1.2 Aeronautical Experience & Certification Requirements
Key Takeaways
- 14 CFR 61.65(d) mandates 50 hours of cross-country flight time as Pilot in Command (PIC), of which at least 10 hours must be in airplanes.
- Applicants must log at least 40 hours of actual or simulated instrument time, including at least 15 hours of dual instrument flight instruction from an authorized CFII in airplanes.
- The qualifying IFR cross-country flight requires traveling at least 250 NM along airways or ATC routing, landing at 3 different airports, and performing 3 different types of instrument approaches using navigational systems.
- 14 CFR 61.65(i) allows crediting up to 20 hours in an approved Advanced Aviation Training Device (AATD) or up to 10 hours in a Basic ATD (BATD); 61.65(h)(2) caps a full flight simulator or flight training device at 20 hours, and 61.65(j) caps any combination of these devices at 20 total hours — only instrument time completed under part 142 may be credited up to 30 hours (61.65(h)(1)).
- Under 14 CFR 91.109, a safety pilot for simulated instrument flight must hold at least a Private Pilot certificate in category and class, have a current medical certificate or BasicMed, and occupy a control seat in an aircraft with functioning dual controls.
Aeronautical Experience & Certification Requirements (14 CFR § 61.65)
Quick Answer: Under 14 CFR § 61.65(d), an applicant for an Instrument Rating - Airplane must hold at least a Private Pilot Certificate and have logged: (1) 50 hours of cross-country PIC time (at least 10 hours in airplanes); (2) 40 hours of actual or simulated instrument time (at least 15 hours of dual instruction from a CFII in airplanes); (3) a 250-NM IFR cross-country flight along airways/ATC routing with 3 different approaches at 3 airports; and (4) 3 hours of checkride prep within 2 calendar months of the test. Up to 20 hours in an approved AATD (or 10 in a BATD) can be credited under Part 61. Safety pilots under 14 CFR § 91.109 must hold at least a Private Pilot certificate in category/class and a current medical or BasicMed.
Obtaining an instrument rating requires meeting specific regulatory prerequisites under Title 14 of the Code of Federal Regulations (14 CFR) Part 61. The FAA establishes these minimum flight times to ensure that pilots possess both the navigation endurance and the technical instrument handling skills required for safe flight in the National Airspace System (NAS).
14 CFR § 61.65(d) Aeronautical Experience Requirements
An applicant for an Instrument - Airplane rating must log the following minimum flight times:
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| 14 CFR § 61.65(d) EXPERIENCE REQUIREMENTS |
| |
| +---------------------------------------------------------------+ |
| | 50 Hours Cross-Country as Pilot in Command (PIC) | |
| | - Minimum 10 hours in airplanes | |
| | - Meets 14 CFR § 61.1 definition (>50 NM straight line) | |
| +---------------------------------------------------------------+ |
| |
| +---------------------------------------------------------------+ |
| | 40 Hours Actual or Simulated Instrument Time | |
| | - Minimum 15 hours dual instruction from an authorized CFII | |
| | - Dual instruction must be received in airplanes | |
| | - Includes 3 hours prep within 2 calendar months of test | |
| | - Includes the Qualifying 250 NM Long Cross-Country | |
| +---------------------------------------------------------------+ |
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1. Cross-Country Pilot in Command (PIC) Time
- Total Requirement: At least 50 hours of cross-country flight time as PIC.
- Category Specifics: At least 10 hours of this cross-country PIC time must be logged in airplanes (the remaining 40 hours may have been logged in other aircraft categories, such as helicopters, provided it meets the cross-country PIC criteria).
- Cross-Country Definition (14 CFR § 61.1): To count toward the 50-hour cross-country requirement for an instrument rating, the flight must include a point of landing that is more than 50 nautical miles straight-line distance from the original departure point.
2. Instrument Flight Time & Dual Instruction
- Total Instrument Requirement: At least 40 hours of actual or simulated instrument time on the areas of operation listed in 14 CFR § 61.65(c).
- Dual Instruction: At least 15 hours of instrument flight training must be received from an authorized flight instructor (CFII) who holds an instrument-airplane rating on their flight instructor certificate. This training must be completed in airplanes.
- Checkride Preparation: At least 3 hours of instrument flight training from an authorized instructor must be completed within the 2 calendar months immediately preceding the date of the practical test (14 CFR § 61.65(d)(2)(iv)).
The Long IFR Cross-Country Flight (14 CFR § 61.65(d)(2)(iii))
The cornerstone of instrument flight training is the qualifying long cross-country flight. This flight synthesizes en route navigation, weather analysis, ATC coordination, and terminal instrument approach execution.
Under 14 CFR § 61.65(d)(2)(iii), this flight must meet four strict criteria:
- Distance: Flown over a distance of at least 250 nautical miles along federal airways, published RNAV routes, or ATC-directed routing.
- Flight Plan: Conducted under an active IFR flight plan.
- Multiple Airports: An instrument approach must be performed at each of three different airports (e.g., departure airport + 2 intermediate landing airports, or 3 distinct destinations).
- Approach Diversity: Must execute three different kinds of instrument approaches using distinct navigation systems and facilities.
Example of Approach Diversity:
- Airport 1 (KADS): ILS Runway 16R approach (Ground-based Precision localizer & glideslope)
- Airport 2 (KTYR): VOR Runway 4 approach (Ground-based Non-precision angular radial)
- Airport 3 (KGGG): RNAV (GPS) Runway 13 approach (Space-based Satellite approach)
Flight Simulators and Aviation Training Device (ATD) Credits
The FAA permits crediting time logged in approved Flight Simulation Training Devices toward the 40-hour instrument requirement under 14 CFR § 61.65(h), (i), and (j) and Advisory Circular (AC) 61-136B:
| Device Type | Description | Max Credit (NOT under Part 142) | Max Credit (Under Part 142) |
|---|---|---|---|
| BATD | Basic Aviation Training Device (basic flight deck controls, procedural training) | 10 Hours (61.65(i)) | 10 Hours (61.65(i)) |
| AATD | Advanced Aviation Training Device (realistic avionics, ergonomics, multi-screen visuals) | 20 Hours (61.65(i)) | 20 Hours (61.65(i)) |
| FSTD (FFS or FTD) | Full Flight Simulator or Flight Training Device, instruction given by an authorized instructor | 20 Hours (61.65(h)(2)) | 30 Hours (61.65(h)(1)) |
| Any Combination | FFS + FTD + ATD hours added together | 20 Hours Maximum (61.65(j)) | 30 Hours permitted for 61.65(h)(1) training |
[!WARNING] Exam Trap — the 20-hour ceiling. The frequently quoted "30 hours" applies only to instrument time completed in accordance with 14 CFR part 142 (§ 61.65(h)(1)). Outside a part 142 training center, a full flight simulator or flight training device is capped at 20 hours (§ 61.65(h)(2)), and § 61.65(j) caps any combination of FFS, FTD, and ATD credit at 20 total hours. Both the BATD (10-hour) and AATD (20-hour) limits are in the same paragraph — § 61.65(i) — not in § 61.65(j).
Conditions for Simulation Credit
- The device must be approved by the FAA with an active Letter of Authorization (LOA) on file and physically accessible at the training site.
- Time must be logged under the instruction of an authorized instructor (CFII) who observes and signs the logbook.
- The student must perform maneuvers and tasks specified in 14 CFR § 61.65(c).
14 CFR § 61.51(g) Logbook Requirements for Instrument Time
Under 14 CFR § 61.51(g), a pilot may log instrument flight time only for that flight time when the pilot operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.
Mandatory Logbook Entries
Each logbook entry for instrument time must explicitly document:
- Date, Flight Duration, and Route/Locations.
- Location and Type: The location and type of each instrument approach procedure completed.
- Safety Pilot Name: The name of the safety pilot, if the flight was conducted in simulated instrument conditions under a view-limiting device (hood).
- Actual vs. Simulated Conditions: Clear distinction between actual IMC (clouds/visibility below VFR minimums) and simulated instrument time.
- Simulator/Training Device: For ATD/FSTD sessions, the logbook must specify the device type, FAA approval number/LOA, and the instructor's signature and certificate number.
14 CFR § 91.109 Safety Pilot Qualifications & Rules
When a pilot practices instrument flying in visual conditions using a view-limiting device (such as Fogle® or a hood), external visual scanning is obstructed. Therefore, 14 CFR § 91.109(c) strictly requires a Safety Pilot.
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| SAFETY PILOT REGULATORY CHECKLIST |
| |
| [✓] Holds at least a Private Pilot Certificate (14 CFR 91.109(c)(1))|
| [✓] Rated in the same Aircraft Category and Class |
| [✓] Holds a current FAA Medical Certificate or BasicMed (91.109(c)) |
| [✓] Occupies the other control seat with dual controls (91.109(c)) |
| [✓] Forward & side vision adequate to see and avoid traffic |
| [✓] Instrument rating NOT required for safety pilot in VMC (Day/Night|
| (Note: Safety pilot MUST be IFR rated/current if flight is on |
| an IFR flight plan and safety pilot acts as PIC) |
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Detailed Safety Pilot Requirements:
- Certificate Level: Must hold at least a Private Pilot Certificate with category and class ratings appropriate to the aircraft being flown (e.g., Airplane Single-Engine Land).
- Medical Certification: Because the safety pilot is a required crewmember under 14 CFR § 91.109, they must possess a valid FAA medical certificate (1st, 2nd, or 3rd Class) or current BasicMed qualification.
- Dual Controls: The aircraft must be equipped with fully functioning dual controls (14 CFR § 91.109(c)(1)). Note: A throw-over control wheel is permitted only under the specific conditions of 14 CFR § 91.109(d).
- Instrument Rating Requirement: A safety pilot does not need an instrument rating if the flight is conducted in VMC under VFR. However, if the flight is operated on an IFR flight plan or enters actual IMC, the pilot acting as PIC must be instrument rated and current.
Logging PIC Time as a Safety Pilot
- Manipulator of Controls (Hood Pilot): Logs PIC time under 14 CFR § 61.51(e)(1)(i) as the sole manipulator of the controls for an aircraft for which the pilot is rated.
- Safety Pilot: A safety pilot is a required flight crewmember under 14 CFR § 91.109(c). Under 14 CFR § 61.51(f), the safety pilot may log Second in Command (SIC) time while the other pilot is under the hood. Alternatively, if the safety pilot and the flying pilot agree beforehand that the safety pilot will act as the legal PIC of the flight, the safety pilot may log PIC time under 14 CFR § 61.51(e)(1)(iii) for the portion of flight during which they act as PIC and are a required crewmember.
Which of the following describes the qualifying long IFR cross-country flight required by 14 CFR § 61.65(d)(2)(iii)?
Under 14 CFR Part 61, what is the maximum number of hours that may be credited toward the 40-hour instrument requirement in an FAA-approved Advanced Aviation Training Device (AATD)?
Which qualification is legally required for an individual acting as a safety pilot for simulated instrument flight in visual conditions under 14 CFR § 91.109(c)?