FAA instrument rating requirements: the 61.65 hours explained
Checked against the sources below on 29 October 2026. How these guides are written
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An FAA instrument-airplane rating under 14 CFR 61.65(d) needs 50 hours of cross-country time as pilot in command (10 in airplanes) and 40 hours of actual or simulated instrument time, 15 of them from an instructor with an instrument-airplane rating. The 40 must include 3 hours of training in an airplane within 2 calendar months of the test and a 250 nm IFR cross-country with an instructor. Training devices credit at most 20 hours, or 30 in an FFS or FTD in a Part 142 course.
- Cross-country as PIC
- 50 h, of which 10 h in airplanes; each flight lands more than 50 nm straight-line from departure
- Logged before the practical test
- 61.65(d)(1); 61.1 cross-country time (ii)
- Instrument time
- 40 h actual or simulated
- Logged before the practical test
- 61.65(d)(2)
- Instruction from a CFII
- 15 h of the 40, from an instructor with an instrument-airplane rating
- Logged before the practical test
- 61.65(d)(2)
- Recent training
- 3 h instrument flight training in an airplane
- Within 2 calendar months before the test date
- 61.65(d)(2)(i)
- Long IFR cross-country
- 250 nm along airways or ATC routing, IFR flight plan, approach at each airport, 3 kinds of approach
- One flight, in an airplane, with an instructor
- 61.65(d)(2)(ii)
- Device credit
- FFS or FTD 20 h (30 h in a Part 142 course); basic ATD 10 h; advanced ATD 20 h; 20 h combined
- Instructor-given time only
- 61.65(h), (i), (j)
50 hours of cross-country PIC: which flights count
61.65(d)(1) asks for "50 hours of cross-country time as pilot in command, of which 10 hours must have been in an airplane". For an instrument rating, 14 CFR 61.1 narrows cross-country time to a flight "that includes a point of landing that was at least a straight-line distance of more than 50 nautical miles from the original point of departure". A 45 nm trip to the next field is cross-country under the general definition but adds nothing toward these 50 hours.
PIC time follows 61.51(e). A student pilot logs PIC as sole occupant with a solo endorsement while training for a certificate (61.51(e)(4)), so solo cross-countries you flew as a student count when they pass the 50 nm test. If you apply for a combined private pilot certificate and instrument rating, 61.65(g)(1) lets you credit up to 45 hours of cross-country time "performing the duties of pilot in command with an authorized instructor".
Since 21 January 2025 the rule reads "cross-country time" where it used to read "cross-country flight time" (Amendment 61-157, 89 FR 92483). The hours did not change.
40 hours of instrument time and the 15 from a CFII
61.65(d)(2) asks for "Forty hours of actual or simulated instrument time in the areas of operation listed in paragraph (c) of this section, of which 15 hours must have been received from an authorized instructor who holds an instrument-airplane rating". Under 61.51(g)(1) you log instrument time only when you operate the aircraft "solely by reference to instruments under actual or simulated instrument flight conditions".
The other 25 hours need no instructor. In an interpretation to Scott Rohlfing, the FAA Chief Counsel repeats its earlier answer to Taylor Grayson: instrument time "other than instrument training does not require the presence of a CFI but only the presence of an individual qualified to act as a safety pilot". Hood time with a safety pilot counts toward the 40, and the safety pilot's name goes in your logbook (61.51(b)(1)(v)).
The same interpretation settles a common private pilot question. The 3 hours of instrument flight training from 61.109(a)(3) count toward the 40 hours, and toward the 15 only if the instructor who gave them held an instrument rating on their flight instructor certificate.
The 3 recent hours and the long IFR cross-country
The 40 hours must include "Three hours of instrument flight training from an authorized instructor in an airplane that is appropriate to the instrument-airplane rating within 2 calendar months before the date of the practical test" (61.65(d)(2)(i)). These 3 hours have to be in an airplane, so a simulator session inside the window does not meet the item.
61.65(d)(2)(ii) asks for one cross-country flight in an airplane with an instructor, "performed under instrument flight rules, when a flight plan has been filed with an air traffic control facility", involving "A flight of 250 nautical miles along airways or by directed routing from an air traffic control facility", "An instrument approach at each airport" and "Three different kinds of approaches with the use of navigation systems". The 250 nm is the distance flown along airways or ATC routing, not a straight line.
The flight is instruction received. If you hold a private pilot certificate with the airplane class rating and you are the sole manipulator of the controls, 61.51(e)(1)(i) also lets you log it as PIC, so its time counts toward the 50 hours of cross-country PIC as well.
How much simulator and training device time counts
Instrument time given by an instructor in a full flight simulator (FFS) or flight training device (FTD) credits up to 30 hours when it was "completed in accordance with part 142" and up to 20 hours otherwise (61.65(h)). In an aviation training device (ATD) the limit is "10 hours of instrument time received in a basic aviation training device or a maximum of 20 hours of instrument time received in an advanced aviation training device", and only if the FAA approved the device and the training and an instructor gave the time (61.65(i)).
61.65(j) caps the mix: except under the Part 142 allowance, you "may not credit more than 20 total hours of instrument time in a full flight simulator, flight training device, aviation training device, or a combination". 10 hours in a basic ATD plus 15 in an FTD credits 20 hours, not 25.
For device time to count toward the rating, 61.51(g)(4) requires that "an authorized instructor is present to observe that time and signs the person's logbook or training record". AC 61-136B says examiners are told to ask for a copy of an ATD's letter of authorization (LOA), so keep it with your logbook. You can log any amount of device time; only the credit is capped.
Mistakes pilots make
- Counting cross-country flights that land 50 nm or less (straight line) from the departure airport. They are cross-country in your logbook but not toward 61.65(d)(1).
- Putting safety pilot hood time toward the 15 hours. The 15 must come from an instructor who holds an instrument-airplane rating.
- Stacking device time. 10 hours in a basic ATD and 20 hours in an advanced ATD still credit 20 hours in total outside a Part 142 course (61.65(j)).
- Logging device instrument time without the instructor's signature. Without it the time does not count toward the rating under 61.51(g)(4).
- Flying the 3 recent hours in a simulator, or so early that a delayed checkride pushes them outside the 2 calendar months. 61.65(d)(2)(i) needs an airplane, and the window runs back from the test date.
What Off Chocks tracks
- The Instrument Rating progress counts 50 hours of cross-country PIC and 40 hours of actual plus simulated instrument time, and caps the training-device share of the instrument time at 20 hours.
- A flight counts as cross-country on its own when its two airports are more than 50 nm apart; a cross-country figure you type in yourself takes precedence.
- It does not yet check the 15 hours from a CFII, the 10 hours in airplanes, the 3 hours in 2 calendar months or the long IFR cross-country, and it does not apply the 30-hour Part 142 limit or tell a basic ATD from an advanced one (its device types are FFS, FTD, BIT and Other). Check those against your logbook and the device's LOA.
Common questions
- How many hours do you need for an FAA instrument rating?
- 61.65(d) sets no total time. It sets the cross-country PIC, instrument time and instruction minimums in the table above.
- Does safety pilot hood time count toward the 40 hours?
- Yes. The FAA Chief Counsel says instrument time other than the 15 hours of training needs only a person qualified to act as safety pilot. It does not count toward the 15.
- Do my student solo cross-countries count toward the 50 hours of PIC cross-country?
- Yes, when each one landed more than 50 nm straight-line from the departure point. 61.51(e)(4) lets a student with a solo endorsement log PIC as sole occupant.
- How much simulator time counts toward an instrument rating?
- Up to 20 hours of instructor-given time in an FFS, FTD or ATD combined, with a basic ATD limited to 10. In a Part 142 course an FFS or FTD can credit up to 30 hours (61.65(h) to (j)).
- Does the long IFR cross-country have to be 250 nm in a straight line?
- No. 61.65(d)(2)(ii)(A) says "250 nautical miles along airways or by directed routing from an air traffic control facility", with an approach at each airport and three different kinds of approach.
Sources
- 14 CFR 61.65 Instrument rating requirements (eCFR, up to date as of 27 Oct 2026)
- 14 CFR 61.1 Applicability and definitions: cross-country time (eCFR)
- 14 CFR 61.51 Pilot logbooks (eCFR)
- FAA Chief Counsel legal interpretation to Scott Rohlfing on 14 CFR 61.65(d)(2)
- FAA Advisory Circular 61-136B: FAA Approval of Aviation Training Devices and Their Use for Training and Experience (2018)
This is a plain-words summary to help you keep your own records, not legal advice. The regulation and your operator's procedures always take precedence.