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For an IFR currency flight in a high-performance and/or complex airplane where the pilot flying has all the appropriate ratings and endorsements to be PIC, does another pilot with strictly a private ASEL certificate meet the legal requirements to be the safety pilot?

If so, I would assume the entire flight must be conducted in VMC. What other constraints or restrictions apply in such a scenario?

If permissible, how may the safety pilot log the flight so as to count toward future ratings and so on?

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First, can a pilot without an HP endorsement act as safety pilot in an HP aircraft? Since 14 CFR 91.109 only requires a safety pilot to have category and class ratings, there's no need to have any additional endorsements.

That's confirmed in this FAA legal interpretation:

there is no regulatory requirement that a safety pilot have a high performance endorsement to act as safety pilot

The same document says that safety pilots are "encouraged to be thoroughly familiar and current in the aircraft that is used" - which is great advice - but that's it.

As for the flight conditions (IMC/VMC) and rules (IFR/VFR), I'm not sure what you're asking. Is either pilot IFR current? If not, then the flight can only be VFR. This question might be relevant.

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  • $\begingroup$ What about a complex endorsement for the safety pilot? I assume the PIC is current, instrument rated, endorsed out the wazoo. To simplify, the safety pilot has 42 hours total time and just passed a PVT-ASEL checkride yesterday. $\endgroup$
    – Greg Bacon
    Commented Apr 5, 2016 at 20:31
  • $\begingroup$ just rated. and that includes a type rating if required $\endgroup$
    – rbp
    Commented Apr 5, 2016 at 21:10
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61.31 requires these endorsements for the legal pilot in command only. If the safety pilot is not the legal pilot in command the endorsements are not required.

The only requirement is for the safety pilot to be appropriately rated and have a current medical. See 91.109

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    $\begingroup$ I understand the rule, but don't understand the intent. How can the safety pilot be "safe" if he/she is not IFR rated, doesn't know what to look for, and cannot take over if needed? $\endgroup$
    – abelenky
    Commented Apr 5, 2016 at 19:39
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    $\begingroup$ @abelenky IF the actual PIC is the flying pilot (not the safety pilot), then the safety pilot's sole "job" is to be there to watch for conflicting traffic since the actual PIC is unable to do so when under the hood. He doesn't need to know the IFR rules, have an instrument rating, etc. because he isn't the PIC and isn't responsible for the safe outcome of the flight. The actual PIC is. $\endgroup$
    – Lnafziger
    Commented Apr 5, 2016 at 20:01
  • $\begingroup$ Nowhere in 91.109 does it say the safety pilot needs a current medical. Please correct me if I am missing it. $\endgroup$
    – Ryan Mortensen
    Commented Jun 8, 2019 at 5:44
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    $\begingroup$ @RyanMortensen I'm not sure what you're asking, which I'm sure is my fault :-) The FAA's FAQ seems to cover this? $\endgroup$
    – Pondlife
    Commented Jun 15, 2019 at 4:39
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    $\begingroup$ @RyanMortensen That's what I thought but I wasn't sure :-) $\endgroup$
    – Pondlife
    Commented Jun 15, 2019 at 17:58

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