Legal Interpretations
Beard 2012
Summary
The Question
May a flight instructor with an instrument rating but no aircraft category and class ratings give instrument training in a flight simulator or flight training device?
Background
A requester asked about 14 CFR 61.195, which was written before simulators and training devices could be used for training, regarding instrument instruction for instrument, commercial, and ATP applicants in those devices.
The FAA’s Interpretation
No. The FAA has consistently read 14 CFR 61.195(b) and (c) to require an instructor giving instrument training in an aircraft to hold category and class ratings for that aircraft and an instrument rating appropriate to its category. Because simulators and training devices replicate flight by category and class, the same requirements apply to them. The FAA will examine whether to clarify the rule.
- Requester
- Beard
- Issued
- October 17, 2012
- Subject
- Pilot Certification & Privileges
Regulations Cited
Page 1
U.S. Department
of Transportation
Federal AV'iation
Administration
OCT i 7 2U1t
Dear Mr. Beard:
Office of the Chief Counsel
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 Flight Instructor Limitations and Qualifications, specifically whether a pilot who holds a flight instructor certificate with an instrument rating but no aircraft category and class ratings can give instrument instruction to instrument, commercial and ATP applicants in a flight simulator or flight training device.
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 aircraft. Interpretation to Taylor Grayson, January 4, 2010. As§ 61.195 was originally written before the rules permitted flight simulators and flight training devices to be used for training, it does not mention conducting instrument flight training in those devices. However, the FAA has interpreted the instructor requirements under this section to apply to instruction in flight simulators and flight training devices, as well, since these devices are designed to replicate flight by category and class of aircraft. The FAA wi11 examine §61.195 to determine whether we need to clarify the regulation.
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 O'Hara, an attorney in the International Law, Legislation and 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,
fr~Jj'J2
Rebecca ~~cPherson
Assistant Chief Counsel for International Law,
Legislation and Regulations Division, AGC-200
Regulations Referenced
Snapshot retrieved August 6, 2026.