Are there any other implications for flying Complex Airplane (getting endorsements, etc.) now that the CFI and Commercial Pilot Practical tests no longer require the applicant to provide a Complex Airplane for the exam (As of April 24, 2018)?

The official FAA Notice says

There is no change to the complex airplane training and endorsement requirements of § 61.31(e) or to the commercial pilot aeronautical experience requirements of § 61.129(a)(3)(ii) or part 141 appendix D.

So the requirements haven't changed but how about becoming an authorized instructor in a complex airplane now that you could technically become an instructor without ever flying in a complex airplane?

Even though I am supportive of this change, a fundamental change like this usually means there are some unforeseen circumstances, and I'm wondering if there are any far-reaching changes that aren't immediately obvious.

  • 2
    $\begingroup$ It doesn't say you don't have to fly one, just that you don't need to use one for the exam. It doesn't change any of the experience requirements. $\endgroup$
    – Ron Beyer
    Commented May 13, 2018 at 16:57

1 Answer 1


First, as Ron pointed out (and as the FAA Notice you quoted says), you still need 10 hours complex (or turbine) training time for a commercial single-engine certificate. The only change is that you no longer need to do the checkride in a complex aircraft.

Your main question seems to be if it will eventually be possible to instruct in a complex aircraft without having any complex experience. That could indeed happen if the FAA ever implements a proposal to allow Technically Advanced Aircraft (TAA) time as an alternative to complex time for commercial single-engine. Then you could fly a Cirrus (or another fixed-gear TAA) instead of something complex and become a CFI with no complex experience. That proposal requires a change to the regulations so it's a bigger deal than just changing the ACS and it hasn't happened yet.

But, it's already the case today that instructors don't need to be endorsed in the aircraft they instruct in: if they aren't acting as PIC then they don't need to be qualified as PIC. (Whether doing that is a good idea or not is another issue.) So instructors without endorsements wouldn't be a new issue at all, although it might become a more important and common one.

However in reality, insurance often determines what an instructor can do, not the FAA. I fly a C182RG, which is a complex aircraft, and the insurance policy specifies the experience requirements for instructors who use it. In a hypothetical future where you can become a CFI with zero complex time, you simply wouldn't meet the insurance requirements to provide instruction in that aircraft. I know insurance isn't mandatory anyway, but for CFIs and other professionals it's often the deciding factor in what they can and can't do.

As for unintended consequences of this change, I have no idea and we can only speculate. For example, complex single-engine aircraft prices may fall as flight schools sell them off.

  • $\begingroup$ Thanks for your answer, I know SE isn't a place to speculate, so my question was really, more "what impact am I not seeing," which as you pointed out, you still need 10 hours of complex time for Commercial, so perhaps they won't be selling off their complex single-engine airplanes after all. $\endgroup$
    – Canuk
    Commented May 14, 2018 at 17:28
  • $\begingroup$ @Canuk There's no requirement to do your complex training in a single-engine aircraft; the big schools can now have students do CMEL first and then add CSEL using whatever basic trainer they use for private/instrument. There's been a lot of discussion on AOPA and Reddit about how ERAU and others are pushing this (and the TAA thing) hard for economic reasons. No one (?) is making complex singles anymore and it's becoming difficult to find and maintain them. That also means it's slowly becoming less and less likely that commercial pilots will ever fly them professionally. $\endgroup$
    – Pondlife
    Commented May 14, 2018 at 19:04
  • $\begingroup$ Good point. Because the complex singles being made are turboprops (TBM, Pilatus) which would require a type rating anyway? I guess it's the guys who aren't interested in getting their MEL but want to become instructors that might have a hard time getting their CPL without access to a complex airplane for those 10 hours. This is what I was looking for: even though you don't need to produce a complex airplane for the test, FAR 61.129 law.cornell.edu/cfr/text/14/61.129 still requires 10 hours of complex aircraft experience for the certificate. $\endgroup$
    – Canuk
    Commented May 15, 2018 at 18:18
  • $\begingroup$ @Canuk To be completely correct, 61.129 requires 10 hours training in a complex or turbine aircraft. With this change, you could do the training hours in a Cessna Caravan (no type rating required, by the way) then take the checkride in a 172 and you'd have a commercial single-engine certificate with zero complex time. But that's not a very economical way to do it, at least for most people! $\endgroup$
    – Pondlife
    Commented May 15, 2018 at 21:31
  • $\begingroup$ To add to Pondlife's answer, the main economic reason driving this change is the high cost of insurance for single engine complex airplanes. People forget to put the landing gear down or it fails to come down and the airplane gets totaled in a gear up landing. The insurance companies consider complex airplanes more of a risk. $\endgroup$
    – DLH
    Commented May 16, 2018 at 16:22

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