When can you log SIC time? FAA 14 CFR 61.51(f) and 61.55

Checked against the sources below on 29 October 2026. How these guides are written

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You can log second in command time only when a second pilot is required, either by the aircraft's type certificate or by the regulations the flight is conducted under, and you hold the ratings 61.51(f) lists. In an aircraft type certificated for two pilots you must also meet the 61.55 SIC qualifications, which look back 12 calendar months. A safety pilot logs SIC while the other pilot is under the hood. A second pilot added by company policy in a single-pilot aircraft cannot log SIC.

Two-pilot type certificate
Qualified under 61.55; occupy a crewmember station
Flight time in that seat
61.51(f)(1)
Second pilot required by TC or rules
Category, class and instrument rating (if required for the flight)
Time the second pilot is required
61.51(f)(2)
Part 135 SIC development program
Operator's OpSpecs; 61.159(c) met
Time in the program
61.51(f)(3), 135.99(c)
SIC recent experience
Type familiarisation; 3 takeoffs and 3 full-stop landings as sole manipulator; engine-out; CRM
Previous 12 calendar months
61.55(b)
SIC type rating
Needed unless the flight is domestic within US airspace; no practical test
Training within 12 calendar months of applying
61.55(a)(3), (d)
Part 121 SIC
ATP certificate and full type rating; an SIC-only type rating does not satisfy it
Every Part 121 flight
121.436(b)

When SIC time is loggable: 61.51(f)

61.51(f) says "a person may log second-in-command time only for that flight time during which that person" meets one of four tests. Most pilots use two of them. Under (f)(1) you are "qualified in accordance with the second-in-command requirements of § 61.55, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate". Under (f)(2) you hold "the appropriate category, class, and instrument rating (if a class or instrument rating is required for the flight)" and "more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted".

The other two are narrower. Paragraph (f)(3) covers a Part 135 SIC professional development program approved under 135.99(c), in aircraft that do not need a second pilot. Paragraph (f)(4), added in late 2024, covers a pilot designated as SIC by a government entity in a public aircraft operation; that time cannot be used for the private, commercial or instrument experience requirements.

The word that decides most questions is "required". In the June 2014 Cato interpretation a company flew a Citation certificated for one pilot and its policy required two. The FAA answered that the second pilot "is not a required flight crewmember, and cannot log the time as SIC". The same letter said that when the aircraft's certification calls for a second pilot, for example with an inoperative autopilot in that type, the second pilot becomes a required SIC and logs the flight.

The 61.55 SIC qualifications and the SIC type rating

To serve as SIC of an aircraft type certificated for more than one pilot, or in an operation that requires an SIC, 61.55(a) needs at least a private pilot certificate with the category and class rating, an instrument rating or privilege if the flight is IFR, and "at least a pilot type rating for the aircraft being flown unless the flight will be conducted as domestic flight operations within the United States airspace".

61.55(b) adds recent experience "within the previous 12 calendar months": familiarisation with the type's systems, performance, procedures, flight manual and placards, and "three takeoffs and three landings to a full stop as the sole manipulator of the flight controls", engine-out procedures and crew resource management, in the type or a simulator of it. Doing it in the month before or after the month it falls due counts as on time (61.55(c)). Pilots designated as PIC or SIC under Part 91 subpart K, 121, 125 or 135 in that type, and safety pilots under 91.109, are exempt from the training (61.55(f)).

The "SIC Privileges Only" type rating comes from 61.55(d) or (e). The trainer or a chief pilot, director of training or director of operations endorses your logbook that you have "demonstrated the skill and knowledge required for the safe operation of the [Type of Aircraft], relevant to the duties and responsibilities of a second in command", you file FAA Form 8710-1, and "there is no practical test". If your records are electronic, 61.55(d)(3) requires a paper copy carrying the trainer's signature.

Safety pilots and SIC time

91.109(c) makes a safety pilot a required crewmember whenever someone flies in simulated instrument conditions, so the safety pilot meets 61.51(f)(2) for that part of the flight. In the July 2012 Trussell interpretation, when the pilot under the hood acts as PIC and flies, the safety pilot "may log that time as SIC time because Pilot B holds the appropriate category and class ratings for the aircraft being flown and more than one pilot is required under the regulations under which the flight is being conducted". The 2014 Cato letter repeats it for a two-pilot crew in a single-pilot jet.

Trussell also covers the other arrangement. If the safety pilot agrees to act as PIC for the simulated instrument portion, the safety pilot logs that time as PIC under 61.51(e)(1)(iii), and the pilot under the hood logs it as PIC under (e)(1)(i) as sole manipulator. Either way the safety pilot is a required crewmember only while the hood is on, so outside that portion they log neither PIC nor SIC unless they are the sole manipulator. The instrument logging guide covers the safety pilot's qualifications.

SIC time for the ATP, Part 121 and Part 135

All SIC time counts toward the 1,500 hours of total time in 61.159(a). The 250 hours in 61.159(a)(5) must be "as a pilot in command, or as second in command performing the duties of pilot in command while under the supervision of a pilot in command", so plain SIC time does not fill it. SIC time from a 135.99(c) program counts toward the total under 61.159(c) but "may not be used to meet the aeronautical experience requirements in paragraph (a)(5)", and crediting it brings the ICAO limitation of 61.159(e) unless you show you meet the ICAO requirements.

To fly as SIC under Part 121 you need an ATP certificate and an appropriate type rating, and 121.436(b) states that "a second-in-command type rating obtained under § 61.55 does not satisfy the requirements of this section". Under Part 135, 135.245(a) needs at least a commercial certificate with category, class and an instrument rating. Operators set their own hiring minimums and decide what logged time they credit; the regulation and the operator's procedures take precedence over any summary.

Mistakes pilots make

  • Logging SIC as the second pilot in an aircraft certificated for one pilot because the company, a client or the insurer wants two. The FAA's Cato letter says that pilot is not a required crewmember.
  • Logging SIC as safety pilot for the whole flight. Only the time the other pilot is under the hood is loggable, and a safety pilot cannot log cross-country time.
  • Treating an SIC Privileges Only type rating as enough for Part 121 SIC or for logging PIC as sole manipulator. 121.436(b) and the Counsil interpretation say otherwise.
  • Letting the 61.55(b) three full-stop takeoffs and landings, engine-out and CRM lapse past 12 calendar months when your operator does not designate you under Part 91K, 121, 125 or 135.
  • Counting the same hour as both SIC and PIC toward total time.

What Off Chocks tracks

  • In FAA mode the seats are PIC, SIC, Relief (not SIC), PIC Under Supervision (not SIC) and Dual Received. The SIC seat counts as SIC on the FAA 8710-1 and IACRA summaries; the relief and supervised seats count as neither PIC nor SIC there.
  • Off Chocks does not track the 61.55(b) 12-month SIC requirements. You can add your SIC type rating or recurrent check in Credentials with its dates and get a reminder before it runs out.
  • The FAA ATP progress card fills its 250-hour PIC line from PIC entries only; SIC time performing PIC duties under supervision is not added, so that line can read low.

Common questions

Can a safety pilot log SIC time?
Yes, for the time the other pilot is in simulated instrument conditions, because 91.109(c) makes the safety pilot a required crewmember. The FAA's Trussell (2012) and Cato (2014) letters say so.
Can I log SIC in a single-pilot aircraft if my company requires two pilots?
No, unless the type certificate or the operating rules require the second pilot. A company policy does not make you a required crewmember (Cato, June 2014).
Do I need an SIC type rating?
Under 61.55(a)(3) you need at least an SIC type rating unless the flight is domestic within US airspace. Part 121 SIC needs an ATP certificate and a full type rating.
Does SIC time count toward the ATP?
It counts toward the 1,500 hours total. It counts toward the 250 hours of 61.159(a)(5) only when you were performing the duties of PIC under the supervision of a PIC.
How do I get an SIC Privileges Only type rating?
Complete the 61.55(b) training in the type within the 12 calendar months before you apply, get the logbook endorsement and an instructor's recommendation on FAA Form 8710-1, and apply to an examiner or Flight Standards office. There is no practical test.

Sources

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.

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