FAA SODA: Understanding the Statement of Demonstrated Ability

One of the most common questions we receive at Go Flight Medicine is: "What is a SODA and how is it different from a Special Issuance?" If you have a permanent physical condition — a missing finger, monocular vision, color vision deficiency, or a hearing impairment — the FAA's Statement of Demonstrated Ability (SODA) may be your pathway to medical certification without the recurring paperwork and renewals that come with a Special Issuance authorization.

This article breaks down how the SODA process works, who qualifies, and what to expect step by step.

What Is a SODA?

A SODA is a formal FAA document that recognizes a pilot's ability to safely operate an aircraft despite a medical condition that would otherwise be disqualifying under 14 CFR Part 67. It is issued by the Federal Air Surgeon under the authority of 14 CFR 67.401.

The key distinction between a SODA and a Special Issuance is straightforward:

• Special Issuance (SI): Issued for conditions that are chronic, progressive, or require ongoing medical management. Must be renewed — typically annually or at each medical exam cycle. Think diabetes, heart disease, treated depression, or HIMS cases.
• SODA: Issued for conditions that are static or nonprogressive — meaning they are not expected to change over time. A SODA does not expire. Once granted, you present it at each future medical exam, and your AME can issue your certificate on the spot as long as the condition has not worsened.

The FAA's own language makes the distinction clear:

"A Statement of Demonstrated Ability (SODA) may be granted, instead of an Authorization, to a person whose disqualifying condition is static or nonprogressive and who has been found capable of performing airman duties without endangering public safety. A SODA does not expire."

Who Qualifies for a SODA?

A SODA is intended for pilots with permanent physical conditions that are not expected to deteriorate. Common examples include:

• Limb amputations or limb differences — particularly those resulting from trauma or congenital conditions rather than progressive diseases
• Monocular vision — loss of vision in one eye
• Color vision deficiency — historically one of the most common reasons for a SODA. Note: As of January 2025, SODAs are no longer issued for color vision deficiency. Pilots must instead pass one of three approved digital tests or appeal to the FAA for limitation removal.
• Hearing impairments — stable hearing loss that does not meet FAA standards but does not affect operational safety
• Other stable physical disabilities — missing digits, reduced range of motion from old injuries, etc.

Conditions that do not qualify for a SODA include those that are chronic, progressive, or require ongoing medical management:

• Cardiovascular disease
• Diabetes
• Cancer
• Asthma or other progressive pulmonary conditions
• Psychiatric conditions requiring medication (SSRIs, etc.)
• Substance use disorders (HIMS cases)

If your condition is expected to change over time or requires ongoing medical management, it falls under the Special Issuance pathway rather than SODA.

The SODA Process: Step by Step

Obtaining a SODA involves several steps. The process can take a few months, but once complete, you will never have to repeat it unless your condition changes. Here is how it works:

Step 1: Consult with Your AME (and Optionally Your FSDO)

Before starting, talk to your Aviation Medical Examiner about your condition. Your AME can help determine whether your condition is likely to qualify for a SODA versus a Special Issuance. For conditions that will require a Medical Flight Test (MFT) — which is most SODA cases — it is also a good idea to contact your local Flight Standards District Office (FSDO) to discuss the MFT process and expectations.

Step 2: Apply via MedXPress

Submit your medical certificate application through the FAA's MedXPress system as you would for any FAA medical exam. Make sure your medical documentation clearly describes your condition as static and nonprogressive. Your AME should note in the examination that you are requesting authorization for a Medical Flight Test from your chosen FSDO.

Step 3: Expect an Initial Denial

This is the part that catches most pilots off guard: your initial medical certificate application will almost certainly be denied. Do not panic. This is a normal, expected step in the SODA process — not a dead end.

The FAA's Aerospace Medical Certification Division (AMCD) in Oklahoma City must first review your medical documentation before authorizing you to take the Medical Flight Test. The denial letter is simply the mechanism by which the AMCD acknowledges your condition and begins the SODA evaluation process.

Step 4: Receive MFT Authorization

After the AMCD reviews your case, you should receive authorization to take a Medical Flight Test. This document specifies:

• The class of medical certificate you are seeking
• The specific condition being evaluated
• Instructions for scheduling the MFT with an FAA inspector or Designated Pilot Examiner (DPE)

Step 5: Complete the Medical Flight Test

The MFT is the heart of the SODA process. It is a practical flight evaluation designed to demonstrate that your medical condition does not prevent you from safely operating an aircraft. During the MFT, the examiner will evaluate your ability to:

• Operate flight controls effectively
• Perform normal and emergency procedures
• Respond to real-time flight scenarios
• Complete tasks specific to the certificate class you are pursuing

For example, a pilot with a limb amputation might be evaluated on their ability to manipulate throttle, yoke, and rudder pedals with their prosthesis or adaptive equipment. A pilot with monocular vision would be assessed on depth perception, scanning techniques, and traffic avoidance. For more on the MFT process, see our article on FAA Medical Flight Tests.

Step 6: Submit MFT Results to the FAA

After passing the Medical Flight Test, the examiner will provide documentation of your successful completion. Send this paperwork to the AMCD in Oklahoma City. The FAA will review the results and, if everything checks out, issue your SODA.

Step 7: Present Your SODA at Future Medical Exams

Once granted, your SODA does not expire. At each subsequent FAA medical exam, simply present your SODA to your AME. As long as the condition described on the SODA has not adversely changed, your AME can issue your medical certificate directly — no deferral, no waiting for Oklahoma City, no renewal paperwork.

What Can the FAA Put on a SODA?

The Federal Air Surgeon has the authority to include specific conditions on a SODA:

• Operational Limitations: Safety-related restrictions that appear on both the SODA and any medical certificate issued based on it. For example, a pilot with monocular vision might have a restriction against certain operations.
• Functional Limitations: Coordinated with the Director of Flight Standards, these may limit certain privileges of second- or third-class certificates.
• Class Specification: The SODA will specify which class of medical certificate it authorizes — First, Second, or Third Class.

Can a SODA Be Withdrawn?

Yes. Although a SODA does not expire, it can be withdrawn at the Federal Air Surgeon's discretion if:

• There is an adverse change in the holder's medical condition
• The holder fails to comply with any functional or operational limitations
• Public safety would be endangered by continued exercise of airman privileges
• The holder fails to provide medical information reasonably needed for certification
• The holder makes a false statement or entry related to the SODA

If a SODA is withdrawn, the holder receives a letter of withdrawal with the reason and has 60 days to request a written review of the decision, accompanied by supporting medical evidence. The FAA then has 60 days to issue a final decision.

SODA vs. Special Issuance: Quick Comparison

Color Vision and SODAs: What Is Changing

Historically, color vision deficiency has been one of the most common reasons for a SODA. Pilots who could not pass standard screening tests like the Ishihara plates would take an Operational Color Vision Test (OCVT) or Medical Flight Test and receive a SODA if they demonstrated adequate color perception for aviation.

As of January 1, 2025, the FAA no longer issues SODAs for color vision deficiency. Instead, pilots who cannot pass any of the three approved digital computer-based color vision tests — the Color Assessment & Diagnosis (CAD), Rabin Cone Contrast Test (RCCT), or Waggoner Computerized Color Vision Test (CCVT) — must appeal to the FAA to have their color vision limitation removed and be upgraded to a Class 1 certificate. The OCVT/MFT/SODA pathway for color vision is no longer available. For more details, see the FAA AME Guide — Color Vision Testing and our article on FAA Color Vision Testing Pathways.

Practical Tips for the SODA Process

1. Document everything. Have your treating physician provide a detailed letter confirming that your condition is static and nonprogressive. Include the diagnosis, date of onset, current status, and prognosis.
2. Get your AME involved early. Your AME can annotate your MedXPress application correctly and communicate with the AMCD on your behalf, which can prevent delays.
3. Do not be alarmed by the denial. The initial denial is a procedural step, not a final decision. It is how the FAA opens the SODA process.
4. Prepare for the MFT. Fly with your instructor or a safety pilot before the test. Make sure you are comfortable with any adaptive equipment. Practice the specific maneuvers that might be evaluated.
5. Keep your SODA document safe. You will need to present the original at every future FAA medical exam. Consider keeping a copy in a secure location as well.
6. Know your rights. If a SODA is denied or withdrawn, you have the right to request a review. Work with an aviation medical advocate or attorney if needed.

How Go Flight Medicine Can Help

Navigating the SODA process on your own can be confusing, especially when you receive that initial denial letter. At Go Flight Medicine, we have helped pilots through every phase of the SODA process — from initial consultation and AME documentation to MFT preparation and FAA submission.

If you have a static medical condition and are unsure whether you qualify for a SODA versus a Special Issuance, contact us for a consultation. We will review your specific situation and recommend the most efficient pathway to get you back in the cockpit.

References

1. FAA AME Guide — Statement of Demonstrated Ability (SODA)
2. 14 CFR 67.401 — Special Issuance of Medical Certificates
3. Guide for Aviation Medical Examiners — General Information, Airman Appeals