2025 Update for U.S. Private Jet Pilots: Are You Ready for the Latest Customs, Mexico APIS, and FAA Medical Changes?

Operating an international business jet is part art, regulation, and logistics. For U.S. crews dealing with customs, immigration, and changing international processes, staying informed of regulatory changes isn’t optional – it’s mission critical. The Icarus Jet trip support has prepared the following roundup with some recent developments:

  • How to utilize CBP’s Reimbursable Services Program (RSP) of off-hours foreign arrivals
  • Mexico’s new rules of business aviation under APIS/manifest
  • New Release of FAA AME Guide and how it affects your medical certificate

CBP’s Reimbursable Services Program

When traveling internationally during off-peak hours, customs and immigration might cause a scheduling bottleneck. That is where the CBP Reimbursable Services Program (RSP) becomes useful.

What is RSP? Why is it significant?

Under RSP, carriers can require CBP officers to stand by or greet an arriving flight during off-hours – paying for overtime and incidentals. The benefits are greater flexibility, less downtime, and more efficient in-bound activity during slow periods.

Authorization of an RSP agreement takes some four months and culminates in a signing of a memorandum of understanding and a CBP training session by the operator. Approved operators subsequently order services accordingly (typically a week or so in advance) and CBP arranges staff consequently. As a practice, some internal flight departments make use of RSP services on nearly half of all inbound international arrivals.

Cost structure, billing, and caveats

RSP billing is based on the actual officer overtime plus overhead. Standard projections are between $180–$210 an hour an officer, but local variation is standard. Invoices are prepared for a 28-day billing interval which is then mailed about 15 days following the end of this interval. Payment is due in 15 days through Pay.gov.

Operators must be careful if canceling after the CBP-determined cut-off, which can incur a cost (e.g. minimum hours even if you don’t fly). Furthermore, entering into an RSP arrangement is no absolute guarantee that a port director must do so under all circumstances – CBP retains operational discretion.

Best practice for operators

  1. Begin the RSP application well in advance and engage your financial/payments group so that they won’t be blindsided by the initial bill.
  2. Provide lead time when placing orders. Do not assume that last-minute revisions will work.
  3. Keep clear, predictable communications going with your field office of CBP. Sudden changes or ‘moving the goalposts’ can strain relations.
  4. Check annually for CBP user fee schedule updates – in FY 2026, the prepayment fee for first arrival is rising, and passenger arrival fees have small increases.

Incorporating RSP in a proactive manner allows jet operators to lower delays and broaden scheduling opportunities, particularly when dealing with narrow windows internationally. 

Mexico’s new APIS Regime

Mexico recently revised its APIS (Advance Passenger Information System) regime to subject business aviation to a two-step submission process that escalates compliance risk as well as operating restriction.

The two-step submission process

According to new regulations, operators should:

  • Provide manifest/passenger information ahead (leading phase)
  • Reaffirm or confirm information near to departure/arrival

This is for inbound and outbound private and charter only. Failure to comply or late submission may incur delays or denied entry.

What changed?

In the past, a few operators were able to file manifests through third-party services or through existing APIS portals directly, sometimes with more convenience. Mexico’s new regime tightens timing requirements and incorporates required verification steps.

Further, Mexico has been supplementing its requirements regarding passenger information so that it will have all of its flights (even Part 91/135) accounted for. This move increases administrative burdens on operators that have been less formal.

Suggestions for your next flight to Mexico

  • Allow lead time so that dispatch and crew planning can have manifest preparation and verification steps.
  • Match your trip support partner to automate or facilitate a two-step flow.
  • Check your manifest close to flight time to confirm compliance.
  • Watch Mexico communications or alerts for additional changes when industry and regulators further refine implementation.

Failure to comply, even by minutes, can lead to delays, holdovers, or fines.

FAA’s AME Guide: Medical Compliance

Operational readiness is more than just airplanes and procedures – your crew’s medical certificate has to be solid as a rock. Pilots and aviation medical examiners (AMEs) look to the FAA’s Guide for Aviation Medical Examiners (AME Guide) as their bible. 

What’s new 

AME Guide is refreshed monthly (usually a particular Wednesday of a given week) to keep pace with rule changes, disposition tables, and disposition routines. Recent changes incorporate alterations to:

  • Asthma predisposition criteria
  • Low testosterone disposition language
  • Color vision flowchart refinements
  • Revamped pulmonary fibrosis and sarcoid disposition tables sections

As such amendments could affect special issuance or path-forward rules, pilots and medical examiners in aviation have to look through new amendments regularly. 

Final thoughts for operational synergy 

Managing a U.S. business jet operation across borders is a constant juggling act. You desire flexibility on one hand: off-hours access, quick turnarounds, and effortless manifests. But on the other hand, rules must be honored: CBP itineraries, AME requirements, and changing international regulations such as Mexico’s APIS requirements.

The key to staying one step ahead is proactive planning and working with the right team of professionals. Give your flight operations group, dispatchers, medical staff, and financial departments a constant feed of updates. Develop internal checklists against RSP rules, CBP fee cycles, manifest submission deadlines, and AME update cycles. That way, when a late arrival, last-minute routing, or medical nuance appears, it’s not a surprise, but a known variable.

FAQs: 

Q: How far in advance should I submit an RSP request for off-hours arrival?
A: As a best practice, submit your request about a week ahead of your expected arrival. That gives CBP the lead time needed to staff and coordinate.

Q: If we cancel after the cut-off, will we still be charged?
A: Yes. Local CBP leadership will set a minimum cancellation threshold. If cancellation occurs after that, you may still pay for a minimum number of office hours.

Q: Does an RSP agreement expire? Must I renew?
A: No. Once your Reimbursable Services Agreement is approved and signed, it doesn’t expire. You aren’t obligated to request services each year.

Q: What is the latest CBP fee landscape I should budget for?
A: For FY 2026, CBP is raising the one-time business aircraft first arrival prepayment fee, increasing passenger arrival fees slightly, and adjusting maximum caps.

Q: For flights into Mexico, when must APIS be submitted and confirmed?
A: Under the two-step process, you’ll submit manifest data in advance and then reconfirm closer to departure or arrival. Timing requirements are stricter under the new rules.

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