Simplified Flight Controls Credit

FAR 61.9 — Simplified Flight Controls Credit

FAR 61.9 explains when pilot time in simplified flight controls aircraft can't count toward private, commercial, or ATP certificate experience requirements.

In Plain English

FAR 61.9 restricts how flight time logged in an airplane or helicopter with a simplified flight controls (SFC) designation can be applied toward certificate requirements. Even though FAR 61.51(c) generally lets you log and credit flight time, this section carves out specific experience that cannot be satisfied with SFC time when working toward a private, commercial, or airline transport pilot certificate.

Specifically, SFC time may not be used to meet:

Solo flight time for the private pilot certificate under § 61.109(a)(5) (airplane) or (c)(4) (helicopter)
PIC flight time for the commercial pilot certificate under § 61.129(a)(2)(i) and (c)(2)(i)
PIC flight time for the ATP certificate under § 61.159(a)(5)
PIC flight time for the restricted-privileges ATP under § 61.161(a)(3)

The one exception: a private pilot applicant who actually uses an SFC-designated aircraft to take the practical test may apply that time. Operationally, this matters because building hours in a simplified-controls aircraft won't shortcut the stick-and-rudder PIC and solo experience the FAA expects from certificated pilots.

Regulation Text

14 CFR § 61.9

§ 61.9 Inapplicability of simplified flight controls aircraft experience credit. Notwithstanding the requirements specified in § 61.51(c), any pilot time acquired while operating an airplane or helicopter with a simplified flight controls designation may not be used to satisfy the following aeronautical experience requirements for a private, commercial, or airline transport pilot certificate, except for private pilot applicants who present an aircraft with the simplified flight controls designation to conduct the practical test— (a) The solo flight time requirements in § 61.109(a)(5) or (c)(4); (b) The PIC flight time requirements in § 61.129(a)(2)(i) and (c)(2)(i); (c) The PIC flight time requirements in § 61.159(a)(5); and (d) The PIC flight time requirements in § 61.161(a)(3). [Docket FAA-2023-1377, Amdt. 61-159, 90 FR 35211, July 24, 2025]

Oral Exam Questions a DPE Might Ask

Q1Can time flown in an aircraft with a simplified flight controls designation count toward your commercial pilot PIC requirements?

No. Under FAR 61.9(b), simplified flight controls time cannot be used to satisfy the PIC flight time requirements in § 61.129(a)(2)(i) or (c)(2)(i) for the commercial certificate.

Q2Is there any situation where simplified flight controls time can count toward a private pilot certificate?

Yes. FAR 61.9 allows a private pilot applicant who presents a simplified flight controls–designated aircraft for the practical test to use that time toward the solo requirements of § 61.109(a)(5) or (c)(4).

Q3Which ATP experience requirements are off-limits to simplified flight controls time?

Per FAR 61.9(c) and (d), simplified flight controls time cannot be used to meet the PIC flight time requirements in § 61.159(a)(5) or § 61.161(a)(3) for the ATP certificate.

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Related Sections in Part 61

§ 61.1

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