Is there anything in the FARs that would prohibit a commercial pilot from doing multiple trips to ferry friends to an event in his/her personal aircraft assuming that the friends did not provide any compensation?

  • $\begingroup$ When you say "no compensation" do you mean that the pilot pays all the costs? $\endgroup$ Aug 24, 2016 at 4:09

3 Answers 3


If there is no compensation, even a private pilot can do this as much as they want. If the PIC is paying all expenses, they are not receiving anything of value from anyone except themselves.

"Logging hours is compensation" is true in the sense that it can be considered to be a form of compensation when the pilot is not paying all operating costs.

Note that compensation is not necessarily cash. The FAA interprets compensation very broadly. For instance, you may be in violation if you give flights to business partners with the reasonable expectation that you will receive more business from them in the future. This isn't a problem if you're flying friends, though.

  • $\begingroup$ compensation of any kind is irrelevant for the FAA here as the pilot has a CPL. Whether the IRS wants to have a word is another matter entirely. $\endgroup$
    – jwenting
    Oct 21, 2023 at 8:44
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    $\begingroup$ @jwenting A commercial pilot is forbidden from receiving compensation for carrying passengers under most circumstances unless they are operating under an air carrier certificate. $\endgroup$
    – Chris
    Oct 21, 2023 at 14:51

According to this interpretation that seems to match your scenario very closely, as long as you're also attending the event then a single trip is fine but multiple trips are not. And you would be acting as a private pilot, not a commercial pilot.

The interpretation was about an ATP who ferried fellow club members to an event (in nine flights!) and did receive money to cover costs, but the main points would apply to a CPL in your scenario too. In summary:

  • Flight time is compensation, therefore you're being compensated for the flights even if no money changes hands (the ATP argued that flight time in a C172 was worthless to him, but the FAA said they don't analyze individual cases)
  • Acting as a private pilot you can receive compensation only if a "bona fide common purpose" exists
    • If you aren't attending the event yourself, there's no common purpose
    • If you are attending the event, only the first flights there and back have a common purpose; subsequent flights to bring more people to the event do not
  • Acting as a commercial pilot you can receive compensation for transporting people only if you have an air carrier certificate (per 14 CFR 119.1)

You didn't give many details about your scenario, but if you're attending the event yourself then you should be fine for one flight each way under your private privileges. Any more than that and there's no common purpose.

Of course, the caveat here is that every situation is different and perhaps there's something about your case that would result in a different FAA interpretation. However, the basic points about compensation and common purpose are very consistent across interpretations.

(Apologies for not quoting the interpretation directly, but the FAA seems determined to make it as difficult as possible to copy and paste from their documents.)

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    $\begingroup$ I'd really like to see some evidence that this interpretation would be the same if there was no compensation. 'Common purpose' is applicable only if there is compensation, and the air carrier certificate applies only if there is compensation. $\endgroup$ Aug 23, 2016 at 17:26
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    $\begingroup$ Are the passengers paying any of the costs? If there was I understand the issue. If not then where is the compensatiion? The pilot us receiving no compensation even in the form if flight time. $\endgroup$ Aug 24, 2016 at 3:21
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    $\begingroup$ I'm with DJClayworth on this. And even if I weren't, the pilot is not under obligation to actually log his hours, thus removing that "flight time in itself is compensation" argument. $\endgroup$
    – Steve H
    Aug 24, 2016 at 13:33
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    $\begingroup$ Too complex a discussion for comments. I still disagree and my downvote stands. If there has been a judgement or case where a pilot has paid all expenses and still been ruled to be carrying passengers illegally I'd be interested to see it edited into the answer.(The example you give specifically talks about 'shared expenses') $\endgroup$ Aug 24, 2016 at 15:02
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    $\begingroup$ Flight time is only compensation if somebody else pays for it. (or helps you pay for it) If you are buying flight time, it isn't compensation. Otherwise it would be illegal for any private pilot to ever fly! $\endgroup$ Aug 10, 2022 at 0:13

Citing this similar case, if the pilot shares a common purpose with the friends, there seems to be no issue if it is one flight.

Assuming, however, that the pilot planned to attend the race and conducted the flights with this purpose, his bona fide common purpose with his passengers for making the trip would only extend to the first flight to the race site.

If in doubt, as such matters confuse many commercial and airline transport pilots, contact the local FSDO for their interpretation of the intended operation.

Plane type, weight, and passenger capacity also play a role in the legality of the matter. Even if no money changes hands, certain scenarios require an air carrier / commercial operator license.

Is logging hours a compensation? Yes.

The FAA has consistently construed compensation broadly. Compensation "does not require a profit, a profit motive, or the actual payment of funds." Legal Interpretation to Joseph Kirwan (May 27,2005). Rather, compensation is the receipt of anything of value. The FAA has previously found that reimbursement of expenses (fuel, oil, transportation, lodging, meals, etc.), accumulation of flight time, and goodwill in the form of expected future economic benefit could be considered compensation. Legal Interpretation to John W. Harrington (Oct. 23, 1997); Blakey v. Murray, NTSB Order No. EA-5061 (Oct. 28, 2003).—Hancock - (2013)

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    $\begingroup$ I'm not sure why you say there's "no issue"; the interpretation seems fairly clear that multiple trips wouldn't be acceptable. $\endgroup$
    – Pondlife
    Aug 22, 2016 at 1:55
  • $\begingroup$ This cites a case in which there is compensation. I'd like to see evidence that would not change the situation. $\endgroup$ Aug 23, 2016 at 17:27
  • $\begingroup$ @DJClayworth You seem not to be aware that the FAA consistently defines compensation very broadly indeed, and they mention that in every interpretation where it comes up. One of them (the Kirwan interpretation) defines it as "receipt of anything of value"! That can include fuel, food, hospitality, flight time, future goodwill etc. at the FAA's discretion. In practice, it gives the FAA a tool to deal with people abusing the system, not people flying friends for lunch, but as with any regulation there will always be questions about where the boundaries lie. $\endgroup$
    – Pondlife
    Aug 23, 2016 at 18:01
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    $\begingroup$ Are you claiming that flight time is considered illegal compensation even if the pilot pays all expenses? That would seem to imply that a pilot is illegally being compensated even if he is carrying no passengers. $\endgroup$ Aug 24, 2016 at 13:26
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    $\begingroup$ Let us continue this discussion in chat. $\endgroup$ Aug 24, 2016 at 16:24

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