Legal Interpretations
Helton 1992
Summary
The Question
May a flight instructor holding only a third-class medical certificate receive compensation and act as pilot in command during an instructional flight?
Background
The Aircraft Owners and Pilots Association asked whether a certificated flight instructor with a third-class medical certificate may give flight instruction and act as pilot in command for compensation.
The FAA’s Interpretation
Yes, apparently. Part 61 Certification Bulletin 81-2, which discusses the medical certificate's relationship to flight instructor certificates, does not specifically address the issue, but a careful reading suggests a CFI may receive compensation and act as PIC during an instructional flight with only a third-class medical certificate.
- Requester
- Helton
- Issued
- June 12, 1992
- Subject
- Pilot Certification & Privileges
Regulations Cited
Letter text transcribed from the original PDF. Handwritten annotations remain available in Original Letter (PDF).
Page 1
Jun 12, 1992
Mr. Douglas S. Helton
Aircraft Owners and Pilots
Association 412 Aviation Way
Frederick, Maryland 21701-4798
Dear Mr. Helton:
This is in response to your May 21 letter seeking clarification regarding whether a certificated flight instructor (CFI) with a third class medical certificate may give flight instruction and act as pilot in command (PIC) for compensation.
Part 61, Certification Bulletin Number 81-2, discusses the need for a valid airman medical certificate and its relationship to flight instructor certificates. While the bulletin does not specifically address the issue raised in your letter, a careful reading of this bulletin suggests that a CFI may receive compensation and act as PIC during an instructional flight with only a third class medical certificate. We hope this information adequately addresses your question.
Sincerely,
Robert A. Wright
Acting Manager,
General Aviation and Commercial
Division
Regulations Referenced
Snapshot retrieved August 6, 2026.