Instrument Time Credit Rules
A practical interpretation of FAA legal opinion on how private pilot instrument training applies toward instrument rating requirements.
Key Conclusion
Private pilot instrument training can count toward total instrument time, but cannot count toward required instrument instruction hours unless given by a qualified CFII.
Why It Matters
Common confusion:
- All instrument-related training counts the same
- Any instructor time can be credited equally
The FAA separates instrument time from instrument training.
Core Logic
1. Two different requirements
For an instrument rating:
- 40 hours → total instrument time
- 15 hours → instrument training with CFII
👉 These are not interchangeable
2. Private pilot instrument training can count
The 3 hours under §61.109(a)(3):
- “Control and maneuvering by reference to instruments”
👉 Can be applied toward the 40-hour instrument time requirement
3. But not all of it counts as training
To count toward the 15-hour requirement:
- Must be given by a CFII
👉 If the instructor is not instrument-rated, it does not qualify
4. Key distinction
- Instrument time = time spent flying by reference to instruments
- Instrument training = instruction from a qualified CFII
👉 Only the latter satisfies the 15-hour requirement
5. Regulatory intent
The FAA ensures:
- Quantity (40 hours) can include broader experience
- Quality (15 hours) must come from qualified instructors
Common Misunderstandings
- ❌ “All instrument time counts toward the 15 hours”
- ❌ “Instructor qualification doesn’t matter”
👉 Instructor qualification determines training credit
One-Sentence Summary
Instrument time can come from various sources, but required instrument instruction must come from a CFII.