Recently, XPeng AeroHT's X3-F received two pieces of news that appear to point in opposite directions.
The good news is: Bureau test flights have been completed, and the Type Certificate (TC) is pending issuance. The bad news is: Deliveries to end customers will not occur within 2026.
Many people read these two facts together and reached a conclusion: The certificate is coming, but production capacity hasn't kept up, so deliveries are delayed.
But this understanding is wrong. The real answer lies in a document from two years ago.
01 "No Passenger Carriage" Is Not a New Restriction
On March 20, 2024, Guangdong Huitian Aerospace Technology Co., Ltd. submitted an application for the X3-F Type Certificate to the Civil Aviation Administration of China South Central Regional Administration (CAAC SCRA), which was accepted the next day. The application category was clearly stated: Light Sport Aircraft (LSA).
A year later, on March 17, 2025, the Airworthiness Department of the CAAC released the "Draft Special Conditions for the X3-F Aircraft," which is also the first special condition for a split-body flying vehicle flight unit in China. The limitations in the document have been repeatedly cited: The X3-F is restricted to daytime visual flight conditions, primarily for private recreational flying, and may also be used for flight training; it is not intended for commercial passenger carriage.
The key point is that, according to CCAR-21 regulations, aircraft that apply for and obtain a TC under the LSA category correspondingly receive a Light Sport Category Special Airworthiness Certificate, which legally prohibits commercial passenger carriage operations.
In other words, "cannot carry passengers" was never the result of being rejected during the certification sprint; it was the path chosen at project initiation in March 2024. From day one, its target was a certificate for "individuals to buy and fly themselves," not a certificate for "commercial passenger operations."
Comparing this with EHang's EH216-S makes things much clearer. The latter applied for certification under the (unmanned) Normal Category, corresponding to a Standard Airworthiness Certificate, allowing it to be used for commercial passenger carriage operations. It ultimately obtained the Operation Certificate (OC) in March 2025, becoming the world's first manned eVTOL with "all four certificates." The difference between the two companies is not about speed of progress, but rather that they started on two different tracks.
02 The Numbers in the Special Conditions Lock Down the Scenario
Examining the parameters in the X3-F special conditions reveals the weight of this certificate more clearly: maximum takeoff weight not exceeding 960 kg, 1 pilot and a maximum of 1 passenger, maximum flight altitude of 120 meters (AGL), maximum range of 20 km, and maximum flight duration of 20 minutes.
20 km, 20 minutes, 120 meters, two people—this is the scale of "low-altitude experience," not commuting.
Precisely because restrictions were placed on usage, the safety requirements for the LSA category are relatively lower than those for the Normal or Transport categories. Certification can be obtained by meeting "standards acceptable to the authority" or demonstrating "equivalent safety levels recognized by the authority." For reference, when manned-grade eVTOLs carry 5 or more passengers, the catastrophic failure rate requirement must be controlled to the order of magnitude of 10^-9, approaching standards for large airliners.
This is precisely the point most worth the industry understanding: XPeng AeroHT chose a pragmatic route of "getting the product to fly legally first." Using a restricted certificate to gain certification speed, market cultivation time, and real operational data. This is not a discounted certificate; it is a rare clarity in the low-altitude economy.
03 Behind the TC, PC and AC Are Still Queued Up
Returning to the illusion of the "final step."
Completion of bureau test flights and the pending TC are indeed major milestones. However, the Production Certificate (PC) for the X3-F was only accepted in May 2025, followed by the Individual Airworthiness Certificate (AC) process, which requires one certificate per aircraft. Company management previously confirmed that deliveries to end customers cannot occur within 2026; the CFO gave a more conservative estimate at the Dubai Business Forum: consumer deliveries would ideally begin by the end of 2027, potentially slipping to early 2028 depending on the maturity speed of regulatory frameworks and operating environments.
Industry benchmarks are clear: domestically, manned eVTOL projects generally require 3 to 5 years from project launch to obtaining a TC, with a complete certification cycle under a single regulatory body stabilizing at 24 to 40 months. Volant Aerotech's AE200 targets certification in 2027, and Yufeng Future's M1 plans to complete manned airworthiness certification around 2028. The X3-F is not behind; it is simply following the industry's actual pace.
04 The 7,000 Orders Are a List of Intentions
The global cumulative bookings for the "Land Carrier" exceed 7,000 units, with an official price of no more than CNY 2 million. This number is often treated as evidence of exploding demand.
However, it should be noted that these bookings are intentions, not confirmed sales with completed payments and deliveries. Before the TC is issued, and before the PC and AC are finalized, intention orders do not have mandatory fulfillment validity and cannot be converted into revenue.
There is a ready-made mirror here. EHang's EH216-S is the only manned eVTOL globally to possess all four certificates: TC, AC, PC, and OC, having closed the compliance loop. But even so, it lowered its full-year revenue guidance in August 2025 and delivered only 4 units in the first quarter of 2026. Production capacity is not the bottleneck; the speed of order digestion is.
05 2026 Is the Year of Certification, Not Delivery
Zooming out, one sees that the X3-F's situation is quite typical.
On one side is the domestic pace: TC pending, no deliveries within the year, and the driver's license system still under discussion—Huitian is pushing to simplify the light sport category driver's license process, with a flight demonstration zone landing in Changsha as soon as possible. On the other side is the overseas pace: obtaining the first特许飞行证 (Special Flight Permit) for a manned aircraft by a Chinese flying enterprise abroad in the UAE in September 2025, public flight demonstrations in Dubai in October signing 600 intent orders, co-building a regulatory sandbox in September 2026, and the Ruler of Ras Al Khaimah personally visiting Guangzhou on October 20 to pick up an X3-F from the mass production line.
No domestic deliveries while testing overseas first seems misaligned, but it is actually the same logic: Using restricted certificates and overseas sandboxes to accumulate real operational data, feeding back into the domestic regulatory framework. This is not flowers blooming inside walls smelling fragrant outside; it is bidirectional input of regulatory experience.
From a larger policy window perspective, in February 2026, the CAAC released the "Airworthiness Standards for Power-Augmented Aircraft," moving eVTOL review from "negotiation per model" to normalized general standards. The X3-F special conditions happen to be the last and most representative closing case in this transition period.
Conclusion
In the business of flying cars, the biggest chokepoint right now has never been "whether it can fly."
A TC that "cannot carry passengers" and 7,000 undeliverable orders tell a simpler truth together: this industry is transitioning from telling stories to balancing books. Rules, scenarios, delivery, and supporting infrastructure each need to follow their own pace to completion.
For the industry, this is not bad news. Cooling down expectations is precisely the sign that the low-altitude economy is beginning to mature.