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I am an FAA PPL/IR holder living in Spain.

My IR license was issued in May 13 of 2016, it has been over 6 months so now I need to log my 6HIT with a safety pilot.

Is it possible to complete the currency requirements in a simulator even though I have gone past the 6 month mark without flying? Is it possible to complete the currency requirements in the EU with an instructor?

Thanks for any help, my flight school is being really unhelpful as they seem to actually know far less than I do about FAA regulations, this is my last hope!

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    $\begingroup$ "This is my last hope" - I would have thought contacting the FAA directly and asking them would be a suitable option.. $\endgroup$ – Ben Mar 14 '17 at 23:23
  • $\begingroup$ In addition to contacting your home FSO, if your stay was going to be extended, while you were current, you might have been able to convert your license to the local equivalent through IACO. $\endgroup$ – Rowan Hawkins Apr 7 '17 at 5:28
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The easiest option is to find a US CFI/AI holder in the country you are in, to sign off on your approaches. It might be allot easier if s/he is also a Spanish CFI particularly if you are flying in a Spanish registered aircraft. You do not indicate if you hold a certificate from Spain.

It is not uncommon to find instructors with US FAA CFI ratings in other countries.

There is no prohibition of a US CFI giving instruction in another country. There may be of a given country, or operational limitations imposed by aircraft registration, host country operating rules, and insurance limitations, as well as owner / lease limitations.

However, I routinely sign off US pilots for approaches made at Canadian airports, in fulfillment of their US instrument recency requirements.

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CFR 14 §61.57 Recent flight experience: Pilot in command. 2 allows you to use an ATD for instrument currency.

The FAA has an Advisory Circular that describes the requirements for approving an ATD. AC 61-136A Aviation Training Devices. If you know the type of device, you can go to the manufacturers website and find out if they comply with the AC.

I’ve been using a device by http://www.flythissim.com at the local flight school and can log time on it. I can’t use my home sim that uses the same software because it doesn’t conform to the AC.

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  • $\begingroup$ I understand that I can keep it current up to 6 months, but i havent been able to find a sentence in that document which states that i can do the currency after 6 months in a simulator, because in a plane that would require a safety pilot. $\endgroup$ – gaveasky Mar 14 '17 at 16:46
  • $\begingroup$ "(2) Use of a flight simulator or flight training device for maintaining instrument experience. Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in a flight simulator or flight training device,…" Not sure what isn’t clear about this. $\endgroup$ – JScarry Mar 14 '17 at 18:28
  • $\begingroup$ @JScarry The "within the 6 months" part doesn't apply to the OP's situation as they are outside that period. They need to take a proficiency flight, the ATD is for staying current, not getting current. $\endgroup$ – Ron Beyer Mar 14 '17 at 19:53
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    $\begingroup$ @RonBeyer He is within the 1 year time period before he requires an IPC, so there is no difference between flying with a safety pilot and using an ATD. The only thing he can’t do is fly alone in IMC. $\endgroup$ – JScarry Mar 14 '17 at 20:25
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Yes. You can accomplish your instrument experience in a flight simulator, flight training device or advanced training device (ATD).

An authorized instructor with FAA certificates and appropriate ratings must be present for you to log and count the instrument time for recency of experience purposes.

The only reason to accomplish instrument experience is to satisfy the recency of experience requirements in §61.57. This experience has to be logged according to §61.51.


There are two separate types of recency of experience listed in §61.57(c): maintaining instrument experience 61.57(c)(1), (2) and (3) and to regain instrument privileges after it has lapsed for more than six calendar months. §61.57(d) lists out what is required to regain instrument privileges.

§61.57(c) Instrument Experience

(1) Use of an airplane, powered-lift, helicopter, or airship for maintaining instrument experience

(2) Use of a flight simulator or flight training device for maintaining instrument experience.

(3) Use of an aviation training device for maintaining instrument experience.

(4) Combination of completing instrument experience in an aircraft and a flight simulator, flight training device, and aviation training device.

(5) Combination of completing instrument experience in a flight simulator or flight training device, and an aviation training device.

(6) Maintaining instrument recent experience in a glider.

Each of these has its own requirements to maintain instrument experience. If you are still current you are allowed to keep yourself current using one of the methods listed above.


§61.57(d) - Instrument Proficiency Check

A person who has failed to meet the instrument experience requirements of paragraph (c) for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check

(1) The instrument proficiency check must be—

(i) In an aircraft that is appropriate to the aircraft category;

(ii) For other than a glider, in a flight simulator or flight training device that is representative of the aircraft category; or

(iii) For a glider, in a single-engine airplane or a glider.

If a pilot lapses with their instrument currency for more than six calendar months, they must complete an IPC check. If they are in months 7-12 (or 3-8 for ATD in #3) they can complete the previous requirement laid in in §61.57(c).

The IPC must be completed in an aircraft, flight simulator or flight training device. An ATD is not allowable for an IPC check.


§61.51 Pilot Logbooks

(g) Logging instrument time.

(1) A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.

(2) An authorized instructor may log instrument time when conducting instrument flight instruction in actual instrument flight conditions.

(3) For the purposes of logging instrument time to meet the recent instrument experience requirements of §61.57(c) of this part, the following information must be recorded in the person's logbook—

(i) The location and type of each instrument approach accomplished; and

(ii) The name of the safety pilot, if required.

(4) A person can use time in a flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate, rating, or instrument recency experience, provided an authorized instructor is present to observe that time and signs the person's logbook or training record to verify the time and the content of the training session.

61.1. Definitions

Authorized instructor means—

(i) A person who holds a ground instructor certificate issued under part 61 of this chapter and is in compliance with §61.217, when conducting ground training in accordance with the privileges and limitations of his or her ground instructor certificate;

(ii) A person who holds a flight instructor certificate issued under part 61 of this chapter and is in compliance with §61.197, when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate; or

(iii) A person authorized by the Administrator to provide ground training or flight training under part 61, 121, 135, or 142 of this chapter when conducting ground training or flight training in accordance with that authority.

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  • $\begingroup$ I'm not sure that this applies to the OP, 61.51 is about logging time, not about getting current (the OP is outside the 6 month currency required by 61.57). You can accomplish some of your instrument experience in an authorized ATD, but not all of it. You can use an ATD to stay current, but I don't believe you can use an ATD to regain currency after it has expired... $\endgroup$ – Ron Beyer Mar 14 '17 at 19:56
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    $\begingroup$ @RonBeyer. How can you prove you are current unless you log it? You can use a ATD to stay current or get current with an authorized instructor. $\endgroup$ – wbeard52 Mar 14 '17 at 21:37
  • $\begingroup$ Is a CFI in Spain going to count as an authorized instructor? $\endgroup$ – TomMcW Mar 14 '17 at 23:33
  • $\begingroup$ @TomMcW If they have a current and valid US FAA CFI license with appropriate certificates and ratings, they are an approved instructor. $\endgroup$ – wbeard52 Mar 15 '17 at 0:25
  • $\begingroup$ Does that mean he would have to find an FAA licensed instructor in Spain to monitor the sim time? $\endgroup$ – TomMcW Mar 15 '17 at 0:58

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