Legal Interpretations
Kortokrax 2012
Summary
The Question
To give instrument flight training in an aircraft, must a flight instructor hold an instrument rating on the flight instructor certificate in addition to the aircraft's category and class ratings?
Background
A requester asked for an interpretation of 14 CFR 61.195(b)(1) and 14 CFR 61.195(c) and for clarification of an earlier FAA interpretation letter.
The FAA’s Interpretation
Yes. The FAA's consistent interpretation of 14 CFR 61.195(b) and 14 CFR 61.195(c) is that an instructor conducting instrument flight training in an aircraft must hold, on the flight instructor certificate, both category and class ratings for that aircraft and an instrument rating appropriate to the aircraft category.
- Requester
- Kortokrax
- Issued
- July 10, 2012
- Subject
- Pilot Certification & Privileges
Regulations Cited
Page 1
U.S. Deportment
of Transportation
Federal Aviation
Administration
Ju:_l a Wl'-
Kristian Kortokrax ·
Dear Mr. Kortokrax:
Office of the Chief Counsel
800 Independence Ave., SW.
Washington, DC 20591
This is in response to your request for interpretation of 14 C.F.R. 61.195(b)(I) and (c), and clarification of the Grayson interpretation letter of July 6, 2010. It has been the FAA's consistent interpretation of §61.195(b) and (c) that, in order to conduct instrument flight training in an aircraft, a flight instructor must hold on his or her flight instructor certificate ( I ) aircraft category and class ratings for the aircraft in which the training is conducted, and (2) an instrument rating appropriate to the category of aircrafi. Interpretation to Taylor Grayson, January 4, 2010.
We hope this response is helpful to you. If you have additional questions regarding this matter, please contact my staff at (202) 267-3073. This response was prepared by Neal 0 'Hara, an attorney in the Regulations Division of the Office of the Chief Counsel, and was coordinated with the General Aviation and Commercial Division of the Flight Standards Service.
Sincerely,
Rebecca B. Mac herson
Assistant Chief Counsel for Regulations, AGC-200
Regulations Referenced
Snapshot retrieved August 6, 2026.