Earning a commercial pilot certificate marks a significant step in a pilot's career, but the regulatory framework governing what time you can log, how currency is maintained, and what requirements must be met before carrying passengers for compensation is far more layered than at the private level. A deep understanding of 14 CFR Parts 61 and 91, along with the Pilot's Handbook of Aeronautical Knowledge (PHAK, FAA-H-8083-25), is essential both for passing the FAA Commercial Pilot Knowledge Test and for operating legally and safely in the real world. This article covers the full landscape: logging rules, currency requirements, the flight review, and the traps that catch even experienced pilots off guard.
What Flight Time Can You Log?
The foundational logging rule is 14 CFR §61.51, and it applies to every certificate level. A pilot may log pilot-in-command (PIC) time when they are: (1) the sole manipulator of the controls of an aircraft for which they hold the appropriate category and class rating; (2) the sole occupant of the aircraft; or (3) acting as PIC of an operation that requires more than one required pilot by regulation or by the aircraft's type certificate. Note that being rated in the aircraft is the key trigger for criterion one—sitting in the left seat of an aircraft for which you hold no rating does not entitle you to log PIC time, even if you are physically flying it.
Second-in-Command (SIC) Logging
Second-in-command time may be logged under §61.51(f) only when a second pilot is required by the aircraft's type certificate, the applicable operating regulations, or the specific FAA operating rules under which the flight is conducted. If the aircraft is certificated for single-pilot operation and you are acting as a voluntary safety pilot under 14 CFR §91.109, you may log SIC time—but only if you are serving as a required crewmember. To be a required crewmember in that context, the pilot under the hood must be operating under simulated instrument conditions, which triggers the safety pilot requirement. Critically, both pilots must agree before the flight on who logs PIC time, since the safety pilot acting as required crewmember qualifies to log PIC (as sole manipulator criterion shifts to the other pilot) only under the conditions spelled out in §61.51(e).
Logging Flight Training and Instruction Time
A commercial pilot who also holds a flight instructor certificate (CFI) may log pilot-in-command time as the sole manipulator while conducting flight instruction, provided they are rated in that aircraft. The student simultaneously logs dual received. The ability to log PIC during instruction is one reason many commercial pilots pursue the CFI rating early—it builds turbine and complex time efficiently while earning income. However, the CFI candidate must understand that acting as an authorized instructor and logging PIC are governed by different subsections of §61.51 and should not be conflated with operating as PIC under Part 135.
Passenger-Carrying Currency: The 90-Day Rule
Even a pilot with a valid commercial certificate and a current flight review cannot legally carry passengers without recent flight experience. Under 14 CFR §61.57(a) and (b), within the preceding 90 days a pilot must have made at least three takeoffs and three landings in an aircraft of the same category, class, and type (if a type rating is required). For night passenger operations—defined as the period from one hour after sunset to one hour before sunrise—those three takeoffs and three landings must each be to a full stop and must occur during that same night period.
Tailwheel and Other Aircraft-Specific Requirements
Tailwheel aircraft impose an additional layer: all three landings for currency must be to a full stop, regardless of whether the operation is during the day or at night. This is because wheel landings and three-point landings in a conventional-gear aircraft have distinct characteristics that demand deliberate practice. A pilot transitioning from a tricycle-gear airplane to a tailwheel commercial operation must satisfy this full-stop requirement before carrying passengers, even in broad daylight.
For large, turbine-powered multiengine airplanes, §61.57(e) adds a separate currency track: within the preceding 90 days, the pilot must have made three takeoffs and three landings in the same type of airplane, and at least one of those landings must have been made to a full stop. This provision exists because the handling characteristics of large turbine aircraft differ substantially from smaller piston aircraft, even within the same category and class.
Instrument Currency
Instrument currency is required any time a pilot acts as PIC under instrument flight rules (IFR). Under 14 CFR §61.57(c), within the preceding six calendar months a pilot must have performed, in actual or simulated instrument conditions, at least: six instrument approaches, holding procedures and tasks, and intercepting and tracking courses through the use of navigational electronic systems. These tasks may be accomplished in an aircraft, in a full flight simulator, or in a flight training device approved for the purpose.
If the six-calendar-month window lapses without meeting these requirements, the pilot enters a second six-calendar-month grace period under §61.57(d) during which they may still act as PIC under IFR, but only for the purpose of re-establishing instrument currency in actual or simulated instrument conditions. There is no regulatory requirement that a separate safety pilot serve as PIC during this grace period—the pilot working to regain currency remains PIC and may log the flight themselves, whether flying in actual instrument conditions or with a safety pilot aboard (required only if practicing under simulated instrument conditions in VMC per §91.109). If currency is not re-established by the end of that second six-calendar-month window, the pilot must complete an Instrument Proficiency Check (IPC) with an authorized instructor before acting as PIC under IFR. The IPC is not simply a currency flight; it must cover the areas of operation specified in the instrument rating Airman Certification Standards (ACS).
The Flight Review Requirement
Separate from and in addition to all currency requirements, 14 CFR §61.56 mandates that every pilot acting as PIC must have completed a flight review within the preceding 24 calendar months. The review must include at least one hour of ground training and one hour of flight training with an authorized instructor. The instructor reviews current general operating and flight rules of 14 CFR Part 91, as well as the maneuvers and procedures necessary to safely exercise the privileges of the certificate held.
Importantly, successfully completing a practical test for an additional certificate or rating satisfies the flight review requirement—the calendar resets from the date of that test. A pilot who adds a multi-engine rating or an instrument rating on January 15 does not need a separate flight review until January 31 two years later (the end of the 24th calendar month). This interplay between practical tests and flight reviews is a frequent topic on the FAA knowledge test.
Key Numbers and Rules to Know
- 90 days / 3 takeoffs and 3 landings — required for passenger-carrying day VFR privileges (same category, class, type).
- Night currency — same 90-day/3-landing rule, but landings must be full stop and within the night period (1 hour after sunset to 1 hour before sunrise).
- Tailwheel — all three landings must be full stop, day or night.
- 6 calendar months / 6 approaches + holds + intercepts/tracking — required for IFR PIC privileges.
- 24 calendar months — maximum interval between flight reviews.
- IPC — required after two consecutive six-calendar-month periods without instrument currency; must cover IFR ACS task areas.
- Commercial certificate required under 14 CFR §61.133 before acting as PIC for compensation or hire.
Common Test Traps
- Certificate vs. currency confusion: A commercial certificate never expires, but the privileges to exercise it lapse with currency. An expired flight review grounds you even with a valid certificate.
- Day currency does not cover night passengers: Three daytime touch-and-go landings satisfy day currency but not night passenger-carrying requirements, which demand full-stop landings during the night period.
- Calendar months vs. days: A flight review completed on March 15 is valid through the end of March two years later (March 31), not exactly 730 days later. The same logic applies to instrument currency.
- Safety pilot PIC logging: The safety pilot may log PIC only when acting as a required crewmember. Both pilots cannot simultaneously log PIC time under the sole-manipulator and required-crewmember criteria—only one basis applies per pilot per flight segment.
- Type rating currency: For large or turbine aircraft requiring a type rating, the 90-day currency must be in the same type, not just the same category and class.
- IPC vs. currency flight: Flying six approaches during the grace period re-establishes currency; but after the grace period expires, only an IPC with a CFII restores IFR privileges.