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5 Answers

IPC – Instructor Requirements

Asked by: 1929 views Flight Instructor, Instrument Rating

Does an instructor conducting an IPC need to be PIC?

Does the instructor need to have either Single Engine or Multi Engine on the Instructor Certificate?

Consider the following (less than usual) case:

An FAA IPC is to be conducted outside US airspace in a foreign registered aircraft. The applicant is rated on that class and legal for IFR. (Safety Pilot not required.)

The instructor only has Instrument on their certificate.

For instruction in MEL, they would require Multi Engine, but IPC is not instruction?

If the IPC was conducted in an SEL, would the instructor even need SEL on their pilot certificate?

In short, the instructor has ATP-MEL only, plus Instrument Instructor (FAA). The flight is conducted overseas, and both the applicant and instructor are qualified in that jurisdiction.

Many thanks,

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5 Answers



  1. John D Collins on Apr 14, 2022

    Does an instructor conducting an IPC need to be PIC?

    Answer: No, but either the pilot or the instructor must be qualified to act as PIC and act as PIC.

    Does the instructor need to have either Single Engine or Multi Engine on the Instructor Certificate?

    Answer: The instructor must have the appropriate category and class on their flight instructor certificate and their pilot certificate. See 61.195(b) Flight instructor limitations and qualifications.:

    “(b) Aircraft ratings. Except as provided in paragraph (c) of this section, a flight instructor may not conduct flight training in any aircraft unless the flight instructor:
    (1) Holds a flight instructor certificate with the applicable category and class rating;
    (2) Holds a pilot certificate with the applicable category and class rating;”

    Consider the following (less than usual) case:

    An FAA IPC is to be conducted outside US airspace in a foreign registered aircraft. The applicant is rated on that class and legal for IFR. (Safety Pilot not required.)

    The instructor only has Instrument on their certificate.

    For instruction in MEL, they would require Multi Engine, but IPC is not instruction?

    Answer: It would not be instruction to train for a multi-engine rating, but it is training. See

    “14 CFR 61.193 Flight Instructor Privileges:
    (a) A person who holds a flight instructor certificate is authorized within the limitations of that person’s flight instructor certificate and ratings to train and issue endorsements that are required for:
    …
    (7) A flight review, operating privilege, or recency of experience requirement of this part;”

    So, under the regulations, an IPC is considered training.

    If the IPC was conducted in an SEL, would the instructor even need SEL on their pilot certificate?

    Answer: Yes.

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  2. Bryan on Apr 14, 2022

    Instructor limitations and qualifications are controlled in 14 CFR 61.195. Starting in paragraph (b):

    (b) Aircraft ratings. Except as provided in paragraph (c) of this section, a flight instructor may not conduct flight training in any aircraft unless the flight instructor:

    (1) Holds a flight instructor certificate with the applicable category and class rating;

    (2) Holds a pilot certificate with the applicable category and class rating; and

    (3) Meets the requirements of paragraph (e) of this section, if applicable.

    (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, and –

    (i) Meet the requirements of paragraph (b) of this section; or

    (ii) Hold a commercial pilot certificate or airline transport pilot certificate with the appropriate category and class ratings for the aircraft in which the instrument training is conducted provided the pilot receiving instrument training holds a pilot certificate with category and class ratings appropriate to the aircraft in which the instrument training is being conducted.

    (2) If the flight instructor is conducting the instrument training in a multiengine airplane, the flight instructor must hold an instrument rating appropriate to the aircraft used for the instrument training on his or her flight instructor certificate and meet the requirements of paragraph (b) of this section.

    I think (c)(1)(ii) seems to have your answer. The instructor has to have a commercial or ATP “with the appropriate category and class ratings for the aircraft in which the instrument training is conducted.” And the candidate pilot has to have a “pilot certificate with the category and class ratings appropriate to the aircraft in which the instrument rating is being conducted. If the IPC is going to be done in an aircraft that requires a type rating, then paragraph (e) applies which prohibits instruction in that aircraft unless the instructor is type rated for that aircraft.

    So I don’t think the instructor actually has to act as PIC–but they will always be certificated and rated to do be PIC.

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  3. awair on Apr 14, 2022

    Many thanks John & Bryan.

    Clarification that an IPC is considered training is the main point. , for me.

    The other items were supplementary to considering an IPC being conducted overseas.

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  4. Kris Kortokrax on Apr 14, 2022

    “An FAA IPC is to be conducted outside US airspace in a foreign registered aircraft. The applicant is rated on that class and legal for IFR. (Safety Pilot not required.)”

    I have a few questions.

    If the pilot resides in a foreign country and has no access to an airplane of U.S. registry, then why would he need a U.S. (FAA) IPC?

    If the pilot is legal for IFR, why would he need an IPC?

    What certificates do the pilot and instructor hold for the foreign country?

    What U.S. certificates do the pilot and instructor hold?

    61.3(a) address requirements for certificates to fly a U.S. registered airplane anywhere.
    61.3(b) requires a U.S. certificate or a foreign license to fly a foreign registered aircraft within the U.S.
    I suspect that foreign countries have the same certificate requirements.

    I would also note that while 61.56(a) states that a flight review consists of 1 hour of flight instruction and 1 hour of ground instruction, 61.57(d) speaks of a “check” and does not mention the word instruction. Further, 61.195(d)(6) states that “A flight instructor may not endorse a: logbook of a pilot for an instrument proficiency check, unless that instructor has tested that pilot in accordance with the requirements of 61.57(d).”

    Testing is not instruction. Instruction can and should include an evaluation, however, testing, such as a practical test, does not include instruction during the test.

    The instructor may choose the maneuvers to be reviewed for the Flight Review. The IPC is accomplished using the Instrument ACS and the required maneuvers.

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  5. awair on Apr 14, 2022

    Hi Kris,

    That is very helpful. Thank you.

    While I am currently based in the US, I frequently need to return to UK or Europe for licensing requirements. I’ve often seen requests for an IPC to be conducted there.

    This is presumably the case where the pilot expects to exercise the privileges of their FAA certificate, but had not met the logging requirements.

    Anyway, it looks that, to be on the safe side, I’ll wait til I have the necessary Class rating as well as II, before conducting any IPC abroad.

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