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● RDT COMM ·Double-Rice-7609 ·August 11, 2026 ·16:37Z

I’ve lost 6 months instrument currency. My buddy is fully current. Can I log actual imc and approaches if I’m fully at the controls and he is my safety pilot?

I’ve lost 6 months instrument currency. My buddy is fully current. Can I log actual imc and approaches if I’m fully at the controls and he is my safety
Detailed analysis

The scenario describes a common gray area in instrument currency regulations: a pilot who has let their six-month currency lapse under 14 CFR 61.57(c) wants to know whether flying with a currently-qualified pilot in the right seat allows them to log actual instrument meteorological conditions (IMC) and approaches. The short answer is yes, but with an important legal distinction that trips up many GA pilots—the difference between logging flight time and acting as pilot-in-command (PIC).

The core issue is that 61.57(c) currency governs the privilege to act as PIC under IFR or in IMC, not the ability to log instrument time or approaches. Separately, 61.51(g) permits any pilot to log instrument time, including approaches, whenever they are the sole manipulator of the controls while operating solely by reference to instruments, regardless of whether they are current. This means the pilot who has lost currency can absolutely log the actual IMC time and the approaches flown, provided they are hand-flying the aircraft under instrument conditions. What they cannot do is act as PIC for that segment of flight—that role must be filled by the currently-qualified friend, who becomes the PIC of record and bears legal responsibility for the flight, including filing the IFR flight plan and ensuring regulatory compliance.

A frequent point of confusion in this scenario is the term "safety pilot," which technically only applies under 91.109(c) to simulated instrument flight conducted in VMC using a view-limiting device such as a hood or foggles. In actual IMC, there is no simulation occurring, so the safety pilot construct doesn't apply in the same way—instead, the second pilot is functioning as the PIC because the flying pilot lacks current privileges to hold that role. This distinction matters operationally: the currently-qualified pilot must be legally and practically capable of taking over PIC duties, including flying the approach to completion if necessary, since they carry the certificate authority for the flight. It also means logbook entries should reflect this arrangement accurately—one pilot logging PIC time as the rated, current crewmember, and the other logging dual-received or simply instrument/approach time as sole manipulator, not PIC time, for that segment.

For professional pilots, this question may seem elementary, but it surfaces regularly among corporate and charter pilots who fly personal aircraft on the side, as well as flight instructors fielding it from instrument students preparing for instrument proficiency checks (IPCs). Under Part 135 and Part 121, recurrent training and checking cycles keep currency issues largely moot, but many pilots holding ATP or commercial certificates also maintain GA aircraft or fly with friends in club airplanes, where 61.57 currency can lapse during busy seasons. Understanding that lost currency doesn't prevent logging valuable actual-IMC experience—only PIC authority—helps pilots plan efficient paths back to currency, often combining a currency-building flight with a friend before scheduling a formal IPC with a CFII. It's a useful reminder that FAA logging rules and acting authority are governed by separate regulatory sections, a nuance that experienced pilots should be equipped to explain clearly to less experienced aviators or students working toward their instrument rating.

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