AC 61-146

Advisory circular · Pilot Certification and Operations for Sport Pilots, Flight Instructors with a Sport Pilot Rating, and Simplified Flight Controls

Approved
November 14, 2025
Last reviewed
November 18, 2025
Family
AC 61-146 · 1 version
14 CFR parts
61

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed December 5, 2025.

Show pages 1–12

3-6 certificate or BasicMed compliance to provide this training, in accordance with 14 CFR § 61.23(a)(3)(ii) or § 61.329(b), as applicable.

3.8 Compensation for Flight Training Provided by Flight Instructors With a Sport Pilot Rating. Sport pilots may not act as PICs of an aircraft that is carrying a passenger or property for compensation or hire or in furtherance of a business. However, the FAA acknowledges that flight instructors with a sport pilot rating (14 CFR part 61 subpart K) receive compensation for conducting flight training. MOSAIC added new 14 CFR § 61.413(d) to specifically permit this privilege for 14 CFR part 61 subpart K flight instructors. Therefore, a flight instructor with a sport pilot rating may receive compensation for providing flight training in accordance with 14 CFR part 61 subpart K.

A flight instructor may not receive compensation for any other activities or forms of aerial work.

3.9 Aviation Training Device or Flight Simulation Training Device (FSTD) Credit. Sport pilots may credit up to 2.5 hours of training credit in a qualified FSTD or FAA-approved aviation training device representing the appropriate category and class of aircraft to meet the experience requirements of 14 CFR part 61 subpart J if that training was received from an authorized instructor (14 CFR § 61.313(b)).

3.10 Practical Test Required for an Airplane or Helicopter Privilege. The MOSAIC final rule adopted a new requirement in 14 CFR § 61.321(b) to require a practical test when adding an airplane or helicopter privilege to a sport pilot certificate. Though the practical test is a new requirement for the new helicopter privilege, this is a change for sport pilots adding airplane privileges, as sport pilots are no longer able to accomplish a sport pilot proficiency check when adding airplane privileges. Due to the new performance limits and design requirements for aircraft, the FAA determined that the operational differences between airplane and helicopter compared to the other sport pilot privileges are significant enough to warrant a practical test. As a result, 14 CFR part 61 now requires a pilot seeking to add an airplane single-engine or rotorcraft-helicopter privilege to their existing sport pilot certificate to accomplish a practical test. However, pursuant to 14 CFR § 61.321(a), a proficiency check is still required when adding an additional glider, gyroplane, airship, balloon, powered parachute, or weight-shift-control sport pilot privilege.

3.11 New Rotorcraft-Helicopter Privilege for Sport Pilots and Flight Instructors With a Sport Pilot Rating.

3.11.1 Helicopter Privilege. MOSAIC introduced a new helicopter privilege for sport pilots.

These helicopters must be certificated with a simplified flight controls designation during aircraft certification and meet the performance limits and design requirements of 14 CFR § 61.316.

3.11.2 Sport Pilot Training and Flight Time Requirements. A sport pilot who seeks to obtain a rotorcraft category and helicopter class privilege is required to log at least 30 hours of helicopter flight time, including at least 15 hours of flight training, 5 hours of which must

3-7 be solo flight training in the areas of operation listed in 14 CFR § 61.311. Refer to 14 CFR § 61.313(a)(9) for additional requirements within the 30 hours.

3.11.3 Flight Instructors With a Sport Pilot Rating. A pilot who seeks to obtain a flight instructor with sport pilot rating for a rotorcraft category and helicopter privilege is required to log at least 150 hours of flight time as a pilot, including at least 50 hours of helicopter flight time, and at least 15 hours of PIC time in a helicopter. Refer to 14 CFR § 61.411(h).

Additionally, pursuant to 14 CFR § 61.409, the pilot must receive and log ground and flight training from an authorized instructor on the areas of operation of 14 CFR § 61.409 in the rotorcraft category and helicopter class.

3.12 Sport Pilot and Sport Pilot Flight Instructor for Rotorcraft-Helicopter; Airman Certification Standards (ACS). With the anticipation of aircraft certification of helicopters with simplified flight controls, the FAA created two ACS documents:

FAA-S-ACS-26, Sport Pilot for Rotorcraft Category Helicopter—Simplified Flight Controls Privilege Airman Certification Standards; and FAA-S-ACS-31, Flight Instructor with a Sport Pilot Rating for Rotorcraft Category Helicopter—Simplified Flight Controls Privilege Airman Certification Standards. These ACS documents are incorporated by reference in 14 CFR § 61.14 and are required when taking a practical test. The tasks listed in the ACS documents align with the areas of operation in 14 CFR §§ 61.311 and 61.409 for the sport pilot or flight instructor with a sport pilot rating in a helicopter with simplified flight controls.

4-1 CHAPTER 4. SIMPLIFIED FLIGHT CONTROLS DESIGNATION

4.1 Model-Specific Endorsement for Aircraft Certificated With a Simplified Flight Controls Designation. The MOSAIC rulemaking created a new aircraft designation:

simplified flight controls. Aircraft with simplified flight controls are dependent upon automation rather than a pilot’s hand-flying skills to control the aircraft’s flight path and available power. As a result, the FAA added training and qualification requirements for all pilots seeking to act as PICs of an aircraft with a simplified flight controls designation, regardless of their grade of certificate. Specifically, to operate an aircraft with simplified flight controls, a pilot must obtain model-specific training and a logbook endorsement from an authorized instructor in accordance with 14 CFR § 61.31(l) if the pilot already holds the applicable category and class rating or privilege. If the pilot is seeking an initial certificate or rating in that category and class, the pilot must take a practical test. Refer to 14 CFR § 61.45(h).

4.1.1 Simplified Flight Controls Versus Conventional Flight Controls. With the addition of this new simplified flight controls aircraft designation, some pilots may begin their flying career in an aircraft with the simplified flight controls designation. Pilots earning a certificate with an initial aircraft category and class rating or privilege in an M/M with simplified flight controls designation will only be able to fly that specific M/M aircraft after completion of a practical test. Refer to 14 CFR § 61.45(g)(4) and (h)(2). To fly an aircraft within the same category and class without simplified flight controls, the pilot will need to take an additional practical test to demonstrate their ability and skills in an aircraft equipped with conventional flight controls, in accordance with 14 CFR § 61.45(h)(2). For example, if a pilot started their flying in a rotorcraft-helicopter with simplified flight controls and they now seek to operate a helicopter with conventional flight controls, that pilot will need to take an additional practical test.

4.1.2 Flight Training Hour Requirements. There are no prescriptive training hour requirements for simplified flight controls training in accordance with 14 CFR § 61.31(l). The intent is to retain flexibility and deference to an authorized instructor’s expertise in determining when a person is sufficiently proficient in the aircraft operation.

4.1.3 Pilot Training and Endorsement Requirements. Training and endorsement are required for each M/M of aircraft with a simplified flight controls designation prior to operating as PIC under 14 CFR § 61.31(l). This training can be combined with an initial category and class rating or privilege for a pilot certificate, in which case a practical test is required.

4.1.4 Multiple Category and Class Ratings or Privileges With Simplified Flight Controls.

Additionally, if a person already holds a category and class rating or privilege with an M/M simplified flight controls limitation and seeks to operate a different category and class of aircraft with a simplified flight controls designation, that person is required by 14 CFR § 61.45(h)(2) to complete a practical test for that category and class of aircraft.

This is assuming the person does not already hold the category and class rating or privilege on their certificate. For example, if a pilot holds a rotorcraft-helicopter with simplified flight controls limitation and seeks to add an Airplane Single-Engine Land (ASEL) with simplified flight controls but does not already hold the ASEL rating on their

4-2 certificate, they will need to take a practical test in an airplane with simplified flight controls designation. If they do hold the category and class rating or privilege, they will only need the training and endorsement for the specific M/M simplified flight controls limitation, per 14 CFR § 61.45(h)(1). As another example, if a pilot holds a rotorcrafthelicopter with simplified flight controls limitation and seeks to operate a different M/M helicopter with simplified flight controls, they will need the specific M/M training and endorsement but are not required to complete a practical test since they already hold that category and class rating or privilege.

4.1.5 Airman Certification Simplified Flight Controls Requirements Table. Appendix A provides a table of examples of scenarios for airman certification simplified flight controls requirements and will help pilots navigate the new simplified flight controls training and testing requirements.

4.1.6 Simplified Flight Controls Experience Credit. As specified in 14 CFR § 61.9, the FAA set limitations on the applicability of pilot time acquired while operating an aircraft with a simplified flight controls designation that may be credited when seeking a higher-grade pilot certificate or rating. Experience gained by piloting aircraft with simplified flight controls is not equal to the experience acquired when operating aircraft equipped with conventional flight controls due to the reliance on automated operations. The unique operating characteristics of each M/M aircraft with simplified flight controls designation are expected to result in significant differences in pilot skills required for safe operations.

4.1.6.1 Consequently, PIC flight time gained in an aircraft with simplified flight controls is inapplicable for use in satisfying aeronautical experience requirements for higher grades of pilot certificates using conventional flight controls. For example, a person seeking a Commercial Pilot Certificate with a rotorcraft category helicopter class rating may not use pilot time acquired in a helicopter with simplified flight controls designation to meet the PIC flight time experience requirement in 14 CFR § 61.129(c)(2)(i), which requires 35 hours of PIC flight time in a helicopter, due to the differing operational characteristics between the flight controls.

4.1.7 Private Pilot Practical Test in an Aircraft With Simplified Flight Controls Designation.

Pursuant to 14 CFR § 61.9, Private Pilot Certificate applicants who present an aircraft with the simplified flight controls designation for the practical test may count solo time or PIC time in 14 CFR part 61 subpart E. This exception is not provided for higher-grade pilot certificates because the higher-grade pilot certificates require greater aeronautical knowledge, skills, and experience, and afford greater operational privileges (e.g., carrying passengers for compensation or hire) that are higher on the safety continuum and therefore require greater risk mitigation.

4.2 Flight Instructor Training and Endorsement Requirements for Aircraft With a Simplified Flight Controls Designation. Both 14 CFR part 61 subpart H and subpart K flight instructors are required to obtain the M/M limitation prior to conducting flight instruction in that M/M of aircraft with simplified flight controls designation, in accordance with 14 CFR §§ 61.195(m) and 61.415(m).

4-3

4.2.1 Initial Cadre Instructor Pilots. Since the simplified flight controls designation is a new regulatory requirement, the FAA created a provision in 14 CFR § 61.195(n) for a pilot to become initially qualified in an aircraft that is ce r tificated with this simplified flight controls designation. During the aircraft certification process, pilots employed by or used by the manufacturer will gain experience in aircraft with simplified fligh t c ont rols a nd be the best qualified persons to provide initial instruction to authorized instructors and Designated Pilot Examiners (DPE). Title 14 CFR § 61.195(n) refers to these persons as instructor pilots. The instructor pilot must comply with the operational limitations of the aircraft to provide flight training. AC 61-65, Certification: Pilots and Flight and Ground Instructors, provides sample endorsements the instructor pilots and init ial cadre of flight instructors should rec eive in or de r to provide training.

4.2.2 In structor Pilot Prerequisite Qualifications. Only flight instructors who hold a 14 CFR part 61 subpart H flight instructor certificate with the appropriate category and class rating are authorized to receive training from instructor pilots employed or used by the aircraft manufacturer. This will establish the initial cadre of authorized instructors

(i.e., other 14 CFR part 61 subpart H instructors and 14 CFR part 61 subpart K flight instructors) who can conduct the required model-specific flight training in an aircraft with a simplified flight controls designation required by 14 CFR § 61.31(l).

4.2.3 Instructor Pilot Training Requirements. The training requirements identified in 14 CFR § 61.195(n)(2) largely mirror those set forth in 14 CFR § 61.31(l) (i.e., have received and logged model-specific training in that aircraft from an instructor pilot for the manufacturer of the aircraft and received an endorsement validating proficiency).

4.2.4 Flight Instructor Privileges. Once a manufacturer instructor pilot trains and qualifies a 14 CFR part 61 subpart H flight instructor (14 CFR § 61.195(n)), that subpart H flight instructor may then train and endorse other subpart H flight instructors or 14 CFR part 61 subpart K flight instructors (14 CFR § 61.415(n)). The instructors may then train and endorse pilots, sport pilots, and pilot applicants (14 CFR § 61.31(l)).

Appendix A A-1 APPENDIX A. AIRMAN CERTIFICATION SIMPLIFIED FLIGHT CONTROLS

REQUIREMENTS TABLE Note: This table shows some examples of possible certification scenarios for pilots seeking to operate an aircraft with a simplified flight controls designation.

Rotorcraft-Helicopter If you hold a— And you are seeking— Then you must complete— Regulatory Reference Sport pilot certificate with the following:

• Rotorcraft-helicopter privilege; and

• Specific make and model (M/M) simplified flight controls limitation.

To operate another model of rotorcraft-helicopter with simplified flight controls designation at the same certificate level.

The training and endorsement required by 14 CFR § 61.31(l) for each M/M.

Title 14 CFR § 61.45(h)(1).

Sport pilot certificate with the following:

• Rotorcraft-helicopter privilege; and

• Specific M/M simplified flight controls limitation.

A recreational pilot certificate or higher with rotorcraft-helicopter rating (regardless of a simplified flight controls designation).

The applicable requirements for that grade of certificate, including a practical test.

Title 14 CFR part 61 applicable subpart, and subject to 14 CFR § 61.9.

Sport pilot certificate with the following:

• Rotorcraft-helicopter privilege; and

• Specific M/M simplified flight controls limitation.

To operate an airplane category with simplified flight controls designation as an initial applicant for airplane category (and appropriate class) at any certificate grade.

A practical test for that certificate (if applicable), category, and class of aircraft.

Title 14 CFR § 61.45(h)(2) and the applicable certificate requirements.

Sport pilot certificate with the following:

• Rotorcraft-helicopter privilege; and

• Specific M/M simplified flight controls limitation.

To operate any rotorcraft or airplane category without simplified flight controls designation at the same certificate level.

A practical test for that category and class of aircraft.

Title 14 CFR §§ 61.45(h)(2) and 61.316.

Sport pilot certificate with the following:

• Rotorcraft-helicopter privilege; and

• Specific M/M simplified flight controls limitation.

To operate a different category and class, other than airplane category, at the same certificate level.

A proficiency check. Title 14 CFR § 61.321.

Appendix A A-2 Rotorcraft-Helicopter If you hold a— And you are seeking— Then you must complete— Regulatory Reference Recreational pilot certificate or higher with the following:

• Rotorcraft category and helicopter class rating; and

• Specific M/M simplified flight controls limitation.

To operate a different M/M of rotorcraft-helicopter with a simplified flight controls designation at the same certificate level.

The training and endorsement required by 14 CFR § 61.31(l) for each M/M.

Title 14 CFR § 61.45(h)(1).

Recreational pilot certificate or higher with the following:

• Rotorcraft category and helicopter class rating; and

• Specific M/M simplified flight controls limitation.

To operate a rotorcraft-helicopter without a simplified flight controls designation at the same certificate level.

A practical test for that category and class of aircraft equipped with conventional flight controls.

Title 14 CFR § 61.45(h)(2).

Recreational pilot certificate or higher with the following:

• Rotorcraft category and helicopter class rating; and

• Specific M/M simplified flight controls limitation.

To operate an Airplane Category, Single-Engine Land class aircraft with a simplified flight controls designation at the same certificate level.

The requirements to add another category and class rating on the applicable pilot certificate, including a practical test.

Title 14 CFR §§ 61.45(h)(2) and 61.63(b).

Recreational pilot certificate or higher with the following:

• Rotorcraft category and helicopter class rating;

• Specific M/M simplified flight controls limitation rotorcraft-helicopter;

and

• Airplane Category and Single-Engine Land class rating.

To operate an Airplane Category, Single-Engine Land class aircraft with a simplified flight controls designation at the same certificate level.

The training and endorsement required by 14 CFR § 61.31(l) for each M/M.

Title 14 CFR §§ 61.45(h)(1) and 61.31(l)(1).

Appendix A A-3 Rotorcraft-Helicopter If you hold a— And you are seeking— Then you must complete— Regulatory Reference Recreational pilot certificate or higher with a rotorcraft category and helicopter class rating without a simplified flight controls limitation.

To operate a rotorcraft-helicopter with simplified flight controls designation at the same certificate level.

The training and endorsement required by 14 CFR § 61.31(l) for each M/M.

Title 14 CFR § 61.31(l).

Airplane Single-Engine Land (ASEL) or Airplane Single-Engine Sea (ASES) If you hold a— And you are seeking— Then you must complete— Regulatory Reference Sport pilot certificate with the following:

• ASEL privileges;

and

• Specific make and model (M/M) simplified flight controls limitation.

To operate a different M/M of ASEL aircraft with simplified flight controls designation at the same certificate level.

The training and endorsement required by 14 CFR § 61.31(l) for each M/M.

Title 14 CFR § 61.45(h)(1).

Sport pilot certificate with the following:

• ASES privileges;

and

• Specific M/M simplified flight controls limitation.

To operate a different M/M of ASES aircraft with simplified flight controls designation at the same certificate level.

The training and endorsement required by 14 CFR § 61.31(l) for each M/M.

Title 14 CFR § 61.45(h)(1).

Sport pilot certificate with the following:

• ASEL privileges;

and

• Specific M/M simplified flight controls limitation.

A recreational pilot certificate or higher with ASEL rating (with or without a simplified flight controls designation).

The applicable requirements for that grade of certificate, including a practical test.

Title 14 CFR part 61 applicable subpart, and subject to 14 CFR § 61.9.

Sport pilot certificate with the following:

• ASES privileges;

and

• Specific M/M simplified flight controls limitation.

A recreational pilot certificate or higher with ASES rating (with or without a simplified flight controls designation).

The applicable requirements for that grade of certificate, including a practical test.

Title 14 CFR part 61 applicable subpart, and subject to 14 CFR § 61.9.

Appendix A A-4 Airplane Single-Engine Land (ASEL) or Airplane Single-Engine Sea (ASES) If you hold a— And you are seeking— Then you must complete— Regulatory Reference Sport pilot certificate with the following:

• ASEL privilege (or ASES privilege);

and

• Specific M/M simplified flight controls limitation for airplane.

To operate a rotorcraft-helicopter category and class aircraft with simplified flight controls designation as an initial applicant for rotorcraft category and helicopter class at any certificate grade.

A practical test for that certificate (if applicable), category, and class of aircraft.

Title 14 CFR § 61.45(h)(2) and the applicable certificate requirements.

Sport pilot certificate with the following:

• ASEL privilege (or ASES privilege);

and

• Specific M/M simplified flight controls limitation for airplane.

To operate any rotorcraft or airplane category without simplified flight controls designation at the same certificate level.

A practical test for that category and class of aircraft.

Title 14 CFR §§ 61.45(h)(2) and 61.316.

Sport pilot certificate with the following:

• ASEL privilege (or ASES privilege);

and

• Specific M/M simplified flight controls limitation for airplane.

To operate a different category and class, other than rotorcraft-helicopter category, at the same certificate level.

A proficiency check. Title 14 CFR § 61.321.

Recreational pilot certificate or higher with the following:

• ASEL rating; and

• Specific M/M simplified flight controls limitation.

To operate a different M/M of ASEL aircraft with a simplified flight controls designation at the same certificate level.

The training and endorsement required by 14 CFR § 61.31(l) for each M/M.

Title 14 CFR § 61.45(h)(1).

Recreational pilot certificate or higher with the following:

• ASES rating; and

• Specific M/M simplified flight controls limitation.

To operate a different M/M of ASES aircraft with a simplified flight controls designation at the same certificate level.

The training and endorsement required by 14 CFR § 61.31(l) for each M/M.

Title 14 CFR § 61.45(h)(1).

Appendix A A-5 Airplane Single-Engine Land (ASEL) or Airplane Single-Engine Sea (ASES) If you hold a— And you are seeking— Then you must complete— Regulatory Reference Recreational pilot certificate or higher with the following:

• ASEL rating; and

• Specific M/M simplified flight controls limitation.

To operate an ASES aircraft with a simplified flight controls designation at the same certificate level.

A practical test for that category and class of aircraft.

Title 14 CFR § 61.45(h)(2) and the applicable certificate requirements.

Recreational pilot certificate or higher with the following:

• ASEL rating; and

• Specific M/M simplified flight controls limitation.

To operate an ASEL aircraft without a simplified flight controls designation at the same certificate level.

A practical test for that category and class of aircraft equipped with conventional flight controls.

Title 14 CFR § 61.45(h)(2).

Recreational pilot certificate or higher with the following:

• ASES rating; and

• Specific M/M simplified flight controls limitation.

To operate an ASES aircraft without a simplified flight controls designation at the same certificate level.

A practical test for that category and class of aircraft equipped with conventional flight controls.

Title 14 CFR § 61.45(h)(2).

Recreational pilot certificate or higher with the following:

• ASEL rating (or ASES rating);

• Specific M/M simplified flight controls limitation for airplane; and

• Rotorcraft-helicopter rating.

To operate a rotorcraft-helicopter with a simplified flight controls designation at the same certificate level.

The training and endorsement required by 14 CFR § 61.31(l) for each M/M.

Title 14 CFR §§ 61.45(h)(1) and 61.31(l)(1).

Recreational pilot certificate or higher with the following:

• ASEL rating (or ASES rating);

and

• Specific M/M simplified flight controls limitation for airplane.

To operate a rotorcraft-helicopter with a simplified flight controls designation at the same certificate level.

The requirements to add another category and class rating on the applicable pilot certificate, including a practical test.

Title 14 CFR §§ 61.45(h)(2) and 61.63(b).

Appendix A A-6 Airplane Single-Engine Land (ASEL) or Airplane Single-Engine Sea (ASES) If you hold a— And you are seeking— Then you must complete— Regulatory Reference Recreational pilot certificate or higher with an ASEL rating without a simplified flight controls limitation.

To operate an ASEL aircraft with simplified flight controls designation at the same certificate level.

The training and endorsement required by 14 CFR § 61.31(l) for each M/M.

Title 14 CFR § 61.31(l).

Recreational pilot certificate or higher with an ASES rating without a simplified flight controls limitation.

To operate an ASES aircraft with simplified flight controls designation at the same certificate level.

The training and endorsement required by 14 CFR § 61.31(l) for each M/M.

Title 14 CFR § 61.31(l).

Flight Instructors Other Than Flight Instructors With a Sport Pilot Rating (14 CFR Part 61 Subpart H) If you hold a— And you are seeking— Then you must meet the following requirements:

Regulatory Reference Commercial Pilot Certificate (or Airline Transport Pilot (ATP) Certificate) with rotorcraft category and helicopter class rating.

To provide initial flight instructor cadre training in a helicopter with a simplified flight controls designation.

(1) Receive a flight instructor certificate with a rotorcraft-helicopter rating;

(2) Receive and log model-specific training in that aircraft from an instructor pilot for the manufacturer of the aircraft; and

(3) Receive a logbook or training record endorsement from the instructor pilot certifying that the flight instructor is proficient in the safe operation of that model-specific aircraft and the associated simplified flight controls.

Title 14 CFR § 61.195(n).

Appendix A A-7 Flight Instructors Other Than Flight Instructors With a Sport Pilot Rating (14 CFR Part 61 Subpart H) If you hold a— And you are seeking— Then you must meet the following requirements:

Regulatory Reference Flight instructor certificate with rotorcraft category and helicopter class rating issued under 14 CFR part 61 subpart H.

To provide initial flight instructor cadre training in a helicopter with a simplified flight controls designation.

(1) Receive and log model-specific training in that aircraft from an instructor pilot for the manufacturer of the aircraft; and

(2) Receive a logbook or training record endorsement from the instructor pilot certifying that the flight instructor is proficient in the safe operation of that model-specific aircraft and the associated simplified flight controls.

Title 14 CFR § 61.195(n).

Flight instructor certificate with rotorcraft category and helicopter class rating issued under 14 CFR part 61 subpart H.

To provide training in a helicopter with a simplified flight controls designation.

Receive training and an endorsement specified in 14 CFR § 61.31(l).

Title 14 CFR § 61.195(m).

Flight instructor certificate with rotorcraft category and helicopter class rating issued under 14 CFR part 61 subpart H.

To instruct under 14 CFR part 61 subpart K in an airplane with simplified flight controls designation.

Complete a practical test for that category and class privilege.

Title 14 CFR § 61.419.