Regulation Text
§ 61.65 Instrument rating requirements.
(a) General. A person who applies for an instrument rating must:
(1) Hold at least a current private pilot certificate, or be concurrently applying for a private pilot certificate, with an airplane, helicopter, or powered-lift rating appropriate to the instrument rating sought;
(2) Be able to read, speak, write, and understand the English language. If the applicant is unable to meet any of these requirements due to a medical condition, the Administrator may place such operating limitations on the applicant's pilot certificate as are necessary for the safe operation of the aircraft;
(3) Receive and log ground training from an authorized instructor or accomplish a home-study course of training on the aeronautical knowledge areas of paragraph (b) of this section that apply to the instrument rating sought;
(4) Receive a logbook or training record endorsement from an authorized instructor certifying that the person is prepared to take the required knowledge test;
(5) Receive and log training on the areas of operation of paragraph (c) of this section from an authorized instructor in an aircraft, full flight simulator, or flight training device that represents an airplane, helicopter, or powered-lift appropriate to the instrument rating sought;
(6) Receive a logbook or training record endorsement from an authorized instructor certifying that the person is prepared to take the required practical test;
(7) Pass the required knowledge test on the aeronautical knowledge areas of paragraph (b) of this section; however, an applicant is not required to take another knowledge test when that person already holds an instrument rating; and
(8) Pass the required practical test on the areas of operation in paragraph (c) of this section in—
(i) An airplane, helicopter, or powered-lift appropriate to the rating sought; or
(ii) A full flight simulator or a flight training device appropriate to the rating sought and for the specific maneuver or instrument approach procedure performed. If an approved flight training device is used for the practical test, the instrument approach procedures conducted in that flight training device are limited to one precision and one nonprecision approach, provided the flight training device is approved for the procedure performed.
(b) Aeronautical knowledge. A person who applies for an instrument rating must have received and logged ground training from an authorized instructor or accomplished a home-study course on the following aeronautical knowledge areas that apply to the instrument rating sought:
(1) Federal Aviation Regulations of this chapter that apply to flight operations under IFR;
(2) Appropriate information that applies to flight operations under IFR in the “Aeronautical Information Manual;”
(3) Air traffic control system and procedures for instrument flight operations;
(4) IFR navigation and approaches by use of navigation systems;
(5) Use of IFR en route and instrument approach procedure charts;
(6) Procurement and use of aviation weather reports and forecasts and the elements of forecasting weather trends based on that information and personal observation of weather conditions;
(7) Safe and efficient operation of aircraft under instrument flight rules and conditions;
(8) Recognition of critical weather situations and windshear avoidance;
(9) Aeronautical decision making and judgment; and
(10) Crew resource management, including crew communication and coordination.
(c) Flight proficiency. A person who applies for an instrument rating must receive and log training from an authorized instructor in an aircraft, or in a full flight simulator or flight training device, in accordance with paragraph (g) of this section, that includes the following areas of operation:
(1) Preflight preparation;
(2) Preflight procedures;
(3) Air traffic control clearances and procedures;
(4) Flight by reference to instruments;
(5) Navigation systems;
(6) Instrument approach procedures;
(7) Emergency operations; and
(8) Postflight procedures.
(d) Aeronautical experience for the instrument-airplane rating. A person who applies for an instrument-airplane rating must have logged:
(1) Except as provided in paragraph (g) of this section, 50 hours of cross-country time as pilot in command, of which 10 hours must have been in an airplane; and
(2) Forty hours of actual or simulated instrument time in the areas of operation listed in paragraph (c) of this section, of which 15 hours must have been received from an authorized instructor who holds an instrument-airplane rating, and the instrument time includes:
(i) Three hours of instrument flight training from an authorized instructor in an airplane that is appropriate to the instrument-airplane rating within 2 calendar months before the date of the practical test; and
(ii) Instrument flight training on cross country flight procedures, including one cross country flight in an airplane with an authorized instructor, that is performed under instrument flight rules, when a flight plan has been filed with an air traffic control facility, and that involves—
(A) A flight of 250 nautical miles along airways or by directed routing from an air traffic control facility;
(B) An instrument approach at each airport; and
(C) Three different kinds of approaches with the use of navigation systems.
(e) Aeronautical experience for the instrument-helicopter rating. A person who applies for an instrument-helicopter rating must have logged:
(1) Except as provided in paragraph (g) of this section, 50 hours of cross-country time as pilot in command, of which 10 hours must have been in a helicopter; and
(2) Forty hours of actual or simulated instrument time in the areas of operation listed under paragraph (c) of this section, of which 15 hours must have been with an authorized instructor who holds an instrument-helicopter rating, and the instrument time includes:
(i) Three hours of instrument flight training from an authorized instructor in a helicopter that is appropriate to the instrument-helicopter rating within 2 calendar months before the date of the practical test; and
(ii) Instrument flight training on cross country flight procedures, including one cross country flight in a helicopter with an authorized instructor that is performed under instrument flight rules and a flight plan has been filed with an air traffic control facility, and involves—
(A) A flight of 100 nautical miles along airways or by directed routing from an air traffic control facility;
(B) An instrument approach at each airport; and
(C) Three different kinds of approaches with the use of navigation systems.
(f) Aeronautical experience for the instrument-powered-lift rating. A person who applies for an instrument-powered-lift rating must have logged:
(1) Except as provided in paragraph (g) of this section, 50 hours of cross-country time as pilot in command, of which 10 hours must have been in a powered-lift; and
(2) Forty hours of actual or simulated instrument time in the areas of operation listed under paragraph (c) of this section, of which 15 hours must have been received from an authorized instructor who holds an instrument-powered-lift rating, and the instrument time includes:
(i) Three hours of instrument flight training from an authorized instructor in a powered-lift that is appropriate to the instrument-powered-lift rating within 2 calendar months before the date of the practical test; and
(ii) Instrument flight training on cross country flight procedures, including one cross country flight in a powered-lift with an authorized instructor that is performed under instrument flight rules, when a flight plan has been filed with an air traffic control facility, that involves—
(A) A flight of 250 nautical miles along airways or by directed routing from an air traffic control facility;
(B) An instrument approach at each airport; and
(C) Three different kinds of approaches with the use of navigation systems.
(g) An applicant for a combined private pilot certificate with an instrument rating may satisfy the cross-country time requirements of this section by crediting:
(1) For an instrument-airplane rating or an instrument-powered-lift rating, up to 45 hours of cross-country time performing the duties of pilot in command with an authorized instructor; or
(2) For an instrument-helicopter rating, up to 47 hours of cross-country time performing the duties of pilot in command with an authorized instructor.
(h) Use of full flight simulators or flight training devices. If the instrument time was provided by an authorized instructor in a full flight simulator or flight training device—
(1) A maximum of 30 hours may be performed in that full flight simulator or flight training device if the instrument time was completed in accordance with part 142 of this chapter; or
(2) A maximum of 20 hours may be performed in that full flight simulator or flight training device if the instrument time was not completed in accordance with part 142 of this chapter.
(i) Use of an aviation training device. A maximum of 10 hours of instrument time received in a basic aviation training device or a maximum of 20 hours of instrument time received in an advanced aviation training device may be credited for the instrument time requirements of this section if—
(1) The device is approved and authorized by the FAA;
(2) An authorized instructor provides the instrument time in the device; and
(3) The FAA approved the instrument training and instrument tasks performed in the device.
(j) Except as provided in paragraph (h)(1) of this section, a person may not credit more than 20 total hours of instrument time in a full flight simulator, flight training device, aviation training device, or a combination towards the instrument time requirements of this section.
[Docket 25910, 62 FR 16298, Apr. 4, 1997; Amdt. 61-103, 62 FR 40900, July 30, 1997; Amdt. 61-124, 74 FR 42554, Aug. 21, 2009; Amdt. 61-127, 76 FR 19267, Apr. 7, 2011; Amdt. 61-128, 76 FR 54106, Aug. 31, 2011; Docket FAA-2015-1846, Amdt. 61-136, 81 FR 21460, Apr. 12, 2016; FAA-2023-1275, Amdt. 61-157, 89 FR 92483, Nov. 21, 2024]
Research Notes
Research Notes — § 61.65 Instrument Rating Requirements
Governing Advisory Circular
AC 61-65K — Certification: Pilots and Flight and Ground Instructors (current version). The operative AC for § 61.65. Why it matters in practice: it contains the exact endorsement language — word-for-word — that authorized instructors must use to sign off applicants for the instrument rating knowledge test and practical test. Examiners verify these endorsements before accepting an applicant; a paraphrased or incomplete endorsement is grounds for rejection at the door. If you are an applicant, you need to confirm your instructor is using AC 61-65K (not a superseded version like 61-65J) before you show up to the testing center. Earlier versions (AC 61-65J, 61-65G) are superseded and will generate examiner pushback. Source: FAA AC 61-65K
Aviation Training Device Credit — AC 61-136B
AC 61-136B — FAA Approval of Aviation Training Devices and Their Use for Training and Experience. Why this AC matters for your training plan: it determines which ground-based training devices actually count toward your instrument rating — and which do not. Not every simulator qualifies. Only FAA-approved devices on the published ATD list earn credit. A school that runs you through 15 hours in an unapproved desktop unit has burned your time. The credit structure codified in § 61.65(i)–(j): BATD maximum 10 hours; AATD maximum 20 hours; combined FFS/FTD/ATD cap 20 hours total (not additive — one pool). The safety reasoning behind the cap is straightforward: the final instrument experience hours need to come from an aircraft where weather, ATC, and the consequences of errors are real. Source: FAA AC 61-136B
AIM Cross-Reference
AIM Chapter 1, Sections 1-1-17 through 1-1-19 — Navigation systems (GPS, VOR, ILS, NDB) referenced in § 61.65(b)(4)–(5) aeronautical knowledge requirements. Pilots must understand IFR en route navigation and approach systems to satisfy the knowledge test under § 61.65(b). The AIM also covers IFR flight plan filing requirements (AIM 5-1-4 through 5-1-8), directly relevant to the long cross-country requirement in § 61.65(d)(2)(ii). Source: FAA Aeronautical Information Manual
FAA Chief Counsel Letters of Interpretation
- Gebhart Letter (June 2009) — Clarifies cross-country PIC time under § 61.65(d)(1). The ruling matters because it reflects how instrument training prepares pilots for solo IFR operations: in actual IMC, there is no safety pilot beside you. The rule forces your cross-country PIC logging to reflect the pilot who is truly in command — the pilot who would own the entire flight if it went into actual IMC. Specifically: only the pilot conducting the entire flight as a required crewmember may log cross-country time. A safety pilot is only a required crewmember during the under-the-hood portions, not the whole flight — and therefore cannot log cross-country time for that flight. Source: FAA Legal Interpretation — Gebhart (2009)
- Carty Memorandum (February 2022) — Rescinded prior Glaser and Pratte legal interpretations and clarified the "three different kinds of approaches" requirement in § 61.65(d)(2)(ii)(C). Why it matters: the old interpretations drove training programs to require three different navigation systems, which was narrower than what the regulation actually says. The Carty memo confirmed the plain language: three different approach types (ILS, LOC, RNAV, VOR, ASR, etc.) — and different minima lines on the same chart can satisfy this. For instrument students in areas where certain approach types are scarce, this is a meaningful operational clarification. Source: IFR Magazine — Which Three Approaches?
Related Regulations
- § 61.57(c) — Instrument Experience: Governs how instrument currency is maintained post-certification. Interacts with § 61.65 because the six-approach/hold/intercept-and-track requirement for currency uses the same instrument approach categories defined for the rating — what you learn to log correctly during training is the same system you will use to track currency for the rest of your IFR flying career.
- § 61.1(b) — Definition of Cross-Country Time: The operative definition for the 50-hour cross-country PIC requirement in § 61.65(d)(1). Cross-country time for rating purposes requires a landing at a point more than 50 NM straight-line from the departure point.
- § 61.4(b) — Prohibition on Crediting Non-Approved Simulators: Only FAA-approved FFS, FTD, or ATDs may be credited toward instrument time requirements. Personal home simulators (Microsoft Flight Simulator, X-Plane on consumer hardware) do not qualify regardless of realism.
- 14 CFR Part 142: Training centers operating under Part 142 may credit up to 30 hours of FFS/FTD time (vs. the 20-hour cap under Part 61) — relevant to the § 61.65(h)(1) exception.
Amendment History Highlight — Amdt. 61-157 (November 2024)
Amendment 61-157, effective November 2024 (89 FR 92483), made primarily nomenclature and conforming changes throughout Part 61. The ATD time credit structure in §§ 61.65(h)–(j) that separates FFS/FTD caps from ATD (BATD/AATD) caps was established by Amdt. 61-136 (2016). The 2024 amendment did not alter the core hour-credit limits.
Amendment History
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.
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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.