Need Clarification Regarding Registration Number Size Options

[Matthew P]

Aircraft currently in paint, wanting to go back to original size (smaller) registration number as opposed to 12". As I'm reading through the FARs it seems to indicate in one section that, due to the age of my aircraft, I can have the smaller registration numbers, but then the next section seems to say that retaining the smaller registration numbers don't apply IF I have the aircraft repainted....can anyone provide clarification. Primarily want the smaller registration numbers so it doesn't interfere with the paint scheme I'm wanting to go with, and I figure if I fly to the Bahamas, I'll buy some temporary 12" vinyl Numbers.

 

TIA

 

Matt

[Hank]

I can't give FAR references, but I think the smaller N number can be painted on airplanes 30 or more years old. But as you pointed out, the small numbers are not valid for cross-border travel.

The regs apparently allowed smaller numbers at some point, and when the large numbers became required, the small numbers were grandfathered in until the plane was painted. Now us Vintage Mooney owners have a choice! 

[Matthew P]

33 minutes ago, Hank said:

I can't give FAR references, but I think the smaller N number can be painted on airplanes 30 or more years old. But as you pointed out, the small numbers are not valid for cross-border travel.

The regs apparently allowed smaller numbers at some point, and when the large numbers became required, the small numbers were grandfathered in until the plane was painted. Now us Vintage Mooney owners have a choice! 

LOL, so are you saying that you believe that my 60 year old M20E has the option....I'm (unfortunately) thinking that once it goes into paint, regardless of age, that I'm stuck with the 12" Registration....wonder if they'd ever make an issue over it.. Unfortunately I'm not an original paint scheme or it probably wouldn't even be noticed....

 

§ 45.29 Size of marks.

(b) Height. Except as provided in paragraph (h) of this part, the nationality and registration marks must be of equal height and on-

(1) Fixed-wing aircraft, must be at least 12 inches high, except that:

(i) An aircraft displaying marks at least 2 inches high before November 1, 1981 and an aircraft manufactured after November 2, 1981, but before January 1, 1983, may display those marks until the aircraft is repainted or the marks are repainted, restored, or changed;

Edited December 26, 2025 by Matthew P

[Hank]

@Matthew P, you made me look it up.

Ref. 14 CFR Part 45.22(b), shown below (highlighting added for clarity):

Isn't it great when clearly-written paragraphs seem to conflict with each other? That's when you need to read back to the beginning the section for background and context. Your 1966 E can certainly use the small numbers on either the side or the tail, but you need large numbers to cross the border. 

[Matthew P]

Thanks, that's the one that led me to believe that it would be ok...and the one that I'd like to rely upon...I appreciate your time and assistance.

 

Merry Christmas

 

matt

[cliffy]

Why not a call to the local FSDO to avoid any future confusion?

[Brian2034]

In Canada as far as I know small registration numbers are valid on fuselage if they are also on the underside of the wing 

If not on underside of wing, registration has to be 12" height on fuselage . I'll have to check the Canadian" CARS" to verify but we usually go with the above.

[Matthew P]

10 hours ago, cliffy said:

Why not a call to the local FSDO to avoid any future confusion?

Lol, when is the last time you've dealt with a FSDO I have an inquiry into the local FSDO...we'll see...

[Jackk]

12 hours ago, Matthew P said:

LOL, so are you saying that you believe that my 60 year old M20E has the option....I'm (unfortunately) thinking that once it goes into paint, regardless of age, that I'm stuck with the 12" Registration....wonder if they'd ever make an issue over it.. Unfortunately I'm not an original paint scheme or it probably wouldn't even be noticed....

 

§ 45.29 Size of marks.

(b) Height. Except as provided in paragraph (h) of this part, the nationality and registration marks must be of equal height and on-

(1) Fixed-wing aircraft, must be at least 12 inches high, except that:

(i) An aircraft displaying marks at least 2 inches high before November 1, 1981 and an aircraft manufactured after November 2, 1981, but before January 1, 1983, may display those marks until the aircraft is repainted or the marks are repainted, restored, or changed;

^This 

[Matthew P]

34 minutes ago, Jackk said:

^This 

So, if I go back to paragraph 45.22(b) and taking it as it says, there would be no reason to continue to read beyond 45.22(b) as it already stated that the smaller numbering is applicable to my SMALL, built more than 30 years ago aircraft...key wording in 45.22(b) stating SMALL U.S. registered aircraft...whereas 45.29 just states "An aircraft" which would lead me to believe ANY Non-small aircraft regardless of age if repainted unless exempted.

Will be interesting to hear what  the FSDO has to say if they respond..

[takair]

There is an advisory circular I recently went through for the answer for my antique experimental. Let me see if I can find it. 

[PT20J]

You might also ask AOPA - this probably comes up a lot. 

[takair]

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_45-2E.pdf
 

See table 2. Use caution just talking to the FSDO. Not all inspectors are familiar with the nuisances of markings. The antique experimental community suggests carrying the regulation and advisory material with you in case overzealous ramp checker grounds you.  I went so far as to go with 3” NX number.  It is quite the legal corner case. Also, consider where you will operate. If you intend to fly outside of the US, consider what they require, even if US registered. 

[PT20J]

I read the FAR again, and here is how I understand it  

45.22(b) simply says you can operate a small airplane 30 years or older that has 2” numbers. It does not include language such as “notwithstanding paragraph 45.29” so that paragraph still applies which says repainting requires 12” numbers. 

I’ll be interested to hear what the FSDO says. 

[Jackk]

1 hour ago, Matthew P said:

So, if I go back to paragraph 45.22(b) and taking it as it says, there would be no reason to continue to read beyond 45.22(b) as it already stated that the smaller numbering is applicable to my SMALL, built more than 30 years ago aircraft...key wording in 45.22(b) stating SMALL U.S. registered aircraft...whereas 45.29 just states "An aircraft" which would lead me to believe ANY Non-small aircraft regardless of age if repainted unless exempted.

Will be interesting to hear what  the FSDO has to say if they respond..

 It says what it says in the FAR

 People get all messed up trying to read things into regs which are not there 

FARs also often read unlike real laws as they are administrative and are designed to be vague 

 

 Asking the local random ASI their opinion is like asking a random cop about the law, very hit or miss on accuracy. 
 

 If you really want a solid opinion, you got two methods 

 

1 Ask for a interpretation letter from FAA legal, I’d HIGHLY recommend NOT doing this as they something get a hair up their butt and make new precedence 

 

2 Ask a knowledgeable FAA versed atty like Anthony Ison, probably ether be free or maybe kick him a few bucks for lunch.

 

If it were me, and the plane is old enough, I’d paint the small numbers and call it a day.  

ACTUALLY if it were me I’d get the new small numbers cut out of vinyl and call It a day.   There is a reason many experienced folks will paint the whole plane but do the reg in vinyl 

These guys are REALLY good and trusted in aircraft lettering and logos, they also might be a good ask for your question as that’s their entire business 

https://aerographics.com/

Edited December 26, 2025 by Jackk

[Matthew P]

54 minutes ago, takair said:

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_45-2E.pdf
 

See table 2. Use caution just talking to the FSDO. Not all inspectors are familiar with the nuisances of markings. The antique experimental community suggests carrying the regulation and advisory material with you in case overzealous ramp checker grounds you.  I went so far as to go with 3” NX number.  It is quite the legal corner case. Also, consider where you will operate. If you intend to fly outside of the US, consider what they require, even if US registered. 

So, my aircraft falls under "antique" and therefore smaller letters are good to go, but once again, you go down the next table to "fixed wing aircraft" and it blankets 12" requirement without referencing antique aircraft..so the advisory doesn't seem to clarify anything...lol

[Hank]

10 minutes ago, Matthew P said:

So, my aircraft falls under "antique" and therefore smaller letters are good to go, but once again, you go down the next table to "fixed wing aircraft" and it blankets 12" requirement without referencing antique aircraft..so the advisory doesn't seem to clarify anything...lol

The AC was written in 2015; I believe the FAR was updated more recently. 

It would be a very quick call to AOPA, they clearly answered my recent questions about MOSAIC.

[Matthew P]

22 minutes ago, Hank said:

The AC was written in 2015; I believe the FAR was updated more recently. 

It would be a very quick call to AOPA, they clearly answered my recent questions about MOSAIC.

Never thought about calling AOPA...thanks, will give them a call...

[ArtVandelay]

[mention=52821]Matthew P[/mention], you made me look it up.
Ref. 14 CFR Part 45.22(, shown below (highlighting added for clarity):

Isn't it great when clearly-written paragraphs seem to conflict with each other? That's when you need to read back to the beginning the section for background and context. Your 1966 E can certainly use the small numbers on either the side or the tail, but you need large numbers to cross the border. 

But 22 references the other “conflicting sections “ don’t apply.

Bottom line, you can go back to small numbers.

The paint shop should know what’s legal and what’s not.

I went through this and went back to small numbers. No issues with multiple IAs and shops.

[takair]

50 minutes ago, Hank said:

The AC was written in 2015; I believe the FAR was updated more recently. 

It would be a very quick call to AOPA, they clearly answered my recent questions about MOSAIC.

Hank

Not to hijack this, but what was AOPAs answer on MOSAIC. Was there another thread?  I had thought I read that their answer regarding Mooney was no answer. 

[Jackk]

AOPA lawyers are akin to those prepaid legal services, or asking Grock.

 

 It’ll put you near to target, but don’t expect a direct hit 

[Hank]

1 hour ago, takair said:

Hank

Not to hijack this, but what was AOPAs answer on MOSAIC. Was there another thread?  I had thought I read that their answer regarding Mooney was no answer. 

I asked for a friend, since a local CFI thought the no-medical approach would limit him to the old Recreational license and 50nm flight limit. Not so, it will be a Sport license, any airplane up to 4 seats (limited to self plus one passenger) that meets the Vso <= 59 knots requirement. Additional training required for Class B & C. Limited to Day VFR, as night flight requires a Class III, which can be replaced by Basic Med.

[takair]

2 hours ago, Hank said:

I asked for a friend, since a local CFI thought the no-medical approach would limit him to the old Recreational license and 50nm flight limit. Not so, it will be a Sport license, any airplane up to 4 seats (limited to self plus one passenger) that meets the Vso <= 59 knots requirement. Additional training required for Class B & C. Limited to Day VFR, as night flight requires a Class III, which can be replaced by Basic Med.

Ahh, ok….i guess there are a lot of questions out there…lol.  I was wondering about the 59 kcas vs kias requirement, where folks were trying to determine if Mooney means that. I guess that’s for another thread.

[Hank]

7 minutes ago, takair said:

Ahh, ok….i guess there are a lot of questions out there…lol.  I was wondering about the 59 kcas vs kias requirement, where folks were trying to determine if Mooney means that. I guess that’s for another thread.

That would vary by model, and is in the TCDS I think. Or in the Owners Manual.

Pretty sure the long bodies' Vso > 59 knots, and likely the mid-bodies too. This is what mine says, so I think it probably qualifies. Flying under Basic Med, though, it doesn't matter to me.

[tony]

On 12/26/2025 at 12:16 AM, Matthew P said:

Thanks, that's the one that led me to believe that it would be ok...and the one that I'd like to rely upon...I appreciate your time and assistance.

 

Merry Christmas

 

matt

That's hilarious, I have yet to find an inspector that has actually read the FARs.