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4 Answers

CFI-I required to teach commercial students?

Asked by: 5996 views Commercial Pilot, FAA Regulations, Flight Instructor

61.195(c)  reads:

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 ATP certificated if the following requirements are met... 

  1. A CFI cert and pilot certificate for same category and class airplane.
  2. hold and instrument rating on his or her flight instructor certificate.

So my question is, as a new CFI with no instrument rating on my instructor certificate can I teach commercial students (who are already instrument rated) or am I required to have the CFI-I just in general to have them as my students? 

I am currently working on getting initial CFI certificate and am curious of this in order to provide myself with adequate student flow while I work on getting my CFI-I and MEI. 

Thanks to anyone who can provide me some insight on this!

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4 Answers



  1. John D Collins on Jan 14, 2019

    You bolded a portion of the requirement “required for commercial pilot” and not the qualifier which included “the instrument training required for commercial pilot”.

    This is the training for which you must hold an instrument rating on your CFI certificate:

    §61.129 Aeronautical experience.

    (3) 20 hours of training on the areas of operation listed in §61.127(b)(1) of this part that includes at least—

    (i) Ten hours of instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. Five hours of the 10 hours required on instrument training must be in a single engine airplane;

    All the other training for the commercial does not require that the instructor hold an instrument rating on their instructor certificate. So you can do all the training except the 10 hours of instrument training.

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  2. Matt J Adams on Jan 14, 2019

    Thanks John, I realize I cant give the required instrument training, mainly wondering if they are already instrument rated do they still require the training in those areas? Or does the previous training they acquired during instrument training count?

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  3. Mark Kolber on Jan 14, 2019

    Their previous training for the instrument rating counts, but there is a limitation. The log entries need to show they included the instrument tasks listed in 61.129.

    Ever since the Chief Counsel clarified that limitation in the 2010 Hartzell interpretation (https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2010/hartzell%20-%20(2010)%20legal%20interpretation.pdf‘ a number of folks have recommended referencing both 61.65 and 61.129 in the log entries as a way of showing their dual applicability.

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  4. Kris Kortokrax on Jan 14, 2019

    What is really interesting is that “instrument training” is only required for airplane, powered lift (for which no civilian examples exist) and airship (for which no instructor certificate is issued, much less instructor with an instrument rating).

    Where they could really stand to have instrument instruction, for helicopters, the FAA uses the phrase, “control and maneuvering… by reference to instruments”, allowing an instructor with no instrument rating on either pilot or instructor certificate to give the required “training”.

    The myopic leading the blind.

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