Short answer: yes, but only in a specific situation. A safety pilot may log pilot-in-command (PIC) time for the portion of a flight when the other pilot is operating under simulated instrument conditions, but only if the safety pilot is actually acting as PIC and the regulations require a second pilot for that portion of the flight.
This article explains the common safety-pilot scenario under the current Federal Aviation Regulations. It is educational information, not legal advice. Pilots should review the current regulations, FAA legal interpretations, and their own operating circumstances before making a logbook entry.
When is a safety pilot required?
Under 14 CFR § 91.109(c), a civil aircraft may not be operated in simulated instrument flight unless the other control seat is occupied by a safety pilot who has at least a private pilot certificate with the appropriate category and class ratings for the airplane. The safety pilot must occupy the other control seat and be able to see outside the aircraft well enough to perform the required see-and-avoid duties.
Because the safety pilot is a required flight crewmember, the safety pilot must also meet the applicable medical requirements in 14 CFR § 61.3(c). The safety pilot also needs the qualifications and endorsements necessary to act as PIC of the aircraft and the flight as conducted.
How can the safety pilot log PIC time?
14 CFR § 61.51(e)(1)(iii) allows a qualified pilot to log PIC time when that pilot acts as PIC of an aircraft for which more than one pilot is required under the aircraft’s type certification or the regulations governing the flight.
During simulated instrument operations, § 91.109(c) requires the safety pilot. If the two pilots agree before the flight that the safety pilot will act as the legal PIC, the safety pilot may log PIC time under § 61.51(e)(1)(iii) for the period when the other pilot is under the view-limiting device. The safety pilot must actually accept the responsibilities of acting PIC; simply sitting in the right seat does not automatically create PIC time.
Can both pilots log PIC?
Yes. The pilot flying under the hood may log PIC under § 61.51(e)(1)(i) while acting as the sole manipulator of the controls of an aircraft for which that pilot is rated. At the same time, the safety pilot may log PIC under § 61.51(e)(1)(iii) if the safety pilot is the acting PIC and the second pilot is required by § 91.109(c).
The two pilots should document the arrangement clearly in their logbooks, including the simulated-instrument portion and the name of the safety pilot. The person acting as PIC is accepting real responsibility for the flight, including operational and regulatory compliance. This is not merely a way to create extra logbook time.
What if the safety pilot is not acting as PIC?
If the safety pilot is not acting as PIC, that pilot may be able to log second-in-command (SIC) time under § 61.51(f)(2), because § 91.109(c) requires more than one pilot for the simulated-instrument operation. Whether the safety pilot qualifies to log SIC depends on the aircraft, the operation, and the applicable regulatory requirements.
Does an IFR flight plan automatically allow two pilots to log PIC?
No. Filing or flying an IFR flight plan does not, by itself, require two pilots. The safety-pilot rule applies to simulated instrument flight, such as flight under a view-limiting device in visual conditions. If the pilot is in actual instrument meteorological conditions and no second pilot is required by the aircraft’s certification or the applicable regulations, a second pilot does not automatically gain PIC time simply by being present.
Is flight-instructor training the only other time two pilots may log PIC?
No. An authorized flight instructor may log PIC time while providing flight training under § 61.51(e)(3), and the pilot receiving training may also log PIC when the requirements of § 61.51(e) are met. In addition, aircraft or operations that require more than one pilot can create separate PIC or SIC logging opportunities under the regulations. The exact result depends on who is acting PIC, who is manipulating the controls, the aircraft’s certification, and the rules governing the flight.
Therefore, it is not accurate to say that two pilots can never both log PIC except when one is a flight instructor. The safety-pilot provisions are one important exception, and required-crew operations can create others. Each pilot must have a valid regulatory basis for the time entered.
FAA legal interpretations worth reading
- Walker Legal Interpretation: explains when a safety pilot acting as PIC may log PIC under § 61.51(e)(1)(iii), while the pilot flying may log PIC as sole manipulator.
- Speranza Legal Interpretation: discusses the limits on logging PIC when only one pilot is required for the flight.
- AOPA: Logging Time as a Safety Pilot: practical background and logbook considerations.
Practical checklist
- Confirm that simulated instrument flight is actually being conducted and that § 91.109(c) requires a safety pilot.
- Confirm the safety pilot holds at least the required private pilot certificate, category and class ratings, medical qualification, and any needed aircraft endorsements.
- Agree before the flight who will act as PIC.
- Log only the portion of time for which the regulatory basis exists.
- Record the safety pilot’s name and clearly describe the simulated-instrument portion in both logbooks.
Bottom line: A safety pilot can log PIC time, but only when acting as PIC of an aircraft for which a second pilot is required by the regulations. The pilot under the hood may also log PIC as the sole manipulator of the controls when rated for the aircraft. The entry must match the actual responsibilities and the current regulations.
