According to 14 CFR § 91.409 - Inspections:

(b) Except as provided in paragraph (c) of this section, no person may operate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides, unless within the preceding 100 hours of time in service the aircraft has received an annual or 100-hour inspection ...

It seems to me that:

  1. By renting out my aircraft, I am not operating it for hire.
  2. The aircraft is not carrying any person other than a crewmember.

Am I wrong about both of these, or is it legal to rent out aircraft without 100hr inspections?

  • $\begingroup$ Don't forget some Commercial insurance - unless you are adding each renter as named pilot on your policy and the pilot meets the minimum requirements for your insurance? $\endgroup$
    – CrossRoads
    Commented Mar 5, 2019 at 2:18
  • $\begingroup$ @CrossRoads: Couldn't I just request they have renter's insurance? $\endgroup$
    – Zaz
    Commented Mar 6, 2019 at 12:36
  • $\begingroup$ I don't know. I suggest you call your insurance provider and discuss. $\endgroup$
    – CrossRoads
    Commented Mar 6, 2019 at 13:47
  • $\begingroup$ Renter's insurance will protect the renter, not you. It may pay for damage the renter caused to the plane and any liability on their part, but it won't protect you from a liability claim. The renter or their estate or a third party may come after you if the accident is caused by poor maintenance or other cause attributable to you. You need insurance to cover you when renting your plane. Talk to you insurer. $\endgroup$
    – Gerry
    Commented Apr 23, 2022 at 16:10

1 Answer 1


The FAA provides an answer in this Letter Of Interpretation. In this case they discuss it in the context of a company owned aircraft but they tend to care more about how its operated than who owns it.

For instance, if Fly By Knight is going to operate the aircraft to provide flight instruction for hire, then the aircraft must have had an annual or 100-hour maintenance inspection within the preceding 100 hours of time in service. If Fly By Knight is going to rent the aircraft to a customer, however, and does not provide the pilot, that aircraft need not have an annual or 100-hour maintenance inspection within the preceding 100 hours of time in service. See Legal Interpretation, Letter to Berry Rackers from Joseph Brennan, Associate Regional Counsel (May 3, 1984).


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