14 CFR 61.65

Last reviewed July 14, 2026 by Noah Lencki, CFI.

Instrument Rating Requirements — 14 CFR 61.65 Explained

The instrument rating is where flight training stops being a checklist of maneuvers and starts being a second, parallel set of skills layered on top of a certificate the student already holds. §61.65 reflects that: it isn't one hour requirement with a few carve-outs the way §61.109 is — it's four distinct gates (eligibility, knowledge, flight proficiency, and aeronautical experience) that all have to be true before an applicant can test. Here's what each one requires, and where the numbers actually come from.

Eligibility — §61.65(a)(1)–(2)

Before anything else, the applicant has to hold at least a current private pilot certificate — or be concurrently applying for one — with the airplane, helicopter, or powered-lift rating appropriate to the instrument rating sought. A student pilot can work toward both certificates in parallel, but the instrument rating can't stand alone; it's built on top of a private certificate, not instead of one. The section also carries an English- proficiency requirement, with room for the Administrator to place operating limitations on an applicant who can't meet it for medical reasons.

Aeronautical Knowledge and the Knowledge Test — §61.65(a)(3)–(4), (b)

The applicant needs ground training from an authorized instructor, or a home-study course, covering ten listed knowledge areas — the regulations governing IFR operations, the Aeronautical Information Manual, ATC procedures, IFR navigation and approaches, chart use, weather, safe operation under IFR, windshear recognition, aeronautical decision-making, and crew resource management. Two logbook endorsements sit on either end of this: one certifying the applicant is prepared to take the knowledge test (§61.65(a)(4)), and the applicant then has to pass it (§61.65(a)(7)) — with one exception carved out for someone who already holds an instrument rating and is adding a category, who doesn't have to sit the knowledge test again.

Flight Proficiency — §61.65(a)(5), (c)

Training has to cover eight areas of operation, in an aircraft, full flight simulator, or flight training device appropriate to the rating: preflight preparation, preflight procedures, ATC clearances and procedures, flight by reference to instruments, navigation systems, instrument approach procedures, emergency operations, and postflight procedures. These are the instrument ACS's areas of operation — the skills a designated examiner actually evaluates on the practical test, distinct from the hour floors below.

Aeronautical Experience — §61.65(d)

This is the bucket with the numbers most people already half-know, and the one where the details matter more than the totals.

50 Hours of Cross-Country PIC

§61.65(d)(1) requires 50 hours of cross-country time as pilot in command, of which at least 10 hours must be in an airplane (for the instrument-airplane rating specifically — the helicopter and powered-lift ratings each carry their own 10-hour in-category floor). This can be built up well before instrument training starts; it's PIC cross-country time from anywhere in a pilot's logbook, not time flown specifically toward the rating. One wrinkle worth knowing: §61.65(g) lets an applicant pursuing a combined private + instrument path credit up to 45 of the 50 hours from cross-country time performing the duties of pilot in command with an authorized instructor aboard — a narrower path that doesn't apply to a pilot who already holds their private certificate outright.

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, and the instrument time includes...

14 CFR 61.65(d)(2) — read it at eCFR.gov

40 Hours of Instrument Time — and the 15-Hour Instructor Sub-Requirement

The 40-hour bucket takes actual or simulated instrument time without distinction — unlike the Commercial instrument requirement under §61.129(a)(3)(i), which specifically requires a view-limiting device and excludes actual IMC. For the instrument rating, hood time and real IMC count identically toward the 40.

What's easy to miss is the sub-requirement buried in the same sentence: 15 of those 40 hours must have been received from an authorized instructor who holds an instrument-airplane rating — a CFII, not just any CFI. A student who logs instrument time with a safety pilot, or under the hood with an instructor who isn't instrument-rated, is building real instrument proficiency but not necessarily satisfying this specific 15-hour floor. It's a sub-total inside the 40, not a separate bucket, and a school tracking the 40-hour number alone can watch a student clear it without the 15 actually being covered.

The 250-Nautical-Mile Cross-Country

Inside the 40 hours, §61.65(d)(2)(ii) requires instrument flight training on cross-country procedures, including one specific flight: flown with an authorized instructor, under instrument flight rules, on a filed flight plan, covering 250 nautical miles along airways or ATC-directed routing, with an instrument approach at each airport on the route, and three different kinds of approaches using navigation systems. All three conditions — the distance, an approach at every stop, and approach variety — have to be satisfied on the same flight. It's the single most logistically complex training event in the entire rating, and usually the one that gets scheduled last because it needs a full day, cooperative weather, and enough sequential IFR training already behind the student to fly it productively.

3 Hours Within 2 Calendar Months of the Test

§61.65(d)(2)(i) requires 3 hours of instrument flight training within 2 calendar months before the date of the practical test — the same calendar-month framing used for the private pilot test-prep window under §61.109(a)(4): a test in June is covered by training flown any day in April, May, or June, with no distinction between the 1st of the window and the 29th.

Simulator and Training Device Credit

Instrument time earned in a full flight simulator or flight training device counts toward the 40 hours, capped at 20 hours — or 30 hours if the training was completed under a part 142 course (§61.65(h)). Aviation training devices are capped separately: 10 hours for a basic ATD, 20 hours for an advanced one (§61.65(i)). Stack every device category together and, outside the part 142 exception, no more than 20 total hours of FFS/FTD/ATD time may count toward the 40-hour requirement (§61.65(j)) — the rest has to come from an actual airplane.

Practical Test Prerequisites

Once the knowledge test is passed and the hour floors above are met, an instrument applicant faces the same universal gate every certificate and rating does: §61.39's practical-test prerequisites — the endorsement certifying recent training, overall preparedness, and that knowledge-test weak areas were addressed, plus the knowledge test's own 24-calendar-month currency window. §61.65(a)(6) layers an instrument-specific version of the same idea on top: a separate endorsement certifying the applicant is prepared to take the instrument practical test specifically.

What this means for your school

Instrument students are longer-term revenue than most schools give them credit for — 40 hours of instrument time plus 50 of cross-country PIC rarely compresses into a short syllabus, and a student training toward commercial or CFI afterward keeps flying with you well past the instrument checkride. The two numbers that are easiest to lose track of on a spreadsheet are the ones buried inside larger totals: the 15-of-40 instructor sub-requirement (a student can hit 40 hours of instrument time without 15 of it coming from a CFII) and the overlap between cross-country PIC and instrument training on the 250nm flight, which counts toward both requirements at once but only if it's tagged that way. Neither shows up correctly on a bar that just adds up a single "instrument" column.

An instrument rating is built on top of the private pilot certificate under §61.109 and gated at the far end by the same §61.39 practical-test prerequisites every other certificate and rating shares. For how Part 61 training structures a school's day-to-day tracking burden more broadly, see Part 61 vs. Part 141.

The 15-of-40 sub-requirement is exactly the kind of thing a spreadsheet loses.

Maverick tracks cross-country PIC, the 40-hour instrument bucket, and the CFII-instructor sub-portion separately, per student, per flight — so a student can't read "met" on a bar that's actually missing the requirement buried inside it.

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Frequently asked questions

The floor is 40 hours of actual or simulated instrument time under 14 CFR 61.65(d)(2), of which 15 hours must come from an authorized instructor who holds an instrument-airplane rating. Separately, the applicant needs 50 hours of cross-country time as pilot in command, at least 10 of which must be in an airplane (§61.65(d)(1)). Those two floors run in parallel, not in sequence, and most instrument students log well past both before they're actually ready for the checkride.

Not on its own — §61.65(a)(1) requires holding at least a current private pilot certificate, or applying for one concurrently, with the category and class rating appropriate to the instrument rating sought. A student pilot can train toward both at once, but the instrument rating itself can't be issued to someone who doesn't hold, or isn't simultaneously earning, the private certificate.

There's no calendar requirement in §61.65 — only hour floors and proficiency. A private pilot flying two or three times a week can typically finish in a few months; flying less often stretches it out, both because skill decays between lessons and because the 40-hour instrument bucket and the 250-nautical-mile cross-country each take real scheduling to complete. Weather is usually the bigger constraint than the student, since instrument training benefits from actual IMC exposure that isn't available on demand.

Yes — §61.65(d)(2) counts "actual or simulated instrument time" toward the 40-hour bucket without distinction between the two, unlike the Commercial instrument requirement, which requires a view-limiting device specifically. Full flight simulators and flight training devices count too, capped at 20 hours (30 under a part 142 course) per §61.65(h), and basic or advanced aviation training devices are separately capped at 10 or 20 hours under §61.65(i) — with a combined ATD/FTD/FFS ceiling of 20 hours unless the part 142 exception applies (§61.65(j)).

§61.65(d)(2)(ii) requires one cross-country flight under IFR, on a filed flight plan, covering 250 nautical miles along airways or ATC-directed routing, with an instrument approach at each airport on the route and three different kinds of approaches using navigation systems. It's a single flight that has to satisfy all three conditions at once — distance, an approach at every stop, and approach variety — not three separate flights that can be pieced together.