14 CFR 91.205 — Required Equipment for IFR (ATOMATOFLAMES + FLAPS + GRABCARD)

What does 14 CFR 91.205 require, and when does it apply?

14 CFR 91.205(a) establishes that no person may operate a powered civil aircraft with a standard U.S. airworthiness certificate in any operation unless that aircraft is equipped with the instruments and equipment specified in subsections (b) through (f) for that type of operation — and all of that equipment must be in operable condition. The regulation is organized in layers: (b) sets the baseline for VFR day flight, (c) adds requirements for VFR night, (d) adds requirements for IFR, and (e) imposes a DME requirement at or above FL 240. The three standard mnemonics — ATOMATOFLAMES, FLAPS, and GRABCARD — map directly onto subsections (b), (c), and (d). Every item below is drawn verbatim from the current regulatory text.

What is the VFR day equipment list — ATOMATOFLAMES decoded?

14 CFR 91.205(b) lists the minimum equipment required for VFR flight during the day. ATOMATOFLAMES is the mnemonic that captures every item:

Two items warrant close attention. First, the manifold pressure gauge applies only to altitude engines — supercharged or turbocharged powerplants. A normally aspirated engine does not require one. Second, the anticollision light requirement in (b)(11) applies only to small civil airplanes certificated after March 11, 1996. Aircraft certificated before that date are not required to have anticollision lights under (b)(11), though many were retrofitted. The ELT requirement flows through to 91.207, which sets its own conditions and exceptions.

What does VFR night add — FLAPS decoded?

14 CFR 91.205(c) requires all (b) day equipment plus five additional items for VFR night flight, captured by the mnemonic FLAPS:

The landing light requirement is conditional: it applies only if the aircraft is operated for hire. A private pilot flying a personal aircraft at night is not required to have a working landing light. The anticollision light in (c)(3) applies to all U.S.-registered civil aircraft — a broader applicability than the (b)(11) anticollision requirement, which was limited to aircraft certificated after March 11, 1996. For night VFR, both (b)(11) and (c)(3) are in play. The fuses requirement is often tested on oral exams: spare fuses must be accessible to the pilot in flight, not packed in a bag in the baggage compartment.

What does IFR add — GRABCARD decoded?

14 CFR 91.205(d) requires all VFR day and night equipment plus the following IFR-specific items, decoded by the mnemonic GRABCARD:

The radio requirement at (d)(2) is purposefully broad: "suitable for the route to be flown" means the equipment must match the navigation requirements of the actual route — VOR, GPS, ILS, or DME as applicable. It does not dictate specific avionics brands or redundancy levels beyond what the route demands. The rate-of-turn indicator at (d)(3) carries an exception: aircraft equipped with a third attitude instrument system usable through 360 degrees of pitch and roll (installed per 14 CFR 121.305(j)) are not required to carry a separate rate-of-turn indicator. This exception is rarely applicable to general aviation aircraft. The altimeter under (d)(5) must be sensitive and adjustable for barometric pressure — a basic drum-pointer altimeter that cannot be set to the current altimeter setting does not satisfy this requirement.

What is the DME requirement at FL 240 under 91.205(e)?

14 CFR 91.205(e) requires U.S.-registered civil aircraft operating at or above FL 240 within the 48 contiguous states and the District of Columbia to be equipped with approved DME or a suitable RNAV system. This requirement is separate from GRABCARD and does not apply to IFR operations below FL 240. A WAAS GPS receiver that is approved as an RNAV system satisfies (e) in lieu of DME. This is a common exam question: candidates who add DME to their GRABCARD recitation for all IFR operations are adding a requirement that does not exist below FL 240.

What happens when a required instrument is inoperative — 91.213 deferral?

When an instrument or piece of equipment required by 14 CFR 91.205 is inoperative before departure, the deferral process is governed by 14 CFR 91.213 . The outcome depends on whether the aircraft has an approved Minimum Equipment List (MEL) or not:

1. 1
   With an FAA-approved MEL: Consult the MEL. If the MEL authorizes deferral of the inoperative item, placard it inoperative, deactivate or remove it per the MEL procedure, and make the required maintenance log entry. The aircraft may then be operated in accordance with any conditions the MEL imposes.
2. 2
   Without an MEL (most Part 91 GA aircraft): The item may be deferred only if it is not required by 91.205, not required by the aircraft's VFR-day type certificate, not required by an airworthiness directive, and does not cause another instrument or system to be inoperative. If those conditions are met, placard the item inoperative and make a maintenance record entry.
3. 3
   If required by 91.205 and no MEL deferral applies: The aircraft is not airworthy for that operation. The flight must be cancelled or a different aircraft used.

The practical consequence for IFR students: if the attitude indicator fails before an IFR departure and the aircraft has no MEL, you cannot legally depart IFR. That instrument is directly required by 91.205(d)(8). By contrast, a malfunctioning outside air temperature gauge is not a 91.205(d) item, so it can be deferred under 91.213 without an MEL, provided the other conditions are met.

What do DPEs ask about 91.205 during the oral exam?

Examiners expect candidates to recite GRABCARD from memory and immediately explain the purpose of each item. Knowing the mnemonic is not enough — expect follow-on questions that probe the edge cases.

• "Walk me through GRABCARD. What is the regulatory basis for each item?"
• "Your altimeter appears to be working but the Kollsman window is stuck. Are you legal for IFR?"
• "What is the difference between the anticollision light requirement in 91.205(b) and the one in 91.205(c)?"
• "You discover your rate-of-turn indicator is inoperative before an IFR departure. What are your options under 91.213?"
• "Does 91.205 require DME for all IFR flights?"
• "Your aircraft has no MEL. The OAT gauge is broken. The attitude indicator is broken. Which one grounds you, and why?"

Practice Questions

1. You are conducting a preflight for an IFR departure. The gyroscopic directional gyro tumbled overnight and reads incorrectly. The aircraft has no FAA-approved MEL. Can you legally depart IFR? Cite the specific paragraph of 91.205 that governs this.

2. A DPE asks you to recite GRABCARD. After you do, she asks: "Which of those items also has an exception that may allow an aircraft to depart without it?" What is the exception and under what paragraph does it appear?

3. Your aircraft is certificated in 1992. You note the anticollision light is inoperative. Does this ground you for VFR day flight under 91.205(b)? Explain the applicability date.

4. You plan an IFR flight to an airport with an ILS. Your aircraft has a single VHF nav/comm. Does this satisfy 91.205(d)(2)? What does "suitable for the route to be flown" mean in practice?

5. A student asks: "If I'm flying IFR at FL 250, does the GRABCARD list change?" What additional requirement applies and under which subsection of 91.205?

Frequently Asked Questions

Q: What does GRABCARD stand for in 14 CFR 91.205?

GRABCARD decodes the additional IFR equipment required by 14 CFR 91.205(d) : Generator/alternator, Radio (comm and nav), Attitude indicator, Ball (slip-skid indicator), Clock with seconds, Altimeter adjustable for barometric pressure, Rate-of-turn indicator, and Directional gyro.

Q: What does ATOMATOFLAMES stand for?

ATOMATOFLAMES covers the VFR day equipment list under 14 CFR 91.205(b) : Airspeed indicator, Tachometer, Oil pressure gauge, Manifold pressure gauge, Altimeter, Temperature gauges, Oil temperature gauge, Fuel gauges, Landing gear position indicator, Anticollision lights, Magnetic direction indicator, ELT, and Safety belts.

Q: What does FLAPS add for VFR night flight?

FLAPS decodes the additional equipment required by 14 CFR 91.205(c) for VFR night: Fuses (spare set accessible to the pilot), Landing light if operated for hire, Anticollision light system on all U.S.-registered aircraft, Position lights, and Source of electrical energy.

Q: Can you depart IFR with a broken instrument if it is not required by 91.205?

Possibly. Under 14 CFR 91.213 , inoperative equipment not required by 91.205, the MEL, or an airworthiness directive may be deferred by placarding it inoperative, deactivating it, and making a maintenance record entry. Required IFR instruments cannot be deferred without an approved MEL.

Q: Does 91.205 require DME for all IFR flight?

No. 14 CFR 91.205(e) requires an approved DME or suitable RNAV system only for operations at or above FL 240 within the 48 contiguous states and the District of Columbia. DME is not in the baseline (d) IFR equipment list.

Q: What clock is required for IFR flight under 91.205?

14 CFR 91.205(d)(6) requires a clock displaying hours, minutes, and seconds with a sweep-second pointer or digital presentation. A wristwatch that shows seconds satisfies the requirement.

Q: Is an autopilot required for IFR flight under 91.205?

No. 14 CFR 91.205(d) does not list an autopilot among the required instruments for IFR flight under Part 91. Specific operation types (RVSM, certain Cat II/III approaches, Part 135) may impose additional requirements beyond 91.205.

Q: Where does 91.205 appear on the instrument rating checkride?

Examiners typically address 91.205 under ACS Area of Operation II (Technical Subject Areas) and during the pre-departure equipment check. Expect to recite GRABCARD, explain each item's purpose, and discuss the 91.213 inoperative equipment deferral procedure.

Sources

• 14 CFR 91.205 — Instrument and Equipment Requirements (Cornell LII)
• 14 CFR 91.205 — Instrument and Equipment Requirements (GPO eCFR)
• 14 CFR 91.213 — Inoperative Instruments and Equipment (Cornell LII)
• 14 CFR 91.171 — VOR Equipment Check for IFR Operations
• 14 CFR 91.211 — Supplemental Oxygen Requirements
• FAA Instrument Rating ACS (FAA-S-ACS-8C)

This article was researched from FAA primary sources (14 CFR Part 91 via Cornell LII and GPO, Instrument Rating ACS) and citing current regulatory text — drafted by MockDPE. Last updated: May 2026. If you spot an inaccuracy, email corrections@mockdpe.org.