In the US the FAA requires student pilots to receive at least 3hrs of instrument flight training.

Can a flight instructor that does not hold an instrument rating legally provide a private pilot student the 3hrs of instrument training?

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    $\begingroup$ Don't all CFIs have an instrument rating? Perhaps you are referring to a CFII? $\endgroup$
    – Mike Brass
    Commented Aug 26, 2018 at 9:04
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    $\begingroup$ No they do not... $\endgroup$
    – jwzumwalt
    Commented Aug 26, 2018 at 9:17
  • $\begingroup$ According to 61.183, they do. Except for a sport pilot instructor. $\endgroup$
    – Mike Brass
    Commented Aug 26, 2018 at 9:34
  • $\begingroup$ That's only if applying for... "(iv) A flight instructor certificate with an instrument rating." This question is for a flight instructor that has not applied for or received a instrument rating. $\endgroup$
    – jwzumwalt
    Commented Aug 26, 2018 at 9:37
  • $\begingroup$ @MikeBrass No, not all airplane instructors have an instrument rating, but having an instrument rating is currently a prerequisite to apply for a flight instructor airplane certificate. Back in the 90's the rule changed to make it a prerequisite, so it is possible that some old-timer is out there somewhere who is a CFI and is grandfathered in under the old rule with no instrument rating on his pilot certificate (much less his instructor certificate). $\endgroup$ Commented Sep 22, 2019 at 19:50

2 Answers 2


Long story short, a CFI without an instrument rating can provide training on the instrument flying required for a private certificate only. To provide instruction on the use of instruments for an instrument rating, a commercial certificate or an ATP certificate, the CFI must have an instrument rating.

You can read all the details in the Grayson (2010) legal interpretation and the FAA apparently revised 61.195 in 2009 to make this whole topic 'clearer':

§61.195 Flight instructor limitations and qualifications.

A person who holds a flight instructor certificate is subject to the following limitations:


(c) Instrument rating. A flight instructor may conduct instrument training for the issuance of an instrument rating, a type rating not limited to VFR, or the instrument training required for commercial pilot and airline transport pilot certificates if the following requirements are met:

(1) Except as provided in paragraph (c)(2) of this section, the flight instructor must hold an instrument rating appropriate to the aircraft used for the instrument training on his or her flight instructor certificate [...]

As the interpretation explains, the instrument training requirements for a private certificate are very general (61.107 and 61.109): "basic instrument maneuvers", " control and maneuvering of an airplane solely by reference to instruments". But the commercial and ATP requirements are much more specific (this is from 61.129): "attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems". For that reason, CFIs who provide instruction for the private requirements only do not need an instrument rating.

Practically speaking, I've never met a CFI who didn't have an instrument rating. I'm guessing that a CFI without one would have limited value for employers and might even have issues with insurance.

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    $\begingroup$ The relevant part is “instrument rating appropriate… on his or her flight instructor certificate”. You can’t get an CFI without a commercial and instrument rating. So in order to give loggable instruction in a multi-engine plane, you must have your CFII and MEI. Single engine—CFII. $\endgroup$
    – JScarry
    Commented Aug 27, 2018 at 2:28
  • $\begingroup$ @JScarry would find it very strange if I found my IR instructor didn't have an IR himself... $\endgroup$
    – jwenting
    Commented Aug 27, 2018 at 5:57
  • $\begingroup$ @Pondlife - Thanks for the reference. I knew the correct answer but could not remember or find what or where the issue was that caused it to be clarified or updated. It makes sense that a CFI can give all appropriate training for a PPL. $\endgroup$
    – jwzumwalt
    Commented Aug 27, 2018 at 11:06
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    $\begingroup$ Some of these rules have changed historically. I believe that there didn't used to be a requirement for a instrument to get a CFI, and those "old-timers" can continue to instruct. I know someone who got his CFI at 17 years old, but could not get a commercial yet. At the time the FAA wasn't really sure what to do with him and he turned 18 and got his commercial before it was all worked out...Since then the regs have change to require a commercial, and he claims that this was his fault. $\endgroup$
    – Adam
    Commented Aug 27, 2018 at 13:13
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    $\begingroup$ It's what @Pondlife says -- the regs changed. When I got my CFI around 1990 you could get a CFI without an IR, though it wasn't very practical and I guess the FAA thought so also. $\endgroup$
    – user34035
    Commented Aug 30, 2018 at 10:52

Helicopter CFIs are not required to have an Instrument Rating. They may also provide training for the Commercial Helicopter rating (it,and the Pvt Airplane training; is not 'instrument training' as defined by the FAA Legal Dept. Pvt helicopter pilots are not required to have training on instrument control.

  • $\begingroup$ You may add sources and links, possibly restricting this answer to some jurisdictions. $\endgroup$
    – Manu H
    Commented Sep 22, 2019 at 13:21

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