A Closer Look at SOI 3

We just cleared a key certification stage, SOI 3

This update explains more about what the milestone is, and why we think this kind of work is critical to building out our technical and competitive position.

On August 6, 2026 we announced that we have reached Stage of Involvement 3 (“SOI 3”) with the Civil Aviation Authority of New Zealand for two parts of the Merlin Pilot system, the Flight Control Computer and the Automated Communication System. That work was conducted with the Civil Aviation Authority in coordination with the Federal Aviation Administration under a Bilateral Aviation Safety Agreement, the same concurrent pathway we have been on since SOI 1.

Inside the company, [this was a highly anticipated event that was greeted with cheers across our engineering and certification teams], who have been working toward it for a long time. We wanted to unpack this journey and its latest milestone a bit more for non-aviation, non-technical stakeholders outside the company, so investors and others can share in the excitement and better understand why the news matters for the business.

The short version: we believe technical and regulatory milestones like SOI 3 each help validate and differentiate Merlin and its core platform on its path to scaled commercialization across both civil and defense categories. Our goal is to become the operating system of record for the next century of aviation.

From a technical perspective, reaching that goal means proving the software to a regulator in pieces, on the regulator’s schedule, against a standard the regulator sets. This is a high set of bars to clear and it takes time. Each stage we achieve, however, both validates our process and helps build out our moat.

What is a “Stage of Involvement”?

Safety-critical aviation software gets approved through a complex process that looks past what the finished code does and examines how the software was built in the first place. DO-178C, as we described when we cleared SOI 1, our first stage, in 2023, is the governing standard that global certification authorities use to assess commercial software-based aerospace systems. If you have flown on an airliner recently, the flight management system, the autopilot and the engine controls all had to meet the same standards Merlin is currently working against.

Within that standard, a regulator evaluates a software program in four stages, each one a Stage of Involvement. The first (SOI 1) is where the regulator accepts the company plans, which for us meant the Civil Aviation Authority of New Zealand approving our Plan for Software Aspects of Certification. The second (SOI 2) looks at how software is actually being developed against those approved plans. When we cleared it in October 2025, approximately 50 percent of the software data for the Flight Control Computer had been formally reviewed. The third, SOI 3, which is the one we announced today, is where the regulator confirms the software has been tested and verified against its requirements.

The fourth and final stage is the last software compliance gate, and the Supplemental Type Certificate we are working toward follows from completing the sequence.

The Path to SOI 3

We cleared SOI 1 in May 2023. SOI 2 followed in October 2025. SOI 3 arrives today, August 6, 2026, along with a successfully concluded “issue paper” covering our use of AI and machine learning for natural language processing in aviation autonomy.

For many stakeholders including investors, much of our 2026 news so far might look technical and regulatory rather than commercial. So it is important to understand that, especially in a safety- and certification-driven aviation context, we believe there is no separation between the two. Technical and regulatory progress is commercialization.

All of our work and announcements, from completing the Critical Design Review on the C-130J program with USSOCOM on June 4, to completing an autonomous landing at EAA AirVenture Oshkosh on July 20, to collaborating with Israel Aerospace Industries, we believe are critical elements in building a platform and products on which revenue can be built and scaled.

The Issue Paper

An issue paper is the instrument a regulator requires when a technical design feature is not addressed by existing rules. Producing one is deliberately difficult, and it takes company and regulatory teams sitting down together to work out what has to be demonstrated, what evidence will count as a demonstration, and how the gap between an old rule set and a new technology gets closed.

That is why we treat the paper as more than a technical footnote to the milestone: it means we and the Civil Aviation Authority of New Zealand have now agreed on how to define how we close that gap. Specifically, our work with the Civil Aviation Authority of New Zealand covers the AI and machine learning behind natural language processing inside the Merlin Pilot, which is the part of the system that handles communication.

We now have an agreed certification approach, and an agreed standard of evidence. We believe there is a great deal of AI being demonstrated in aviation at the moment and considerably less agreement on how anyone would go about proving it, and that agreement is precisely what an operator with a fleet, a safety department or an insurer ultimately will need before using our platform at scale.

Early, and Moving with Urgency

We have a long way to go. There are no shortcuts in certification, nor should there be. Merlin Pilot has been demonstrated on the Cessna Caravan, the Beechcraft King Air, the de Havilland Twin Otter, the Rutan Long-EZ and the Cozy Mark IV, and we are making progress on its integration on the KC-135 with the U.S. Air Force and on the C-130J with USSOCOM. The certification basis we are establishing on the Caravan is one we expect to extend to other Part 23 aircraft types and classes.

Every gate we clear on the core is meant to make the next airframe easier, and every airframe we add gives the core more to learn from.

That is what we mean by an operating system of record for autonomous flight. Not just a system certified for a specific airframe, but a portable system that can meet the robust certification standards for a wide variety of airframes.

Sources

SOI 1, Business Wire, May 15, 2023. SOI 2, Business Wire, October 27, 2025. SOI 3, GlobeNewswire, August 6, 2026. C-130J Critical Design Review, Merlin release, June 4, 2026. Autonomous landing at EAA AirVenture Oshkosh, Merlin release, July 20, 2026. Israel Aerospace Industries memorandum of understanding, Merlin release, July 23, 2026. Airframe integrations reported by FlightGlobal, August 2024, and FLYING Magazine, April 2025. Part 23 extension of the Caravan certification basis reported by FLYING Magazine, April 2025. Issue paper requirement described in Merlin’s published recommendations for the OSTP AI Action Plan, merlinlabs.com. DO-178C compliance pathway and the CAA four-stage process described in the SOI 1 release, May 15, 2023. Approximately 50 percent Flight Control Computer software data review described in the SOI 2 release, October 27, 2025.

Cautionary Statement Regarding Forward-Looking Statements

This post contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. All statements other than statements of historical fact should be considered forward-looking statements, including without limitation statements regarding the achievement of future certification milestones and Merlin’s coordination with the Civil Aviation Authority of New Zealand and the Federal Aviation Administration under the Bilateral Aviation Safety Agreement, Merlin’s expectations regarding the capabilities, performance, and applications of the Merlin Pilot autonomy platform, including its AI/ML-based natural language processing and full flight autonomy capabilities, and the anticipated benefits and future development of Merlin’s autonomous flight technology. These forward-looking statements are based on our current expectations, assumptions, and projections about future events and trends. These forward-looking statements are neither promises nor guarantees, but involve known and unknown risks and uncertainties that could cause actual results to differ materially from those expressed or implied by the forward-looking statements, including without limitation the risks and uncertainties detailed under the section entitled “Risk Factors” of our final prospectus, dated May 13, 2026, filed with the SEC on May 13, 2026, and our subsequently filed Quarterly Reports on Form 10-Q, which are available from the SEC. Except as required by applicable law, we undertake no obligation to update any of these forward-looking statements after the date of this blog.