Direct Answer
To get RVSM authorization, 14 CFR §91.180 requires two things: your aircraft and operation must meet the minimum standards of 14 CFR Part 91 Appendix G, and you must be authorized by the Administrator or your country of registry. There are two ways to satisfy the authorization. The legacy path is an aircraft data package plus a Letter of Authorization (LOA) for Part 91, or OpSpec / MSpec paragraph B046 for Part 135 / 125, issued by your FAA Flight Standards office. The ADS-B Out path — added by the December 2018 final rule, effective January 22, 2019, and codified in Appendix G Section 9 — lets an aircraft with a qualified ADS-B Out system meeting §91.227, flown by pilots with sufficient RVSM knowledge, operate in U.S. domestic RVSM airspace with no LOA or OpSpec at all.
The catch: the ADS-B relief is domestic only. For any operation outside U.S.-controlled airspace — oceanic, international, or another country’s RVSM airspace — you still need an LOA or OpSpec / MSpec B046, because ICAO Annex 6 requires a specific authorization from the State of the Operator. And on both paths the underlying requirements still apply: RVSM-grade altitude-keeping equipment, the recurring §91.411 and §91.413 tests every 24 months, pilot RVSM knowledge, and continuous FAA height-keeping monitoring. RVSM is a documentation-and-equipment regime — the authorization is only as good as the records that keep it valid.
A quick clarification before we go deep, because it trips up nearly everyone: getting RVSM authorization is not the same as keeping your RVSM equipment current. This guide is about getting the authorization — the §91.180 / Appendix G approval, the LOA or B046, and the ADS-B path. The companion piece on RVSM altimeter, static, and transponder inspection records covers the recurring equipment side — the §91.411 and §91.413 tests that keep an authorized aircraft RVSM-eligible. You need both: the authorization to fly RVSM, and the inspection records that prove the aircraft still qualifies. FileFlo tracks the authorization document and the inspection records together so neither one quietly lapses.
The Two Paths to RVSM Authorization
Start from the regulation. 14 CFR §91.180 says no person may operate a civil aircraft in RVSM airspace unless (1) the operator and the operator’s aircraft comply with the minimum standards of Part 91 Appendix G, and (2) the operator is authorized by the Administrator or the country of registry. Condition (1) — the aircraft equipment and the operating standards — never goes away. What changed in 2019 is how you can satisfy condition (2).
Path 1 — LOA / OpSpec B046
The legacy approval. Works everywhere, including international.
Submit an aircraft data package and program documentation to your FSDO / CMO; the FAA issues a Letter of Authorization (Part 91) or OpSpec / MSpec paragraph B046 (Part 135 / 125).
Required for: any RVSM operation, and the only valid path for oceanic / international RVSM.
Path 2 — ADS-B Out (domestic)
Added 2019. No LOA / OpSpec needed for U.S. domestic RVSM.
If the aircraft has a qualified ADS-B Out system meeting §91.227 and pilots have sufficient RVSM knowledge (Appendix G Section 9), you may fly U.S. domestic RVSM with no FAA authorization document.
Stops at: the edge of U.S.-controlled airspace. Beyond it, revert to Path 1.
The ADS-B path removes paperwork, not requirements
The 2019 rule eliminated the application and authorization document for domestic operations — it did not eliminate the equipment standards, the maintenance program, the pilot-knowledge requirement, or FAA height monitoring. Appendix G still governs the aircraft. The most common mistake is treating “no LOA required” as “no RVSM requirements,” or assuming domestic relief follows you across an international boundary. It does not.
Path 1: The LOA / OpSpec B046 Approval Process
This is the four-part process to obtain a Letter of Authorization (Part 91) or OpSpec / MSpec paragraph B046 (Part 135 / 125). It remains the path for any operator that flies outside U.S.-controlled airspace, and the path of record for operators that prefer a held authorization document.
Confirm the aircraft is RVSM-capable (Appendix G, Section 2)
Verify the aircraft has the required altitude-keeping equipment: two independent altitude-measurement systems, an altitude-alerting system, an automatic altitude-control system, and a transponder — and that its altimetry system error is contained within the tolerance band for its certification category. For most business aircraft this is established by the type certificate, an RVSM service bulletin, or an STC. The output is an RVSM aircraft data package.
Build the RVSM maintenance program
Document how the altimetry and altitude-keeping systems will be tested and maintained — including the recurring §91.411 altimeter / altitude-reporting test and §91.413 transponder test (each every 24 calendar months) and any RVSM-specific altimetry checks. This program is part of what the FAA reviews before issuing authorization.
Establish the RVSM pilot-knowledge / training element
Pilots must have sufficient knowledge of RVSM operating procedures, contingency procedures, and weather/turbulence procedures. Part 135 and 125 operators fold this into their approved training program; Part 91 operators document it as part of the LOA application.
Submit to your FSDO / CMO and receive B046
Submit the aircraft data package and program documentation to your FAA Flight Standards office. After review, the FAA issues the authorization: a Letter of Authorization (LOA) B046 for Part 91, or OpSpec / MSpec paragraph B046 for Part 135 / 125. That document, listing the approved aircraft and airspace, is your operator authorization under §91.180.
What “B046” actually is: B046 is the standardized FAA authorization paragraph for RVSM. It appears as a stand-alone Letter of Authorization for Part 91 operators and as a numbered paragraph inside the Operations Specifications (Part 135) or Management Specifications (Part 91K / 125) for certificate and management-specification holders. It names the specific approved aircraft and the authorized airspace. If you operate a charter certificate, your director of operations and chief pilot should know exactly which tails are on your B046 and keep it amended as the fleet changes.
Is your RVSM authorization actually airtight?
The free FAA Readiness Score tool checks the document layers behind RVSM — the authorization, the recurring §91.411 / §91.413 inspections, and the aircraft equipment records — and flags the ones most likely to lapse before an inspector ever asks. No signup; under 3 minutes.
Run the Free FAA Readiness ScorePath 2: The ADS-B Out Path (U.S. Domestic RVSM)
On December 21, 2018, the FAA published the final rule Use of Automatic Dependent Surveillance-Broadcast (ADS-B) Out in Support of Reduced Vertical Separation Minimum (RVSM) Operations, effective January 22, 2019. It revised Part 91 Appendix G to add Section 9: an aircraft equipped with a qualified ADS-B Out system meeting §91.227 may operate in U.S. domestic RVSM airspace without first obtaining an LOA or OpSpec, provided pilots have sufficient RVSM knowledge. Here is what that path looks like in practice.
Confirm a qualified ADS-B Out system (§91.227)
The aircraft must be equipped with an ADS-B Out system that meets the performance requirements of 14 CFR §91.227. This is the same ADS-B Out mandate equipment most operators already installed for §91.225, but it must meet the full §91.227 performance standard to support RVSM under Appendix G Section 9.
Confirm the aircraft still meets Appendix G altitude-keeping standards
The ADS-B path does not waive the equipment standards. The aircraft must still hold altitude within tolerance — Appendix G Section 9 references an altimetry system error (ASE) that does not exceed 200 feet in RVSM airspace. The altitude-keeping and altimetry equipment requirements of Section 2 still apply.
Ensure pilots have sufficient RVSM knowledge
Even without an LOA, pilots operating in RVSM airspace must have sufficient knowledge of RVSM procedures and contingency procedures. There is no FAA application reviewing this on the domestic ADS-B path — the responsibility sits with the operator, which makes documenting it internally a sound practice.
Fly domestic RVSM — no LOA / OpSpec required
For operations within U.S. domestic RVSM airspace, no LOA, OpSpec, or MSpec is required. The FAA continuously monitors ADS-B Out height-keeping performance at RVSM altitudes. NOTE: this relief is domestic only — for any operation outside U.S.-controlled airspace you still need a B046 authorization (see the International box below).
Why the rule exists
ADS-B Out broadcasts precise position and pressure-altitude data the FAA can monitor continuously. Because the agency can now watch height-keeping performance directly at RVSM altitudes, the case-by-case LOA review for domestic operations became redundant for ADS-B-equipped aircraft. The result is less paperwork for operators that already installed ADS-B Out for the §91.225 mandate — while the FAA retains the ability to flag an aircraft whose altitude-keeping drifts out of tolerance.
The International / Oceanic Exception
If you leave U.S.-controlled airspace, you still need a B046 authorization — ADS-B or not.
ICAO Annex 6 requires the State of the Operator to issue a specific RVSM authorization. The U.S. domestic ADS-B relief in Appendix G Section 9 does not satisfy that requirement for operations outside U.S.-controlled airspace. So a U.S. operator flying RVSM to Canada, Mexico, the Caribbean, Bermuda, across the North Atlantic, or anywhere oceanic must still hold a Letter of Authorization (Part 91) or OpSpec / MSpec paragraph B046 (Part 135 / 125) — even if the same aircraft needs no authorization for the domestic legs of the same trip.
This is the single most expensive RVSM misunderstanding in business aviation: a flight department drops or never obtains its LOA after 2019 thinking ADS-B covers everything, then files an international RVSM flight plan it is not authorized to fly. International RVSM also typically pairs with a broader international-operations document set — overflight and landing permits, RNP authorizations, and the rest. If you fly internationally, treat the RVSM authorization as one item in your international operations documents and records stack, and keep the B046 current alongside them.
Rule of thumb: domestic-only operators with a qualified ADS-B Out system can use the Section 9 path and skip the LOA. Any operator that ever crosses an international boundary or flies oceanic should obtain and maintain the LOA / B046 — it is far cheaper than discovering mid-trip that you cannot legally enter RVSM airspace en route to your destination.
The RVSM Records That Keep Your Authorization Valid
Whichever path you use, RVSM is a documentation-and-equipment regime. The authorization is only as good as the records underneath it. These are the documents to keep current and retrievable — the ones an FAA surveillance review of your aircraft and authorization will look for.
RVSM Letter of Authorization (LOA) B046 — Part 91
14 CFR §91.180; Appendix G §3
The operator authorization document for Part 91 RVSM. Required for international/oceanic RVSM even with ADS-B Out. Track the issue date, listed aircraft, and any amendments.
OpSpec / MSpec paragraph B046 — Part 135 / 125
14 CFR §91.180; Appendix G §3
The RVSM authorization paragraph in your Operations or Management Specifications. Amended whenever an aircraft is added to or removed from RVSM authority.
RVSM aircraft data package / equipment list
14 CFR Part 91 Appendix G §2
The compliance data showing the aircraft meets RVSM altitude-keeping standards — dual altimetry, altitude alerting, autopilot, transponder, and ASE tolerance. Often anchored to a type certificate, service bulletin, or STC.
ADS-B Out compliance documentation
14 CFR §91.227
Evidence the ADS-B Out system meets §91.227 performance — the basis for domestic RVSM authority under Appendix G Section 9, and the source the FAA monitors for height-keeping.
Altimeter / altitude-reporting system test record
14 CFR §91.411
Required every 24 calendar months. A lapsed §91.411 test means the aircraft is no longer RVSM-compliant regardless of the authorization on file.
ATC transponder test record
14 CFR §91.413
Required every 24 calendar months. Pairs with the §91.411 test; both underpin continued RVSM and IFR eligibility.
RVSM maintenance program record
14 CFR Part 91 Appendix G §2
The program governing recurring altimetry and altitude-keeping maintenance, plus the signoffs that show it was followed.
FAA height-monitoring results
FAA RVSM monitoring program (guidance)
The FAA continuously monitors altitude-keeping (including automatic monitoring of ADS-B Out flights). A monitoring result showing ASE out of tolerance can require corrective action — keep these notifications with the authorization file.
Pilot RVSM knowledge / training records
14 CFR Part 91 Appendix G §3
Documentation that crews have sufficient RVSM and contingency-procedure knowledge. Required on both paths; especially worth keeping on the ADS-B domestic path where the FAA does not review an application.
FileFlo: the proof layer for your RVSM authorization and its records
FileFlo is a compliance document intelligence platform — a proof layer that organizes the documents your operation already produces and proves them audit-ready. It does not obtain your LOA, write your RVSM maintenance program, engineer your altimetry, decide whether you need international authorization, or interact with the FAA on your behalf. What it does is classify over 600 document types against the governing CFR, store your LOA / OpSpec B046 alongside the aircraft RVSM equipment data, and track the recurring records that keep the authorization valid — the §91.411 altimeter test and §91.413 transponder test on their 24-month cadence, the RVSM maintenance signoffs, the ADS-B compliance documentation, and any FAA height-monitoring results.
In practice that means the moment your altimeter-system test is 90 days from its 24-month due date, you know — instead of finding out when the aircraft is technically no longer RVSM-compliant. The authorization document and every record behind it live in one place, retrievable in seconds. For the equipment side specifically, pair this with the detail in RVSM altimeter / transponder inspection records.
Related FAA authorization & compliance reading
Frequently Asked Questions
How do I get RVSM authorization for a Part 91 or Part 135 aircraft?
Under 14 CFR §91.180, no person may operate in RVSM airspace (FL290–FL410) unless two conditions are met: the operator and aircraft comply with the minimum standards of 14 CFR Part 91 Appendix G, and the operator is authorized by the Administrator or the country of registry. There are now two paths to satisfy the authorization condition. Path 1 (the legacy path): submit an aircraft data package for RVSM approval and obtain a Letter of Authorization (LOA) under Part 91, or RVSM Operations Specification / Management Specification paragraph B046 under Part 135. Path 2 (the ADS-B Out path, added by the 2018 final rule effective January 22, 2019, codified in Appendix G Section 9): if the aircraft is equipped with a qualified ADS-B Out system meeting 14 CFR §91.227 and the pilots have sufficient knowledge of RVSM requirements, the operator may fly in U.S. domestic RVSM airspace without an LOA or OpSpec at all. The other RVSM requirements — aircraft equipment standards, pilot knowledge, maintenance, and FAA height monitoring — still apply on both paths.
Do I still need an RVSM LOA if my aircraft has ADS-B Out?
It depends entirely on where you fly. For operations only within U.S. domestic RVSM airspace, no — the 2018 ADS-B Out final rule (Appendix G, Section 9) eliminated the LOA/OpSpec/MSpec requirement for aircraft equipped with a qualified ADS-B Out system meeting 14 CFR §91.227, flown by pilots with sufficient RVSM knowledge. For operations outside U.S.-controlled airspace — oceanic, international, or in another country's RVSM airspace — you still need an LOA (Part 91) or an OpSpec/MSpec paragraph B046 (Part 135/125), because ICAO Annex 6 requires the State of the Operator to issue a specific authorization regardless of ADS-B equipage. Many flight departments that fly to Canada, Mexico, the Caribbean, or across the Atlantic keep their LOA active for exactly this reason. The ADS-B path removes the paperwork only for the domestic case.
What is RVSM and where does RVSM airspace start?
RVSM stands for Reduced Vertical Separation Minimum. In RVSM airspace, the vertical separation between aircraft is reduced from 2,000 feet to 1,000 feet between flight level 290 (FL290, roughly 29,000 feet) and FL410 (roughly 41,000 feet) inclusive, per 14 CFR Part 91 Appendix G Section 1. The reduction nearly doubles the number of usable altitudes at the most fuel-efficient cruise levels for jets and high-performance turboprops, which is why nearly every business jet operator needs RVSM capability. Below FL290 RVSM does not apply, and above FL410 standard 2,000-foot separation resumes. Because the 1,000-foot buffer leaves a thin margin for altitude-keeping error, the FAA imposes precise altimetry, autopilot, and altitude-alerting equipment standards (Appendix G Section 2) and continuously monitors how well each aircraft holds its assigned altitude.
What is OpSpec / LOA paragraph B046?
B046 is the standardized authorization paragraph the FAA issues to grant RVSM operating authority. For a Part 91 operator it appears as a Letter of Authorization (LOA) titled B046; for a Part 135 or Part 125 certificate holder it appears as Operations Specification (OpSpec) or Management Specification (MSpec) paragraph B046. The B046 authorization lists the specific aircraft (by make, model, and registration) approved for RVSM, the airspace authorized, and any limitations. It is issued by your FAA Flight Standards office (FSDO / CMO) after you submit the aircraft data package showing the aircraft meets Appendix G Section 2 equipment standards and demonstrate your RVSM maintenance and pilot-knowledge programs. Under the 2018 ADS-B Out rule, B046 is no longer required for purely domestic RVSM operations in an ADS-B-equipped aircraft — but it is still the document you need for international and oceanic RVSM.
What does the RVSM approval process actually involve?
On the legacy LOA/OpSpec path, the RVSM approval process has four parts. First, aircraft approval: per Appendix G Section 2, you submit a data package showing the aircraft has the required altitude-keeping equipment — two independent altitude-measurement systems, an altitude-alerting system, an automatic altitude-control system, and a transponder — and that its altimetry system error is contained within the tolerances for its certification category. For most business aircraft this comes from the type certificate, an RVSM service bulletin, or an STC compliance statement. Second, an RVSM maintenance program describing how altimetry and altitude-keeping systems are tested and maintained. Third, an RVSM pilot training / knowledge element covering RVSM procedures, contingency procedures, and weather-related turbulence procedures. Fourth, submission to your FSDO or Certificate Management Office, which reviews the package and issues the LOA or OpSpec/MSpec B046. On the ADS-B Out path for domestic operations, you do not submit this package to the FAA at all — but you must still hold the equipment, maintenance, and knowledge elements, because they remain regulatory requirements under Appendix G.
What is the difference between RVSM aircraft approval and operator authorization?
They are two separate things that the regulation treats independently. Aircraft approval (Appendix G Section 2) is about the airframe: does this specific aircraft have the required altimetry, autopilot, altitude-alerting, and transponder equipment, and is its altitude-keeping error within tolerance? That approval is documented in the aircraft records — the RVSM equipment list, the altimetry compliance data, and the maintenance program. Operator authorization (Appendix G Section 3) is about the operator: is this operator authorized to conduct RVSM operations, and do its pilots have sufficient RVSM knowledge? On the legacy path, operator authorization is the LOA or OpSpec/MSpec B046. An aircraft can be RVSM-capable (approved) while the operator is not yet authorized, and vice versa — both must be satisfied under §91.180 before you fly RVSM. FileFlo tracks both layers: the aircraft RVSM equipment and altimetry records, and the operator's authorization document and pilot-knowledge records.
Does RVSM authorization expire, and what ongoing records do I need to keep?
The LOA or OpSpec/MSpec B046 itself does not carry a fixed expiration date the way a medical certificate does — but it remains valid only as long as the underlying conditions stay true, and your FAA office can amend or rescind it. The records that keep it valid do expire and recur: the §91.411 altimeter / altitude-reporting system test and the §91.413 transponder test are each required every 24 calendar months; the RVSM maintenance program drives recurring altimetry checks; pilot RVSM knowledge is maintained through your training program; and the FAA continuously performs height-keeping performance monitoring on your aircraft (including automatic monitoring of ADS-B Out flights at RVSM altitudes), which can generate an altimetry-system-error finding requiring corrective action. The practical compliance task is keeping the authorization document, the aircraft equipment list, the recurring inspection records, and any height-monitoring results all current and retrievable in one place.
What happens if I fly RVSM airspace without the proper authorization?
Operating in RVSM airspace without satisfying both conditions of §91.180 — aircraft and operator compliance with Appendix G, and authorization by the Administrator or country of registry — is a regulatory violation that can result in FAA enforcement action. In practice the more common problems are subtler: flying internationally on the assumption that domestic ADS-B relief covers oceanic airspace (it does not), letting a §91.411 or §91.413 test lapse so the aircraft is no longer technically RVSM-compliant, or ignoring a height-monitoring notification that the aircraft's altitude-keeping is out of tolerance. Any of these can surface during an FAA surveillance review of your aircraft and authorization records. Because RVSM is a documentation-and-equipment regime, most of the exposure is record-keeping exposure — which is exactly the gap FileFlo is built to close. For any specific authorization or enforcement question, consult your FSDO and an aviation attorney.
Keep your RVSM authorization and its records in one place
FileFlo stores your LOA or OpSpec B046 alongside the aircraft RVSM equipment data and tracks every recurring record that keeps it valid — the §91.411 and §91.413 tests on their 24-month cadence, the maintenance signoffs, and any FAA height-monitoring results — with expiration alerts before anything lapses. Starter at $89/month; Professional at $299/month (unlimited aircraft + users). Five-day free trial, no credit card required.
5-day free trial · No credit card required · Cancel anytime · FileFlo is the proof layer that organizes your authorization and records — it does not obtain the LOA, engineer your avionics, or interact with the FAA for you.