Safety Starts at the Top Act of 2026

The Safety Starts at the Top Act of 2026 (H.R. 10077) amends federal aviation law to create new board of directors rules for large companies that hold Federal Aviation Administration (FAA) delegated authority. Specifically, it requires high-revenue Organization Designation Authorization (ODA) holders—entities allowed to perform certain approvals or functions on behalf of the FAA—to include specific labor and safety representatives on their governing boards.

* **High-revenue ODA holders:** Companies authorized by the FAA to carry out delegated functions that bring in at least $15 billion in annual gross revenue. * **Labor organizations:** Unions representing employees directly involved in aircraft design and manufacturing at covered companies. * **Aerospace safety experts:** Qualified safety professionals who meet the bill's criteria to serve as board members. * **The Federal Aviation Administration (FAA):** The regulatory agency responsible for enforcing the rules and revoking authority from non-compliant entities.

* **Board Structure Requirements:** Covered companies must annually certify to the FAA Administrator that their board of directors includes: * Two labor representatives, including one representative from each labor organization representing employees directly involved in aircraft design and manufacturing. * Two aerospace safety representatives who have proven experience in aerospace safety and demonstrable safety-related outcomes. * **Enforcement and Deadlines:** The FAA Administrator is required to revoke (rescind) delegated ODA authority from any covered entity that fails to comply with the board composition and certification rules within 90 days of the bill becoming law.

The bill summary does not mention any direct federal spending, grants, taxes, or user fees. It establishes an annual gross revenue threshold of $15 billion to determine which companies must follow the board structure rules.

* **Revenue Limit:** The board requirements only apply to ODA holders with at least $15 billion in annual gross revenue. Smaller ODA holders below this financial threshold are not subject to these provisions based on the summary. * No specific waivers or individual exceptions to the mandatory rescission deadline are provided in the summary.

Very large aviation companies ($15 billion+ in annual gross revenue) that perform safety or design approvals on behalf of the FAA must add labor and aerospace safety representatives to their boards of directors. If a covered company fails to meet these board requirements within 90 days of enactment, the FAA must take away its delegated approval authority.