Direct Answer — ADS-B Out and the PAPR in Four Sentences
Under 14 CFR §91.225, ADS-B Out has been required since January 1, 2020 in Class A, Class B, and Class C airspace, within the 30-nautical-mile Mode C veil around the busiest Class B airports, and in Class E airspace at and above 10,000 feet MSL over the 48 contiguous states — and the installed equipment must meet the broadcast performance standard in 14 CFR §91.227 (position accuracy and integrity expressed as NACp, NIC, NACv, SIL, and SDA). Above 18,000 feet MSL you must use 1090ES; below that, in §91.225(d) airspace, either 1090ES or UAT is acceptable. The Public ADS-B Performance Report (PAPR) — a free report you request from the FAA at adsbperformance.faa.gov for any flight detected in FAA coverage — is the practical proof that your equipment actually meets §91.227 in flight, and it flags a Non-Performing Emitter. The PAPR is not a CFR-required record, but it is the single best document to keep on file after installation, after avionics or GPS-source maintenance, and periodically thereafter.
"Installed" is not the same as "performing"
The most common ADS-B finding is not a missing box — it is an installed box that broadcasts degraded or incorrect data: a misconfigured ICAO address, a weak or wrong-class GPS position source, an antenna problem, or a setup that fails the §91.227 performance numbers in flight. §91.225 requires the equipment to meet §91.227, not merely to exist. The PAPR is how the FAA — and you — find that out before it becomes a problem.
Where ADS-B Out Is Required — 14 CFR §91.225
14 CFR §91.225 defines the airspace in which ADS-B Out has been required since January 1, 2020 — Class A through §91.225(a), plus the airspace listed in §91.225(d). For a turbine Part 135 or Part 91K operator, the practical answer is "essentially everywhere you fly" — but the rule is specific, and an inspector reads it literally.
Class A airspace
All of Class A (generally at and above 18,000 feet MSL), required by §91.225(a) rather than the (d) list. 1090ES required here — see the link rules below.
Class B and Class C airspace
All Class B and Class C airspace areas, including from the surface up.
The 30-NM Mode C veil
Within 30 nautical miles of the busiest Class B primary airports listed in appendix D, section 1 to part 91, from the surface to 10,000 feet MSL.
Above Class B / Class C
Above the ceiling and within the lateral boundaries of Class B or Class C, up to 10,000 feet MSL.
Class E at/above 10,000 ft MSL
Class E airspace at and above 10,000 feet MSL over the 48 contiguous states and the District of Columbia — excluding the airspace at and below 2,500 feet above the surface.
Gulf of Mexico Class E
Class E airspace over the Gulf of Mexico at and above 3,000 feet MSL, within 12 nautical miles of the U.S. coastline.
Which Link — 1090ES or UAT — and the FL180 Line
§91.225 does not just say where — it says which equipment link is acceptable in which airspace, and the dividing line is 18,000 feet MSL.
In Class A airspace, the aircraft must have ADS-B Out equipment meeting the performance requirements referenced in §91.225(a) and §91.227 — implemented as 1090 MHz Extended Squitter (1090ES).
UAT is not sufficient for Class A. Any aircraft that operates above FL180 — essentially every turbine Part 135 and fractional aircraft — must be 1090ES-equipped.
Below 18,000 feet MSL, in the airspace described in §91.225(d), the aircraft may use either 1090ES or a Universal Access Transceiver (UAT) on 978 MHz — as long as the equipment meets §91.227.
UAT is the lower-altitude, general-aviation option. A piston aircraft that never climbs into Class A can be UAT-only and fully compliant; a jet cannot.
Exceptions and deviations — §91.225(e), (f), (g)
Aircraft never originally certificated with an engine-driven electrical system (certain gliders and balloons) have a narrow exception under §91.225(e). When equipped, §91.225(f) requires you to operate the ADS-B Out equipment in the transmit mode at all times unless otherwise authorized by the FAA or directed by ATC. And under §91.225(g), to fly in (d) airspace without operative ADS-B Out you need ATC authorization: if it is installed but inoperative, the request to the ATC facility having jurisdiction may be made at any time; if the aircraft is not equipped at all, the request must be made at least one hour before the proposed operation.
ADS-B Out lives in the same equipment family as the transponder, so its records belong alongside the recurring inspection records. For the 24-calendar-month transponder and altimeter tests that an inspector cross-checks next to ADS-B, see the §91.411 / §91.413 altimeter and transponder inspection records, and for how the installation entry itself must be written, see the §43.9 maintenance record entry requirements.
The Performance Standard — 14 CFR §91.227
14 CFR §91.227 is the part of the rule that the box has to actually live up to. It defines the data the ADS-B Out system must broadcast and the minimum quality of that data. These are the numbers a PAPR measures your flight against. The five quality parameters below are the ones that matter most for compliance.
The §91.227 Quality Parameters
| Parameter | What it expresses | §91.227 minimum |
|---|---|---|
| NACp | Navigation Accuracy Category — Position: how accurate the broadcast position is | Less than 0.05 NM |
| NIC | Navigation Integrity Category: the containment radius around the reported position | Less than 0.2 NM |
| NACv | Navigation Accuracy Category — Velocity: how accurate the broadcast velocity is | Less than 10 meters/second |
| SIL | Source Integrity Level: probability the reported position exceeds the NIC radius without alert | Less than or equal to 1 × 10⁻⁷ per flight hour |
| SDA | System Design Assurance: integrity of the equipment design itself | Per the §91.227 standard |
Source: 14 CFR §91.227. §91.227 also specifies the full set of broadcast message elements (position, barometric and geometric altitude, velocity, Mode A code, aircraft identification, emergency status, and the quality indicators above) and how quickly changes must be reflected in the broadcast. Verify the exact, current values against the regulation text — the parameters above are the compliance-critical ones.
Two things make §91.227 different from a once-and-done install:
It depends on the GPS position source
NACp, NIC, and SIL come from the position source feeding the transmitter. An ADS-B box paired with an under-spec or improperly configured GPS source will broadcast the install perfectly and still fail the performance numbers. Maintenance on the GPS source can change ADS-B performance.
The FAA watches for Non-Performing Emitters
The FAA continuously monitors ADS-B broadcasts and flags aircraft transmitting non-compliant or incorrect data as Non-Performing Emitters (NPE). An NPE flag is the FAA telling you your installed equipment does not meet §91.227 in flight — and it is exactly what a PAPR surfaces for your own aircraft.
Related Aviation Compliance Guides
The Public ADS-B Performance Report (PAPR) — Your Proof It Performs
The FAA built a free, self-service tool — the Public ADS-B Performance Report (PAPR), at adsbperformance.faa.gov — so any operator or avionics shop can verify that an aircraft's ADS-B Out broadcast met the §91.227 performance requirements on a specific flight detected within FAA surveillance coverage. It is the single most useful document in the ADS-B records picture, because it closes the gap between "the box is installed" and "the box performs."
- A flight date in Zulu (UTC) time — optionally a specific flight time
- Your U.S. tail number, OR the ICAO 24-bit address (hex, octal, or decimal)
- Your name and email address (the report is emailed back)
- The ADS-B data link type — 1090ES, UAT, or dual
- Make/model of the ADS-B transmitter and the position source (usually the GPS)
- Who installed it — Part 145 repair station, mechanic, factory, or self-installed
- A report — typically emailed within about 30 minutes — analyzing your detected flight
- Whether the broadcast met the §91.227 performance requirements (the position-quality parameters)
- An indication if the aircraft was flagged as a Non-Performing Emitter (NPE)
- A document you can save as evidence that the installation performs in flight
When to pull a PAPR
There is no CFR-mandated PAPR schedule — but the events that make a PAPR worth pulling are predictable:
- Right after the ADS-B installation or STC — confirm the new install actually performs before relying on it.
- After any avionics or GPS-position-source maintenance — the parameters that drive §91.227 can change with the position source.
- Periodically as a health check, and especially if you receive any FAA contact about your broadcast or an NPE flag.
- Before a surveillance audit or aircraft transaction — a clean PAPR is fast, free evidence that the ADS-B installation is sound.
The PAPR is evidence, not a substitute for the test records
A current PAPR proves §91.227 performance — but it does not satisfy the §91.413 24-calendar-month transponder test, and the transponder test does not prove §91.227 ADS-B performance. On aircraft where the 1090ES function lives inside the Mode S transponder, the same box is involved, but the two records answer different regulatory questions. Keep the PAPR, the transponder test sign-off, and the installation paperwork as separate, distinctly filed records.
Record Discipline — The Complete ADS-B Evidence Set
ADS-B compliance is proven by a small but specific cluster of documents. Here is what a complete, audit-ready ADS-B record set looks like — and the specific ways operators leave it incomplete.
Complete ADS-B Record Set
- The ADS-B Out installation entry / STC paperwork — the §43.9 record of the install
- Documentation of the data link (1090ES / UAT) and the approved GPS position source
- A current PAPR showing the broadcast met §91.227 — post-install and post-maintenance copies
- The §91.413 24-calendar-month transponder test sign-off (separate record)
- Any ATC deviation authorizations under §91.225(g), if relied upon
- For the fleet, the ADS-B equipage status of each tail in one place
How These Records Fail
- Treating the installation entry as the end of the story — no PAPR, no proof of performance
- Never re-pulling a PAPR after GPS-source or avionics maintenance changed performance
- Assuming the §91.413 transponder test covers ADS-B performance — it does not
- An NPE flag the operator never knew about because no one ever requested a PAPR
- UAT-only equipage on an aircraft that operates above FL180 (Class A needs 1090ES)
- Relying on §91.225(g) deviations operationally without keeping the authorization on file
FileFlo as the ADS-B Records Layer
FileFlo is a compliance document intelligence platform — a read-only proof layer that sits alongside your avionics shop and maintenance-tracking stack and completes it. It does not install ADS-B Out, monitor your live broadcast, request PAPRs for you, or run a maintenance-tracking, dispatch, or flight-operations system. What it does is make the records that prove ADS-B compliance instantly producible.
- Classifies uploaded ADS-B documents against their role — installation/STC entry, PAPR, §91.413 transponder test, deviation authorization — and keeps them distinct
- Indexes each tail’s ADS-B equipage (1090ES / UAT / dual) and position source so the fleet picture is one view
- Tracks the PAPR as a follow-up record and prompts a fresh pull after avionics or GPS-source maintenance
- Surfaces a missing or stale ADS-B record before a surveillance audit or aircraft transaction
- Generates an inspector-format records binder on demand, organized by aircraft and by requirement
FileFlo classifies 600+ compliance document types and manages records across Part 91, Part 135, and Part 145 operators in a single platform. Pricing: Starter $89/mo, Professional $299/mo. 5-day free trial, no credit card required. FileFlo keeps the documents that prove compliance audit-ready — it does not install avionics, monitor your ADS-B broadcast, or run a safety management system (SMS), dispatch system, or flight operations system.
ADS-B Applies Across Operators — the Records Accountability Differs
§91.225 and §91.227 are general Part 91 operating rules — they apply to any aircraft in the designated airspace, regardless of certificate. What changes by operator is who owns the ADS-B records and how a lapse surfaces.
Who is responsible
Owner/operator
Owner holds the install paperwork and should pull a PAPR after install and after avionics work. Most likely to never request a PAPR at all.
Who is responsible
DOM + accountable manager
ADS-B records fold into the maintenance program and the aircraft files an inspector reviews during surveillance. 1090ES is effectively mandatory (Class A).
Who is responsible
Program manager
Fleet-wide equipage and performance must be tracked per tail; a single NPE aircraft is a program-level records gap, not just one airplane.
ADS-B records sit inside the broader set of aircraft and operator records an inspector cross-checks. See Part 91 aircraft records requirements for where the install entry lives, the Part 91K fractional ownership compliance records for the program view, and what operational control means in Part 135 for who actually answers for the aircraft. The same recurring-records discipline applies to the FAA Part 135 SMS 2027 deadline and to airworthiness directive compliance records.
Frequently Asked Questions
Where is ADS-B Out required under 14 CFR §91.225?
ADS-B Out has been required since January 1, 2020 in the airspace defined by 14 CFR §91.225: Class A airspace (required by §91.225(a) — Class A is not part of the (d) list); and the airspace listed in §91.225(d) — all Class B and Class C airspace; within 30 nautical miles of the busiest Class B primary airports listed in appendix D, section 1 to part 91 (the so-called Mode C veil), from the surface up to 10,000 feet MSL; above the ceiling and within the lateral boundaries of Class B and Class C up to 10,000 feet MSL; Class E airspace at and above 10,000 feet MSL over the 48 contiguous states and the District of Columbia, excluding airspace at and below 2,500 feet above the surface; and Gulf of Mexico Class E airspace at and above 3,000 feet MSL within 12 nautical miles of the U.S. coastline. If you fly a Part 135 turbine fleet, you are almost always in §91.225 airspace.
What is the difference between §91.225 and §91.227?
They are two halves of one requirement. 14 CFR §91.225 tells you WHERE ADS-B Out is required (the airspace) and which equipment links are acceptable in which airspace. 14 CFR §91.227 tells you HOW WELL the equipment must perform — the actual broadcast performance standard. §91.225 references §91.227 directly: the installed equipment must meet the §91.227 performance requirements. In practice, §91.225 is the airspace and link-eligibility rule, and §91.227 is the position-quality rule (NACp, NIC, NACv, SIL, SDA). A piece of equipment can be physically installed and still fall short of the §91.227 numbers in flight, which is exactly what a Public ADS-B Performance Report (PAPR) reveals.
What is a Public ADS-B Performance Report (PAPR) and how do I request one?
A PAPR is a free FAA report, requested through the FAA's ADS-B performance website (adsbperformance.faa.gov), that analyzes one of your flights detected within FAA surveillance coverage and tells you whether your ADS-B Out broadcast met the §91.227 performance requirements. You provide a flight date in Zulu (UTC) time, your U.S. tail number or ICAO 24-bit address, your name and email, your data link type (1090ES, UAT, or dual), the make/model of your ADS-B transmitter and position source, and who installed it. The report is typically emailed back within about 30 minutes. The FAA also automatically flags aircraft that appear to be transmitting Non-Performing Emitter (NPE) data. A clean PAPR is the practical proof that your installation actually performs, not just that it is installed.
Is the PAPR a required record under the CFR?
No. There is no CFR section that requires you to keep a PAPR on file. §91.225 and §91.227 require the equipment to be installed and to perform; they do not mandate a specific performance report. But the PAPR is the most direct evidence that your equipment meets §91.227 in actual flight, and the FAA built the tool specifically so operators and installers can self-verify. Treating the PAPR as a record you pull after installation, after any avionics or GPS-source maintenance, and periodically thereafter is a best practice — not a regulation. FileFlo treats it as a trackable document: it indexes the PAPR alongside the installation paperwork and the §91.413 transponder test so the whole ADS-B evidence picture lives in one place.
Does ADS-B Out replace the §91.413 transponder test?
No. They are separate obligations that touch related equipment. The ATC transponder test under 14 CFR §91.413 is a 24-calendar-month test and inspection of the transponder against appendix F of part 43. ADS-B Out under §91.225 / §91.227 is a continuous broadcast performance requirement, not a 24-month test. On many aircraft a 1090ES ADS-B Out function is built into a Mode S transponder, so the same box is involved — but the §91.413 transponder sign-off does not by itself prove §91.227 ADS-B performance, and a current PAPR does not satisfy the §91.413 transponder test. Keep both records, and keep them distinct. See our guide on the §91.411 / §91.413 24-month altimeter and transponder records for the test side.
What links are allowed — 1090ES versus UAT — and where?
Under 14 CFR §91.225(a), in Class A airspace (at and above 18,000 feet MSL) the aircraft must be equipped with 1090 MHz Extended Squitter (1090ES) ADS-B Out meeting §91.227; UAT is not sufficient for Class A. Under §91.225(b), below 18,000 feet MSL in the §91.225(d) airspace, you may use either 1090ES or a Universal Access Transceiver (UAT) on 978 MHz, as long as it meets §91.227. The practical takeaway: any aircraft that operates above FL180 — which is essentially every turbine Part 135 and Part 91K aircraft — needs 1090ES. UAT-only is a general-aviation, below-18,000-feet option. The FL180 line is the dividing point in §91.225.
Can I fly in ADS-B airspace if my ADS-B Out is inoperative or not installed?
Only with ATC authorization, under 14 CFR §91.225(g). If your ADS-B Out is installed but inoperative, a request to deviate may be made to the ATC facility having jurisdiction over the airspace at any time. If the aircraft is not equipped with ADS-B Out at all, the request must be made to that ATC facility at least one hour before the proposed operation. §91.225(f) also requires that, when equipped, you operate the ADS-B Out equipment in the transmit mode at all times unless otherwise authorized by the FAA or directed by ATC. Aircraft never originally certificated with an engine-driven electrical system (for example certain gliders and balloons) have a narrow exception under §91.225(e).
Does FileFlo install, monitor, or fix ADS-B Out equipment?
No. FileFlo is a compliance document intelligence platform — a read-only proof layer. It does not install ADS-B Out, monitor your live broadcast, request PAPRs for you, or run a maintenance-tracking, dispatch, or flight-operations system. What FileFlo does is classify and index the records that prove ADS-B compliance — the installation and STC paperwork, the §91.413 transponder test sign-off, the PAPR you pull from the FAA, and any LOA or operations-specification authorizations — then track follow-up dates and surface alerts so a stale or missing ADS-B record never surprises you in a records audit or surveillance inspection. The equipment work is done by your avionics shop; the FAA generates the PAPR; FileFlo keeps the proof audit-ready.
Prove your ADS-B actually performs — and keep the record
FileFlo classifies your ADS-B installation paperwork, PAPR, and §91.413 transponder test, keeps each tail's equipage and position source indexed, prompts a fresh PAPR after avionics maintenance, and generates a complete inspector-format records binder on demand. Starter plan $89/mo. Professional $299/mo. 5-day free trial — no credit card required.
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Written by Chad Griffith, Founder & CEO of FileFlo — compliance document intelligence. Reviewed June 9, 2026. FileFlo is a compliance document intelligence platform, not legal counsel, an A&P, or an avionics shop. Verify all airspace requirements, §91.227 performance thresholds, equipment eligibility, and who-may-sign rules with a certificated A&P or IA, your avionics shop, and your FSDO.