I’m a US based private pilot building time toward the instrument rating. A CFI flies with me as safety pilot for simulated instrument conditions. They are not a CFII yet. If I fly a XC under the hood and finish with a practice approach in VMC while still under the hood, can I log the approach? I have read through FAA InFO 15012 and the approach meets all of the requirements. I understand if the safety pilot were an appropriately rated private pilot I can log the approach and follow the requirements for logging the safety pilot. Can I log the approach and log “dual received” at the same time with a non-II CFI? If not, given where I’m at in training, would I be better off to log the approach, or log dual received, or does it even matter? For reference, the CFI will have their II soon, I will reach XC and simulated/actual IFR minimum hour requirements, and we will begin dedicated IFR training to meet the requirements of FAR 61.65.

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    $\begingroup$ If you can log an instrument approach under the hood in VFR conditions with a Private Pilot in your right seat, I can see no logical reason why you shouldn't be able to with a CFI in the same seat. And I don't see any language in the InFO link that would refute that. $\endgroup$ Nov 7, 2021 at 18:25
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    $\begingroup$ Welcome to aviation.SE! If I understand correctly, you have a private certificate without an instrument rating. You’re asking if you can log training time in actual IMC with a CFI (not a CFII). Is that correct? And can you clarify what you mean by “logging an approach”? Are you asking if you can log the approach to count towards your instrument rating training as required in 61.65(c) and (d)? $\endgroup$
    – Pondlife
    Nov 7, 2021 at 22:32
  • $\begingroup$ You do not have an instrument rating. There is no reason to log an approach in this situation. I would simply log simulated instrument time and dual given. Since you mentioned a cross country flight, the CFI cannot log XC time if he doesn't sign your logbook as dual given. If he is only acting as a safety pilot, he would not meet the definition of cross country flight. There are legal interpretations issued stipulating such. $\endgroup$
    – wbeard52
    Nov 7, 2021 at 22:44
  • $\begingroup$ @757toga You are reading the FAR incorrectly. Section (2) of that FAR requires the instructor to be a CFII. "(2) Holds an instrument rating appropriate to the aircraft used for the training on his or her flight instructor certificate..." $\endgroup$ Nov 8, 2021 at 23:21
  • $\begingroup$ @757toga Your analysis of the FAR is still incorrect. Nowhere does that section talk about 15 hours of anything. The OP is asking if he can log dual towards an instrument rating when the CFI is not a CFII. He cannot, and the CFI could lose his ticket if he's caught sanctioning such behavior. $\endgroup$ Nov 9, 2021 at 5:02

2 Answers 2


As you have noted, FAR 91.109(c)(1) requires that the Safety Pilot must hold at least a private pilot certificate. The pilot certificate must have category and class ratings that are appropriate to the aircraft being flown. The safety pilot is not required to hold an instrument certificate if the flight is conducted in VFR conditions.

You can log the approach as part of the practice flight requirements, and if you have agreed so with the safety pilot you log is as PIC, but you may not, however, log the flight as "dual received" for the purpose of obtaining an instrument rating unless the Safety Pilot is in fact a CFII. "Soon" will not pass muster if you get your logs audited by the FAA.

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    $\begingroup$ Thank you all for the responses. This clears things up. And to clarify, all flights are in VMC. As wbeard52 states, I will log simulated instrument and dual received. There is no reason to log an approach as I am not instrument rated, and because the instructor is not CFII, it won’t count toward the 15 hours required by FAR 61.65. Again, thank you all for the responses. $\endgroup$ Nov 8, 2021 at 3:54
  • $\begingroup$ Since it won't count towards your 61.65 requirements for instrument training, why log it as dual? Furthermore, it can only be logged as dual if your CFI actually signs it off. Is this non-CFII signing it off? Sounds like this person is just acting as a safety pilot, so I would just log it as if I had a, you know, safety pilot on board. Which means simulated instrument and DO log the approach and just write their name in as safety pilot. Not that you need the approach for currency, but that's the standard accepted way of logging time with a safety pilot. $\endgroup$
    – Dave-CFII
    Nov 8, 2021 at 11:36
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    $\begingroup$ @Dave-CFII 61.65 requires 40 hours of hood/actual, but only 15 must be with a CFII; the other 25 can be with a safety pilot, such as his CFIA friend. $\endgroup$
    – StephenS
    Nov 8, 2021 at 14:25
  • $\begingroup$ @Dave-CFII logging the CFIA time as dual received (and also perhaps notation as Safety Pilot) will not be counted towards the 15 required CFII training hours of course, but since a CFIA can give specific instrument training per 61.195(l) logging it as such properly characterizes the flight time and may also contribute to a future insurance benefit. $\endgroup$
    – user22445
    Nov 8, 2021 at 14:43
  • $\begingroup$ Logging dual received is not legal in this situation unless you are logging it as dual received for something other than an instrument rating. A CFIA can only give instrument dual when they are giving basic instrument instruction for PPL as part of syllabus requirements. Again, you cannot receive dual anything towards an instrument rating from someone who is not a CFII. The only issue is deciding who logs the PIC time, you or the safety pilot, and that has to be agreed before taking off. $\endgroup$ Nov 8, 2021 at 23:14

Your Question (based on the circumstances you provide:) Can you log the Instrument Approach (IAP) and "Dual Received" at the same time?

NOTE: (for this question).

CFIA refers to a CFI who does NOT hold an Instrument-Airplane rating on their Flight Instructor certificate;

CFII refers to a CFI who does hold an Instrument-Airplane rating on their Flight Instructor certificate.

Pertinent U.S. FAR Regulations


FAR 61.65 (d) Aeronautical experience for the instrument-airplane rating. A person who applies for an instrument-airplane rating must have logged:

(2) Forty hours of actual or simulated instrument time in the areas of operation listed in paragraph (c) of this section, of which 15 hours must have been received from an authorized instructor who holds an instrument-airplane rating, and the instrument time includes: (emphasis is mine)

(NOTE: the 15 hours noted above must be dual received from a CFII)


61.195 Flight instructor limitations and qualifications. A person who holds a flight instructor certificate is subject to the following limitations:

(l) Training on control and maneuvering an aircraft solely by reference to the instruments. A flight instructor may conduct flight training on control and maneuvering an airplane solely by reference to the flight instruments, provided the flight instructor -

(1) Holds a flight instructor certificate with the applicable category and class rating; OR (emphasis is mine - note: category is "airplane" and class is "single engine land")

(2) (this is not relevant to your question - note the "OR" in item 1 above)

Answer: (logging the IAPs)- You can log the IAPs that you conduct with a non-CFII, but there are no regulatory benefits in doing so. Since you are not instrument rated you have no currency requirements to meet. Also, since you are not training with a CFII the flight proficiency requirements specified under 61.65 (c) (6)- training in "Instrument Approach Procedures" cannot be satisfied. But you may want to log the IAPs for your personal reference.

Answer: (logging Dual Received)- FAR 61.65(d)(2) requires at least 15 hours of flight training (dual received) from a CFII. The remaining 25 hours of actual or simulated flight time can be with a CFIA (or any qualified pilot acting as Safety Pilot).

If your instructor for your PPL was a CFIA you have already received at least 3 hours of dual received (from a non-CFII) in control and maneuvering an airplane solely by reference to the flight instruments (ref: FAR 61.109 (a)(3)). So, you may only need 22 hours (or less) of the remaining required 25 hours of actual or simulated instrument flight time since you completed at least 3 of these hours during your PPL training.

FAR 61.195 (l) [noted above] allows a CFIA to administer training in the control and maneuvering of the airplane solely by reference to the instruments. So, as long as a CFIA is providing dual instruction limited to the control and maneuvering of the airplane solely by reference to the instruments, you could log this time as dual received (CFIA must endorse your logbook). But importantly, this dual received cannot substitute for any of the 15 hours of required training that must be given by a CFII.

Also, like logging the IAPs, there is no regulatory benefit (as the holder of a PPL) to your logging this dual received time from a CFIA, but you may want to for personal reference or perhaps some future insurance benefit.


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