14 CFR 61.65(d)(2) says:

(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:

So 15 hours must be with an instructor. What about the other 25? Can I fly in instrument meteorological conditions (IMC) "solo" (not the hood) like I did for my private pilot license (PPL) after an instructor sign off? Or does this just mean that I need another instrument rated (IR) pilot with me, but it doesn't necessarily have to be a certified flight instructor (CFI)? If that is the case, and I use the hood rather than actual IMC, does the other pilot need an IR or just a PPL?

Basically, how do you fulfill the other 25 hours?

  • $\begingroup$ Not that it will change the answers in this case. IFR flight plans require a pilot on board that is IFR rated and current. You should consider splitting the four questions here into a few others, though. $\endgroup$
    – egid
    Jun 9, 2015 at 2:47
  • $\begingroup$ Welcome to Aviation.SE. $\endgroup$
    – DeltaLima
    Jun 9, 2015 at 6:38
  • 1
    $\begingroup$ Two words: safety pilot. $\endgroup$ Jun 9, 2015 at 16:38

3 Answers 3


The remainder of the 25 hours can be completed with a Safety Pilot, a CFI, or a CFII.

A safety pilot must be able to act as PIC of the aircraft you are flying. Also, if the safety pilot is acting/desinated as PIC, both you and the safety pilot can log PIC time for when you are flying under the hood. If you are acting as PIC, the safety pilot can log SIC time for being a required flight crew member (FAR61.51(f)).

You cannot file an IFR flight plan or fly in IMC unless a current Instrumented Rated pilot is on board and acts as PIC.

  • 4
    $\begingroup$ Regarding your last sentence, the instrument rated pilot must also be the PIC and not simply on board. $\endgroup$
    – Lnafziger
    Jun 9, 2015 at 20:12
  • 6
    $\begingroup$ It's important to note that the safety pilot permits flight in VMC only while the instrument trainee is under the hood. $\endgroup$
    – egid
    Jun 9, 2015 at 20:53
  • 3
    $\begingroup$ @egid Not if the safety pilot is the PIC and instrument rated/current. $\endgroup$
    – Lnafziger
    Jun 11, 2015 at 19:23
  • $\begingroup$ I actually don't think that's true. Got a link? $\endgroup$
    – egid
    Jun 11, 2015 at 19:24
  • 1
    $\begingroup$ @egid That is not correct. If the instrument rated and current safety pilot acts as PIC and files IFR, both pilot can enter IMC logging PIC time. The safety pilot logs PIC because he is acting as PIC and is a required flight crew member. The IR student logs PIC time for being sole manipulator of control. And yes, anyone can be the sole manipulator of control under part 91 regardless of rating. $\endgroup$
    – fjch1997
    Oct 26, 2018 at 4:41

If you don't want to use an instructor - which is the best and safest way to get those 25 hours - there are only two other ways I can think of to get them: use a safety pilot; or use time logged under another instrument rating.

14 CFR 91.109 explains the safety pilot requirements:

(c) No person may operate a civil aircraft in simulated instrument flight unless—

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown. [...]

Note that if you use a safety pilot you have to log his/her name per 61.51 and - contrary to somewhat popular belief - the safety pilot does require a current medical (at least according to AOPA's lawyers).

The second way would be if you already have or had an instrument rating, probably a foreign one. In that case, the time logged under your foreign privileges is acceptable to the FAA for ratings purposes (see this question).

Note that your instructor will not sign you off for solo instrument flight after 15 hours. There is no instrument rating equivalent of the private solo endorsement: you can only fly under IFR (or below VFR minimums) after you pass the IR checkride. Even if you use an instrument rated 'safety pilot' in IMC then he must be acting PIC because you have no instrument rating. If you try to get around those rules you'll either kill yourself or be operating illegally.

  • $\begingroup$ Can the safety pilot use BasicMed? $\endgroup$
    – Someone
    Apr 2, 2023 at 14:39

Here are the requirements for simulated instrument flight with a safety pilot, taken from 91.109. They only need a private certificate, along with the appropriate ratings in that category and class, but not instrument.

14 CFR 91.109:

c) No person may operate a civil aircraft in simulated instrument flight unless—

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and

(3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single-engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when—

(i) The safety pilot has determined that the flight can be conducted safely; and

(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.


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