AC 61-146

U.

S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Pilot Certification and Operations for Sport Pilots, Flight Instructors with a Sport Pilot Rating, and Simplified Flight Controls Date: 11/14/25 AC No: 61-146 Initiated by: AFS-800 Change:

This advisory circular (AC) provides guidance on the changes to Title 14 of the Code of Federal Regulations (14 CFR) part 61 concerning sport pilot certification, training, and operations in accordance with the Modernization of Special Airworthiness Certification (MOSAIC) final rule regulatory amendments. MOSAIC also facilitates the new simplified flight controls designation for aircraft and associated pilot training requirements.

H ugh Thomas for Lawrence Fields Executive Director, Flight Standards Service

ii

CONTENTS Paragraph Page

Chapter 1. Introduction1-1

1.1 Purpose of This Advisory Circular (AC)1-1

1.2 Audience1-1

1.3 Where You Can Find This AC1-1

1.4 Effective Date1-1

1.5 Background1-1

1.6 AC Feedback Form1-2

Chapter 2. Sport Pilot General Provisions2-1

2.1 Sport Pilot Aircraft Design and Performance Limitations2-1

2.2 Aircraft Conformity Since Original Aircraft Certification2-1

Chapter 3. Sport Pilot Training, Certification, and Operational Privileges3-1

3.1 Sport Pilot Certification and Privileges3-1

3.2 Maximum Stalling Speed Limitation3-1

3.3 Sport Pilot Maximum Seating Capacity3-1

3.4 Endorsement Requirements Based on Maximum Continuous Power (VH)3-2

3.5 Airplanes With a Manual Controllable Pitch Propeller3-2

3.6 Aircraft With Retractable Landing Gear3-3

3.7 Night Operations3-4

3.8 Compensation for Flight Training Provided by Flight Instructors With a Sport

Pilot Rating3-6

3.9 Aviation Training Device or Flight Simulation Training Device (FSTD)

Credit3-6

3.10 Practical Test Required for an Airplane or Helicopter Privilege3-6

3.11 Ne w Rotorcraft-Helicopter Privilege for Sport Pilots and Flight Instructors

With a Sport Pilot Rating3-6

3.12 Sport Pilot and Sport Pilot Flight Instructor for Rotorcraft-Helicopter;

Airman Certification Standards (ACS)3-7

Chapter 4. Simplified Flight Controls Designation4-1

4.1 Model-Specific Endorsement for Aircraft Certificated With a Simplified Flight

Controls Designation4-1

iii

4.2 Flight Instructor Training and Endorsement Requirements for Aircraft

With a Simplified Flight Controls Designation4-2

Appendix A. Airman Certification Simplified Flight Controls Requirements TableA-1

1-1 CHAPTER 1. INTRODUCTION

1.1 Purpose of This Advisory Circular (AC). This AC provides guidance for sport pilot and flight instructor applicants and pilots who seek to obtain or exercise sport pilot or flight instructor certificate with a sport pilot rating privileges under the applicable provisions of Title 14 of the Code of Federal Regulations (14 CFR) part 61. Additionally, this AC also provides guidance for pilots seeking to operate aircraft with a simplified flight controls designation.

Note: This is a guidance document. Its content is not legally binding in its own right and will not be relied upon by the Department as a separate basis for affirmative enforcement action or other administrative penalty.

Conformity with the guidance document is voluntary only. Nonconformity will not affect rights and obligations under existing statutes and regulations.

1.2 Audience. The primary audience for this AC is applicants, pilots, flight instructors, designated examiners, and aviation safety inspectors (ASI) who conduct certification functions for pilots or have oversight of a designee who performs pilot or instructor certifications. The secondary audience includes Flight Standards Service (FS) offices.

1.3 Where You Can Find This AC. You can find this AC on the Federal Aviation Administration’s (FAA) website at https://www.faa.gov/regulations_policies/advisory_cir culars and the Dynamic Regulatory System (DRS) at https://drs.faa.gov.

1.4 Effective Date. This AC is effective as of October 22, 2025.

1.5 Background. In 2004, the FAA published the final rule titled, Certification of Aircraft and Airmen for the Operation of Light-Sport Aircraft (69 FR 44772), which established rules for the manufacture, certification, operation, and maintenance of light-sport aircraft (LSA). That rule provided for the operation and manufacture of aircraft weighing less than 1,320 pounds (or 1,430 pounds for aircraft intended for operation on water). These “light-sport” aircraft included airplanes, gliders, balloons, powered parachutes, weight-shift-control aircraft, and gyroplanes. This rule defined the performance limits and design criteria of LSA in 14 CFR § 1.1.

1.5.1 Certification of Sport Pilots. The 2004 final rule provided for the certification of sport pilots under 14 CFR part 61 subpart J, and flight instructors with a sport pilot rating under 14 CFR part 61 subpart K, limited to the operation of aircraft that met the 14 CFR § 1.1 LSA definition.

1.5.2 Modernization of Special Airworthiness Certification. In 2025, the FAA published the “Modernization of Special Airworthiness Certification” final rule (“MOSAIC”). This rule separated aircraft certification requirements from pilot certification requirements.

1.5.2.1 Sport pilot certification and operational privileges are now addressed within 14 CFR part 61, including performance limits and design requirements for aircraft that sport pilots and flight instructors with a sport pilot rating may operate. The FAA expanded what aircraft sport pilots can operate and added

1-2 operational privileges that require additional training and qualification requirements. Chapter 3, Sport Pilot Training, Certification, and Operational Privileges, further discusses those changes to 14 CFR part 61 specific to sport pilots (subpart J) and flight instructors with a sport pilot rating (subpart K).

1.5.2.2 In addition to the expanded operational privileges for sport pilots, the MOSAIC final rule also integrated aircraft with a simplified flight controls designation into the regulatory framework, as well as the specific training and endorsement requirements for pilots seeking to act as pilots in command (PIC) of those aircraft. The detailed training is described in Chapter 4, Simplified Flight Controls Designation.

1.6 AC Feedback Form. For your convenience, the AC Feedback Form is the last page of this AC. Note any deficiencies found, clarifications needed, or suggested improvements regarding the contents of this AC on the Feedback Form.

2-1 CHAPTER 2. SPORT PILOT GENERAL PROVISIONS

2.1 Sport Pilot Aircraft Design and Performance Limitations. Title 14 CFR § 61.316 prescribes the new performance limits and design requirements for the aircraft that sport pilots may operate. These changes allow more aircraft types to be eligible for sport pilot operations, provided the aircraft meets the performance and design limitations of 14 CFR § 61.316. This chapter describes the aircraft performance and design limitations for sport pilot operations and highlights significant changes.

2.1.1 Weight Limitation. There is no longer a specified weight limitation for the aircraft a sport pilot may operate. The FAA determined that performance-based standards are more appropriate based on the safety continuum concept, and the other existing performance and design characteristics provide appropriate limitations for sport pilot operations.

2.1.2 Maximum Airspeed Limitation. The MOSAIC rulemaking removed historical maximum airspeed limitations for sport pilot operations. Formerly, under the 14 CFR § 1.1 LSA definition, sport pilots were limited to operating an aircraft with a maximum airspeed in level flight with maximum continuous power (VH) of not more than 120 Knots Calibrated Airspeed (KCAS), or a never-exceed speed (VNE) of 120 KCAS for gliders. However, the FAA retained 14 CFR § 61.327, which requires specific training and endorsement for sport pilots seeking to operate an aircraft with a VH above or below 87 KCAS. This is further discussed in Chapter 3.

2.1.3 Powerplant Limitation. The MOSAIC rulemaking removed the historical limitation restricting sport pilots to operating aircraft with a single reciprocating engine. The new 14 CFR § 61.316 allows for the operation of aircraft with any powerplant types under sport pilot privileges. However, with the removal of the engine design limitation, the FAA amended 14 CFR § 61.315 to specifically state that a sport pilot may not act as PIC of an aircraft that requires a pilot to hold a type rating, in accordance with 14 CFR § 61.31(a). The FAA continues to prohibit a sport pilot from operating an aircraft that requires a pilot to hold a type rating due to the complexity associated with operating those aircraft and the training footprint of sport pilots.

2.2 Aircraft Conformity Since Original Aircraft Certification. LSA previously defined in 14 CFR § 1.1 required an aircraft to have met all design requirements since its original certification. The MOSAIC final rule retains the “since its original certification” requirement for aircraft performance limits and design requirements in the new 14 CFR § 61.316(a). Sport pilots cannot operate an aircraft that has been modified since its original certification to otherwise qualify an aircraft for sport pilot use under 14 CFR § 61.316(a). Modifications to an aircraft to meet 14 CFR § 61.316(a) criteria may allow operation of aircraft with overall increased complexity to a level that is inappropriate for the skill and training capabilities of the sport pilot. Therefore, sport pilots may only act as PICs of an aircraft meeting the performance limits and design requirements of 14 CFR § 61.316(a) if that aircraft meets the following requirements since its original certification.

2-2

2.2.1 Maximum Stalling Speed or Minimum Steady Flight Speed. A maximum stalling speed or minimum steady flight speed without the use of lift-enhancing devices (VS1) of not more than 45 KCAS, except for airplanes, which must have a VS1 speed of not more than 59 KCAS at the aircraft’s maximum certificated takeoff weight and most critical center of gravity (CG) (14 CFR § 61.316(a)(1)).

2.2.2 Seating Capacity. A maximum seating capacity of 2 persons, except for airplanes, which may have a maximum seating capacity of 4 persons (14 CFR § 61.316(a)(2)).

2.2.3 Non-Pressurization Cabin. A non-pressurized cabin, if equipped with a cabin (14 CFR § 61.316(a)(3)).

2.2.4 Gyroplanes. For gyroplanes, a fixed-pitch, semi-rigid, teetering, two-blade rotor system (14 CFR § 61.316(a)(4)).

2.2.5 Powered Aircraft Other Than Balloons or Airships. The loss of partial power would not adversely affect directional control of the aircraft, and the aircraft design must allow the pilot the capability of establishing a controlled descent in the event of a partial or total powerplant failure (14 CFR § 61.316(a)(5)).

2.2.6 Helicopters. Must be certificated with the simplified flight controls designation (14 CFR § 61.316(a)(6)).

2.2.7 Gliders. Specifically required by 14 CFR § 61.316(a)(7) to have fixed or retractable landing gear. As discussed, 14 CFR § 61.316(a) requires an aircraft to have met the performance limits and design requirements since its original certification. Consequently, for sport pilot operations, a glider must have had that fixed or retractable landing gear since its original certification.

2.2.8 Powered Aircraft Other Than a Glider. For powered aircraft other than a glider, fixed landing gear, except as provided in 14 CFR § 61.316(b) (14 CFR § 61.316(a)(8)), and a fixed, ground-adjustable, or an automated controllable pitch propeller, except as provided in 14 CFR § 61.316(b) (14 CFR § 61.316(a)(9)).

2.2.9 Retractable Gear and Propeller Privileges. Title 14 CFR § 61.316(b) permits sport pilots to act as PICs of an aircraft with retractable landing gear or an airplane with a manual controllable pitch propeller after receiving the specified training and instructor endorsement. However, these systems are not required to have been installed since the aircraft’s original certification. Therefore, 14 CFR § 61.316(b) allows a sport pilot to operate aircraft (except for gliders) that have had landing gear modifications and airplanes that have had propeller modifications if those sport pilots meet the training and endorsement requirements set forth in 14 CFR § 61.331.

3-1 CHAPTER 3. SPORT PILOT TRAINING, CERTIFICATION, AND OPERATIONAL

PRIVILEGES

3.1 Sport Pilot Certification and Privileges. Title 14 CFR part 61 prescribes the requirements for obtaining sport pilot certificates and flight instructor certificates with a sport pilot rating and the associated privileges. Unlike higher-grade pilot certificates, a sport pilot certificate is not issued with category and class ratings. Instead, sport pilots obtain privileges endorsed in their logbook for the specific category and class, and, in some cases, specific make and model (M/M) aircraft.

Note: Pilots who hold a higher grade of pilot certificate with the appropriate category and class rating but choose to exercise those same category and class privileges at the sport pilot level must comply with the sport pilot privileges and limitations of 14 CFR part 61.

3.2 Maximum Stalling Speed Limitation.

3.2.1 Stalling and Flight Speeds. Title 14 CFR § 61.316(a)(1) permits a sport pilot to act as PIC of an aircraft with a maximum stalling speed or minimum steady flight speed without the use of lift-enhancing devices (VS1) of not more than 45 KCAS, except for airplanes, which must have a VS1 speed of not more than 59 KCAS at the aircraft’s maximum certificated takeoff weight and most critical CG.

3.2.2 Aftermarket Alterations. For sport pilot operations, aircraft must meet the 14 CFR § 61.316(a)(1) stalling speed limitation since its original certification, as discussed in paragraph 2.2. An aircraft may not use aftermarket alterations (e.g., vortex generators, Short Takeoff and Landing (STOL) kits, or lift-enhancing designs) that lower the stalling speed to meet aircraft eligibility requirements of 14 CFR § 61.316(a) for sport pilot operations. Nevertheless, the installation of these modifications after an aircraft’s original certification is permitted. However, the aircraft’s original certification VS1 CAS stalling speed, prior to the installation of the modification, must meet 14 CFR § 61.316 requirements. For example, for an airplane to meet those requirements, that airplane must not exceed the maximum 59 KCAS VS1 stalling speed at its original certification.

3.3 Sport Pilot Maximum Seating Capacity. Title 14 CFR § 61.316(a)(2) permits sport pilots to act as PICs of an aircraft with a maximum seating capacity of 2 persons, except for airplanes, which MOSAIC expanded to a maximum seating capacity of 4 persons.

This change allows pilots to operate a wider variety of certificated airplanes. However, the number of people a sport pilot may carry on board an aircraft has not changed.

3.3.1 Sport Pilot Privilege Maximum Occupant Limitation. A sport pilot acting as PIC may only carry one passenger on board (14 CFR § 61.315(c)(4)). For instance, a sport pilot may act as PIC of an airplane with a seating capacity of up to four seats but may only operate that airplane with one passenger, necessarily leaving up to two seats vacant.

Similarly, a flight instructor with a sport pilot rating may only carry their student on board (14 CFR § 61.415(k)). Pilots who hold a higher-grade pilot certificate may choose to utilize sport pilot privileges, but when exercising sport pilot privileges, pilots

3-2 must comply with sport pilot privileges and limitations, in accordance with 14 CFR §§ 61.301(c) and 61.303. With respect to 14 CFR § 61.316(a)(2) seating limitations, the pilot may only act as PIC of an aircraft with a maximum seating capacity of two seats, or four seats in the case of airplanes.

3.3.2 Seating Removal Limitation. Title 14 CFR § 61.316(a) requires an aircraft to have met the performance limits and design requirements since its original certification. Therefore, a sport pilot may only act as PIC of an aircraft that has met the maximum seating capacity requirements of 14 CFR § 61.316(a)(2) since its original certification. The FAA noted during MOSAIC rulemaking that simply removing seats from an aircraft originally certificated with a seating capacity of more than two seats (or four seats for airplanes) does not change the originally certificated design and performance of that aircraft, which accommodated the larger seating capacity and is associated with heavier, more complex aircraft. Consequently, a sport pilot may not remove seats from an aircraft to establish eligibility under 14 CFR § 61.316.

3.4 Endorsement Requirements Based on Maximum Continuous Power (VH). As noted in paragraph 2.1.2, MOSAIC removed the former 120 KCAS VH speed limitation (or VNE in the case of gliders) for aircraft a sport pilot may operate. However, the sport pilot training and endorsement requirements of 14 CFR § 61.327 were retained.

3.4.1 VH Less Than or Equal to 87 Knots. A sport pilot may operate an airplane meeting the performance limits and design requirements of 14 CFR § 61.316 with a VH less than or equal to 87 KCAS by complying with 14 CFR § 61.327(a). This requires the sport pilot to receive and log ground and flight training from an authorized instructor in an airplane that has a VH less than or equal to 87 KCAS and receive a logbook endorsement from the instructor who provided the training stating the pilot is proficient to operate an airplane with a VH less than or equal to 87 KCAS.

Note: The training and endorsement requirements of 14 CFR § 61.327(a) are not required if a sport pilot has logged flight time as PIC of an airplane with a VH less than or equal to 87 KCAS prior to April 2, 2010.

3.4.2 VH Greater Than 87 Knots. A sport pilot may operate an aircraft meeting the performance limits and design requirements of 14 CFR § 61.316 with a VH greater than 87 KCAS by complying with 14 CFR § 61.327(b). This requires the sport pilot to receive and log ground and flight training from an authorized instructor in an aircraft that has a VH greater than 87 KCAS and receive a logbook endorsement from the instructor who provided the training stating the pilot is proficient to operate an aircraft with a VH greater than 87 KCAS.

3.5 Airplanes With a Manual Controllable Pitch Propeller. Historically, sport pilot operations were limited to either a fixed or ground-adjustable propeller for powered aircraft. Under 14 CFR § 61.316(b), sport pilots are now permitted to operate airplanes equipped with a manual controllable pitch propeller. To exercise these privileges, a sport pilot must meet the training and endorsement requirements specified in 14 CFR § 61.331(b). The additional training and endorsement mitigate the increased risks

3-3 associated with operator errors affecting safety. To note, sport pilots may also operate automated controllable pitch propellers, but they do not need to meet 14 CFR § 61.316(b).

3.5.1 Sport Pilot Training and Endorsement Requirements for Propellers. Title 14 CFR § 61.331(b) details the training and endorsement requirements for sport pilots seeking privileges to operate an airplane with a manual controllable pitch propeller. Sport pilots have two options to comply with these requirements:

3.5.1.1 A sport pilot may satisfy the training and endorsement requirements required for operating complex airplanes as specified in 14 CFR § 61.31(e); or

3.5.1.2 A sport pilot may receive and log ground and flight training from an authorized instructor in an airplane that has a manual controllable pitch propeller and receive an endorsement from the instructor certifying that they are proficient to operate the airplane.

3.5.2 Flight Instructor Training and Endorsement Requirements. Title 14 CFR § 61.415(l) requires flight instructors with a sport pilot rating to complete the additional training and receive an instructor endorsement for the operation of airplanes equipped with manual controllable pitch propellers, as specified in 14 CFR § 61.331(b), prior to providing flight instruction in an airplane with a manual controllable pitch propeller.

3.6 Aircraft With Retractable Landing Gear. Historically, sport pilots were only permitted to operate powered aircraft with fixed landing gear, except for aircraft intended for operation on water, which required either fixed or retractable landing gear. Title 14 CFR § 61.316 retains the requirement for powered aircraft to have fixed landing gear and adds a new provision to permit sport pilots to operate an aircraft that has retractable landing gear by complying with the training and endorsement requirements specified in 14 CFR § 61.331(a).

3.6.1 Sport Pilot Training and Endorsement Requirements for Retractable Gear. Title 14 CFR § 61.331(a) specifies the training and endorsement requirements for sport pilots seeking privileges to operate an aircraft with retractable landing gear. Sport pilots have two options to comply with these requirements:

3.6.1.1 A sport pilot may satisfy the training and endorsement requirements required for operating complex airplanes as specified in 14 CFR § 61.31(e); or

3.6.1.2 A sport pilot may receive and log ground and flight training from an authorized instructor in an aircraft that has retractable landing gear and receive an endorsement from the instructor certifying that they are proficient to operate that aircraft.

3.6.2 Operation on Water With Retractable Landing Gear. The MOSAIC final rule clarifies that a sport pilot may operate a powered aircraft intended for operation on water with either fixed or retractable landing gear but requires these sport pilots to obtain the training and endorsement specified in 14 CFR § 61.331(a). Historically, sport pilots were

3-4 permitted to operate aircraft intended for operation on water with retractable landing gear without requiring specific training or endorsement. Therefore, sport pilots who historically operated an aircraft intended for operation on water with retractable landing gear may continue to do so without obtaining the training and endorsement of 14 CFR § 61.331(a). Title 14 CFR § 61.331(c) states that the training and endorsement is not required for pilots that logged PIC time in an aircraft intended for operation on water with retractable landing gear before October 22, 2025. Sport pilots who did not log PIC time in an aircraft intended for operation on water with retractable landing gear prior to October 22, 2025, must obtain the endorsement specified in 14 CFR § 61.331(a), which will ensure pilots are trained for these types of operations and mitigates the risk associated with the potential mishandling of retractable landing gear on an aircraft intended for operation on water.

3.6.3 Gliders With Fixed or Retractable Landing Gear. Sport pilots continue to be permitted to operate gliders with fixed or retractable landing gear. Sport pilots are not required to comply with the training and endorsement requirements of 14 CFR § 61.331 to operate a glider with retractable landing gear.

3.6.4 Flight Instructor Training and Endorsement Requirements. Title 14 CFR § 61.415(l) requires flight instructors with a sport pilot rating to complete the additional training and receive an instructor endorsement for the operation of aircraft with retractable landing gear, as specified in 14 CFR § 61.331(a), prior to providing flight instruction in an aircraft with retractable landing gear.

3.7 Night Operations. Historically, sport pilot privileges did not include night operations.

The FAA now permits night operations under 14 CFR § 61.329, which requires additional night training, an authorized instructor qualifying endorsement, and additional medical qualifications.

3.7.1 Training Requirements for Sport Pilot Night Operations. For a sport pilot to operate at night, they must receive 3 hours of night flight training from an authorized instructor (14 CFR § 61.329(a)). This training must include the following: (1) one cross-country flight at night with a landing at an airport at least 25 nautical miles (NM) from the departure airport, except for powered parachutes; and (2) 10 takeoffs and 10 landings to a full stop at night.

3.7.1.1 Night flight training time can count toward the total flight time requirement in 14 CFR § 61.313.

3.7.1.2 Any night flight training received while obtaining a higher-grade certificate may count toward the time required in 14 CFR § 61.329. This previous experience may only be credited toward the same category and class of sport pilot night privileges sought. The pilot must still obtain the required endorsement specified in 14 CFR § 61.329(c), regardless of whether the pilot holds a higher grade of pilot certificate.

3-5

3.7.2 Endorsement Requirements for Sport Pilot Night Operations. Upon obtaining the required night flight training of 14 CFR § 61.329(a), a sport pilot must receive a logbook endorsement from an authorized instructor certifying that they met those training requirements and are proficient in the operation of the aircraft at night in the category and class for which the sport pilot seeks privileges (14 CFR § 61.329(c)).

3.7.3 Medical Eligibility Requirements Specific to Sport Pilot Night Operations. To act as PIC at night using sport pilot privileges, a pilot must hold an FAA medical certificate issued under 14 CFR part 67 (i.e., at least a third-class medical certificate) or hold a driver’s license and meet the 14 CFR § 61.113(i) BasicMed conditions and limitations (14 CFR § 61.329(b)).

3.7.3.1 Though a third-class medical certificate and BasicMed compliance are also used to exercise private pilot privileges, when complying with either of these medical requirements for the purposes of exercising sport pilot privileges, sport pilot privileges and limitations continue to apply (e.g., sport pilot certificate limits under 14 CFR § 61.315 and aircraft performance limitations and design requirements under 14 CFR § 61.316). For example, a sport pilot may not carry more than one passenger on board an aircraft, regardless of their medical qualifications.

3.7.3.2 A sport pilot is only affected by the additional medical qualification requirements if they choose to exercise these new, optional night privileges (14 CFR § 61.23(c)(1)(vi)). However, the longstanding medical requirements for sport pilot daytime operational privileges are unchanged under MOSAIC.

Sport pilots may operate powered aircraft during the day if they hold either a medical certificate or U.S. driver’s license, in accordance with 14 CFR § 61.23(c)(1)(i), (ii), or (iii), as appropriate. Sport pilots may operate a glider or balloon during the day without a medical certificate, in accordance with 14 CFR § 61.23(b)(1), (2), or (6), as appropriate.

3.7.4 Flight Instructor Qualifications to Provide Night Flight Training to Sport Pilot. The night training and endorsement can only be obtained from a qualified instructor.

3.7.4.1 In accordance with 14 CFR § 61.415(n), a flight instructor with a sport pilot rating (14 CFR part 61 subpart K) may provide training in an aircraft at night if they completed the night experience of 14 CFR § 61.329(a) and received the endorsement of 14 CFR § 61.329(c) in the category and class of aircraft in which they intend to provide flight training. Additionally, a flight instructor with a sport pilot rating would need to meet the medical requirements of 14 CFR § 61.329(b) to provide flight training in an aircraft at night.

3.7.4.2 A 14 CFR part 61 subpart H flight instructor may provide the night flight training and endorsement in accordance with 14 CFR part 61 subpart J if they are rated in the subject aircraft for which they are providing the training. A 14 CFR part 61 subpart H instructor must hold at least a third-class medical