If I Start Therapy, Do I Have to Tell the FAA?

TL;DR. No, not immediately, and the gap between what pilots fear here and what is actually required is wide enough to be worth closing. The FAA's own FAQ says pilots are "not obliged to report until your next application for medical certificate." When that application comes, all visits to licensed healthcare providers, including therapists and counselors, go on MedXPress. A few categories do not. Grounding is a separate question governed by 14 CFR § 61.53, and it turns on symptom severity, not on the fact that you are in therapy.

In May 2026 the FAA added three documents to Item 47 of the Guide for Aviation Medical Examiners. Most of the coverage focused on the headline sentence: counseling or therapy is encouraged when medically appropriate. That is a genuine shift and it deserved the attention.

But the documents underneath it answer a more practical question, and it is the one I hear most often from pilots who are weighing whether to book a first appointment. Not "does the FAA approve of therapy" but "if I go, what do I have to tell them, and when."

The answers are more specific than most pilots expect. They are also, in several places, more permissive.

---

Why this question decides whether pilots get care at all

It is worth being direct about what is actually at stake here, because it is not paperwork.

Pilots avoid mental health care. Not because they do not need it, and not because they doubt it would help, but because the certification consequences are unclear and the cost of guessing wrong is a career. When the price of asking is unknown and the worst case is total, saying nothing and hoping starts to look like the rational move. It is not, but it is understandable.

The FAA has effectively acknowledged this. You do not publish three documents encouraging therapy, write an FAQ about when reporting is required, and produce a separate guidance sheet for psychotherapists unless you have concluded that the ambiguity itself is causing harm. The FAQ's own language points the same way: aviators are "encouraged to seek help early before conditions get severe."

That is the frame worth holding for the rest of this post. What follows is not administrative trivia. For a lot of pilots these rules are the deciding factor in whether a first appointment ever gets booked, and the fear is consistently larger than the actual obligation.

---

The reporting timeline is not what most pilots assume

The single most common fear is that starting therapy triggers an immediate obligation to notify the FAA. It does not.

From the FAA's Therapy, Psychotherapy, and Counseling FAQs for Pilots and ATCS (updated 05/27/2026):

Must I report to the FAA immediately? Pilots: No. You are not obliged to report until your next application for medical certificate.

Air traffic controllers are treated differently. ATCS must abide by FAA Order 3930.3C 9.e.1-5 and should consult the appropriate flight surgeon before performing safety-related duties. If you are a controller rather than a pilot, that is your governing rule, not this one.

So for pilots the obligation attaches at your next MedXPress application. Between now and then, the question is not reporting. It is whether you are fit to fly on any given day, which is a different test entirely and is covered below.

---

What actually has to be reported, and what does not

This is the part worth bookmarking. The FAA draws lines here that are narrower than the blanket "report everything" most pilots assume.

Type of contact	Reportable on MedXPress?
Any visit to a licensed healthcare provider, including psychotherapists and counselors	Yes
Educational counseling	No
Religious counseling	No, unless the clergy member is also a licensed counselor
Couples counseling	No, unless you were referred for individual therapy
Employee Assistance Program (EAP) consultation	Generally excluded, unless it resulted in a referral for psychiatric evaluation or treatment

Two things follow from that table.

First, the trigger is the licensure of the person you are talking to and the nature of the referral, not the subject matter of the conversation. A pastoral conversation and a session with a licensed clinical social worker are treated differently even if you discuss the same thing.

Second, the couples counseling and EAP lines both hinge on referral. Going is one thing. Being referred onward into individual therapy or psychiatric treatment is what moves it into reportable territory. If you are unsure which side of that line you are on, that is a question worth asking your provider directly and getting a clear answer on, because you will be attesting to it later.

---

Grounding is a separate question with a different test

Reporting and grounding get conflated constantly. They are governed by different rules and different triggers.

Grounding runs on 14 CFR § 61.53, which the FAQ quotes in part:

no person may act as pilot in command, or in any other capacity as a required pilot flight crewmember, while that person knows or has reason to know of any medical condition that would make the person unable to meet the requirements for the medical certificate necessary for the pilot operation

The FAA's own framing of how that applies to mental health: "If the severity of the symptoms is enough to impair concentration, memory, emotional stability, judgment, decision-making, alertness, etc., then yes. Otherwise, no."

Being in therapy is not itself a grounding event. Symptom severity is.

The FAQ lists specific examples where self-grounding is called for:

• Losing control with alcohol, or use of mind-altering substances including misusing medications
• Major depression, meaning low mood combined with difficulty doing day-to-day activities, loss of interest or pleasure in most normal activities, sleep disturbances
• Delusions, hallucinations, or paranoia
• Severe anxiety or panic attacks
• Rapid mood changes, difficulty regulating emotions, or increased sensitivity to stressors or conflicts
• Suicidal thoughts
• Any other mental state or situation that significantly distracts from in-cockpit functioning, controlling, awareness, or communication

And then a sentence I would encourage every pilot to sit with, because it directly contradicts the fear that grounding yourself marks you as a problem:

Self-grounding is a professional safety decision and is also viewed as a sign of good insight.

That is the FAA telling you, in the guide its own examiners work from, that the judgment to stop flying is evidence of the judgment they want you to have.

---

What happens to your records

The second most common fear, after reporting, is that therapy notes end up in a federal file.

Will the FAA see my therapy records? Usually not. If documentation is requested, it is usually a brief summary from the therapist.

When therapy information is reviewed, the FAQ says the FAA focuses on diagnosis, insight, stability, current functioning, and risk factors. Not session content.

It also lists what the agency looks for from the aviator, which reads less like a compliance checklist and more like a description of a safe pilot. The aviator should be able to demonstrate the ability to:

• Recognize symptoms
• Seek appropriate help
• Self-assess fitness for duty on a daily basis
• Self-ground when necessary

---

Practical mechanics worth knowing before your first appointment

A few operational details from the same set of documents that will save you a conversation later.

The words do not matter. "Does it matter if my therapist uses the word psychotherapy or counseling? No. For FAA purposes, the terms therapy, psychotherapy, and counseling are equivalent."

Credential floor. When choosing a provider, make sure they are licensed with at least a Master's degree.

Bring the FAA's own document to the first visit. The FAQ tells pilots to provide a copy of Information for Psychotherapists Treating Pilots and ATCS to the provider. That document asks therapists to use DSM-5-TR diagnostic terminology and to avoid both upcoding and minimization. That second half is easy to miss and it matters: a therapist trying to protect your certificate by softening the record is not doing you a favor, because the FAA is reading for accuracy and consistency.

Therapy does not automatically produce a diagnosis. "The therapist should make an assessment, which may or may not be a diagnosis."

Therapy is compatible with the certificate you already hold. "Psychotherapy is compatible with both an unrestricted medical certificate and special issuance/special consideration."

---

What did not change

Worth stating plainly, because the encouraging tone of the update has been read more broadly than it should be.

The May 2026 update added resources. It did not alter the certification framework. Item 47 still holds that psychotropic medication use is disqualifying for aeromedical certification unless covered by the listed exceptions, and AMEs are still directed to defer and forward records to the Aerospace Medical Certification Division in those cases.

Talk therapy and medication are on different tracks. You can use both, and for many conditions the combination is more effective than either alone, but the FAQ is direct that "aviators taking medication will have additional requirements."

If you are on or considering an antidepressant, the SSRI pathway is its own subject with its own timelines. We cover it in SSRIs and the Cockpit: Why Stability Periods Exist and in the SSRI and Special Issuance resource page.

---

What to do with this

If you have been putting off a first appointment because you did not know what it would cost you administratively, the honest answer from the FAA's own documents is: less than you think, and nothing at all until your next medical application.

1. Check whether your situation is even reportable. Use the table above. Educational, religious and unreferred couples counseling sit outside it.
2. Choose a licensed provider with at least a Master's degree, and hand them the FAA's psychotherapist document at the first visit.
3. Keep reporting and grounding separate in your head. Reporting happens at your next application. Grounding is a daily fitness-for-duty judgment under § 61.53.
4. Note the date of your next medical. That is when the reporting obligation attaches, and it is the moment to have your dates and provider details straight.
5. If any of the self-ground triggers apply, stop flying. The FAA has said in writing that doing so reflects good insight.

None of this is a substitute for a conversation with your AME, and nothing here is medical or legal advice. If your situation is complicated, particularly if medication is involved or you already hold a special issuance, talk to your AME or a HIMS AME before your application rather than after.

---

Sources

• FAA, Therapy, Psychotherapy, and Counseling FAQs for Pilots and ATCS (updated 05/27/2026)
• FAA, Information for Psychotherapists Treating Pilots and ATCS (updated 05/27/2026)
• FAA, Therapy, Psychotherapy and Counseling Information: Pilots / ATCS
• FAA, Guide for Aviation Medical Examiners, Item 47, Psychiatric Conditions
• 14 CFR § 61.53, Prohibition on operations during medical deficiency