Form 8110-3 Explained: How DER Findings of Compliance Move Aircraft Programs Forward

FAA Form 8110-3, Statement of Compliance, is the document a Designated Engineering Representative (DER) signs to certify that specific technical data complies with applicable airworthiness standards. It is the only FAA form a DER may sign under their designated authority. The form is governed by FAA Order 8110.37 and is used in type certification, supplemental type certification, technical standard order authorizations, parts manufacturer approvals based on test and computation, and major design changes. Each signed form is scoped to a specific configuration of data and to the DER’s authorized areas.

For any FAA certification program that relies on Designated Engineering Representatives, FAA Form 8110-3 sits at the center of the workflow. It is the regulatory artifact through which a DER’s finding of compliance becomes part of the formal certification record. Misunderstandings about what the form does and what it does not do are a frequent source of delay in certification programs, particularly for applicants new to working with delegated authority.

This article explains what Form 8110-3 is, when it applies, what the DER’s signature actually authorizes, and the practical workflow around its use. For background on the DER role itself, see our post on what an FAA DER is and why drone and eVTOL projects need one.

What the form is

Form 8110-3, the Statement of Compliance, is the document a DER uses to record a finding of compliance with applicable airworthiness regulations for a specific configuration of technical data. The form is governed by FAA Order 8110.37, the DER Handbook, which prescribes how the form is completed, what supporting documentation must be attached, and how the form is submitted to the FAA.

The form’s authority comes from 14 CFR §183.29, which establishes the DER as a private person appointed by the Administrator to act on behalf of the FAA in finding compliance. When the DER signs Form 8110-3, the signature is not the DER’s personal endorsement it is the formal exercise of delegated authority, equivalent in scope to an FAA engineer’s finding of compliance within the same authorized area.

Three points are essential to understand:

1. The signature certifies a specific configuration. Each Form 8110-3 references particular technical data a drawing, a report, an analysis, a test plan, or a set of these at a specific revision level. If the data changes, a new Form 8110-3 is required to cover the new configuration.

2. The signature is bounded by the DER’s authorization. A DER’s authorization defines the regulations and technical areas in which they may find compliance. A DER authorized in structures may not sign Form 8110-3 for a flight test compliance finding unless they are separately authorized in flight test. The form itself documents the specific authorization basis.

3. The form is the only signature instrument a DER may use under designated authority. A DER may issue technical opinions, write reports, or sign internal documents in many forms, but the only document that carries the weight of delegated FAA authority is Form 8110-3.

When the form applies

Form 8110-3 is used across the spectrum of FAA certification activities. The most common applications:

Type certification. During a type certification program, DERs find compliance with specific airworthiness regulations across the airframe, propulsion, systems, structures, and flight test disciplines. Each compliance finding is documented on Form 8110-3 and submitted to the responsible Aircraft Certification Office as part of the project’s compliance documentation. For UAS pursuing type certification under §21.17(b), the same workflow applies. See our post on Part 21.17(b) special class certification for context.

Supplemental type certification. STC programs follow the same pattern. The DER finds compliance with the regulations that apply to the modified design and documents each finding on Form 8110-3. The volume of forms in an STC program depends on the scope of the modification; a simple equipment installation may require a handful of forms, while a major structural modification may require dozens.

Technical Standard Order Authorizations (TSOA). TSOAs authorize the manufacture of an article that meets the minimum performance standards established in a particular TSO. DER compliance findings on Form 8110-3 support TSOA applications by establishing that the article meets the applicable performance standards.

Parts Manufacturer Approval (PMA). PMAs based on test and computation rely on DER compliance findings to establish that the replacement part is at least equivalent in design to the part it replaces. Form 8110-3 documents the compliance finding that supports the PMA.

Major changes to type design. Under 14 CFR §21.93, type design changes are classified as major or minor. Major changes require new compliance findings, and Form 8110-3 documents those findings for the affected portions of the design.

What the DER actually signs

The form itself is structured to capture several specific elements:

• The identification of the data to which the finding applies drawing numbers, report numbers, revision levels, and dates

• The regulations with which the data is found to comply

• The basis for the finding typically a reference to the project’s certification plan and the compliance methods used

• The DER’s authorization details the FAA office that issued the delegation, the authorized areas of compliance, and the DER’s authorization number

• The signature, date, and the DER’s printed name

Each of these elements has consequence. The data identification creates the configuration baseline. The cited regulations establish the scope of the finding. The compliance basis links the finding to the previously coordinated certification plan. The authorization details establish that the DER had the authority to make the finding.

The practical workflow

In a well-run program, Form 8110-3 is not the first step it is the last step in a longer sequence that the DER and the applicant work through together.

1. Certification basis and compliance method coordination. Before any compliance finding is made, the certification basis (the regulations that apply) and the compliance methods (how compliance will be shown) must be coordinated with the FAA. This is typically documented in a Project Specific Certification Plan accepted by the responsible ACO.

2. Data preparation. The applicant prepares the technical data drawings, analyses, test reports, qualification documents that will support the finding.

3. DER review. The DER reviews the data for compliance with the applicable regulations. This is the substantive work: confirming that the analysis methods are correct, the test data is sufficient, the assumptions are valid, and the conclusions follow from the data.

4. Finding and signature. When the DER determines that the data complies, the DER prepares Form 8110-3, identifies the specific data and regulations covered, and signs the form.

5. Submission and acceptance. The form is submitted to the FAA as part of the project’s compliance documentation. The responsible FAA engineer reviews the submission and either accepts the finding or issues an issue paper requesting additional information.

6. Configuration control. Once a finding is accepted, the underlying data is under configuration control. Subsequent revisions to the data require new compliance findings.

Common pitfalls

Several issues recur in DER programs:

• Scope mismatches. A DER signs a finding outside their authorized area, or the cited regulations don’t match the actual content of the data being approved. Both result in rejected submissions and rework.

• Configuration drift. The data referenced on Form 8110-3 is revised after the finding is made, without a corresponding new finding to cover the revision. The original finding no longer applies, but the program continues as if it does.

• Insufficient compliance basis. The form cites the regulations but does not adequately describe how compliance was shown. The FAA engineer reviewing the submission cannot trace the finding to specific evidence, and the submission is returned for clarification.

• Missing certification plan coordination. A DER makes a finding using a compliance method that was not coordinated with the FAA in the certification plan. Even if the finding is technically sound, it may not be accepted without retroactive plan coordination.

How Martin Solutions supports DER work

Martin Solutions provides DER services across structures, systems, and certification disciplines applicable to UAS, eVTOL, and certified aircraft programs. Our work includes data review, compliance finding, Form 8110-3 preparation, and direct coordination with the responsible Aircraft Certification Office. For applicants new to delegated authority, we structure DER engagement to align with the project’s certification plan and reduce the risk of submission rework.

See our airworthiness certificate services and FAA airworthiness certification services pages for details on how DER work integrates with the broader certification workflow.

Frequently Asked Questions

Can anyone sign a Form 8110-3?

No. Only a DER acting within their authorized area may sign Form 8110-3 under designated authority. The DER’s authorization, issued by an FAA Aircraft Certification Office under 14 CFR §183.29, defines the specific regulations and technical disciplines in which the DER may make findings of compliance.

What happens if a DER signs outside their authorization?

The finding is not valid. The FAA may reject the submission, require the applicant to obtain a properly authorized DER’s finding, and in serious or repeated cases initiate action against the DER’s authorization.

How is Form 8110-3 different from Form 8130-3?

Form 8110-3 documents a DER’s finding of compliance with airworthiness standards for specific technical data. Form 8130-3, the Authorized Release Certificate (Airworthiness Approval Tag), is used by manufacturers and repair stations to release individual parts and components as airworthy. The two forms serve fundamentally different purposes and are not interchangeable.

Can a Form 8110-3 be revised?

A signed Form 8110-3 itself is not revised. If the underlying data changes, a new Form 8110-3 is prepared to cover the new configuration. If an error is found in a signed form, the form is typically superseded by a corrected form that explicitly references and replaces the original.

Does the DER need to be employed by the applicant?

No. DERs may serve as either Company DERs (employed by the applicant or manufacturer) or Consultant DERs (acting as independent contractors). Both types may sign Form 8110-3 within their authorized areas, though some procedural details differ between the two.

How does Form 8110-3 relate to the certification plan?

The Project Specific Certification Plan establishes which regulations apply, what compliance methods will be used, and how compliance findings will be documented. Each Form 8110-3 signed during the program should be consistent with the certification plan. Findings using compliance methods not coordinated in the plan typically require either retroactive plan coordination or supplemental submission.

Where does the form go after the DER signs it?

The signed form is submitted to the responsible FAA office along with the supporting technical data, as part of the project’s compliance documentation. The form itself is one element of a larger submission package that the FAA engineer reviews.

What is FAA Order 8110.37?

FAA Order 8110.37 is the Designated Engineering Representative Handbook the FAA’s procedural guidance for DERs and the FAA offices that manage them. It covers selection, appointment, training, and management of DERs, and includes detailed instructions for preparing and submitting Form 8110-3.

Bottom line

Form 8110-3 is the formal mechanism by which DER expertise is transferred into the FAA’s certification record. Understanding the form’s scope, the authority it carries, and the workflow that surrounds it is essential for any applicant working with delegated authority. Programs that treat Form 8110-3 as the routine endpoint of careful technical work rather than as a procedural step to be expedited close their compliance documentation faster and with fewer FAA-driven revisions.