Logging PIC Time: Rules and Nuances
FAA regulation 14 CFR § 61.51(e) governs when a pilot may log PIC time:
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Solo flights: If you are the only occupant, you may log PIC time when you are rated and meet medical and currency requirements.
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Sole manipulator: If you are controlling the aircraft for which you are rated, even with a passenger or another pilot aboard, you can log PIC time.
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Required multi-pilot operations: If more than one pilot is required (for example, simulated instrument training or type certification), both the acting PIC and the other rated pilot may log PIC (or SIC) time as appropriate.
Important distinctions:
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Being the acting PIC, the one legally responsible, does not always entitle you to log PIC time, unless you are also the sole manipulator in a single-pilot scenario.
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Example Scenario: Two Private Pilots on a Cross-Country Flight
Pilot A and Pilot B are both certificated private pilots, rated in single-engine land airplanes. They decide to fly together in a Cessna 172 for a cross-country. Before the flight, they agree that Pilot A will act as PIC for the entire flight — meaning Pilot A is legally responsible for the aircraft’s operation, airworthiness decisions, and regulatory compliance.
However, once airborne, Pilot B is the one flying the aircraft the entire way — manipulating the controls, making maneuvers, and handling navigation tasks.
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Pilot A (the acting PIC) is legally responsible for the flight, but because only one pilot is required for this operation under Part 91 and Pilot A is not manipulating the controls, Pilot A cannot log PIC time.
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Pilot B, on the other hand, can log PIC time because 14 CFR § 61.51(e)(1)(i) permits the “sole manipulator of the controls of an aircraft for which the pilot is rated” to log PIC time.
So in this single-pilot operation, the acting PIC (Pilot A) carries the legal responsibility but does not get loggable PIC time. Only the manipulating pilot (Pilot B) does.
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Safety pilots in simulated instrument conditions may log PIC time only when acting as PIC and qualified to do so; otherwise they may log SIC.
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Example Scenario: Safety Pilot During Simulated Instrument Flight
Pilot A is practicing instrument approaches under the hood (wearing a vision-limiting device) to maintain currency. Because Pilot A cannot see outside for traffic avoidance, regulations require a safety pilot to be on board. Pilot B, another qualified pilot, agrees to act as the safety pilot.
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Pilot A is the sole manipulator of the controls while under the hood. Under 14 CFR § 61.51(e)(1)(i), Pilot A may log PIC time because they are flying the aircraft for which they are rated.
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Pilot B, the safety pilot, is required crew under 91.109(b). If Pilot B and Pilot A agreed that Pilot B would also be acting PIC during the hood work, then Pilot B may also log PIC time. If not, Pilot B may log SIC time for that period.
Important limitation: The safety pilot is only required during the portion of flight when the manipulating pilot is under the hood. For other parts of the flight, such as takeoff, landing, or visual segments, the safety pilot is not required crew and therefore cannot log time.
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Logging PIC time at flight schools
Most flight schools teach that PIC time is earned:
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When you are the sole manipulator and rated
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During solo flights meeting regulatory prerequisites
Student pilots typically log solo PIC time after securing a solo endorsement, while multi-pilot environments (such as Part 61 instrument training) may allow dual logging under certain circumstances.
Beyond compliance, maintaining accurate logbooks, whether paper or digital, is essential not just for certificates and ratings, but for credibility and career advancement.
PIC Responsibilities Vary by Aircraft and Operation Type
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Single-engine general aviation: One pilot, acting PIC and manipulator, fulfills both roles. With a second rated pilot, the roles can be divided, and PIC may change during the flight, so this varies depending on how the pilots decide to conduct the flight.
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Multi-crew or complex operations: PIC may act as commander while others manipulate controls; responsibilities and logging may vary. This will usually be determined by the operator, not the pilots.
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Air taxi or airlines: PIC is designated by operations authority and subject to stricter oversight and administrative structure.
Relevant CFR References
14 CFR § 91.3: “The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft.”
14 CFR § 61.51(e): Outlines conditions under which a pilot may log pilot-in-command flight time, including as sole manipulator of the controls, as the only occupant, or when more than one pilot is required.
ICAO Annex 1: Defines Pilot in Command as the pilot responsible for the operation and safety of the aircraft during flight time.
Conclusion
Understanding who is the Pilot in Command (PIC), what that means legally, operationally, and in terms of logbook rules, is essential for pilots and flight schools alike. The PIC holds ultimate responsibility, but not always the sole logbook credit, and the details matter.
At Flex Air, we don’t just help you fill your logbook. We train you to become responsible, competent PICs. Are you ready to build real pilot-in-command skills? Contact Flex Air today and take command of your aviation journey.