Task III.A
Pilot Qualifications
To determine the applicant understands pilot training and qualification requirements for different levels of pilot certificate including student pilot, sport pilot, recreational pilot, private pilot, commercial pilot, and flight instructor; can apply that knowledge, manage associated risks, demonstrate appropriate skills, and provide effective instruction.
References: 14 CFR parts 61, 68, 91; AC 60-28, AC 68-1; FAA-H-8083-2, FAA-H-8083-3, FAA-H-8083-23, FAA-H-8083-25; POH/AFM
Quick Review
Conversational Q&A — quiz yourself before the oral.
The evaluator must select at least one Task from Area III, so budget real preparation here even though it looks like reheated private-pilot material. It isn't. The objective for this task says you understand pilot qualification requirements "for different levels of pilot certificate including student pilot, sport pilot, recreational pilot, private pilot, commercial pilot, and flight instructor" — and that you can provide effective instruction on them. Two new burdens fall on you: you now have to know your own certificate's rules (61.183, 61.195, 61.197), and you have to be able to teach certification to somebody who has never read a regulation in their life.
Skill S1 is narrow and concrete: deliver instruction on at least two of the elements in K1 through K4. Come with a lesson, not a recitation.
- At least 18 years old
- Read, speak, write, and understand English (medical-reason limitations may be placed on the certificate instead)
- Hold a commercial or ATP certificate with the category and class appropriate to the CFI rating sought, and an instrument rating if seeking airplane single-engine, airplane multiengine, powered-lift, or instrument CFI
- A logbook endorsement on the fundamentals of instructing listed in 61.185, appropriate to the required knowledge test (61.183(d)) — no exceptions to this one
- Pass the FOI knowledge test on the 61.185(a)(1) areas (61.183(e)) — this is the part that can be skipped, and only if you hold a CFI or ground instructor certificate issued under Part 61, hold a teacher's certificate from a state, county, city, or municipality authorizing you to teach at the 7th grade or higher, or are employed as a teacher at an accredited college or university
- Pass the knowledge test on the 61.185(a)(2) and (a)(3) areas (61.183(f))
- Endorsement on the 61.187(b) areas of operation (61.183(g))
- Spin endorsement and demonstrated instructional proficiency in stall awareness, spin entry, spins, and spin recovery, after training in an airplane or glider, as appropriate, that is certificated for spins (61.183(i))
- Log at least 15 hours PIC in the category and class appropriate to the rating sought
- Pass the practical test (61.183)
- 8 hours of flight training maximum in any 24-consecutive-hour period (61.195(a)) — note it is a rolling 24 hours, not a calendar day, and it counts flight training only
- Except as provided in 61.195(c), you must hold a flight instructor certificate with the applicable category and class rating and a pilot certificate with the applicable category and class rating to conduct flight training in an aircraft (61.195(b))
- The 61.195(c) exception: for instrument training toward an instrument rating, a type rating not limited to VFR, or the instrument training required for a commercial or ATP certificate, you may instead hold an instrument rating appropriate to the aircraft on your CFI certificate plus a commercial or ATP certificate with the appropriate category and class — provided the pilot receiving the training holds a pilot certificate with category and class ratings appropriate to that aircraft (61.195(c)(1)(ii)). It does not apply to instrument training in a multiengine airplane (61.195(c)(2)), where full 61.195(b) compliance is required. 61.195(l) carves out attitude-instrument training the same way
- No self-endorsements for any certificate, rating, flight review, authorization, operating privilege, practical test, or knowledge test (61.195(i))
- Type rating on your pilot certificate required to instruct in an aircraft requiring one (61.195(e))
- At least 5 hours PIC in the specific make and model before giving training for a certificate or rating in a multiengine airplane, helicopter, or powered-lift (61.195(f))
- Training must be given from an aircraft complying with 91.109, and for a certificate or rating the aircraft must have at least two pilot stations in the same category, class, and type as appropriate (61.195(g))
You may not endorse:
- A student's logbook for solo unless you gave the flight training required for solo and determined the student is prepared to conduct the flight safely under known circumstances, subject to any limitations you write into the logbook
- A solo cross-country unless you determined the student's flight preparation, planning, equipment, and proposed procedures are adequate for that flight under existing conditions
- Solo in Class B airspace or at an airport within Class B unless you gave ground and flight training in that airspace or at that airport and determined the student is proficient
- A recreational pilot's logbook unless you gave the required ground and flight training and found the pilot proficient
- A flight review unless you conducted it per 61.56(a)
- An instrument proficiency check unless you tested the pilot per 61.57(d)
Every one of these is written as a determination you personally make. The signature is not paperwork — it is the FAA delegating a safety judgment to you.
You sign every trainee's logbook entry, keep the solo and test endorsement record, and retain it for 3 years (61.189) — covered in depth under Task II.K, along with the TSA citizenship-retention choice applicants routinely state backwards.
The Task III.A angle is the consequence: 61.189 quietly builds a file on you, because your endorsement record is a running list of your own pass rate. That record is the evidence behind two later privileges: renewing your CFI certificate by endorsing at least 5 applicants for a practical test with at least 80 percent passing on the first attempt (61.197(b)(2)(i)), and the training-endorsement privileges tied to that same record (61.195(h)(2)(ii)).
So the recordkeeping habit isn't administrative hygiene, it's the evidence for your own certificate. An instructor who keeps a sloppy endorsement record can't renew by activity even if the students all passed, because the record is the proof and there is no reconstructing it three years later. Set up the format on day one and never let it lapse.
The entry must be endorsed legibly by you and must include:
- A description of the training given
- The length of the training lesson
- Your signature, certificate number, and certificate expiration date or recent experience end date, consistent with 61.197 (61.51(h)(2))
That last item changed with the December 2024 rule — a CFI certificate issued now does not expire, so what you write is your recent experience end date. Teach students to check that date; a training entry signed by an instructor without current recent experience does not count.
You may exercise CFI privileges only if within the preceding 24 calendar months you have satisfied one of the 61.197(b) recent-experience options:
- Pass a practical test for a rating on your CFI certificate or for an additional CFI rating
- Endorse at least 5 applicants for a practical test in the preceding 24 calendar months with at least 80 percent passing on the first attempt
- Serve within the preceding 24 calendar months as a company check pilot, chief flight instructor, company check airman, or Part 121/135 flight instructor, or in a position involving regular evaluation of pilots
- Complete an approved flight instructor refresher course (FIRC) within the preceding 3 calendar months
- Pass a U.S. Armed Forces instructor pilot or pilot examiner proficiency check within the preceding 24 calendar months
- Serve as an instructor in an FAA-sponsored pilot proficiency program meeting 61.197(b)(2)(v)
Miss the window and you cannot instruct until reinstated under 61.199. A certificate issued before December 1, 2024 is renewed by establishing recent experience before the expiration month (61.197(e)).
It depends entirely on whether you are acting as PIC or a required flight crewmember.
- Yes — at least third class when exercising CFI privileges and acting as PIC or required crewmember (61.23(a)(3)(ii))
- No medical at all when exercising CFI privileges and not acting as PIC or a required crewmember (61.23(b)(7)) — e.g., instructing a rated, current pilot who is the legal PIC
- BasicMed works: you may act as PIC or required crewmember on a driver's license under 61.113(i) conditions (61.23(c)(1)(vii)) — 7 occupants or fewer, 12,500 lb maximum takeoff weight, no more than 6 passengers, 18,000 ft MSL, 250 kt (61.113(i))
Duration for CFI use of a medical: when acting as PIC or required crewmember, a certificate expires the last day of the 60th month after the exam if you were under 40, the 24th month if 40 or older (61.23(d)(1)(iv), (v)).
An unexpired medical certificate is a floor, not a clearance. 61.53 is a self-grounding rule that operates continuously between exams, and it has three branches keyed to what the operation requires:
- Operations requiring a medical (61.53(a)). If you hold a Part 67 medical, you may not act as PIC or in any other capacity as a required pilot flight crewmember while you know or have reason to know of a medical condition that would make you unable to meet the requirements for the medical necessary for that operation, or while you are taking medication or receiving other treatment for a condition that has that effect.
- Operations not requiring a medical (61.53(b)). For the 61.23(b) operations — which is exactly the CFI instructing a rated, current pilot who is the legal PIC — the standard becomes: no acting as PIC or required crewmember while you know or have reason to know of any condition that would make you unable to operate the aircraft in a safe manner. There is no version of 61.53 you can fly under sick.
- BasicMed and driver's-license operations (61.53(c)). For 61.23(c) operations, you meet (a) if you hold a Part 67 medical and no U.S. driver's license, and (b) if you hold a U.S. driver's license.
Two instructor angles. First, "reason to know" is deliberately broader than a diagnosis — a new medication is the trigger students most often miss. Second, teach it as primacy: the day a student first calls off a lesson for a head cold is the day the habit sets. If you fly the lesson anyway because the airplane is booked, you have taught the opposite lesson, permanently.
Not needed: a medical certificate, if the student holds a valid U.S. driver's license, meets 61.23(c)(3), and operates within 61.89(a) and (b) and the 61.113(i) conditions (61.89(d)).
A student pilot may not act as PIC (61.89(a)):
- Carrying a passenger, or property for compensation or hire
- For compensation or hire, or in furtherance of a business
- On an international flight (narrow Alaska/Yukon exception)
- With flight or surface visibility less than 3 SM by day or 5 SM at night
- When the flight cannot be made with visual reference to the surface
- Contrary to any limitation you placed in the logbook
That last one is your tool. If the student shouldn't fly in more than 8 knots of crosswind yet, write it in the logbook and it becomes regulatory.
- Pre-solo aeronautical knowledge test you administer, covering applicable parts 61 and 91, airspace rules and procedures for the solo airport, and flight characteristics and operating limitations of the make and model — and you must review every incorrect answer with the student before authorizing solo (61.87(b))
- Pre-solo flight training in the 15 maneuvers and procedures of 61.87(d) for a single-engine airplane, with demonstrated proficiency in that make and model or a similar one (61.87(c))
- A make-and-model solo endorsement — valid only if given within the 90 days preceding the flight, and updated every 90 days thereafter (61.87(n), 61.87(p)(4))
- Night solo requires separate night training at that airport, night navigation training in the vicinity, and its own 90-day make-and-model endorsement (61.87(o))
- Solo cross-country requires a category endorsement, a make-and-model endorsement, and a per-flight endorsement after you review the student's planning — specifying the make and model, stating the planning and preparation are correct and the student is prepared to make the flight safely under the known conditions, and that your limitations are met (61.93(c))
The narrow exception: repeated specific solo cross-country flights within 50 NM of the origin airport don't need the per-flight endorsement, provided you trained the student in both directions over the route including pattern entry and exit, takeoffs, and landings at the airports used (61.93(b)(2)).
- Student pilot — no passengers, no compensation, 3 SM day / 5 SM night visibility, visual reference to the surface, bound by the instructor's logbook limitations (61.89)
- Sport pilot — one passenger maximum, day only (except per 61.329), no Class A, 10,000 ft MSL or 2,000 ft AGL whichever is higher, 3 SM visibility, visual reference to the surface, no towing, Class B/C/D only with the 61.325 endorsement, and must pay at least half the shared operating expenses (61.315)
- Recreational pilot — one passenger maximum, within 50 NM of the departure airport unless endorsed for cross-country under subpart E, Class B/C/D only with the 61.101(d) training and endorsement, pro rata share only (61.101)
- Private pilot — may not carry persons or property for compensation or hire, may not fly for compensation, with the familiar carve-outs: incidental to business, pro rata share with passengers, 91.146 charity flights, search-and-location reimbursement, aircraft salesman with 200 hours, glider towing under 61.69 (61.113)
- Commercial pilot — may be compensated, but only for operations that don't require an air carrier certificate (61.133; covered in depth in the Commercial guide)
- Flight instructor — may give training and endorsements per 61.193, subject to 61.195
In your personal possession or readily accessible in the aircraft: your pilot certificate, an appropriate medical certificate (or the BasicMed documents), and photo identification (61.3).
A student pilot must carry, on all solo cross-country flights, the pilot logbook, the student pilot certificate, and any other record required by 61.51 — because the endorsements are the authorization (61.51(i)(2)). A sport pilot must carry the logbook or other evidence of required endorsements on all flights (61.51(i)(3)).
Teach it as a rule with a reason: for most pilots the certificate proves the privilege, but for a student the logbook is the privilege.
Don't define the terms and move on. Make the student produce the gap in their own numbers.
Ask them to write down the regulatory floor for the flight they want to take — flight review within 24 calendar months (61.56); three takeoffs and landings in the preceding 90 days to carry persons, to a full stop if the airplane is a tailwheel (61.57(a)(1)); and — separately — three takeoffs and landings to a full stop in the preceding 90 days between 1 hour after sunset and 1 hour before sunrise to carry persons at night (61.57(b)(1)). Then ask what they'd actually need to fly that trip to ACS tolerances: last time in that make and model, last crosswind landing, last time into an unfamiliar field, last night landing.
The teaching point lands when the student sees the two lists are different lengths. AIH 1 states it plainly: safe pilots understand the difference between what is legal and what is smart. Then convert the gap into a written personal minimum — a number, not a feeling.
Deep Dive
Teaching certification without putting the student to sleep
Regulations are the classic rote-learning trap. AIH 3 puts rote at the lowest of the four practical learning levels — rote, understanding, application, correlation — and warns that rote learning "is superficial and is not easily retained" (AIH 3). A student who can recite 61.113 and cannot answer "may your neighbor buy the gas?" has learned nothing useful.
The fix is scenario-based training. Teach the reg once, then live in the scenarios: your friend offers you $50 for the ride; your employer wants you to fly to a meeting; a charity asks for a raffle flight. Each scenario forces the student to apply and then correlate.
Four blocks, roughly 45 minutes:
- Motivation (why now). Not "the FAA requires it" — instead, "in three lessons you'll be alone in this airplane, and these rules are the only thing standing between you and me when I'm not there." AIH ch. 3's law of readiness: learners set aside what they see no immediate need for.
- Presentation, simple to complex. Student limitations (61.89) first, because those apply to them on Tuesday. Then the solo endorsement structure. Certificate levels above private come later.
- Application. Hand them three scenarios and have them find the answer in the FAR/AIM themselves — not in a test-prep app. The skill you're building is looking it up, because the reg will change and their memory won't update.
- Review and evaluation. Ask correlation-level questions ("your endorsement is dated 74 days ago and the wind is 12 gusting 18 — talk me through it"), not closed questions. AIH 4 notes closed-ended questions "tend to evaluate the learner's understanding only at the rote level."
| Student error | Root cause | Correction |
|---|---|---|
| Treats currency as proficiency | Never saw the gap quantified | Have them build a written personal minimums checklist (AIH Appendix D) |
| Thinks the medical certificate authorizes the flight | Conflates medical with certificate | Separate the three questions: certificate, medical, currency |
| Believes the 90-day solo endorsement is "about three months" | Rote memorization of a fuzzy number | Make them compute the actual calendar date and write it on the endorsement page |
| Assumes cost-sharing means "split it however" | Never read 61.113(c) | Work an actual dollar example — pro rata share, and only fuel, oil, airport expenditures, or rental fees |
| Can't find anything in the regulations | Only ever used a test-prep app | Open-book drills against the actual CFR text |
Naming the error out loud is the instructional act. AIH ch. 3's law of primacy — what is learned first "creates a strong, almost unshakable impression" — is why you correct a certification misconception on the day it appears, not at the stage check.
The risk management of endorsing
That you sign for something you did not personally verify. AIH 9 is blunt: a flight instructor who fails to ensure a learner meets the regulatory requirements before endorsing solo or an additional rating "is exhibiting a serious deficiency in performance," the FAA may hold that instructor accountable, and it "represents a breach of faith with the learner."
Your mitigations, in order:
- Use AC 61-65 wording. AIH Appendix C recommends endorsements be worded as closely as possible to the AC samples; at minimum you must cite the applicable part 61 section. Using the AC ensures you don't omit a required endorsement.
- Verify every prerequisite yourself against the reg text — hours, currency, prior endorsements, knowledge test results — before the pen touches the page.
- Never self-endorse anything (61.195(i)).
- Assess the English Language Standard. AIH Appendix C: if you doubt the learner meets the AELS, do not endorse the review or check as complete, and consider contacting your FSDO (AC 60-28).
- Add a limitation when you're not fully comfortable. Nothing prevents an instructor from adding a requirement, and a logbook limitation on a student becomes enforceable under 61.89(a)(8).
The 8710 recommendation and the flight proficiency logbook endorsement are each valid for 60 days, and AIH 9 says both dates should be the same. Signing that recommendation "imposes a serious responsibility" — the applicant should demonstrate the complete procedure prescribed in the applicable ACS, and in no instance less.
DPEs and FAA inspectors accept your recommendation as evidence of qualification and as proof you reviewed the knowledge areas the applicant missed on the written. If you would not send this applicant on the checkride today, the answer is more training, not an earlier signature.
Who may train an initial CFI applicant — the question about your own instructor
Ground training must come from an authorized instructor who either holds a ground or flight instructor certificate with the appropriate rating, has held it at least 24 calendar months, and has given at least 40 hours of ground training; or holds the certificate and has given at least 100 hours of ground training in an FAA-approved course (61.195(h)(1)).
Flight training must come from a CFI who meets 61.183 eligibility, holds the appropriate certificate and rating, meets the requirements of the part under which training is given, and one of:
- Has held a CFI certificate at least 24 calendar months and given at least 200 hours of flight training as a CFI (80 hours for a glider rating); or
- Has trained and endorsed at least 5 applicants for a practical test in the preceding 24 calendar months with at least 80 percent passing on the first attempt; or
- After meeting the flight-training hours, graduated from an FAA-approved flight instructor enhanced qualification training program under Part 141 or 142 (61.195(h)(2))
Know this one because it explains why your own CFI is qualified to sign you off — and because the same 5-applicant / 80-percent figure reappears in 61.197 recent experience.
Instructing in an aircraft that isn't yours, and other qualification traps
Legal first, then honest.
Legal: do I hold the CFI certificate and the pilot certificate with that category and class (61.195(b))? If this is instrument training, the 61.195(c) alternative may apply instead — but not in a multiengine airplane. Does it require a type rating — if so, do I hold it on my pilot certificate (61.195(e))? If it's a multiengine airplane and the training is for a certificate or rating, do I have 5 hours PIC in that specific make and model (61.195(f))? Do I need a 61.31 endorsement myself — high performance, complex, tailwheel, pressurized? Does the airplane have two pilot stations and comply with 91.109 (61.195(g))?
Honest: the certificate says I may, not that I should. The specific hazards of teaching in an unfamiliar airplane are that I don't know its failure modes, I don't have a calibrated sight picture for its landing attitude, and I have not built the reflex for where the controls are. All three degrade exactly when a student does something wrong. My mitigation is to fly it solo or with a knowledgeable instructor first, brief the abnormal procedures I've never seen, and decline the lesson if schedule pressure is the only reason I'd say yes.
The same logic applies to an unfamiliar flight display — not knowing what mode the autopilot is in is a loss-of-control risk, not an inconvenience.
Yes: a certificated flight instructor may log PIC flight time for all flight time while serving as the authorized instructor, provided the instructor is rated to act as PIC of that aircraft (61.51(e)(3)). The student simultaneously logs PIC as sole manipulator of the controls of an aircraft for which the student is rated (61.51(e)(1)(i)) — or, if a student pilot, logs PIC only under the narrow 61.51(e)(4) conditions.
Teach the distinction that resolves the apparent paradox: logging PIC and acting as PIC are different regulatory concepts. Two people can log it; only one is acting as PIC, and who that is should be settled out loud in the preflight brief — which is also the 61.23 question about whether you need a medical today.
Official ACS elementsreference
Knowledge4 elements
The applicant demonstrates understanding of:
AI.III.A.K1Certification, currency, and recordkeeping requirements, including training and logbook entries.AI.III.A.K2Privileges and limitations of pilot certificates and ratings at student pilot, sport, recreational, private, commercial, and flight instructor levels.AI.III.A.K3Medical certificates: class, expiration, privileges, temporary disqualifications, and operations under BasicMed.AI.III.A.K4Documents pilots must possess to exercise privileges of the specified certificate(s) and rating(s).
Risk Management2 elements
The applicant is able to identify, assess, and mitigate risk associated with:
AI.III.A.R1Proficiency versus currency.AI.III.A.R2Flying unfamiliar aircraft or operating with unfamiliar flight display systems and avionics.
Skills1 element
The applicant exhibits the skill to:
AI.III.A.S1Deliver instruction on at least two of the elements specified in K1 through K4.