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Operational Update – DLA AIR Card Compliance Enhancements

X-1 will release updates on April 6, 2026 to support portions of the new DLA requirements that begin April 1, 2026.

Written by Caroline
Updated this week

Over the past several months, the DLA AIR Card program requirements have continued to evolve, creating additional operational and administrative work for FBO teams across the industry. Many operators are now being asked to implement new documentation and processing steps that differ from long-standing contract fuel workflows. You can find the full list of requirements here:

X-1FBO has been actively adapting the platform to support these requirements as they develop. Because program guidance and processor implementations have continued to change, our focus has been on providing practical tools that allow operators to meet the requirements while minimizing disruption to day-to-day operations wherever possible.

Important:

These updates address only part of the DLA requirements. FBOs remain responsible for reviewing official DLA communications and submitting required documentation through the DLA portal operated by KHI when required. X-1 cannot provide guidance on how to use the DLA portal.

As part of that effort to address the requirements X-1 will release updates on April 6, 2026 (Sprint 29) to support portions of the new DLA requirements that begin April 1, 2026.

At the same time, X-1, fuel suppliers, and many FBOs are working with the National Air Transportation Association (NATA) to engage industry stakeholders and government representatives and ensure the operational realities faced by FBOs are clearly understood as this program continues to evolve.

Learn more about how these changes are impacting FBOs and the steps we are taking to address them by clicking here:


Updates for All Processors

(AHT, MSA, KHI – including World Fuel, Avfuel, Titan, AEG, Phillips 66)

Contract Price on the Invoice

Beginning April 1, the DLA requires the contract price to appear on the invoice when printed or transmitted via XML.

To support this requirement, Sprint 29 will introduce a “Show Prices” option in AIR Card payment settings that FBOs can enable to display pricing on AIR Card invoices.

This requirement primarily applies when the FBO holds the DLA contract directly.

FBOs that do not hold the DLA contract directly should review the Important Considerations section below, as different workflows may apply when the contract is held by the fuel supplier.


Digital Signature Capture for Priced Invoices

Signed invoices are now required for AIR Card transactions. X-1FBO will support digital signature capture on priced invoices using the existing “Request Signature by Email” functionality.

Recommended workflow

  1. Create the invoice in X-1FBO once the transaction is complete and the contract price has been entered

  2. Use the “Request Signature by Email” option to send the priced invoice to the receiving party

  3. The recipient reviews the invoice and applies a digital signature through the secure link provided in the email

  4. The signed invoice is stored with the transaction record in X-1FBO

Important:

Signatures must be captured after the invoice is closed but before batch settlement. Otherwise, the signed invoice must be submitted through the DLA/KHI portal.

While this method is immediately available it will have limitations based on the crews ability to carry mobile devices with access to email.

Additional Signature Capture Option (In Development)

X-1FBO will also introduce a signature capture application for X-1 SinglePoint devices, allowing signatures to be collected directly on the ramp or at the front desk.

This capability will allow operators to capture signatures in person at the time of service using the X-1 SinglePoint device.

This feature requires additional testing and validation. Deployment timelines will be shared once available.


MSA and KHI Processor Locations

(Titan, AEG and other supported networks)

Beginning April 6 (Sprint 29), X-1FBO will support transmission of signed invoices to the DLA during batch settlement for MSA and KHI processor locations.

Important notes:

  • Signatures must be captured after the invoice is closed and before batch settlement

  • Invoices signed after batch settlement will not be transmitted through X-1

  • Those invoices must be submitted separately through the DLA/KHI portal

To assist with verification, a “Sent” indicator will be added to the Batch History page so FBOs can confirm which invoices were transmitted with signatures.


AHT Processor Locations

(World Fuel, Phillips 66, Avfuel)

Locations using AHT processors will not have the signature transmission enhancement at this time, as AHT does not currently support receiving signed invoices within batch settlement files.

AHT and its partner networks are working on this capability, but a timeline for support is currently TBD.

Important:

Until these capabilities are developed, AHT locations must continue to upload signed invoices through the DLA portal operated by KHI or through supplier-provided submission tools.


Important Considerations for Locations Where the Fuel Supplier Holds the DLA Contract

In many locations, the fuel supplier holds the DLA contract rather than the FBO.

While X-1FBO will allow the contract price to appear on the invoice as required by the DLA, this may create accounting differences that FBO operators should understand before using the feature.

The DLA requirement for priced invoices creates an issue where the FBO would be required to create an invoice DIFFERENT from the amount they will be paid for the transaction. The contract price shown on the invoice will represent the supplier’s contractual price to the DLA, which may not match the amount the FBO ultimately receives from the supplier for the fuel sale.

This may create confusion for pilots and will also affect AR reconciliation between the supplier and the FBO.

Important:

For this reason, X-1 recommends that FBOs where the supplier holds the contract consider using the KHI-provided portal or supplier-provided submission tools, where available, for AIR Card documentation and submission.

If this approach is used, operators may create offline invoices in X-1FBO using their normal pricing to the supplier, rather than using the DLA contract price on the invoice generated within the system.

Operators should review the tools provided by their fuel supplier and the DLA program administrator when determining the appropriate workflow.

For additional guidance, please review the KHI provided program training resources:

Providing Industry Feedback

Because these changes have the potential to significantly affect day-to-day fueling operations, industry feedback is extremely important.

X-1 encourages FBO operators, suppliers, and other industry participants to share their experiences and operational concerns so that they can be communicated to the appropriate stakeholders involved in the program.

If your location processes AIR Card transactions, we encourage you to provide feedback on areas such as:

  • Operational challenges created by the new requirements

  • Additional administrative workload required to comply with documentation requirements

  • Payment or reconciliation risks associated with transaction validation or invoice submission

  • Whether these requirements may affect your location’s willingness or ability to continue supporting AIR Card transactions

You can submit feedback here:

Industry input will help ensure that the operational realities of the aviation fueling community are clearly represented as discussions around the AIR Card program continue.

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