January 2025 Color Vision Changes - Summary & What It Means

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pilotprep

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This information is based on FAA publications and guidance. DM me if you’d like the sources.

With the new year came significant changes to FAA color vision testing requirements. I've been researching this topic and wanted to share a summary for anyone affected or just curious about the changes.

The Change (Effective January 1, 2025)

The FAA has retired the Ishihara plates and all other legacy color vision tests for pilot medical certification. Only three computer-based tests are now approved:

  • City Occupational Colour Assessment & Diagnosis (CAD; AVOT-PRO-US)
  • Rabin Cone Contrast Test (RCCT) — Air Force/Army/Navy/Coast Guard version
  • Waggoner Computerized Color Vision Test (CCVT)
These tests display randomized patterns, eliminating the possibility of memorization that existed with the old plate tests.

Background

This change traces back to NTSB recommendations following the 2002 FedEx 727 accident in Tallahassee, where the first officer's color vision deficiency was cited as a contributing factor. The FAA has been working toward computerized testing since authorizing these three tests in May 2023, making them mandatory as of this year.

Key Points
  • Frequency: Color vision screening is now a ONE-TIME requirement. Since CVD is typically hereditary and stable, once you've demonstrated adequate color vision, you won't retest at each renewal. Exceptions: certain medications affecting color vision, or medical conditions like glaucoma/cataracts.
  • Grandfathering: Pilots holding a medical certificate WITHOUT a color vision limitation as of December 31, 2024 are grandfathered. The AME simply marks "Pass" on future exams — no computerized test required.
  • Upgrading Medical Class: A 3rd class holder upgrading to 1st or 2nd class WILL need to pass one of the three computerized tests.
  • Existing SODA/LOE Holders: Those with a SODA or LOE for 1st or 2nd class continue under existing authorization. Those with 3rd class SODA/LOE keeping their 3rd class don't need retesting. However, 3rd class SODA/LOE holders wanting to upgrade to 1st/2nd will need to pass a computerized test.

Failure: If unable to pass any of the three tests, the AME issues a 3rd class with limitation #104: "Valid for day visual flight rules (VFR) only." The pilot can appeal to the Federal Air Surgeon or pursue operational testing (OCVT/MFT) pathways.

Practical Considerations
  • Not all AMEs have the equipment yet. The Waggoner CCVT is most common due to lower cost (~$1,000 vs. $10,000+ for CAD)
  • Testing can be done at eye specialists; results are accepted if properly documented
  • You can attempt any or all three tests — no limit on attempts
  • There's no "easier" test universally; it depends on your specific type of color deficiency
Anyone else gone through the new testing? Curious to hear experiences.
 
What about those of us who haven't held consistent levels of medical certificate? I.e., skipped around between 1, 2, and 3? Assume it's based on the class held at the time of implementation?
 
sunlight said:
What about those of us who haven't held consistent levels of medical certificate? I.e., skipped around between 1, 2, and 3? Assume it's based on the class held at the time of implementation?
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TL;DR: It's about your current certificate + what you're applying for, not your historical path through the classes.

Good question — the grandfathering isn't based on which class you hold, it's based on whether you have a color vision LIMITATION on your certificate.So the logic is:
1. Do you currently have a medical with NO color vision restriction? → You're grandfathered for renewals at that class or below
2. Are you upgrading to a HIGHER class than you currently hold? → You'll need to take one of the new computerized tests.

So if you've bounced between 1st, 2nd, and 3rd over the years but never had a color vision limitation, you're fine to renew whatever class you currently hold. The "gotcha" is only if you're moving UP — say you let your 1st class lapse, dropped to 3rd, and now want 1st or 2nd again. That upgrade would trigger the new testing requirement.
The FAA AME Guide specifically says pilots who've "previously met the CVT standards are not required to test unless they are upgrading their FAA Medical Certificate to a higher class."
 
pilotprep said:
1. Do you currently have a medical with NO color vision restriction? → You're grandfathered for renewals at that class or belo classw
2. Are you upgrading to a HIGHER class than you currently hold? → You'll need to take one of the new computerized tests.
Click to expand...
No, this is wrong. If you ever passed a medical with one of the standard pre-2015 tests OR did the full up 1st/2nd OCVT/MFT, you are good for any class FOREVER.

The only time someone with that has already holds or previously held a medical needs to to the new tests is in the specific case of holding a third class medical via taking the OCVT (lightgun test).
 
flyingron said:
No, this is wrong. If you ever passed a medical with one of the standard pre-2015 tests OR did the full up 1st/2nd OCVT/MFT, you are good for any class FOREVER.

The only time someone with that has already holds or previously held a medical needs to to the new tests is in the specific case of holding a third class medical via taking the OCVT (lightgun test).
Click to expand...
You are right and thanks for the catch. Guilty of oversimplification. Here's from a more careful review of FAA AME Guidelines:

Section A says pilots who "historically passed any previously FAA-approved color vision test" don't need the new computerized test "for all classes." So if you passed Ishihara (or any legacy test) without limitation at any point, you're good for any class going forward.
The upgrade requirement specifically applies to 3rd class SODA/LOE holders wanting 1st/2nd — not to everyone who's moved between classes.
 
Ff you have EVER, prior to 1/1/2025 held a second or a first class you will not ever be requried to pass aany of the color vision computer testing.

Many AMEs didn't upgrade. A lot have the Waggoner (as do I). There are only six places in the USA to get a Rabin Cone and I have not found a vendor for the CAD. The licenses are incredibly expensive for the latter two.

Beware: the Rabin is the USN color vision test, and the CAD was the USAF test until recently. They are hard. I've only had a handful that could pass the Rabin when they could not pass the Waggoner.

B
 
bbchien said:
Ff you have EVER, prior to 1/1/2025 held a second or a first class you will not ever be requried to pass aany of the color vision computer testing.

Many AMEs didn't upgrade. A lot have the Waggoner (as do I). There are only six places in the USA to get a Rabin Cone and I have not found a vendor for the CAD. The licenses are incredibly expensive for the latter two.

Beware: the Rabin is the USN color vision test, and the CAD was the USAF test until recently. They are hard. I've only had a handful that could pass the Rabin when they could not pass the Waggoner.

B
Click to expand...
How do we prove we once held higher if we currently only hold a third?
 
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