Regulation Text
§ 61.9 Inapplicability of simplified flight controls aircraft experience credit.
Notwithstanding the requirements specified in § 61.51(c), any pilot time acquired while operating an airplane or helicopter with a simplified flight controls designation may not be used to satisfy the following aeronautical experience requirements for a private, commercial, or airline transport pilot certificate, except for private pilot applicants who present an aircraft with the simplified flight controls designation to conduct the practical test—
(a) The solo flight time requirements in § 61.109(a)(5) or (c)(4);
(b) The PIC flight time requirements in § 61.129(a)(2)(i) and (c)(2)(i);
(c) The PIC flight time requirements in § 61.159(a)(5); and
(d) The PIC flight time requirements in § 61.161(a)(3).
The short answer
14 CFR § 61.9 provides that, notwithstanding § 61.51(c), pilot time in an airplane or helicopter with a simplified flight controls designation may not satisfy specified solo and PIC experience for private, commercial, or ATP certificates — except for private pilot applicants presenting such an aircraft for the practical test.
Research Notes
Common Questions
Which experience requirements can't be met with simplified flight controls time?
The section names four sets of requirements.
“(a) The solo flight time requirements in § 61.109(a)(5) or (c)(4); (b) The PIC flight time requirements in § 61.129(a)(2)(i) and (c)(2)(i); (c) The PIC flight time requirements in § 61.159(a)(5); and (d) The PIC flight time requirements in § 61.161(a)(3).” (14 CFR § 61.9)
Is there any exception to this exclusion?
Yes — the exclusion does not apply to private pilot applicants who present a simplified flight controls aircraft to conduct the practical test. That is the only carve-out in the text.
What aircraft does this cover?
It applies to an airplane or helicopter operated with a “simplified flight controls designation,” and applies notwithstanding the logging rules of § 61.51(c).
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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AOA's Decoded pages are plain-English interpretation for training and reference. They are not legal advice and do not replace the official regulation. Always confirm current requirements against the authoritative source before acting.
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.