Reinstatement of Flight Instructor Privileges

Regulation Text

§ 61.199 Reinstatement of flight instructor privileges.

(a) Flight instructor privileges. The holder of a flight instructor certificate who has not complied with the flight instructor recent experience requirements of § 61.197 may reinstate their flight instructor privileges by filing a completed and signed application with the FAA and satisfactorily completing one of the following reinstatement requirements:

(1) If 3 calendar months or less have passed since the last month of the flight instructor's recent experience period, the flight instructor may successfully complete an approved flight instructor refresher course consisting of ground training or flight training, or a combination of both, or satisfy one of the requirements specified in paragraph (a)(2) of this section.

(2) If more than 3 calendar months have passed since the last month of the flight instructor's recent experience period, the flight instructor must satisfactorily complete one of the following:

(i) A flight instructor certification practical test, as prescribed by § 61.183(h), for one of the ratings held on the flight instructor certificate; or

(ii) A flight instructor certification practical test for an additional rating.

(3) For military instructor pilots and pilot examiners, provide a record showing that, within the preceding 6 calendar months from the date of application for reinstatement, the person—

(i) Passed a U.S. Armed Forces instructor pilot or pilot examiner proficiency check; or

(ii) Completed a U.S. Armed Forces instructor pilot or pilot examiner training course and received an additional aircraft qualification as a military instructor pilot or pilot examiner that is appropriate to the flight instructor rating sought.

(b) Flight instructor ratings. (1) A flight instructor rating or a limited flight instructor rating on a pilot certificate is no longer valid and may not be exchanged for a similar rating or a flight instructor certificate.

(2) The holder of a flight instructor rating or a limited flight instructor rating on a pilot certificate may be issued a flight instructor certificate with the current ratings, but only if the person passes the required knowledge and practical test prescribed in this subpart for the issuance of the current flight instructor certificate and rating.

[Docket 25910, 62 FR 16298, Apr. 4, 1997, as amended by Amdt. 61-104, 63 FR 20289, Apr. 23, 1998; Amdt. 61-124, 74 FR 42562, Aug. 21, 2009; Amdt. 61-142, 83 FR 30279, June 27, 2018; Docket FAA-2023-0825, Amdt. 61-155, 89 FR 80052, Oct. 1, 2024]

Research Notes

Research Notes — § 61.199 Reinstatement of Flight Instructor Privileges

Two Reinstatement Tracks Based on How Long It's Been

§ 61.199(a) divides the reinstatement path into two tracks based on elapsed time since the last month of the recent experience period:

3 calendar months or less lapsed: May reinstate via a FIRC (an approved flight instructor refresher course) OR by satisfying any § 61.199(a)(2) requirement.
More than 3 calendar months lapsed: Must complete a full CFI practical test — either for an existing rating held or for an additional rating. No FIRC-only path available.

This two-track structure creates a meaningful distinction: a brief lapse (3 months or less) can be fixed with relatively low effort (a FIRC); a longer lapse requires essentially re-demonstrating CFI competency before a DPE. Source: 14 CFR § 61.199

The "Flight Instructor Rating on a Pilot Certificate" Distinction

§ 61.199(b) addresses a legacy issue: some pilots hold a "flight instructor rating" or "limited flight instructor rating" on their pilot certificate rather than a separate flight instructor certificate. These ratings are no longer valid and cannot be exchanged for a flight instructor certificate. A pilot in this situation who wants to become a CFI must meet all current requirements from scratch — they receive no credit for the legacy rating. Source: 14 CFR § 61.199(b)

What "Filing a Completed and Signed Application" Means

Reinstatement requires filing a completed application with the FAA — this is done through IACRA. A CFI who has lapsed cannot simply take a FIRC and resume instructing; they must complete the application process with the FAA before privileges are restored. Source: FAA IACRA

CFI Commentary

Highlighted phrases in the regulation text above link to instructor notes at the bottom of this page. Look for the amber or blue highlights — each one flags a gotcha or a pro tip worth knowing.

Amendment History

2024-10-01

Multiple amendments. The 2024 amendment (Amdt. 61-155) revised § 61.199 to align with the new recent-experience framework: the reinstatement tracks now reference the 'recent experience period' rather than a certificate expiration date.

Amendment: 61.199

AOA Notes

These notes correspond to the highlighted phrases in the regulation text above. Each one flags something worth knowing — a common misread, a checkride gotcha, or a practical pro tip.

Gotcha: The 3-Month Grace Window: A FIRC Can Reinstate You — But Not Prevent Lapse

If your recent experience lapses and 3 calendar months or less have passed, you can reinstate by completing a FIRC and filing an application with the FAA. This is the 'soft' reinstatement path — less disruptive than a full practical test. Here's the critical distinction from § 61.197: using a FIRC for reinstatement under § 61.199 is different from using a FIRC to maintain recent experience under § 61.197(b)(2)(iii). For maintenance, the FIRC must be completed within the preceding 3 calendar months before your window closes. For reinstatement, you use it after the fact — once your privileges have already lapsed. The practical message: don't let it lapse in the first place. The 3-month grace window exists for genuine oversights, not as a planned buffer. Once you're past 3 months, you're looking at a full practical test — and that's a significantly higher bar than completing a FIRC.

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Gotcha: Old 'Instructor Rating on Pilot Certificate' — These Are Dead Ends

Before the modern CFI certificate structure, some pilots held 'flight instructor ratings' or 'limited flight instructor ratings' directly on their pilot certificates rather than as a separate instrument. § 61.199(b) is unambiguous: these ratings are no longer valid and cannot be exchanged for a current flight instructor certificate. If someone shows you a pilot certificate with an old instructor rating on it and asks whether they can use it to instruct, the answer is no. They need to complete the full current CFI certification process — written tests, practical test, all eligibility requirements — to hold a valid flight instructor certificate. The legacy rating provides no credit toward the new certificate.