past or current psychotherapy is allowed. Medication is allowed if it was a single mental health medication last taken, prescribed or recommended two or more years ago. The pathway does not apply to major depressive disorder or persistent depressive disorder, recurrent episodes, a history of more than one medication at a time, or anyone previously on a special issuance for antidepressants. Those cases are deferred to the FAA.

On antidepressants, nine medications are now conditionally acceptable with a special issuance, used as a single agent: citalopram, escitalopram, fluoxetine, sertraline, bupropion (SR/ER only), desvenlafaxine, duloxetine, venlafaxine and vilazodone. The pilot must be clinically stable on the same dose for at least 3 continuous months, then be evaluated by a HIMS AME, who submits the case to the FAA. The FAA also says it has reduced how often pilots on antidepressants need cognitive testing, and that it has hired more mental health professionals to shorten wait times for return-to-fly decisions (FAA Pilot Mental Fitness).

The new AME Assisted Special Issuance, added in July 2026, takes some of the waiting out of renewals. After the FAA grants the first authorization, the AME can reissue at later exams if the pilot brings the required paperwork: clinic progress notes at least every six months, at least one of them from a physician, the latest within 90 days of the exam, and a status summary completed by the treating physician and the AME. New diagnoses, symptoms or concerns go back to the FAA.

The May 2026 therapy update did not adopt the ARC's recommendation to drop therapy disclosure. What it did was tell pilots, AMEs and therapists, in writing, how the FAA treats therapy. NBAA summarized it: AMEs are told to focus on the underlying condition and its severity, not on the fact that someone sought therapy.

What has not happened: we found no FAA announcement of the non-punitive disclosure pathway the ARC proposed in REC2. For a pilot who left something off past applications, that remains the largest unresolved question. The ARC itself noted that the FAA cannot grant immunity from prosecution for false statements on the application; only the Department of Justice can.

What pilots must report

The FAA's therapy and counseling FAQs (May 27, 2026) are the clearest statement of current policy:

Therapy is compatible with a medical. "Psychotherapy is compatible with both an unrestricted medical certificate and special issuance/special consideration."
Report on the next application, not immediately. Pilots are "not obliged to report until your next application for medical certificate."
All visits to licensed providers, including psychotherapists and counselors, are reported. Educational counseling, religious counseling (unless the clergy member is also a licensed counselor) and couples counseling (unless the pilot has been referred for individual therapy) do not need to be. EAP consultations can be left off unless they resulted in a referral for psychiatric evaluation or treatment.
Seeing a therapist does not automatically create a diagnosis. If there is one, the AME may issue or defer depending on the diagnosis, severity and risk factors.
The FAA usually does not see therapy records. If documentation is requested, it is usually a brief summary from the therapist.

The duty not to fly while impaired has not changed. Under 14 CFR 61.53, you may not act as a required crewmember while you know or have reason to know of a condition that would make you unable to meet the medical standard. The FAQ says to self-ground if symptoms are severe enough to impair concentration, memory, emotional stability, judgment, decision-making or alertness, and adds: "Self-grounding is a professional safety decision and is also viewed as a sign of good insight."

For context, the FAA says its initial deferral rate for all mental health diagnoses is around 20%, that "the vast majority are cleared after an evaluation," and that only about 0.1 to 0.2% of applicants who disclose any health issue and finish the process get a final denial (FAA medical myths page).

Peer support and HIMS

Peer support programs are run mostly by pilot unions and airlines, staffed by trained pilot volunteers. ALPA describes its program as available 24/7 and confidential, and says calls do not need to be reported on the medical application. Confidentiality holds except "in the rare instances when an immediate risk of harm to the caller or others is apparent" (ALPA, July 2026). The FAA's FAQ also lists peer support programs as a place to start when looking for a therapist.

HIMS is a separate program. It is a partnership of airlines, unions and the FAA that supports pilots with substance dependence through treatment, recovery and a monitored return to flying under a special issuance (HIMS). HIMS AMEs also handle the antidepressant pathway described above, which is why many pilots on that pathway deal with a HIMS AME even though substance use is not involved.

Legislation: where it stands

FAA Reauthorization Act of 2024. Section 411 of the law set up an Aeromedical Innovation and Modernization Working Group to review the special issuance process, the list of conditions AMEs can issue for, and mental health protocols and medications, including actions taken on the ARC's recommendations. It also created an aviation workforce mental health task group that must report to Congress within two years of being set up (House T&I section-by-section). The FAA says the Federal Air Surgeon co-chairs the working group (FAA Safety Briefing, September 2025).

Mental Health in Aviation Act. The House passed H.R. 2591 by voice vote on September 8, 2025 (AOPA). The Senate version, S.3257, cleared the Senate Commerce Committee unanimously on April 14, 2026 (AOPA). On September 25, 2026, the Senate passed it by unanimous consent as the John A. Hauser Mental Health in Aviation Act, named for a University of North Dakota aviation student who died by suicide in 2021 (Aero Crew News). The Senate also passed the Aviation Medication Transparency Act (S.3258) the same day.

According to the sponsors, Senators Hoeven and Duckworth, the Senate-passed bill would (Duckworth release):

require the FAA to modernize its mental health regulations for pilots and controllers;
require annual reviews of the special issuance process;
authorize $15 million a year (FY2026 to FY2029) to recruit and train more AMEs, and $1.5 million a year for campaigns to reduce stigma.

The bill also directs the FAA to implement the 2024 ARC's recommendations (CBO). The medication bill would require the FAA to publish, within one year, a clear list of acceptable medications, any duty limits, and which drugs are "Do Not Issue" or "Do Not Fly."

As of the end of September 2026, neither bill is law. The Senate amended the mental health bill before passing it, so the House must act again before it can go to the president (AvWeb). The House version of the medication bill, H.R. 2592, had cleared the House Transportation and Infrastructure Committee but not the full House. NATCA has urged both chambers to resolve the differences and pass identical versions when they return in November (NATCA).

How Europe does it

Europe made peer support a legal requirement. Commission Regulation (EU) 2018/1042 of July 23, 2018 (EUR-Lex) added three rules for commercial air transport operators: a support program for flight crew, a psychological assessment before a pilot starts line flying, and a policy to prevent and detect misuse of alcohol and other psychoactive substances. The rules were due to apply in August 2020 and were deferred to February 14, 2021 because of the pandemic (EASA).

The core rule, CAT.GEN.MPA.215, says the operator "shall enable, facilitate and ensure access to a proactive and non-punitive support programme." EASA's guidance material (ED Decision 2018/012/R) expects peers trained in psychological first aid, access to mental health professionals who know aviation, confidential handling of personal data, and a non-punitive policy that allows temporary relief from flight duties without fear of dismissal.

The difference is structural. In Europe, every commercial air transport operator must provide a program. In the US, peer support is common through unions and airlines but is not a regulatory requirement, so a pilot at a smaller operator without a union may have no program at all.

Practical guidance

Start with peer support if you have it. It is run by pilots, it is confidential within the limits described above, and a call does not have to be reported.
Seeing a therapist is allowed. Look for a licensed provider with at least a master's degree, and give them the FAA's "Information for Psychotherapists Treating Pilots and ATCS" on the first visit, as the FAA suggests.
Be accurate on MedXPress. Report reportable visits at your next application. The application is signed under federal false-statement law, and a disclosed history is usually easier to resolve than a discovered omission.
Ground yourself when you need to. The FAA's list of self-grounding examples includes severe anxiety or panic attacks, major depression, and suicidal thoughts. Treatment and recovery come first; the medical can follow.
Get advice before your exam if you have a history. An AME, a HIMS AME or your union's aeromedical advisors can tell you which pathway applies and what paperwork to bring.

If you need help now

If you are struggling, you do not have to sort out the medical question first. Call your union or company peer support line, or talk to your doctor or a licensed therapist. In the US, you can call or text 988, or chat at 988lifeline.org; the 988 Lifeline is free, confidential and available 24/7. Outside the US, contact your local emergency number or your operator's support program. If you or someone else is in immediate danger, call emergency services.

Sources

This is general information, not operating guidance. Your company's procedures, your aircraft's manuals and the regulations come first.