Direct Answer
An FAA civil penalty is a monetary sanction the agency assesses through the administrative procedures in 14 CFR §13.16 (companies and all hazardous-materials cases) and 14 CFR §13.18 (individual pilots, flight engineers, mechanics, and repairmen). The maximums are set by 49 U.S.C. §46301 and adjusted for inflation in 14 CFR §13.301: for violations occurring on or after December 30, 2024, the per-violation maximum is $75,000 for a person other than an individual or small business concern, and $1,875 for an individual or small business concern (a separate $17,062 maximum applies to certain categories, including hazardous materials).
You do not owe the number on the notice. An FAA civil penalty begins with a Notice of Proposed Civil Penalty — a proposal you can answer, reduce, settle in an informal conference, or contest. Companies can request a hearing before an administrative law judge under 14 CFR Part 13, subpart G, with an appeal to the FAA decisionmaker; individual airmen can appeal an order of assessment to the National Transportation Safety Board; and a final order is reviewable in the U.S. Court of Appeals under 49 U.S.C. §46110. Because most penalties against legitimate operators are built on missing or unretrievable records, the records you can produce are often the single biggest lever on the final number.
If a Notice of Proposed Civil Penalty has landed on your desk, the most useful thing to understand first is what it is not. It is not a verdict, it is not a bill, and the dollar figure on it is not what you will necessarily pay. It is the formal opening of a process that the regulations deliberately build with off-ramps — written responses, requests for reduction, an informal conference, a hearing, an appeal. The number is the FAA's assessment of the violations it believes your records show. Much of this article is about how that number is built and how it comes down.
One framing matters before anything else: an FAA civil penalty is different from a compliance action (a documented corrective-action plan the FAA uses for many minor or first-time issues, with no monetary penalty) and different from certificate action (suspension or revocation, which affects your authority to operate). For where the penalty track fits in the FAA's broader enforcement toolkit, see FAA compliance action vs. enforcement action and letter of correction vs. warning notice vs. investigation.
How Much Can the FAA Fine You?
The amounts are set by statute and adjusted for inflation each year, so any figure you cite needs a date stamp. The statutory base lives in 49 U.S.C. §46301, and the current inflation-adjusted maximums live in 14 CFR §13.301. The figures below are the maximums that apply to violations occurring on or after December 30, 2024 (published at 89 FR 106291, Dec. 30, 2024). Because they adjust annually, always confirm the current schedule before relying on a number.
Maximum civil penalty per violation
14 CFR §13.301 — adjusted amounts, effective Dec. 30, 2024Person other than an individual or small business concern
$75,000
49 U.S.C. §46301(a)(1) · 14 CFR §13.301
Where most certificated companies fall. This is the per-violation maximum — case totals stack across many violations.
Individual or small business concern (general)
$1,875
49 U.S.C. §46301(a)(1) · 14 CFR §13.301
Per violation, for an individual or small business concern not covered by the §46301(a)(5) categories below.
Airman serving as an airman
$1,875
49 U.S.C. §46301(a)(1) · 14 CFR §13.301
Per violation, where the airman is acting in that capacity. Appeals for individual airmen run to the NTSB under §13.18.
Individual or small business concern — hazmat & enumerated categories
$17,062
49 U.S.C. §46301(a)(5) · 14 CFR §13.301
A separate, higher per-violation maximum for the categories enumerated in §46301(a)(5), including hazardous materials.
"Per violation" is why headlines hit six figures
$75,000 is the ceiling for a single violation, not a cap on a case. Under 49 U.S.C. §46301, a separate violation can be counted for each day a continuing violation persists and, where applicable, for each flight involving the violation. One missing record category repeated across many pilots, aircraft, or months multiplies into dozens of countable violations — which is how a set of administrative paperwork failures becomes a six-figure proposed penalty. We break the arithmetic down in our companion piece on FAA fines for Part 135 paperwork violations.
There is also a jurisdictional ceiling on the administrative track. Under §13.16 and §13.18, when the amount in controversy exceeds $50,000 for an individual or small business concern (or $400,000 for other persons), the FAA cannot assess the penalty administratively — the matter goes to a U.S. district court instead. Below those thresholds, the streamlined civil-penalty process described in the next sections applies.
How the FAA Assesses a Civil Penalty
A civil penalty does not start with the dollar figure — it starts with violations. The FAA (typically through the office of the Chief Counsel for Enforcement) reviews the facts an investigation developed, identifies which Federal Aviation Regulations it believes were violated, counts the violations, and applies its sanction guidance to arrive at a proposed amount. Two documents do the heavy lifting: the statute and the FAA's internal enforcement policy.
The statute sets the ceiling and the counting rule
49 U.S.C. §46301 fixes the maximum per violation and, critically, the rule that a separate violation occurs for each day a continuing violation persists and, where applicable, for each flight involved. 14 CFR §13.301 supplies the current inflation-adjusted maximums. Together they bound how high the arithmetic can reach.
FAA sanction guidance sets the proposed amount
Within those bounds, the FAA weighs aggravating and mitigating factors under its enforcement sanction guidance in FAA Order 2150.3 (agency policy, not a regulation) — the nature and seriousness of the violation, whether it was deliberate or repeated, the operator's compliance history, and the size of the business. Falsification and repeat findings push toward the top of the range and toward certificate action.
Which rule governs your case — §13.16 or §13.18?
The two administrative civil-penalty rules split by who the respondent is, and the difference matters because they route to different appeal forums:
- 14 CFR §13.16 applies to a person other than an individual acting as a pilot, flight engineer, mechanic, or repairman — i.e., companies and operators — and to all persons for hazardous-materials violations. Appeals run through an FAA administrative law judge to the FAA decisionmaker.
- 14 CFR §13.18 applies to an individual acting as a pilot, flight engineer, mechanic, or repairman. An individual who receives an order of assessment may appeal it to the National Transportation Safety Board.
The practical implication: the same underlying event can produce a company penalty under §13.16 and an individual penalty under §13.18 against, say, the pilot or the director of maintenance — proceeding on parallel tracks to different decisionmakers. Which rule, which forum, and which strategy fits a specific case is exactly the kind of question to bring to an aviation attorney.
The cheapest way to win a penalty case is to never have the gap
The free FAA Readiness Score walks through the document categories that drive Part 135 enforcement — training currency, maintenance releases, duty/rest records, required management, drug-and-alcohol program — and flags the gaps most likely to surface as findings. No signup; under 3 minutes.
Run the Free FAA Readiness ScoreThe Appeal Process, Step by Step
Here is the path from a Notice of Proposed Civil Penalty to a final, reviewable order. The early steps are shared by §13.16 and §13.18; the tracks diverge at the hearing/appeal stage. Deadlines are short and consequential — the window in step 2 is the most important one in the whole process, and it is the moment to have an aviation attorney involved.
The Notice of Proposed Civil Penalty arrives
The action begins when the FAA sends a Notice of Proposed Civil Penalty stating the charges and the proposed amount. This is a proposal — the FAA’s opening position — not a finalized debt. The clock starts here, and the notice tells you how long you have (30 days under §13.16, or 15 days under §13.18) and where to send your response.
You choose how to respond (30 days under §13.16; 15 days under §13.18)
Under both §13.16 and §13.18 you may: pay the proposed (or an agreed) amount; answer in writing with information, documents, and witness statements showing no violation occurred or the amount is not warranted; submit a written request to reduce the penalty, stating the amount and the reasons; or request an informal conference with the agency attorney. For an individual airman, §13.18 also lets you ask that an order of assessment be issued so you can take the matter to the NTSB.
The informal conference — where most cases move
The informal conference is a meeting with the FAA agency attorney to discuss the matter and submit relevant information or documents. It is not a trial; it is the practical venue where proposed penalties are most often reduced or resolved. The strength of your position here turns on the records you can put on the table.
A final notice, then a hearing (the §13.16 track)
If the matter is not resolved informally under §13.16, the FAA issues a final notice of proposed civil penalty; within 15 days you can pay or request a formal hearing before an administrative law judge under the rules of practice in 14 CFR Part 13, subpart G. The ALJ issues a decision, which either party may appeal to the FAA decisionmaker.
The order of assessment and appeal to the NTSB (the §13.18 track)
For an individual acting as a pilot, flight engineer, mechanic, or repairman, §13.18 provides that an individual who receives an order of assessment may appeal the order to the National Transportation Safety Board. The NTSB, not an FAA ALJ, hears that appeal.
Judicial review of the final order
A final order — whether from the FAA decisionmaker under §13.16 or the NTSB under §13.18 — is subject to judicial review in the U.S. Court of Appeals under 49 U.S.C. §46110. There is also a jurisdictional line: when the amount in controversy exceeds $50,000 for an individual or small business concern (or $400,000 for other persons), the matter goes to U.S. district court rather than the administrative assessment track.
Yes, you can negotiate — and most cases move at the informal conference. Both §13.16 and §13.18 expressly let you submit a written request to reduce the proposed penalty and request an informal conference with the agency attorney. Proposed penalties are frequently reduced there, because the FAA's figure reflects the violations it believes the records reveal. Produce the records that prove a requirement was met, and the corresponding count can come off the proposal. How to conduct that negotiation, and whether to escalate to a hearing or appeal, are legal-strategy decisions for an aviation attorney.
Related enforcement reading
Why Your Records Are the Real Leverage
The uncomfortable truth about FAA civil penalties against legitimate operators is that they are usually built on missing proof, not unsafe flying — an expired competency check nobody flagged, a maintenance action without a matching airworthiness release, a manual revision that was never distributed. That is bad news going in, but it is also the source of your leverage once a notice arrives.
Before a notice: no gap, no violation to count
The FAA counts missing or non-conforming records as violations. If every required record exists, is current, and matches how you actually flew, there is nothing to stack. Complete documentation is the difference between a clean surveillance visit and the first domino of a penalty case.
After a notice: proof removes the count
At the informal conference, the most persuasive thing you can do is hand the agency attorney the document that proves the requirement was met. Because the proposed amount is built from a count of violations, producing the missing proof can take violations off the proposal — which is how proposed penalties get reduced.
On the deadline: retrievability beats reconstruction
The response window is short. Operators who can produce a complete, dated, inspector-ordered record set in days — not reconstruct it under pressure — preserve every off-ramp the process offers. Records you cannot find on time are, functionally, records you do not have.
This is also why the voluntary-disclosure programs matter: when you find a problem yourself, fix it, and report it correctly, you may avoid a civil penalty altogether. See the Voluntary Disclosure Reporting Program (VDRP) for Part 135 and how a NASA ASRS report can provide enforcement protection. And when an investigation produces a records request, know your obligations — see responding to an FAA records request during an investigation.
FileFlo: the proof layer that lowers your civil-penalty exposure
FileFlo is a compliance document intelligence platform — a read-only proof layer that sits alongside your existing stack (flight scheduling, maintenance tracking, training software) and organizes the documents those systems produce. It does not represent you to the FAA, DOT, or NTSB, file appeals or responses, conduct your audit, or give legal advice. What it does is make the records that drive enforcement current, complete, and retrievable: it classifies over 600 document types against the governing CFR, tracks expiration windows on every medical, training check, and equipment inspection, surfaces each one 90/60/30 days before it lapses, and produces an inspector-format binder on demand.
Put plainly: civil penalties against legitimate operators are built on missing proof. FileFlo's job is to make sure the proof is never missing — so a surveillance visit stays clean, and if a Notice of Proposed Civil Penalty ever does arrive, you can produce the records that take violations off the count. For the legal strategy, you bring an aviation attorney. For the documents, you bring FileFlo.
Frequently Asked Questions
How much can the FAA fine you?
It depends on who the violator is, and the maximums are adjusted for inflation each year. Under the FAA's current schedule of adjusted maximum civil penalties at 14 CFR §13.301 (the figures effective for violations occurring on or after December 30, 2024), the maximum under 49 U.S.C. §46301(a)(1) is $75,000 per violation for a person other than an individual or small business concern (most certificated companies), and $1,875 per violation for an individual or small business concern, and the same $1,875 for an airman serving as an airman. A separate, higher maximum of $17,062 per violation applies to an individual or small business concern in certain categories, including hazardous materials. These are per-violation maximums — the six-figure totals in FAA press releases are many separate violations stacked together, and they are almost always proposed amounts, not collected ones.
What is a Notice of Proposed Civil Penalty?
It is the letter that formally starts an FAA civil penalty action. The FAA's procedures live in 14 CFR §13.16 (for a person other than an individual airman, plus all hazardous materials cases) and 14 CFR §13.18 (for an individual acting as a pilot, flight engineer, mechanic, or repairman). The notice states the charges and the proposed penalty amount. Critically, it is a proposal — the FAA's opening position — not a bill you owe. Receiving one opens a defined window in which you can respond, and what you do in that window shapes everything that follows. Because the notice is fact-specific and time-sensitive, an aviation attorney should review it before you respond.
How do I appeal an FAA civil penalty?
The path depends on which rule applies. After the FAA issues a Notice of Proposed Civil Penalty, you generally have 30 days to respond under §13.16 (or 15 days under §13.18, for an individual airman): you can pay the proposed amount, submit written information and documents showing no violation occurred or that the amount is not warranted, request that the penalty be reduced, or request an informal conference with the agency attorney. Under §13.16 (companies and hazmat) you may request a formal hearing before an administrative law judge under the rules of practice in 14 CFR Part 13, subpart G, with an appeal to the FAA decisionmaker, and then judicial review of a final order under 49 U.S.C. §46110. Under §13.18 (individual airmen and mechanics), an individual who receives an order of assessment may appeal the order to the National Transportation Safety Board, with judicial review of the NTSB's final decision. This is a general map of the process, not legal advice — consult an aviation attorney.
What is the difference between a civil penalty and a fine?
In everyday speech people use them interchangeably, and the FAA's own documents use the term civil penalty. A civil penalty is a monetary sanction assessed through the agency's administrative civil-penalty procedures under 14 CFR §§13.16 and 13.18, governed by the statutory maximums in 49 U.S.C. §46301 and the inflation-adjusted amounts in 14 CFR §13.301. It is distinct from a criminal fine, which would be imposed by a court in a criminal prosecution, and distinct from certificate action (suspension or revocation), which affects your authority to operate rather than your wallet. When you read that the FAA fined an operator, what almost always happened is that the FAA proposed a civil penalty under these administrative rules.
Can you negotiate an FAA fine?
Yes — the civil penalty process is built to allow it. After a Notice of Proposed Civil Penalty, both §13.16 and §13.18 expressly let you submit a written request to reduce the proposed penalty (stating the amount and the reasons) and request an informal conference to discuss the matter with the agency attorney. Proposed penalties are frequently reduced through that informal process and through settlement, because the FAA's opening figure reflects the violations it believes the records show. The single biggest source of leverage in that conversation is documentation: when you can immediately produce complete, dated records proving the work was done and the requirement was met, proposed violations can fall away — the agency is counting missing proof, and proof that exists removes the count. How to actually conduct the negotiation is a legal-strategy question for an aviation attorney.
What happens if you don't pay an FAA civil penalty?
Ignoring a Notice of Proposed Civil Penalty does not make it disappear — it forfeits your best options. If you do not respond within the time the notice allows, the FAA can issue a final order assessing the civil penalty without the benefit of your defense, information, or settlement discussion. Once a civil penalty becomes a final order and the appeal avenues are exhausted, it is a government debt the FAA can refer for collection, including through the Department of Justice or Treasury collection processes. The whole point of responding on time is to keep the matter in the stage where you can contest it, reduce it, or settle it. Whether and how to respond in a specific case is a decision to make with an aviation attorney.
What is the statute of limitations on an FAA civil penalty?
FAA civil penalty actions are generally subject to the five-year federal statute of limitations in 28 U.S.C. §2462, which requires the government to commence an action to enforce a civil fine or penalty within five years from the date the claim first accrued. That five-year clock is the outer boundary for the FAA to initiate an enforcement action for a given violation. Because a continuing violation — including an ongoing recordkeeping gap — can be treated as a separate offense for each day it persists under 49 U.S.C. §46301, the practical exposure window for an unresolved documentation problem can reach well past the date it first appeared. The application of the limitations period to a specific set of facts is a question for an aviation attorney.
How can good records reduce my civil penalty exposure?
Most FAA civil penalties against legitimate operators are built on missing, expired, inconsistent, or unretrievable records — not on unsafe flying. That cuts two ways. Going in, complete and current records mean there is no gap for the FAA to count as a violation. Once a notice arrives, the same records are your fastest route to reducing the proposed amount: in the informal conference you can produce the document that proves a requirement was met, and that proposed violation can come off the count. Three habits prevent most exposure: (1) surface every expiring record — medicals, training checks, inspections — 90/60/30 days before it lapses; (2) keep every required record retrievable on demand in the order an inspector requests it; and (3) reconcile your records against what was actually flown. FileFlo is the compliance proof layer that does the first two automatically. It does not represent you to the FAA, file your appeal, or give legal advice.
Understand the operating rules behind the penalty
The penalty is built from a count. Don't hand them the count.
Almost every FAA civil penalty against a legitimate operator is assembled from records that were missing, expired, or didn't match the operation. FileFlo tracks every required document, surfaces what's about to lapse, and produces an inspector-ready binder in seconds — so the proof is there before the FAA asks, and there to produce if a notice ever arrives. Starter at $89/month, Professional at $299/month (unlimited pilots + aircraft). Five-day free trial, no credit card.
5-day free trial · No credit card required · Cancel anytime · A compliance document proof layer — not a replacement for your SMS, dispatch, or maintenance tracking system, and not legal counsel. FileFlo does not represent you before the FAA, DOT, or NTSB.