Legal Interpretations
Rubin 1991
Summary
The Question
Must a certificated flight instructor who gives flight instruction for compensation hold a second-class medical certificate rather than a third-class one?
Background
A requester asked the FAA to confirm in writing what FAA certification staff had said by phone about which medical certificate a flight instructor needs when paid to give flight instruction.
The FAA’s Interpretation
No. A second-class medical certificate is not required to give flight instruction, and a third-class medical certificate is acceptable even when the instructor receives compensation and acts as pilot in command for the instruction flight. The FAA pointed to Part 61 Certification Bulletin 81-2, which discusses the airman medical certificate and its relationship to the flight instructor certificate.
- Requester
- Rubin
- Issued
- October 21, 1991
- Subject
- Pilot Certification & Privileges
Regulations Cited
Page 1
Oct 21, 1991
Dear Mr. Rubin,
This is in response to your October 7 letter seeking confirmation of information given to you during a telephone conversation with Mr. James Byers of my staff.
During that telephone conversation and in your October 7 letter, you asked whether a certificated flight instructor giving flight instruction for compensation is required to hold a current 2nd class medical certificate or whether a third class medical certificate is acceptable.
Mr. Byers correctly informed you that a 2nd class medical certificate is not a requirement to give the subject flight instruction and that a third class medical certificate would be acceptable even if the instructor was receiving compensation and acting as pilot in command for the instruction flight.
Part 61 Certification Bulletin Number 81-2 discusses the subject concerning the need for a valid airman medical certificate and its relationship to the flight instructor certificate. We have enclosed a copy of this publication for your information and convenience. We hope this information adequately addresses your questions and wish you success in your aviation endeavors.
Sincerely,
James R. Riddle
Manager, Certification Branch
Regulations Referenced
Snapshot retrieved August 6, 2026.