Per 14 CFR 61.129, a person who applies for a commercial pilot certificate for airplanes (both single and multiengine) must log at least ten hours of instrument training.

Assuming a pilot obtains their instrument rating prior to training for their commercial pilot certificate, can the instrument time logged during training for an instrument rating be used to satisfy this requirement (assuming class of aircraft requirements are met)?


5 Answers 5


Short answer: yes, if the training has been logged with the remark that it meets the requirements of both 61.129 and 61.65.

This topic became confusing because of an FAA interpretation that says:

[...] are the requirements of 14 C.F.R. §61.129(c)(3)(i) [commercial certificate] met by the student getting an instrument rating or training for an instrument rating? The answer is no. The training giving to satisfy the instrument training aeronautical experience of §61.129(c)(3)(i) may also be used to count towards the aeronautical experience of §61.65(e) [instrument rating], but the opposite is not true. The reason for this is that the training required under §61.65(e) is general, while the training under §61.129(c)(3)(i) lists very specific operations that must be accomplished to satisfy the requirements.

But that interpretation was surprising to many people because it implied that a commercial certificate requires additional instrument training, even if you already hold an instrument rating. So AOPA requested a clarification (more information here); you can read the whole thing, but the key statement from the FAA is this:

We are merely clarifying the requirement that the applicant for a commercial pilot certificate provide evidence that they have met the requirements of §61.129. There is not an exact equivalence between the training required for an instrument rating under §61.65 and the aeronautical experience requirements under §61.129.

Practically speaking (as the AOPA article explains) that means that your CFII should explicitly log the training as covering both requirements:

[AOPA] urges instrument pilot applicants and flight instructors to be sure that instrument training is clearly logged to indicate that the training given meets the requirements of 14 CFR 61.65 as well as those of 14 CFR 61.129. That would avoid questions about the training’s applicability should the pilot one day advance to training for a commercial pilot certificate.


Yes, your instrument training conducted during your IFR certificate will count towards a Commercial certificate.

This is based on the assumption that your flights have been logged by a current CFII.

There may be additional IFR related training that pertains to CPL such as meeting certain requirements as set out by the Practical Tests Standards booklet (PTS).

  • $\begingroup$ Airmen Certification Standards (ACS) is replacing PTS. IMO the primary change is the explicit addition of risk management. $\endgroup$
    – mongo
    Apr 18, 2017 at 7:32

Yes, and the acid test is what the examiner (DPE) considers acceptable. So as a CFI, what I do, if there is any doubt, is to create a summary of the requirements, and reference the date&time for the log entry, so that the DPE can establish that the requirements are satisfied.

CFI initial rides tend to get extreme scrutiny, and I use the same approach there, namely a checklist of the essential requirements for the rating, and the references to show where those requirements were satisfied. The FAA inspectors love it. The DPEs love it. It makes everyone's job easier, and saves hassles.

So as a student, instrument or commercial, I would assemble your list of the rating requirements, and reference the log entries supporting those requirements. Then have your CFI signoff on your worksheet after he reviews your data. Present a copy to your DPE (yep, a copy for his records if he wishes). It will help your checkride start on a good note.

After 37 years, I have never had a student sent home because they did not meet the rating experience requirements.


You absolutely can and just about to everyone applying for a commercial certificate does do that. Aeronautical experience is immediately transferable to an certificate you are seeking, provided it meets the guidelines for aeronautical experience listed in the FAR 61.129 for the specific certificate.

Much of the experience you log early on can be immediately transferable to other certificates, even in other categories or classes of aircraft. For instance a person who holds a commercial certificate in an airplane single engine land could apply for a commercial certificate in a rotorcraft helicopter with as little as 50 hours total time in helos; the rest may be transferred from the applicants flight experience in other aircraft.


Yes. However, the CFI must log the training as accomplishing the instrument time for the commercial certificate.

See the Theriault interpretation.

  • 4
    $\begingroup$ That's not what this legal interpretation says. In paragraph three, it says "the training given to satisfy the instrument training aeronautical experience of §61.129(c)(3)(i) [instrument training for commercial pilot] may also be used to count toward the aeronautical experience of §61.65(e) [instrument rating], but the opposite is not true." $\endgroup$
    – newmanth
    Aug 14, 2015 at 14:29
  • $\begingroup$ No. Under the 61.65 aeronautical experience requirements for a commercial certificate, there is no requirement that the trial or simulated instrument time be earmarked for a commercial certificate. $\endgroup$ Apr 17, 2017 at 22:57

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