Commercial Pilot License Requirements: 14 CFR 61.129

To hold a commercial pilot certificate with an airplane single-engine land rating you must be at least 18 years old, hold at least a private pilot certificate, and have logged at least 250 hours of flight time including 100 hours in powered aircraft, 100 hours as pilot in command and 50 hours of cross-country pilot-in-command time. You then pass a knowledge test and a practical test. The hours live in 14 CFR 61.129(a), the eligibility rules in 61.123, and this page walks through both in the order you will meet them.

If you want the route rather than the regulation, read how to become a commercial pilot, and for the local course see the commercial pilot license in Los Angeles, which is the pillar this page sits under. For the money, our commercial pilot license cost breakdown prices every hour listed below. All citations were checked against the current text of Part 61 on eCFR.

Eligibility: 14 CFR 61.123

Before the hours matter, 61.123 sets out who may apply for the certificate at all. You must:

• be at least 18 years of age;
• be able to read, speak, write and understand the English language;
• hold at least a private pilot certificate, or meet the alternative in 14 CFR 61.73 for military pilots;
• receive and log ground training from an authorized instructor, or complete a home-study course, on the aeronautical knowledge areas in 61.125, and hold an instructor endorsement for the knowledge test;
• receive and log flight training on the areas of operation in 61.127(b), and hold an instructor endorsement for the practical test;
• pass the knowledge test and pass the practical test; and
• meet the aeronautical experience requirements of 61.129 for the category and class sought.

There is one requirement people expect to find in 61.123 that is not there: the medical certificate. That lives in 14 CFR 61.23(a)(2), which requires at least a second-class medical certificate to act as pilot in command or as a required pilot flight crewmember in operations requiring a commercial pilot certificate. In practice that means you can train and take the checkride on a third-class medical, but you cannot exercise the privileges the certificate gives you until you hold a second class. Our page on the second-class medical certificate covers what the examination adds.

The 250 Hours, Decoded

61.129(a) is written as a set of overlapping requirements rather than a list of separate hours, which is why it confuses people. The 250 is the total. Everything underneath it is a slice of that same 250, and slices overlap.

Why The Hours Overlap

A single flight can satisfy several lines at once, and understanding that is the difference between a sensible plan and a wasteful one. The 300-nautical-mile cross-country in (a)(4)(i) is also cross-country pilot-in-command time under (a)(2), also airplane time under (a)(1), and also part of the 250. A night cross-country flown solo counts toward (a)(4), the night requirements, cross-country PIC time and the total, all at once.

This is why we tell commercial students to plan their remaining hours on paper before they fly any of them. Fifty hours flown thoughtfully can close four requirements. Fifty hours flown in circles above the Valley closes one.

The Choice In (a)(4): Solo Or Duties Of Pilot In Command

61.129(a)(4) gives you two ways to log those 10 hours: solo flight time in a single-engine airplane, or flight time performing the duties of pilot in command in a single-engine airplane with an authorized instructor on board. The second option exists mainly for pilots whose insurance, rental agreement or employer will not permit solo flight in the aircraft concerned, and it costs more because the instructor is being paid. Where solo is available it is almost always the cheaper route.

The Two Long Cross-Countries

Two flights in 61.129 are large enough to need planning as events rather than lessons.

The 300-nautical-mile cross-country under (a)(4)(i) must total not less than 300 nautical miles with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original point of departure. From Van Nuys that is a genuinely good day out: north up the Central Valley, east across the desert, or a coastal run with a turn inland. The 250-mile leg is the binding constraint, and it is worth measuring on a chart rather than estimating.

The 2-hour night cross-country under (a)(3)(iii) and its daytime twin must each cover a straight-line distance of more than 100 nautical miles from the original point of departure, in a single-engine airplane, with an authorized instructor. Southern California makes the night version one of the best flights in the whole certificate: the basin from 6,500 feet after dark is a sight that stays with people. Our page on night flying covers the recency rules that go with it.

What Counts As Complex Or Technically Advanced

61.129(a)(3)(ii) asks for 10 hours in a complex airplane, a turbine-powered airplane, or a technically advanced airplane. The three are alternatives, not a sequence.

• A complex airplane has retractable landing gear, flaps and a controllable-pitch propeller. Our Piper Arrow PA-28R, N316EF, is the classic example: 200 hp, retractable gear, constant-speed propeller.
• A technically advanced airplane is defined in 61.129(j) as one with an electronic primary flight display including the required flight instruments, an electronic multifunction display including a moving map with GPS navigation, and a two-axis autopilot integrated with the navigation and heading guidance system, all of it continuously visible.
• A turbine-powered airplane qualifies on its own terms and is rarely the practical option at this stage.

Do not confuse this training requirement with the endorsement you need to act as pilot in command of a complex airplane, which comes from 14 CFR 61.31(e) and is a separate event. We price the complex endorsement in the Arrow at $999, and our page on complex and high-performance endorsements explains both.

How Much Simulator Time Counts Toward 250

14 CFR 61.129(i) allows a maximum of 50 hours of training in a full flight simulator, flight training device or aviation training device to be credited toward the total aeronautical experience requirements for an airplane rating, where the training is given by an authorized instructor. A course conducted by a Part 142 training center may credit up to 100 hours.

We are a Part 61 school and do not hold a Part 142 certificate, so 50 hours is our ceiling, and we use 45 of them across our private, instrument and commercial packages in the FAA-approved Redbird MCX. At $120 an hour inside a package against $269 for a rental airplane, that credit is the largest legitimate saving available on the way to 250 hours. Simulator hours that count sets out the caps certificate by certificate.

Part 61 And Part 141 Are Not The Same Number

You will see 190 hours quoted for a commercial certificate. That figure comes from the approved course requirements for Part 141 pilot schools, not from Part 61. We train under Part 61, so the applicable number here is 250 hours under 61.129(a), and we say so rather than letting the smaller figure sit in the background.

In practice the difference matters less than it appears. A Part 141 course trades flexibility for a lower legal minimum, and most Part 141 students finish above 190 anyway. Our page on Part 61 versus Part 141 in Los Angeles goes through the trade honestly.

The Knowledge Areas And The Areas Of Operation

14 CFR 61.125 lists the aeronautical knowledge areas your ground training must cover and the knowledge test will examine. They include the regulations applying to commercial pilot privileges and limitations, NTSB accident reporting requirements, basic aerodynamics and the principles of flight, meteorology including windshear recognition and avoidance, weight and balance computations, performance charts and the effects of exceeding performance limitations, pilotage and dead reckoning, air navigation facilities, aeronautical decision making, aircraft systems, maneuvers and emergency operations, night and high-altitude operations, and operating within the National Airspace System.

14 CFR 61.127(b)(1) lists the areas of operation for the airplane single-engine rating, and the practical test is organized around them: preflight preparation, preflight procedures, airport operations, takeoffs and landings and go-arounds, performance maneuvers, ground reference maneuvers, navigation, slow flight and stalls, emergency operations, high-altitude operations, and postflight procedures.

The Commercial Pilot – Airplane Airman Certification Standards, FAA-S-ACS-7B, effective 31 May 2024, expand each of those into tasks with knowledge, risk management and skill elements and state the tolerances you must fly to. Performance maneuvers is the area most private pilots underestimate — chandelles, lazy eights, steep spirals and eights on pylons are flown to standards tighter than anything on a private checkride. Our page on commercial pilot maneuvers covers them individually.

The Instrument Rating Limitation In 61.133

This is the requirement that is not a requirement, and it catches people out. 14 CFR 61.133(a)(2) provides that an applicant for a commercial pilot certificate with an airplane category and single-engine class rating who does not hold an instrument rating in the same category and class will be issued a certificate carrying the limitation: the carriage of passengers for hire in airplanes on cross-country flights in excess of 50 nautical miles, or at night, is prohibited. The limitation is removed when you satisfactorily complete the requirements of 61.65 for an instrument rating in that category and class.

So the instrument rating is legally optional and practically mandatory. A commercial certificate that cannot carry passengers for hire beyond 50 miles or after dark is not a certificate an employer has much use for. Every commercial student we train holds the instrument rating first, and our pages on instrument rating requirements and what it costs cover that step.

Multi-Engine And Other Classes

61.129 has separate paragraphs for each class. The airplane multi-engine land requirements in 61.129(b) mirror the single-engine list but require the relevant hours in multi-engine airplanes, including 10 hours of training in a multi-engine complex or TAA airplane. Most pilots add the multi-engine rating as a class rating on an existing commercial certificate rather than taking the commercial checkride in a twin, which is faster and far cheaper. Our multi-engine rating is a seven-day accelerated course at $5,100 in the Piper Seminole, and multi-engine rating requirements covers the regulation.

A Checklist Before You Commit

1. Total your logbook properly: total time, powered aircraft time, airplane time, PIC time, cross-country PIC time and night time, each as a separate number.
2. Subtract each from the 61.129(a) requirement and write down the largest gap. That is your plan.
3. Book the second-class medical before the checkride, not after.
4. Sit the knowledge test early; the result is valid for the calendar month plus 24 calendar months.
5. Plan the 300-nautical-mile cross-country and the two 100-mile flights as specific routes on a chart.
6. Decide whether the instrument rating comes first. For almost everyone it should.

Related Reading

• How to become a commercial pilot — the whole route in order.
• Commercial pilot license cost — every hour above, priced.
• Commercial pilot maneuvers — chandelles, lazy eights and eights on pylons.
• Commercial pilot training in California — the state picture.
• Instrument rating requirements — the rating that removes the 61.133 limitation.
• What a commercial pilot does — the work available at 250 hours.

Commercial Pilot Requirements FAQ

How Many Hours Do You Need For A Commercial Pilot License?

250 hours of total flight time under 14 CFR 61.129(a) at a Part 61 school, including 100 hours in powered aircraft with 50 in airplanes, 100 hours of pilot-in-command time with 50 in airplanes and 50 of cross-country, 20 hours of training on the commercial areas of operation, and 10 hours solo or performing the duties of pilot in command.

What Is The Minimum Age For A Commercial Pilot License?

18 years old, under 14 CFR 61.123(a). There is no upper age limit for the certificate itself. The mandatory retirement age of 65 applies to pilots in Part 121 airline operations, not to commercial pilots generally.

What Medical Certificate Does A Commercial Pilot Need?

At least a second-class medical certificate to exercise commercial privileges, under 14 CFR 61.23(a)(2). You may train and take the practical test on a third-class medical, but you cannot be paid to fly until you hold the second class.

What Is The 300 Nautical Mile Cross-Country Requirement?

Under 14 CFR 61.129(a)(4)(i), one cross-country flight of not less than 300 nautical miles total distance with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original point of departure. It may be flown solo or performing the duties of pilot in command with an instructor aboard.

How Many Complex Hours Are Required For A Commercial Certificate?

Ten, under 14 CFR 61.129(a)(3)(ii), and they may be flown in a complex airplane, a turbine-powered airplane or a technically advanced airplane. A technically advanced airplane is defined in 61.129(j) as having an electronic primary flight display, an electronic multifunction display with a moving map and GPS, and an integrated two-axis autopilot, all continuously visible.

Do You Need An Instrument Rating For A Commercial Pilot License?

Not to be issued one, but without it 14 CFR 61.133(a)(2) places a limitation on the certificate prohibiting the carriage of passengers for hire on cross-country flights of more than 50 nautical miles or at night. The limitation is removed by completing the 61.65 instrument rating requirements in the same category and class.

Why Do Some Schools Say 190 Hours Instead Of 250?

Because 190 is the minimum for an approved commercial course at a Part 141 pilot school. We train under Part 61, where the applicable figure is 250 hours under 61.129(a). Most Part 141 students finish above 190 in any case.

How Much Simulator Time Counts Toward The 250 Hours?

Up to 50 hours of approved full flight simulator, flight training device or aviation training device time under 14 CFR 61.129(i), given by an authorized instructor, at a Part 61 school. A Part 142 training center course may credit up to 100 hours.

Bring Your Logbook And We Will Total It Properly

Almost everyone who asks us about commercial requirements has a logbook with most of the answer already in it, and a couple of columns they have never totaled. Book a free consultation, bring the book, and we will work out exactly which lines of 61.129 you are short on and what closing them costs. If you are earlier in your training, a 60-minute discovery flight at $229 is logged as dual instruction and counts toward every one of these totals. Call (818) 330-1318 any day between 9 AM and 9 PM, or visit 7900 Balboa Blvd, Van Nuys, CA 91406, on Van Nuys Airport.