Demystifying Flight Time Logging: Navigating Tricky Differences in Aviation Regulations

Logging the flight time can be a challenge when you need to meet the requirements of different authorities such as FAA, EASA and Transport Canada. While they share many similarities, there are some crucial differences that you should know to stay out of trouble and probably save some money.

Firstly, let me explain some terms.

PIC (Pilot In Command) is the person who assumes responsibility for the entire flight, fills out the aircraft logs, and has the final authority. According to EASA regulations, you can log PIC time only if you act as a PIC. However, FAA rules allow you to log PIC time in some other cases, which I will explain later in this post.

PICUS (PIC under supervision) is the person who acts as a PIC, but under specific circumstances. For example, in the UK, a student logs PICUS time during a checkride with the examiner. I haven’t seen PICUS time in the FAA regulations.

SIC (Second In Command). This is the co-pilot or first officer for a multi-pilot aircraft.

Safety pilot. This is not actually a pilot, but a person who monitors the pilot’s actions for some reason. Legally, they are passengers, but sometimes they can be a flight instructor who does not provide flight training (and, accordingly, does not log their flight time). In some very special cases they can log flight time too when they act as a required flight crew member (which I will explain later).

Passenger. This is just a passenger who does not perform any duties.

VMC (Visual Meteorological Conditions). These are meteorological conditions when there are visual references outside the aircraft, such as the horizon or landmarks on the ground. Essentially, it’s flight conditions outside the clouds or heavy precipitation.

IMC (Instrument Meteorological Conditions). This is when we are not in VMC. Usually, this is when we are in the clouds and cannot navigate using outside references. Legally, VMC has necessary minimums, and when we are below these minimums, we can consider the conditions as IMC.

VFR (Visual Flight Rules). Legally, we can fly under VFR when we are in VMC and can use outside references for navigation and separation from other aircraft. It does not mean that we MUST fly VFR in VMC, but we are definitely NOT allowed to fly VFR in IMC.

IFR (Instrument Flight Rules). These flight conditions assume that we use instruments for navigation and separation from other aircraft. We may not be able to see anything outside the aircraft, but it is not necessary. Legally, we can fly under IFR in both IMC and VMC. This is mainly relevant for EASA, where we can log IFR time in any meteorological conditions, but for FAA, we cannot log instrument time in VMC regardless of our flight rules. This is one of the essential differences between the two authorities.

Total time. This is the total flight time, regardless of the role we are performing as a crew member or a student. Of course, we log only cockpit time, your airline vacation trips do not count 🙂

Dual time. Dual given (or instructor) time means that we are providing flight instruction to someone. Dual received time means that we are receiving flight instruction from a certified instructor.

Night time. This is generally the time after sunset to sunrise, but there are some nuances. For example, FAA counts night landings only after 1 hour after sunset and not later than 1 hour before sunrise. Some EASA countries allow us to log night time no earlier than 30 minutes after sunset and not later than 30 minutes before sunrise. ICAO and EASA have the same definition, but there are some local regulations, such as in the CAP393 UK. It’s essential to check local documents to log night time correctly. I log night time from sunset to sunrise, and night landings one hour after sunset to be legal for both authorities.

Solo time. This is usually relevant only for students. It refers to the flight time when the student pilot is alone in the aircraft, without taking aboard even a passenger’s dog, regardless of whether the dog is licensed and knows how to fly the airplane or not. Once you have a license, only PIC time matters.

Solo acting. This means that only this person used the flight controls. Nobody else should touch the yoke, pedals, or anything that adjusts the flight parameters. For example, it can even be dual-received hours with a flight instructor next to you, but the instructor should not touch the flight controls. In the FAA world it is possible to log these hours are PIC time.

Instrument time refers to flight time using only flight instruments, without any reference outside the aircraft. This term is essential for the FAA, whereas the EASA uses IFR time instead. Clouds are not always present during the training, and initially, students do not want to fly in them. The FAA allows both actual instrument time (flight time in IMC) and simulated instrument time (flight time with a view-limiting device like a “hood” or “foggles”).

It is technically possible to log simulated instrument time even in VMC without a view-limiting device (“I used only flight instruments for flying”), but it does not make sense since a view-limiting device is a kind of guarantee. To log actual instrument time, the conditions should be real IMC, usually in the clouds, and not just below the legal VMC minimums. It’s kind of a very contradictory question, but it is safer to log simulated instrument time only with a view-limiting device and actual instrument time in the clouds to avoid any misinterpretation.

In the EASA world it is possible to log IFR hours any time on an IFR flight plan in the IFR-certified airplane, regardless of conditions outside.

Cross-country time. In EASA documents, the term “navigation flight” is used instead of “cross-country”, and refers to any flight where the aircraft departs from the circuit. For the FAA, it is any flight that a pilot conducts in an aircraft and includes a landing at a point other than the point of departure. However, there are additional limitations that need to be met to fulfill different criteria, which I will explain in detail.

Total flight time can be logged during any flight where any flight duties are performed.

Dual received time refers to training time with an instructor. This time should be logged when a flight instructor logs their dual given time. Usually instructors want to do that even if they don’t provide any verbal instruction during the flight and act more like safety pilots 🙂

IFR flight time can be logged with an IFR clearance and under an IFR flight plan, regardless of meteorological conditions. Instrument hours should be logged in IMC or with a view-limiting device, regardless of ‘real’ ATC clearance. For example, a flight instructor can give a ‘simulated’ ATC clearance.

As I’ve already said, there are some differences between EASA and FAA requirements for logging flight time.

PIC for the EASA and FAA

For EASA, it’s simple: you can only log PIC hours when you act as a PIC. This means that only one person can log PIC time. During flight training it is the flight instructor, who assumes responsibility. Dual received time cannot be logged as PIC time.

However, FAA regulations allow pilots to log PIC time in more cases. A pilot may log PIC time if they are the sole occupant of the aircraft, the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges, or is acting as PIC where more than one pilot is required (according to the ‘required crewmember’ rule), which is described in FAR 1.1, 61.51 [e].

‘Required crewmember’ typically applies to multi-pilot aircraft, but it’s not the only case. The most interesting case, for example, is in a training airplane such as a small Cessna 152 or 172, if a pilot uses a view-limiting device, the second pilot becomes a required crewmember in VMC under VFR!

Another case where both pilots can log PIC time is flying with a flight instructor and manipulating the flight controls, but it is true only for the FAA world.

Logging cross-country (XC) time

Essentially, “cross-country” refers to a flight between a point of departure and a point of arrival using standard navigation procedures. The FAA provides this definition in 14 CFR 61.1(b)(3)(i), and EASA FCL also mentions “following a pre-planned route.”

For EASA, any flight from airport A to airport B can be logged as a cross-country flight if it is planned and navigation procedures are followed, even the use of visual aids qualifies.

The FAA only allows flights at least 50 miles from the departure airport to be logged as cross-country flights for meeting private, instrument, or commercial minimums. More details can be found in this great paper from AOPA.

For meeting sport pilot minimums, any flight over 25 miles can be logged as cross-country.

However, the most interesting part is meeting the ATP minimums. It is not even required to have a destination! Any flight beyond 50 miles from the departure point can be logged as a cross-country flight, whether or not the aircraft lands somewhere else or just returns home after overflying some landmark.

In all other cases, a basic definition can be used. For instance, Part 135 allows flights from A to B to be counted as cross-country, even if less than 50 miles.

The nightmare begins if we don’t have an electronic logbook since the paper version does not have enough columns to summarize everything. Initially, I only had a paper logbook, so it took me some time to properly enter all previous flights into my electronic version and set the parameters, such as “cross-country more than 50nm,” “cross-country less than 50nm,” “acting as PIC” and so on 🙂

Hopefully, this information will prevent you from getting lost in the documents and regulations. If you require further information, do not hesitate to ask me!





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