CDC order imposes COVID-19 entry testing requirements for all arriving air travellers


Starting January 26, 2021, all air passengers travelling into the United States, including by private flights, air charter, and general aviation aircraft, will be required to show proof of a negative COVID-19 test result or documentation of having recovered from COVID-19, regardless of vaccination status. All passengers must complete an attestation affirming their compliance with the CDC requirements and provide it to their aircraft operator.


The requirements in the CDC Order apply to all aircraft, including airlines, air charter operators, and private aircraft operators arriving in the United States.

Beginning on January 26, 2021, aircraft operators are responsible for:

  1. Verifying that each passenger has completed an attestation. Attestations may be completed electronically or on paper. The aircraft operator must keep a copy of each attestation for two years.
  2. Confirming each passenger has documentation of their negative test result or proof of recovery. The documentation should indicate that the passenger has taken a COVID-19 viral test no more than 3 calendar days before their flight departure with a negative result, or that a passenger who has recovered from COVID-19 has received clearance from a public health official to travel. Aircraft operators do not need to retain copies of these documents.
  3. Not permitting any passenger to board without verifying the attestation and confirming the documentation.


The following limited exemptions are provided in the CDC Order.

  1. The testing and attestation requirements do not apply to children under 2 years of age.
  2. Crew members on official duty, including those in an assigned deadhead status, are exempt from the testing requirement as long as they follow industry standard protocols for the prevention of COVID-19 as set forth in the relevant FAA-issued SAFO.
  3. Operators transporting COVID-19 passengers pursuant to CDC authorisation.
  4. Certain law enforcement, government and military operations.
  5. CDC recognises that certain countries may not have available testing capacity. Any operator wishing to conduct operations to the U.S. from such locations must request and receive a waiver directly from the CDC.


The CDC documents provide specific details on the types of acceptable documentation and the actions required of both passengers and aircraft operators. Operators intending to conduct international flights should immediately review the CDC documents, establish compliance plans and implement the requirements of the Order for flights on and after January 26, 2021.

The CDC has a webpage including the Order, Attestation and FAQs.

NATA strongly advises operators to proactively reach out to international travellers to ensure they have a testing plan for their trip. Operators should also review their contracts and cancelation policies to ensure they account for any potential contingencies associated with this Order, including positive test results from crew or passengers, passenger refusal to test or provide attestation, or passenger failure to test in the required time window. Please consult with legal counsel for any necessary changes.