When can you log flight time as PIC or SIC? The answer is not always as simple as who is flying the airplane or which seat you occupy. The regulations distinguish between being rated to fly an aircraft, being authorized to act as PIC, actually acting as PIC, and what flight time you can log. While those concepts often overlap, they are not necessarily the same.
This distinction comes up in some fairly common situations. Can you log PIC time while flying an aircraft if you do not have a required endorsement? What can you log while serving as a safety pilot? What if an insurance company requires a second pilot even though the aircraft can legally be flown by one?
To work through these questions, there are four basic questions to keep coming back to:
Under FAR § 61.5, aircraft ratings are generally organized by category, class, and type, when a type rating is required. Categories include airplane, rotorcraft, glider, and others. For airplanes, classes include single-engine land, multiengine land, single-engine sea, and multiengine sea. A type rating applies to a specific aircraft when required—generally large or turbojet-powered aircraft.
If your certificate says “Airplane Single-Engine Land,” you are rated in that category and class. In some circumstances, the regulations grant privileges to operate aircraft without placing a corresponding rating on the pilot certificate. This distinction matters because FAR 61.51(e)(1)(i) permits a pilot to log PIC time as sole manipulator of the controls of an aircraft for which the pilot is “rated or has privileges.”
Being rated, however, does not necessarily mean you are authorized to act as PIC. FAR 61.31, for example, may require an endorsement before acting as PIC of a tailwheel, complex, or high-performance airplane. A current flight review under FAR 61.56 may also be required. These requirements do not change the underlying category or class rating; rather, they impose additional requirements before exercising PIC privileges.
FAR § 1.1 defines PIC as the person who has final authority and responsibility for the operation and safety of the flight, has been designated as PIC, and holds the appropriate category, class, and type rating, if appropriate. Those requirements address who may act as PIC. Logging PIC time, however is a separate question.
Under § 61.51(e)(1)(i), a pilot may generally log PIC time while the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges. Thus, there are circumstances where a pilot can log PIC time even though that pilot cannot act as PIC.
Consider Pilot A, a private pilot rated airplane single-engine land but without a tailwheel endorsement. Pilot B holds the same rating and has the required tailwheel endorsement. Pilot B acts as PIC of a single-engine tailwheel airplane but allows Pilot A to fly for part of the trip.
Without the required endorsement, Pilot A cannot act as PIC. But Pilot A remains rated airplane single-engine land and may generally log PIC time under FAR 61.51(e)(1)(i) for the time Pilot A is the sole manipulator of the controls. Importantly, for the portion of the flight where Pilot A is the sole manipulator of the controls, Pilot B remains the acting PIC but does not log that portion as PIC. In this operation, Pilot B has no separate basis to log PIC time while Pilot A is manipulating the controls.
Safety-pilot operations illustrate the importance of the fourth question: why is the second pilot there?
Assume now that Pilots A and B are appropriately rated and flying an aircraft certificated for single-pilot operation. Pilot A wants to practice instrument approaches under simulated instrument conditions. Pilot A manipulates the controls for the entire flight but uses a view-limiting device for a portion of it. Pilot B serves as the safety pilot required by FAR 91.109(c).
Pilot A may log the entire flight as PIC under FAR 61.51(e)(1)(i) because Pilot A is the sole manipulator of the controls. What Pilot B may log during the simulated-instrument portion depends on who is acting as PIC.
If Pilot B acts as PIC, Pilot B may also log PIC time, but only during the simulated-instrument portion under FAR 61.51(e)(1)(iii). FAR 91.109(c) requires a safety pilot during that portion of the flight, meaning more than one pilot is required by regulation. Here, Pilot B is the one acting as PIC. Thus, both pilots may log PIC for the same period, but for different regulatory reasons.
If Pilot A instead acts as PIC, Pilot B may log SIC time under FAR 61.51(f)(2) during the simulated-instrument portion. Although the aircraft is certificated for single-pilot operation, FAR 91.109(c) requires Pilot B’s presence while Pilot A operates under simulated instrument conditions. That regulatory requirement provides the basis for Pilot B’s SIC logging.
Insurance adds one final wrinkle. A policy may require particular experience, recurrent training, or even a second pilot when the FARs otherwise permit single-pilot operation. But an insurance requirement does not, by itself, create loggable flight time. An insurer might require a second pilot aboard, but that requirement alone does not make the pilot a required flight crewmember for the purposes of logging SIC time.
That brings us back to the fourth question. For SIC time, why is the second pilot there? If the answer is because the aircraft certification or regulations require one, there may be a basis for logging SIC. If the answer is simply because an insurance company wants one, that alone generally does not create loggable SIC time. Insurance requirements are contractual; they do not rewrite regulations.
So, before adding those tenths to your logbook, return to the same four questions: What am I rated or privileged to fly? Who is acting as PIC? Who is manipulating the controls? And why is the second pilot there? If you answer those questions first, deciding where the time belongs becomes considerably easier.
