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https://www.ecfr.gov/cgi-bin/retrieveECFR?gp&n=14y2.0.1.1.2&r=PART#se14.2.61_1183

The or below is very confusing. Doesn't it mean I need an Instrument rating or one of the things that follows it in the list? Or means one or the other, not both. Furthermore, when would one of the things that follows in the list NOT apply?

(2) An instrument rating, or privileges on that person's pilot certificate that are appropriate to the flight instructor rating sought, if applying for—

(i) A flight instructor certificate with an airplane category and single-engine class rating;

(ii) A flight instructor certificate with an airplane category and multiengine class rating;

(iii) A flight instructor certificate with a powered-lift rating; or

(iv) A flight instructor certificate with an instrument rating.

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    $\begingroup$ It is so unfortunate that the US gov / FAA can't author clear regulations. Decades go by where this remains confusing, see below, some think yes, others think no. If I have an instrument rating, it implies I have one of the other things it lists. So, statong "An instrument rating, or" here adds nothing but confusion unless it IS required. But if it IS required it should state AND not OR $\endgroup$ – chup Dec 10 '19 at 14:04
  • $\begingroup$ I see what you mean. Everyone is convinced he's right, even though there are opposing opinions. It wouldn't be the US gov't if it was clear and obvious... $\endgroup$ – FreeMan Dec 10 '19 at 16:09
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For most people, the answer is yes—you need an instrument rating to be a CFI or CFII for the categories that are listed.

It is possible to become an ATP by using military experience. In that specific case a person has instrument privileges but may not have an instrument rating.

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  • $\begingroup$ Why do you believe that you need an ATP to be a CFI? $\endgroup$ – Ron Beyer Dec 10 '19 at 2:26
  • $\begingroup$ @RonBeyer You don’t need an ATP to be a CFI but if you have an ATP you meet the instrument requirement for CFI. As far as I know, the only way to become an ATP without having an instrument rating is to get an ATP based on military experience. $\endgroup$ – JScarry Dec 10 '19 at 3:11
  • $\begingroup$ Right, so I'm not sure why you are talking about ATP at all? You don't need it to be a CFI, and you don't need an instrument rating to be a CFI either... You need one for ATP, but not all CFI's are on an ATP-track. $\endgroup$ – Ron Beyer Dec 10 '19 at 3:23
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    $\begingroup$ @RonBeyer For most people, to become a CFI in the categories listed in the question, you must have an instrument rating. The only exception that I know of is if you got your ATP through military experience and thereby skipped the normal CFI progression. $\endgroup$ – JScarry Dec 10 '19 at 3:42
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    $\begingroup$ @RonBeyer ATPL doesn't have an instrument rating per se; the confusing word in the CFI regs quoted is to account for the fact that ATPLs still have instrument privileges. But the only way to get an ATPL without first getting an instrument rating is via the military. $\endgroup$ – StephenS Dec 10 '19 at 15:44
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What they mean by that is if you hold an ATP - AIRPLANE SINGLE ENGINE, OR AIRPLANE MULTI-ENGINE, these certificates do not have instrument ratings associated with them, though you may serve as PIC on an IFR flight with an ATP ASE/AME. (you must hold an CPL ASEL/AMEL with an IA rating to apply for an ATP ASE/AME Certificate). So you may apply for a flight instructor certificate if you have an ATPL only.

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A CFI is required to have an instrument rating on their pilot certificate. On the bottom of each FAR is citations pointing to the background and revisions of that regulation.

Here is the quote from 62 FR 16298

In proposed paragraph (c), the FAA added requirements for an applicant for a flight instructor certificate with a helicopter, airship, or powered-lift rating to hold an instrument rating. This was in addition to the existing requirement, which only specified that an applicant for a flight instructor certificate with an airplane or instrument rating hold an instrument rating on his or her pilot certificate.


The website ecfr.gov shows the reference as 62 FR 16220 but Cornell Law Website shows it as 62 FR 16298. I don't know why the ECFR website is incorrect.


From 62 FR 40907

The FAA has clarified the eligibility requirement contained in paragraph (c)(2) for persons seeking a flight instructor certificate. Under new paragraph (c)(2), an applicant is required to hold either a commercial pilot certificate with an instrument rating or an ATP certificate with instrument privileges on that applicant’s pilot certificate that is appropriate to the flight instructor rating sought. The word ‘‘privileges’’ refers to the instrument privileges held by airline transport pilots.

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  • $\begingroup$ This docket is from 1997. How do we know there were other secret dockets published elsewhere? The regs are the regs. They are on ecfr.gov. If something needs clarification, it should be updated in the regs, not secret pdfs from decades ago $\endgroup$ – chup Dec 10 '19 at 14:06
  • $\begingroup$ Those dockets are the preamble to the regs. It let's us know what the FAA was thinking as well as the industry through comments received by the FAA. On the bottom of each reg it shows you where to find the preambles. The regs were updated in 1997. Tbat preamble is still valid today. $\endgroup$ – wbeard52 Dec 10 '19 at 14:21
  • $\begingroup$ I like this answer, but the doc is so old and the wording is so different, I can't accept it. I have no way of knowing the 1997 doc is legit, or that there's not some newer doc floating around. Thanks. $\endgroup$ – chup Apr 16 '20 at 13:39
  • $\begingroup$ You can search for the FR codes listed on the bottom of the regulation. They are the research notes for the finished product. I agree it should be plain language but the finished legalese is there for a purpose. $\endgroup$ – wbeard52 Apr 16 '20 at 15:32
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You do not need an instrument rating to become a Certified Flight Instructor, as the regulations you quoted state. You just have to be rated for the type in which you are instructing.

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