Imagine the airport manager emails your board asking for the club's tax returns and membership list, "to confirm you're operating as a flying club". It's not the friendliest email to open over breakfast, and you'll want a calm, quick answer.
At a US airport that has taken federal money, the answer comes from section 10.6 of FAA Order 5190.6C, the Airport Compliance Manual. It treats a flying club as a group of private owners and a rental business as a commercial operator, and the difference comes down to five rules. Only members fly the aircraft. The club charges no more than the aircraft cost to run and replace. Instructors and mechanics are paid or credited, never both. Neither the club nor its members sell anything at the airport to non-members. And the club never markets itself as a place to learn to fly.
Break them and the club can be made to stop operating as a club at every airport its sponsor controls. So it's worth knowing them before that email arrives.
Club or rental operation, rule by rule#
Section 10.6 sets out general conditions plus nine items the FAA suggests airports adopt. Here's how they line up against a rental business on the same field:
| Question | Flying club (Order 5190.6C, 10.6) | Rental operation |
|---|---|---|
| Who owns the aircraft | The club in its own name, or all members together, with equal property rights (10.6b) | The business or its lessors |
| Who may fly them | Members only, plus an instructor from a flight school based on the airport when teaching a member (10.6c(2) and (3)) | Any qualified customer |
| Charter, air taxi, rental to others | Not allowed (10.6c(2)) | Rental is its business; charter and air taxi need FAA certification |
| Revenue from the aircraft | No more than needed to operate, maintain and replace them; no net earnings to any individual, including as salaries or bonuses (10.6b) | Priced for profit |
| Flight instruction | Members only, under the conditions below (10.6c(2) and (3)) | Anyone who pays |
| Selling goods or services | Neither the club nor its members may lease or sell goods or services at the airport to anyone who is not a member; the club may sell or exchange its capital equipment (10.6c(5)) | Anyone |
| Advertising | Must not hold out as an FBO, specialised service operator, maintenance facility or flight school, nor say in any marketing that it is a flight school or a business where people can learn to fly (10.6c(8) and (9)) | Free to advertise |
| Airport standards | Not subject to commercial FBO requirements, provided it meets the airport's flying club conditions (10.6c(1)) | Commercial minimum standards |
The bit with teeth is 10.6d. If the club breaks these requirements, or lets one or more members do so, the sponsor may require it to stop all operations as a flying club at every airport the sponsor controls. If your county or city runs several fields, that's all of them.
Which document applies, and who it binds#
Order 5190.6C took effect on 20 February 2026. It cancelled and replaced Order 5190.6B, the 2009 manual that most club guidance you'll find still cites. The flying club section kept its number, 10.6, in chapter 10 (Reasonable Commercial Minimum Standards), and it carries forward the amendments from the FAA's 2016 flying club policy (81 Fed. Reg. 13719).
The Order doesn't regulate your club directly. It's guidance to FAA staff on what airport owners (sponsors) promised in return for federal grants or property. The sponsor writes its flying club items into the airport's minimum standards and rules, and those, with your lease, are what your club actually signs up to.
So we'd read your airport's own documents first. They may be stricter in places, such as a cap on paid instruction, and the Order expressly allows that.
If you aren't sure whether your airport is obligated at all, ask the airport manager. Under the current sponsor assurances, a development grant binds a public sponsor for the useful life of the project up to 20 years (at least 10 years for a private sponsor), and land bought with federal funds binds it without limit.
Why airports enforce the flying club rules#
Grant assurance 22 obliges the sponsor to make the airport available on reasonable terms and without unjust discrimination to all kinds of aeronautical activity. Order 5190.6C says a genuine flying club counts as an individual under it, with the right to fuel and maintain its own aircraft with its members.
The FBO and the flight school, meanwhile, pay for their place on the field through rent and minimum standards. You can see why they'd be touchy. The FAA's 2016 policy is blunt about the worry: businesses that call themselves a "flying club" "in order to avoid having to comply with the airport's minimum standards for commercial service providers", which "put other commercial aeronautical service providers at an economic disadvantage."
How the FAA defines a flying club#
Order 5190.6C defines a flying club as "a nonprofit entity (e.g., corporation, association, or partnership) organized for the express purpose of providing its members with aircraft for their personal use and enjoyment only."
Section 10.5f of the same chapter lists "for profit aircraft flying clubs" next to flight training and charter as examples of specialised aviation service operations, the single-service commercial providers. So a club run for profit is a commercial operator in the FAA's eyes, whatever the sign on the hangar door says.
Paying instructors and mechanics in a flying club#
Until 2016, member instructors couldn't be paid at all. They could only be credited against dues or flight time. The FAA changed that after a petition from AOPA.
One of the comments on that petition makes the problem very easy to picture. It came from the president of a non-profit club at Skyhaven Airport in Rochester, New Hampshire. The airport had no flight school, so members couldn't get checkouts or further training in club aircraft without breaking airport policy. And several local instructors would have joined the club if they could have been paid.
The current rule, 10.6c(3), allows instruction in club aircraft in two cases:
- Both the instructor and the person being taught are members of the club that owns the aircraft.
- The instruction is given by a lessee based on the airport that provides flight training, and the person being taught is a club member.
Either way, the instructor may be paid, or may be compensated with credit against dues or flight time. What they may not do is get paid while also on waived or discounted dues or flight time. The FAA agreed with the FBO association NATA here, saying that offering both "may result in abuse and the use of outside instructors and mechanics who have no investment of time or commitment to the club." The sponsor may also limit how much paid instruction happens.
Mechanics follow the same pattern under 10.6c(4), with one extra condition. The mechanic must also be a qualified, registered member and part owner of the club's aircraft. The sponsor may cap paid maintenance too.
This is the bit we'd be most careful with, because it's easy to get wrong with the best of intentions. Say you have a member CFI who flies with five club students. Under the first option, they pay full dues like everyone else and get paid for their instruction. Under the second, their dues are waived or discounted, or they earn flight time credit, and they aren't paid. What you can't have is a CFI on waived or discounted dues who also invoices students for lessons. That's exactly the combination the 2016 policy ruled out.
So write the decision down, for each instructor and each mechanic. It feels like paperwork for its own sake until somebody asks.
What the money rule means for your hourly rate#
The rule says a club "may not derive greater revenue from the use of its aircraft than the amount needed for the operation, maintenance and replacement of its aircraft". It's the one a sponsor can test against your tax return.
It doesn't ask you to break even to the cent. Replacement is expressly a cost, so an engine reserve and savings towards the aircraft's eventual replacement are within the rule. What a sponsor is more likely to question is a surplus with no stated purpose, or money flowing to individuals.
Here's an illustrative budget for one Cessna 172 flown 400 hours a year, with figures picked for easy arithmetic rather than taken from any real club:
| Item | Per year | Per hour at 400 hours |
|---|---|---|
| Insurance | $4,800 | $12.00 |
| Hangar | $6,000 | $15.00 |
| Annual inspection and routine maintenance | $8,000 | $20.00 |
| Engine reserve ($44,000 overhaul over a 2,000-hour TBO) | $8,800 | $22.00 |
| Fuel, 8 US gallons an hour at $6.50 | $20,800 | $52.00 |
| Total | $48,400 | $121.00 |
Run your own numbers in the aircraft cost per hour calculator.
A wet rate of $121, or a lower rate with monthly dues carrying the fixed costs, keeps the aircraft funded with no unexplained surplus. Now say the board sets $135 to build a fund to replace the aircraft when it's retired. That's fine, but minute the decision and keep the money in a named reserve. A fund for an additional aircraft doesn't count as replacement, so talk to your sponsor before building one from hourly rates.
The rate we'd steer well clear of is one set to match the FBO down the road, with the surplus spent on anything other than the aircraft. That's hard to square with 10.6b, and 10.6d lets the sponsor end the club's status over it. For the method behind the numbers, see how to set a hire rate.
Recruiting members without advertising lessons#
Items 8 and 9 catch clubs that never meant to act like a business. Picture a keen new committee member who puts "Learn to fly with us" across the top of the website, hangs a banner at the county fair offering lessons, or sells discovery flights to visitors. Each of those presents the club as a flight school or as selling services to non-members. Item 5 goes further: neither the club nor any member may sell fuel, rides or aircraft time at the airport to anyone who isn't a member.
You can still recruit, and you should. Describe the club as a non-profit group of pilots sharing aircraft, say what membership costs and list the aircraft. Keep training out of public marketing entirely. Explain instruction to a prospective member in conversation, or in the members' handbook.
If you're unsure where your airport draws the line, show the sponsor your website copy before it goes live. It's a far easier conversation before than after.
If your airport has a Part 141 or Part 61 school as a lessee, the second route in 10.6c(3) lets its instructors teach your members in your aircraft. That often suits a club that's short of instructors. See Part 61 or Part 141 for how those schools work.
Documents to keep ready for the sponsor#
Under section 10.6c the sponsor can ask for documents reasonably needed to show the club is a non-profit and not an FBO, such as tax returns, insurance policies and membership lists. Item 7 says the club should file whatever periodic documents the sponsor requires.
Keep these current and you can answer that email from the airport manager in an afternoon:
- the club's articles and bylaws, showing non-profit status, aircraft ownership and equal member property rights;
- a current membership list with join dates;
- insurance policies for each aircraft;
- the latest tax return;
- the board's decisions on hourly rates, dues and reserves;
- a record, for each instructor and mechanic, of whether they are paid or credited;
- the airport's current flying club conditions, with the date you last read them.
Under 11.9d the sponsor can also hold a club claiming self-service status to the same rules as its other self-fuelling and self-maintaining operators. So add any self-service permit the airport issues to the pile.
Keeping flying club records in Volanti#
Everything on that list except the bylaws and the tax return comes from the club's daily records. And pulling those together from a handful of spreadsheets is real work, and it tends to land on a volunteer treasurer late in the evening.
Volanti's booking rules can refuse a booking unless the pilot holds an active membership, so the members-only rule holds at the moment someone books. Every completed flight is priced at the club's rate and charged to the member's account. Credit approved for an instructor or mechanic is held on their account and applied to their charges automatically, so the ledger shows whether each one is paid or credited.
Member records keep an audit trail of changes, and reporting exports members, flights and charges as CSV, plus a report of transactions against each aircraft, for the sponsor's file. The flying clubs page shows how it fits a club.
The compliance decisions stay with your board and your airport. The records behind them, though, don't have to be assembled by hand.