What Is a Temporary Operating Authorization and When Do You Need One?

Just bought an aircraft and waiting on registration? A Temporary Operating Authorization letter lets you fly legally while FAA paperwork processes. Here's what it is and how to get one.

What Is a Temporary Operating Authorization and When Do You Need One?

You've just bought an aircraft. The title has transferred, you have a bill of sale, and you're ready to fly — but your FAA registration paperwork is still processing. Do you just wait on the ground?

Not necessarily. A Temporary Operating Authorization (TOA) letter is a document that allows you to operate an aircraft legally during the gap between purchase and FAA registration processing.

What Is a Temporary Operating Authorization Letter?

A TOA letter is an owner-generated document that establishes your legal right to operate the aircraft during the registration processing period. It's not an FAA-issued document — it's created by the buyer and carried in the aircraft alongside the bill of sale and any existing registration documentation.

The letter typically contains:

  • Aircraft N-number, make, model, and serial number
  • Buyer's name and address
  • Date of sale/transfer
  • Statement that the aircraft was purchased and registration is pending
  • Reference to the FAA's 90-day operating period for newly purchased aircraft

The Legal Basis

Under 14 CFR 47.31(b), a buyer of an aircraft may operate it for up to 90 days after purchase without a certificate of registration, provided they carry a copy of the bill of sale or other evidence of ownership. The TOA letter serves as that supporting documentation alongside the bill of sale.

This does not mean you can fly indefinitely without registration. The 90-day clock starts from the date of sale. If your FAA registration hasn't come through in that window, you need to follow up with the FAA directly.

When Do You Actually Need One?

You need a TOA letter if:

  • You've purchased an aircraft and your registration application is still being processed
  • You're flying the aircraft home after purchase before the new registration arrives
  • You need to demonstrate current ownership during a ramp check while awaiting registration

You do NOT need a TOA if:

  • Your registration is current and in your name
  • You're operating a club or shared aircraft under existing registration
  • You're a student flying a school's aircraft

What to Keep in the Aircraft

During the TOA period, keep in the aircraft:

  • The TOA letter (signed by you as the new owner)
  • A copy of the bill of sale showing you as the buyer
  • The old registration (if you have it from the seller) — it's technically expired for the new owner but provides supporting aircraft identity documentation

Generate One in Seconds

Aeradex generates a properly formatted TOA letter for free at aeradex.com/pilot/documents. If you completed a title transfer through Aeradex, your buyer and aircraft data are already populated. If not, you fill in the details manually. The tool requires a verified Hangar account — it won't generate TOA letters for aircraft you haven't verified as yours.

The letter is always free. Aircraft registration paperwork shouldn't ground you when you can be flying.