I completed my IFR checkride on the 15th of May this year, the next day I moved to Spain to study my EASA ATPL (airline transport pilot license).

A friend of mine here in Spain is doing his time building and I am allowed to sit in the right seat with him. Would I be allowed to log my approaches (66HIT) from the right seat even though I don't have an EASA PPL and the aircraft is registered in Spain?

I ask because that would save me the cost of paying for an instructor and a checkout flight as well as the hassle of flying alone in airspace which is completely new to me!


1 Answer 1


In my opinion, no.

§61.51(g) states that one must log instrument time to meet the instrument experience requirements of §61.57(c), and defines instrument time as "that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions."

§1.1 defines flight time as "Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing."

All of the types of "pilot time" that can be logged are described in §61.51. Since you are not rated to act as PIC or SIC, none of them apply to you (unless your friend is an authorized instructor, anyway).

Essentially, from a legal standpoint you are a passenger, not a pilot. Therefore your time in the plane is not "pilot time," and it follows that it is not "instrument time" either. So you cannot log anything to meet the currency requirements.

  • $\begingroup$ Non of what you quoted says anything about aircraft registration. $\endgroup$ May 23, 2023 at 14:18
  • $\begingroup$ @MichaelHall The FAA only has the authority to authorize a pilot to act as PIC or SIC in US-registered civil aircraft or that is flown within the NAS. By implication, I don't see how OP can be considered to be rated in an aircraft of Spanish registry or acting as a pilot in one. $\endgroup$
    – Chris
    May 23, 2023 at 17:58
  • $\begingroup$ If EASA recognizes his FAA certification does that change the answer? $\endgroup$ May 23, 2023 at 18:37
  • $\begingroup$ @MichaelHall Yes, I think so. $\endgroup$
    – Chris
    May 23, 2023 at 18:39

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