I know I have said it a million times, but a common question we get at the AOPA Flying Club Initiative is about FAA Order 5190.6B, Change 3. In other words, the Airport Compliance Manual. Or, more simply, “Where do all these flying club rules actually come from?” When I started at AOPA a little over a year ago, this was one of the first documents I was introduced to. I was already a flight instructor, and in my entire aviation career I had never once heard of it. Like many pilots, I had spent plenty of time with tabbed‑up FAR/AIM books for checkrides, but this FAA order was completely new to me.
FAA Order 5190.6B is a lengthy document that outlines the grant assurances and obligations airports agree to when they accept federal funding. In many cases, those obligations remain in place for 10 to 20 years. The order serves as guidance for airport sponsors and managers, covering issues like fair access, nondiscrimination, and the critical distinction between aeronautical users and commercial operators. If you scroll about 118 pages into the more than 450‑page document, you will find Section 10.6, Flying Clubs. This is easily one of my and Cade’s favorite sections.
Flying clubs are an interesting and absolutely essential part of general aviation. They make flying more affordable, but from the outside they can look like a business. In reality, flying clubs are nonprofit organizations, and the FAA has specific rules about how they must operate. By understanding and following these guidelines, clubs help ensure that airport managers and the FAA remain supporters. In the sections that follow, we will walk through some of the key points in Section 10.6. Keep in mind that airports that do not accept federal funding may not be bound by these requirements, and some states impose additional grant assurances of their own. If you have state‑specific questions, we are always happy to help.
Under FAA Order 5190.6B, a flying club is defined as a nonprofit entity—such as a corporation, association, or partnership—created solely to provide its members with aircraft for their personal use and enjoyment. That definition is intentionally narrow. It emphasizes that a flying club exists for the benefit of its members only, not the general public, and that its purpose is access to aircraft rather than the provision of services. This nonprofit, member‑focused structure is the foundation the FAA uses to distinguish legitimate flying clubs from commercial operators, regardless of whether money changes hands or instructors are involved.
FAA Order 5190.6B treats a flying club as an individual aeronautical user for purposes of airport grant assurances, rather than as a commercial business. This means a club has the right to fuel and maintain its own aircraft using its members, just as an individual owner would. At the same time, the order gives airport owners the authority to request reasonable documentation such as proof of insurance and a current membership list to confirm that the club is truly operating as a nonprofit flying club and not as a flight school, FBO, or other commercial entities. In practice, this provision is more about verification. Airports are allowed to check a club’s structure and activities to ensure it remains consistent with the FAA’s definition of a noncommercial flying club. This is great news for flying clubs as it clearly says you get to operate as an individual.
FAA Order 5190.6B draws a firm boundary between flying club activities and commercial aviation services. Under this policy, flying clubs may not offer or conduct charter, air taxi, or aircraft rental operations, all of which are considered commercial uses of aircraft. Clubs are permitted to conduct flight instruction only for their regular members, and only club members are allowed to operate club aircraft. The intent is to prevent flying clubs from functioning like flight schools or rental operations while preserving their core purpose of providing members with personal access to aircraft. This restriction is central to how the FAA distinguishes nonprofit, member‑based clubs from commercial operators on public airports.
I know we have talked about this before, but FAA Order 5190.6B provides specific guidance on when flight instruction may take place using flying club aircraft. Instruction is permitted in a club‑owned aircraft as long as both the instructor and the person receiving instruction are members of the club, or when the instruction is provided by an airport‑based flight training provider and the student is a club member. In either case, the instructor may be compensated for providing instruction, either through direct payment or through a credit toward dues or flight time, but not both at the same time. The order also allows airport sponsors to place reasonable limits on the amount of compensated instruction that occurs. Together, these conditions are intended to allow legitimate member instruction while preventing flying clubs from operating in a way that resembles a commercial flight school. Feel free to read more here about instruction in your club.
FAA Order 5190.6B also addresses maintenance performed within a flying club. A qualified mechanic who is a registered club member and part owner of a club aircraft is permitted to perform maintenance on that aircraft. The mechanic may be compensated for the work either through direct payment or through a credit toward dues or flight time, but not both at the same time. As with flight instruction, the airport sponsor is allowed to place reasonable limits on how much compensated maintenance may be performed. This guidance allows clubs to use the skills of qualified member mechanics while ensuring that maintenance activity does not evolve into a commercial operation.
FAA Order 5190.6B makes clear that flying clubs and their members may not lease, sell, or provide any goods or services to anyone who is not a club member while operating on the airport. This prohibition is intended to keep clubs from engaging in any activity that resembles a commercial business serving the public. The order does include one narrow exception. A flying club is permitted to sell or exchange its own capital equipment, such as aircraft or major assets, without being considered a commercial operator. Allowing clubs to dispose of or replace equipment recognizes normal ownership needs while still maintaining a bright line between nonprofit flying clubs and businesses that offer goods or services for hire.
This one is simple; airport managers might want to see documentation of members and tax returns. This can help prove that the club is a flying club.
FAA Order 5190.6B also prohibits flying clubs from holding themselves out to the public as fixed base operators, specialized aviation service providers, maintenance facilities, or flight schools. This means clubs may not advertise or promote themselves in a way that suggests they offer services to the general public, even if those services are similar to what an FBO or flight school provides. Because flying clubs are not commercial operators, they are not required to comply with airport minimum standards that apply to those businesses, but that exemption only applies as long as the club does not present itself as one. This provision reinforces the FAA’s core principle that flying clubs must remain clearly member‑focused and noncommercial in both their activities and how they describe themselves.
FAA Order 5190.6B is explicit that flying clubs may not describe themselves, in any form of marketing or communication, as a flight school or as a business where people can learn to fly. Language that suggests the club offers training services to the public crosses the FAA’s noncommercial boundary, even if instruction is otherwise permitted for members. This means clubs should not call themselves a flight school online, advertise flight training, or offer discovery flights to the public. That is not a flight club. The consequences of violating this requirement can be serious. If a flying club, or a member acting on its behalf, operates outside the FAA’s definition, the airport sponsor may require the club to terminate its operations as a flying club at all airports it controls. How a club presents itself publicly matters just as much as what it actually does. If your club calls itself a flight school online, advertises flight training, or offers discovery flights to the public, it is operating as a commercial flight business, not as a flying club.
Closing Thoughts
The consistent theme throughout FAA Order 5190.6B is straightforward. Flying clubs are not commercial operators, and they are expected to operate in a way that clearly reflects that distinction. Airports are under increasing pressure to enforce grant assurances consistently, and as a result, flying clubs are receiving closer scrutiny than they may have in the past. Operating within the FAA’s definition is not about limiting clubs, but about protecting them from being reclassified as something they are not.
Understanding and respecting these boundaries helps clubs maintain positive relationships with airport sponsors and neighboring businesses. Flight schools and FBOs carry significant regulatory, insurance, staffing, and facility overhead because they operate as commercial enterprises and are required to meet commercial standards. Flying clubs are intentionally treated differently, but only as long as they remain clearly nonprofit, member-focused, and noncommercial in both practice and presentation.
Operating the right way today helps avoid much larger problems tomorrow. Clubs that understand these rules, communicate carefully, and stay within their intended purpose are far more likely to remain in good standing with their airport, preserve long term access, and continue providing affordable flying opportunities for their members well into the future.
