Is AC 20-27D mandatory or advisory?

Advisory Circulars provide non-binding guidance; they describe acceptable means of compliance but do not themselves create regulatory requirements.

Can I use electronic signatures on required documents?

Electronic signatures are generally valid under the ESIGN Act (15 U.S.C. §7001) and UETA where adopted, provided intent, consent, attribution, and retention requirements are satisfied.

What authentication level should I use for signers?

Choose authentication proportional to risk: email or SMS for low risk, multifactor or identity proofing for legal declarations or high-assurance submissions.

How should I store signed compliance packages?

Store signed PDFs with embedded audit trails in a secure repository with encryption at rest, access controls, and versioning to preserve integrity for audits.

Who may sign compliance attestations or declarations?

Authorized company officers, designated engineering representatives, or persons with delegated authority should sign; ensure signer authority is documented in corporate records.

What happens if documentation is incomplete?

FAA reviewers may issue requests for additional information, which can delay approval and increase project cost; thorough initial submissions reduce this risk.

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FAA Advisory Circular 20-27D

FAA Advisory Circular 20-27D

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What FAA Advisory Circular 20-27D Is and how it fits in FAA guidance

FAA Advisory Circular 20-27D is an FAA-issued guidance document that explains acceptable means, methods, and practices for complying with airworthiness and operational expectations related to the specific avionics or electronic system topic it covers. Advisory Circulars provide non-binding FAA recommendations to manufacturers, operators, certificating authorities, and maintenance organizations and are used to align design, test, documentation, and operational procedures with FAA expectations without creating new regulatory requirements.

Why this Advisory Circular matters for certification and operations

FAA Advisory Circular 20-27D clarifies recommended compliance approaches, documentation standards, and test methods so applicants and installers can reduce ambiguity during certification reviews and conformity assessments.

Typical users and stakeholders who rely on FAA Advisory Circular 20-27D

Primary audiences include manufacturers, design approval holders, repair stations, and certification engineers preparing substantiating data for FAA review.

Aircraft manufacturers and OEM engineering teams preparing compliance packages for design approval and installation.
Repair stations and maintenance organizations documenting modifications, installations, and test results for returning aircraft to service.
FAA designees, certification engineers, and quality auditors reviewing submitted means of compliance and associated analysis.

Step-by-step approach to using FAA Advisory Circular 20-27D

Follow a sequence that maps AC guidance to your design, test plan, and submission materials to streamline FAA review.

01

Review Scope: Confirm the AC topic applies to your system or installation.
02

Map Requirements: Translate AC recommendations into measurable design and test criteria.
03

Document Evidence: Compile test results, analysis, and compliance cross-reference matrix.
04

Engage FAA: Coordinate with the assigned FAA project engineer or designee early.

Technical considerations for electronic delivery and signing

Prepare files and authentication methods to preserve integrity and enable reproducible review records.

File Formats: PDF/A preferred
Authentication: Email, SMS, or stronger
Integrations: CRM and document storage

Typical e-submission workflow settings to prepare

Configure your digital workflow so documents are versioned, signed, and archived with clear metadata and access controls.

Field	Configuration
Signer Authentication	Email + optional SMS OTP
Document Versioning	Enable auto-incrementing versions
Audit Trail Capture	Record IP, timestamp, and actions
Retention Metadata	Add filing date and record owner

How electronic submission typically proceeds

A clear, repeatable flow ensures reviewers receive complete, authenticated packages and that retention obligations are met.

Prepare Package: Assemble documents, cross-references, and test reports.
Apply Signatures: Obtain required eSign or wet signatures as specified.
Submit to FAA: Upload via designated FAA portal or send to assigned engineer.
Archive Records: Store signed package with audit trail and metadata.

Core components to include when aligning with FAA Advisory Circular 20-27D

Ensure each compliance package contains the AC cross-reference, technical substantiation, test plans, and quality assurance artifacts requested by FAA reviewers.

Scope Statement

Define system boundaries, affected aircraft models, and operational contexts so reviewers can determine AC applicability and required evidence.

Compliance Matrix

Provide a table mapping AC paragraphs to specific data, test results, or procedures, making it straightforward for FAA staff to verify conformity.

Test Reports

Include raw data, test setup descriptions, measured results, and pass/fail criteria demonstrating that the system meets the AC's recommended performance.

Safety Assessment

Document failure conditions, mitigations, and hazard analyses consistent with accepted safety assessment practices referenced by the FAA.

Installation Drawings

Supply detailed drawings, wiring diagrams, and interface specifications to confirm the installation preserves aircraft integrity and does not create new hazards.

Maintenance Instructions

Attach required maintenance and inspection procedures so continuing airworthiness obligations are clear to operators and repair stations.

Security and compliance items to note for electronic records

Encryption in transit: TLS 1.2/1.3

Encryption at rest: AES-256

Audit Trails: Detailed action log

Compliance Standards: SOC 2 Type II

Healthcare BAA: HIPAA requires BAA

FDA / 21 CFR: 21 CFR Part 11 controls

Common consequences of inadequate adherence to AC guidance

Certification Delay: Extended review timelines

Application Rejection: FAA may request rework

Operational Limits: Temporary operating restrictions

Increased Costs: Additional testing or engineering

Liability Exposure: Greater post-release risk

Record Deficiencies: Incomplete audit trail

Pricing snapshot for eSignature vendors suitable for AC 20-27D workflows

Compare core pricing and capability signals for common eSignature vendors when planning an electronic signing solution for compliance packages.

	signNow	DocuSign	Adobe Sign	PandaDoc	HelloSign
Starting Price	$8/user/mo	$15/user/mo	$14/user/mo	$19/user/mo	$15/user/mo
Free Trial	Yes, 7-day free trial	No	No	Yes, limited	Yes, limited
Bulk Send	Yes	Yes	Yes	Yes	No
Audit Trail	Yes	Yes	Yes	Yes	Yes
HIPAA Compliant	Yes	Yes	Yes	No	No

Frequently asked questions about applying FAA Advisory Circular 20-27D

Answers to common questions about AC applicability, eSigning, submission expectations, and recordkeeping for compliance packages.

Need help? Contact support

Is AC 20-27D mandatory or advisory?
Advisory Circulars provide non-binding guidance; they describe acceptable means of compliance but do not themselves create regulatory requirements.
Can I use electronic signatures on required documents?
Electronic signatures are generally valid under the ESIGN Act (15 U.S.C. §7001) and UETA where adopted, provided intent, consent, attribution, and retention requirements are satisfied.
What authentication level should I use for signers?
Choose authentication proportional to risk: email or SMS for low risk, multifactor or identity proofing for legal declarations or high-assurance submissions.
How should I store signed compliance packages?
Store signed PDFs with embedded audit trails in a secure repository with encryption at rest, access controls, and versioning to preserve integrity for audits.
Who may sign compliance attestations or declarations?
Authorized company officers, designated engineering representatives, or persons with delegated authority should sign; ensure signer authority is documented in corporate records.
What happens if documentation is incomplete?
FAA reviewers may issue requests for additional information, which can delay approval and increase project cost; thorough initial submissions reduce this risk.

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