ACS Task IR.I.A — Pilot Qualifications (Instrument Rating)

What does ACS Task IR.I.A test?

IR.I.A is the first task the DPE evaluates and it sets the tone for the entire oral. The task tests whether you understand the legal requirements for acting as PIC under IFR — not just that the rules exist, but how they apply to your specific situation on the day of the checkride. The FAA Instrument Rating ACS (FAA-S-ACS-8C) organizes this task into three elements: Knowledge, Risk Management, and Skills.

Most DPEs open the oral with a variant of "Are you current and legal to act as PIC under IFR today?" Your answer is the gateway to the entire task. A candidate who answers that question fluently — naming the specific regulation, the specific tasks they completed, and the dates — demonstrates the kind of self-awareness the ACS demands. A vague answer invites follow-up that can drag the oral into difficult territory early.

What is the instrument currency requirement under 14 CFR 61.57(c)?

To act as PIC under IFR, you must have logged, within the preceding 6 calendar months, the following tasks in actual IMC, simulated IMC under a view-limiting device, or an approved training device per 14 CFR 61.57(c)(1):

• 6 instrument approaches
• Holding procedures and tasks
• Intercepting and tracking courses through the use of navigational electronic systems

This is the "6/6/HITS" rule: 6 approaches, Holding, Intercepting, Tracking, within 6 calendar months. Note that "6 calendar months" means the 6 calendar months preceding the month of the flight — not 180 days. If your currency window opens in November, it closes at the end of May (not 180 days from November 1).

Under 14 CFR 61.57(c)(2), you may complete these tasks in a full flight simulator, flight training device, or aviation training device provided the device represents the category of aircraft for the instrument privileges you are maintaining. You may also mix simulator time and actual flight time to satisfy the requirement.

What happens when instrument currency lapses?

When currency lapses, the duration of the lapse determines the path back. 14 CFR 61.57(d) governs:

The IPC must cover the ACS instrument standards and be administered by an authorized instructor who holds an instrument rating in the same category of aircraft. After a successful IPC, your 6-month currency clock resets.

What certificates and documents does 14 CFR 61.3 require?

Under 14 CFR 61.3, you must have in your physical possession or readily accessible in the aircraft:

• Your pilot certificate (physical card or temporary certificate from the Airmen Certification Branch)
• A current medical certificate issued under 14 CFR Part 67 (or valid BasicMed documentation if applicable)
• Government-issued photo identification (driver's license, passport, U.S. Armed Forces ID, or airport security credential)

The DPE verifies all three at the start of the oral exam before the test clock begins. An expired medical, a forgotten pilot certificate, or no photo ID terminates the checkride immediately. Bring all three documents.

What are the logbook requirements under 14 CFR 61.51?

14 CFR 61.51 governs what pilots must log and how. Key provisions for the instrument pilot:

Instrument time logging: You may log instrument time "only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument conditions." Time under a foggles but operating VFR in VMC is legitimate simulated instrument time. Time under the hood at cruise with a safety pilot qualifies.

Approach entries: For instrument currency purposes, 14 CFR 61.51(g) requires you to record the location and type of each instrument approach in your logbook. "ILS," "RNAV (GPS) LPV," or "VOR" must appear — "approach" alone is insufficient. The airport identifier or name must also be recorded.

Safety pilot entries: When you fly simulated instrument conditions with a safety pilot, the safety pilot's name must appear in your logbook. The safety pilot must hold at least a private pilot certificate with appropriate aircraft category and class ratings, and the aircraft must require two pilots or the safety pilot must be acting as required crew.

PIC time: Under 14 CFR 61.51(e), you may log PIC time as the sole manipulator of the controls in an aircraft for which you are rated, regardless of who is acting as PIC for legal purposes.

What were the aeronautical experience requirements to earn the instrument rating?

The DPE may ask you to explain how you met the eligibility requirements under 14 CFR 61.65(d) — this is a knowledge element of IR.I.A. For the instrument-airplane rating, the requirements are:

• 50 hours of PIC cross-country flight time, with at least 10 hours in airplanes
• 40 hours of actual or simulated instrument time in the required ACS areas of operation
• At least 15 of the 40 hours with an authorized instrument instructor (CFII) in an airplane
• At least 3 hours of instrument training from a CFII within the 2 calendar months before the practical test
• One IFR cross-country flight of at least 250 nm, with at least 3 different kinds of approaches using navigation systems

Simulator credit toward the 40-hour instrument requirement is capped at 20 hours (non-Part 142 device) or 30 hours (Part 142 qualified simulator). No more than 20 total hours in a flight simulator, FTD, or ATD may count toward the 40-hour instrument experience requirement, per 14 CFR 61.65(i).

Risk Management elements in IR.I.A

The ACS requires you to identify and mitigate hazards associated with flying when you are not current or are overconfident about your abilities. The key risk management elements the DPE evaluates in IR.I.A include:

Currency vs. proficiency distinction: Currency is the legal minimum under 14 CFR 61.57(c). Proficiency is the ability to fly safely. Advisory Circular AC 61-98D explicitly addresses this gap — a pilot who is just barely current after logging 6 approaches in a simulator 6 months ago may not be proficient to fly a real approach to minimums in actual IMC. The ACS expects you to articulate this distinction and describe how you would assess your own proficiency before accepting an IFR flight.

Personal minimums: The DPE will often ask what your personal minimums are and how you established them. A sound answer references your actual IFR experience, recent currency, and how personal minimums exceed published approach minimums to account for proficiency gaps.

Preflight action: This task cross-references the preflight requirements of 14 CFR 91.103, which requires a PIC to become familiar with all available information concerning a flight before departure. Pilot qualifications are part of that preflight action — verifying your own currency is a preflight task, not an afterthought.

Skill elements in IR.I.A

The skill element of IR.I.A is narrow: the DPE expects you to use your logbook (or a digital equivalent you can demonstrate and explain) to determine your actual instrument currency status. You should be able to:

1. 1
   Identify the most recent 6 calendar months in your logbook that contain instrument approaches.
2. 2
   Count the approaches and confirm you have at least 6 logged with location and type.
3. 3
   Confirm holding procedures and intercepting/tracking are logged within that same window.
4. 4
   State whether you are currently IFR current, and if not, explain your path to reestablish currency.
5. 5
   Show the DPE your CFII endorsement confirming you are prepared for the practical test.

The DPE will typically walk through this with you on the day of the checkride. Come with your logbook organized and a clear mental picture of your most recent currency-qualifying flights.

What the DPE Looks For

The DPE is evaluating three things simultaneously in IR.I.A:

1. Regulatory fluency: Can you name the specific regulation, not just describe the concept? "Under 61.57(c)(1)" is a stronger answer than "the currency rule."
2. Self-awareness: Do you actually know whether you are current today, and can you prove it? DPEs have seen candidates who thought they were current and were not.
3. Risk posture: Do you understand that currency is a floor, not a ceiling? The best candidates voluntarily note when they are current but may not be proficient, and describe how they manage that gap.

The DPE will also cross-check your CFII endorsements against your logbook entries. Your endorsement for the practical test under 14 CFR 61.65(a)(6) must be present and current. If the DPE cannot find it, the oral ends.

Common Errors in IR.I.A

• Confusing calendar months with a 180-day count — the rule uses calendar months, not days.
• Failing to log approach type and location — 'ILS Approach' without an airport identifier does not satisfy 14 CFR 61.51(g).
• Forgetting that holding and intercepting/tracking must also be logged, not just approaches.
• Not knowing the IPC requirement — candidates who say 'I'd just go fly more approaches' after more than 6 months of lapsed currency are wrong.
• Arriving without required documents — missing medical, missing photo ID, or expired temporary certificate stops the checkride before it starts.
• Treating currency as proficiency — stating 'I am current' without acknowledging the proficiency gap signals to the DPE that you have not internalized AC 61-98D.
• Unable to locate CFII endorsements quickly — fumbling through a logbook looking for endorsements is a poor first impression.

Practice Questions

Frequently Asked Questions

Sources

• 14 CFR 61.57 — Recent Flight Experience: Pilot in Command
• 14 CFR 61.65 — Instrument Rating Requirements
• 14 CFR 61.51 — Pilot Logbooks
• 14 CFR 61.3 — Requirement for Certificates, Ratings, and Authorizations
• FAA Instrument Rating ACS (FAA-S-ACS-8C)
• AC 61-98D — Currency Requirements and Guidance for the Instrument-Rated Pilot

This article was researched from FAA primary sources (ACS, 14 CFR Parts 61 and 91, AC 61-98D) and cross-referenced against Cornell LII for current regulatory text by MockDPE. Last updated: May 2026. If you spot an inaccuracy, email corrections@mockdpe.org.