Logging PIC as SIC Under FAA Rules
Many commercially rated civilian pilots and military-rated aviators sit in the right seat for hundreds or thousands of hours and assume that time can only be logged as Second-in-Command (SIC). That assumption is often incomplete—and sometimes costly when it comes to ATP certificates, type ratings, insurance, or airline applications.
Under longstanding FAA legal interpretations, a properly rated pilot serving as SIC in Part 91, 135, or 121 operations may log Pilot-in-Command (PIC) time for the portions of the flight during which that pilot is the sole manipulator of the controls.
This is not a loophole. It is an explicit recognition by the FAA of the difference between acting as PIC and logging PIC time.
The Critical Distinction: Acting vs. Logging
Acting as PIC (14 CFR § 1.1) means you are the pilot designated by the certificate holder who is responsible for the safety and operation of the aircraft. Only one pilot can act as PIC at a time.
Logging PIC time (14 CFR § 61.51(e)) is a separate recordkeeping rule. It allows pilots to credit aeronautical experience for certificates, ratings, and currency. Two pilots can log PIC time simultaneously under different provisions of the regulation.
The key provision is § 61.51(e)(1)(i):
A sport, recreational, private, commercial, or airline transport pilot may log pilot-in-command flight time for that flight time during which that person… is the sole manipulator of the controls of an aircraft for which the pilot is rated…
What the FAA Legal Interpretations Actually Say
Carpenter Interpretation (February 9, 1999) In a Part 121 scenario, the FAA confirmed that when the certificate holder designates a PIC and an SIC, and the SIC is the sole manipulator of the controls (and is rated for the aircraft), the SIC may log that time as PIC. The designated PIC remains the acting PIC for the entire flight, but the sole-manipulator SIC still logs PIC under the regulation.
Counsil Interpretation (April 13, 2012) This Chief Counsel letter refined the earlier guidance. It confirmed that sole-manipulator time can be logged as PIC only if the pilot holds the appropriate category, class, and type rating that is not limited to “SIC Privileges Only.” An SIC-only type rating does not satisfy the “rated” requirement for logging PIC under § 61.51(e)(1)(i).
These principles apply equally to operations under Part 91K and Part 135 when the aircraft or the regulations under which the flight is conducted require more than one pilot.
Practical Requirements for Logging the Time as PIC
To log sole-manipulator time as PIC while serving as SIC, you generally need:
- To be the sole manipulator of the flight controls (hand-flying or managing the autopilot both qualify under FAA guidance).
- To hold the full type rating for the aircraft (no “SIC Privileges Only” limitation).
- To meet the other baseline requirements of § 61.51(e)(1)(i) (appropriate category and class ratings).
You do not need to be the designated/acting PIC for the flight. You remain the assigned SIC for operational and company purposes.
Why This Matters for Civilian Commercial and Military-Rated Pilots
Many military pilots transition with substantial multi-crew time that was logged primarily as SIC or co-pilot. Proper documentation of sole-manipulator segments can strengthen ATP applications and type-rating eligibility.
Civilian commercial pilots building time in 135 or 91 operations often under-report usable PIC experience simply because they were assigned to the right seat.
Accurate logging affects total PIC time shown on applications, insurance underwriting, and future upgrade potential.
Incorrect assumptions about “right-seat time only” can leave legitimate experience on the table.
Important Caveats
You cannot double-count the same hour as both PIC and SIC for total flight time purposes.
Logging the time as PIC under § 61.51 does not automatically make you the acting PIC, nor does it satisfy operator-specific PIC qualification, operating experience, or recent experience requirements under Parts 121, 135, or 91K.
Special rules apply under an SIC Professional Development Program (PDP) authorized by § 135.99(c). Those programs have their own logging provisions.
Next Steps for Accurate Logging
Review your logbook entries against the actual flight segments in which you were the sole manipulator and confirm your type rating status. When in doubt, the controlling documents remain the Carpenter (1999) and Counsil (2012) legal interpretations together with the current text of 14 CFR § 61.51(e).
Understanding these rules is not about creative logging—it is about accurately reflecting the experience the FAA already recognizes.