Simulator Use for Type Ratings

FAR 61.64 Simulator Use for Type Ratings

FAR 61.64 explains how flight simulators and FTDs may be used for pilot certification, type ratings, and Level C sim-only checkrides with PIC limitations.

In Plain English

FAR 61.64 governs when a flight simulator or flight training device (FTD) may be used in place of an aircraft for pilot training and the practical test.

The simulator or FTD must:

  • Represent the category, class, and type of the rating sought; and
  • Be qualified and approved by the Administrator and used under an approved Part 141, 142, 121, or 135 training course (the last two only if the applicant is a pilot employee of that carrier).

For a type rating in a turbojet, turbo-propeller, helicopter, or powered-lift, the entire practical test (except preflight) may be done in a Level C or higher simulator if the applicant meets specific experience benchmarks—such as already holding a related type rating without limitation, prior military PIC time, 500 hours in type, or 1,000–2,000 hours including turbine time.

If the applicant does not meet those experience requirements, they must either fly select tasks (preflight, normal takeoff, ILS, missed approach, normal landing) in the actual aircraft, or accept a PIC limitation on their certificate. That limitation can later be removed by completing 25 hours of supervised PIC operating experience logged and attested by a fully qualified PIC, then presented to an Examiner or Flight Standards office.

This matters because it lets airlines and training centers efficiently train pilots in high-fidelity simulators without compromising safety standards.

Regulation Text
14 CFR § 61.64
§ 61.64 Use of a flight simulator and flight training device. (a)If an applicant for a certificate or rating uses a flight simulator or flight training device for training or any portion of the practical test, the flight simulator and flight training device— (1) Must represent the category, class, and type (if a class or type rating is applicable) for the rating sought; and (2) Must be qualified and approved by the Administrator and used in accordance with an approved course of training under part 141 or part 142 of this chapter; or under part 121 or part 135 of this chapter, provided the applicant is a pilot employee of that air carrier operator. (b) Except as provided in paragraph (f) of this section, if an airplane is not used during the practical test for a type rating for a turbojet airplane (except for preflight inspection), an applicant must accomplish the entire practical test in a Level C or higher flight simulator and the applicant must— (1) Hold a type rating in a turbojet airplane of the same class of airplane for which the type rating is sought, and that type rating may not contain a supervised operating experience limitation; (2) Have 1,000 hours of flight time in two different turbojet airplanes of the same class of airplane for which the type rating is sought; (3) Have been appointed by the U.S. Armed Forces as pilot in command in a turbojet airplane of the same class of airplane for which the type rating is sought; (4) Have 500 hours of flight time in the same type of airplane for which the type rating is sought; or (5) Have logged at least 2,000 hours of flight time, of which 500 hours were in turbine-powered airplanes of the same class of airplane for which the type rating is sought. (c) Except as provided in paragraph (f) of this section, if an airplane is not used during the practical test for a type rating for a turbo-propeller airplane (except for preflight inspection), an applicant must accomplish the entire practical test in a Level C or higher flight simulator and the applicant must— (1) Hold a type rating in a turbo-propeller airplane of the same class of airplane for which the type rating is sought, and that type rating may not contain a supervised operating experience limitation; (2) Have 1,000 hours of flight time in two different turbo-propeller airplanes of the same class of airplane for which the type rating is sought; (3) Have been appointed by the U.S. Armed Forces as pilot in command in a turbo-propeller airplane of the same class of airplane for which the type rating is sought; (4) Have 500 hours of flight time in the same type of airplane for which the type rating is sought; or (5) Have logged at least 2,000 hours of flight time, of which 500 hours were in turbine-powered airplanes of the same class of airplane for which the type rating is sought. (d) Except as provided in paragraph (f) of this section, if a helicopter is not used during the practical test for a type rating in a helicopter (except for preflight inspection), an applicant must accomplish the entire practical test in a Level C or higher flight simulator and the applicant must meet one of the following requirements— (1) Hold a type rating in a helicopter and that type rating may not contain the supervised operating experience limitation; (2) Have been appointed by the U.S. Armed Forces as pilot in command of a helicopter; (3) Have 500 hours of flight time in the type of helicopter; or (4) Have 1,000 hours of flight time in two different types of helicopters. (e) Except as provided in paragraph (f) of this section, if a powered-lift is not used during the practical test for a type rating in a powered-lift (except for preflight inspection), an applicant must accomplish the entire practical test in a Level C or higher flight simulator and have 500 hours of flight time in the type of powered-lift for which the rating is sought. (f) If the applicant does not meet one of the experience requirements of paragraphs (b)(1) through (5), paragraphs (c)(1) through (5), paragraphs (d)(1) through (4), or paragraph (e) of this section, as appropriate to the type rating sought, then— (1) The applicant must complete the following tasks on the practical test in an aircraft appropriate to category, class, and type for the rating sought: Preflight inspection, normal takeoff, normal instrument landing system approach, missed approach, and normal landing; or (2) The applicant's pilot certificate will be issued with a limitation that states: “The [name of the additional type rating] is subject to pilot in command limitations,” and the applicant is restricted from serving as pilot in command in an aircraft of that type. (g) The limitation described under paragraph (f)(2) of this section may be removed from the pilot certificate if the applicant complies with the following— (1) Performs 25 hours of flight time in an aircraft of the appropriate category, class (if a class rating is required), and type for which the limitation applies under the direct observation of the pilot in command who holds a category, class (if a class rating is required), and type rating, without limitations, for the aircraft; (2) Logs each flight and the pilot in command who observed the flight attests in writing to each flight; (3) Obtains the flight time while performing the duties of pilot in command; and (4) Presents evidence of the supervised operating experience to any Examiner or Flight Standards office to have the limitation removed. [Docket FAA-2006-26661, 76 FR 78143, Dec. 16, 2011, as amended by Docket FAA-2018-0119, Amdt. 61-141, 83 FR 9170, Mar. 5, 2018; FAA-2023-1275, Amdt. 61-157, 89 FR 92485, Nov. 21, 2024]
Oral Exam Questions a DPE Might Ask
Q1What must a flight simulator or FTD meet to be used for your practical test?
Per FAR 61.64(a), the device must represent the category, class, and type for the rating sought, and be qualified and approved by the Administrator, used under an approved Part 141, 142, 121, or 135 training course.
Q2Under what conditions can a turbojet type rating practical test be completed entirely in a simulator?
FAR 61.64(b) allows the entire test (except preflight) in a Level C or higher simulator if the applicant meets one of five experience criteria, such as holding a related turbojet type rating without limitation, having 500 hours in type, or 1,000 hours in two different turbojets of the same class.
Q3If an applicant doesn't meet the experience requirements for an all-simulator type rating checkride, what happens?
Under FAR 61.64(f), they must either complete preflight, normal takeoff, ILS approach, missed approach, and normal landing in the actual aircraft, or receive a PIC limitation on the certificate, which can be removed under FAR 61.64(g) after 25 hours of supervised PIC experience.
Practice this with our AI examiner

Examiner Reed adapts to your responses and probes deeper on weak spots — full ACS coverage, not a script.

Studying for a checkride?
Related Sections in Part 61
Master the FARs
Stop reading regs. Start drilling them.

Every cite verified against the live FAR/AIM. Adaptive questions surface your weak areas. Mock checkrides predict your DPE pass rate.

5 questions/day free • No credit card
FAR 61.64 — Flight Simulator & FTD Use for Practical Tests