The scenario described in this forum post touches on a routine but frequently misunderstood corner of FAR 61.57: whether two pilots, both lapsed on their instrument currency and both within the six-calendar-month "grace period," can legally serve as each other's safety pilot to regain currency. The answer is yes, and this is a well-established practice among instrument-rated pilots. Under 61.57(c), a pilot must log six instrument approaches, holding procedures, and intercepting/tracking courses within the preceding six calendar months to remain current to act as PIC under IFR. If that window lapses, the pilot enters a second six-month grace period during which they can still regain currency by performing those tasks with a safety pilot rather than needing to fly with an instructor or take a full instrument proficiency check (IPC). Only after 12 months of total lapse does an IPC become mandatory per 61.57(d).
The critical requirement here is that the safety pilot must hold at least a private pilot certificate with the appropriate category and class rating, and must be able to act as PIC of that aircraft (meaning appropriate endorsements, medical, and if the safety pilot is not sharing the flight for currency purposes, they don't need a current medical if they're not logging PIC time toward certification requirements—though best practice and most interpretations require a valid medical if any PIC time is logged). Notably, the safety pilot is not required to hold an instrument rating at all under 61.57(c), since their job is purely to serve as a lookout for traffic while the flying pilot is under the hood. However, in this case both pilots are instrument-rated, which is actually advantageous: it means either can competently monitor the approach, catch procedural errors, and step in if something goes sideways, adding a layer of safety beyond the bare minimum required by the regulation. The arrangement described—alternating roles, flying approaches with holds and course intercepts/tracking in VMC with the safety pilot maintaining visual separation—is precisely the textbook method flight instructors and DPEs point to for legally and safely regaining IFR currency without an IPC.
For working pilots, particularly those flying Part 91 personal or business aircraft, this kind of reciprocal arrangement is a low-cost, practical way to stay current between recurrent training cycles, and it's especially relevant for corporate and charter pilots who may fly VFR-heavy missions or sit reserve for stretches long enough to lapse on approaches. While Part 135 and 121 operators typically have far more rigorous currency and recency requirements baked into recurrent training, checkrides, and OpSpecs that supersede basic 61.57 minimums, many business aviation pilots flying under Part 91 or 91K (fractional) still rely on the same currency logic as GA pilots when between formal training events. Understanding the grace period nuance also matters for scheduling: a pilot who lets currency lapse doesn't need to panic and book a CFII immediately—there's a full additional six months to self-remediate with a qualified safety pilot before an IPC becomes mandatory.
One aspect worth flagging for the original poster and readers: the person under the hood must file and fly under IFR procedures conceptually (approach plates, published holds, proper intercepts) even though the flight itself remains conducted in VMC for the safety pilot's benefit—this is not the same as flying in actual IMC, and does not satisfy any actual instrument time logging requirements, only currency requirements. This distinction between "currency" (61.57) and "proficiency" is one the broader aviation community increasingly emphasizes, especially as accident data continues to show loss-of-control and CFIT events disproportionately involve pilots who were technically current but not truly proficient. Threads like this one reflect a healthy trend in the GA community: pilots proactively seeking clarification on regulatory nuance before acting, and using peer support structures—safety pilot swaps, flying clubs, online forums—to maintain safety margins rather than treating the FARs as a bare minimum checkbox exercise.