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Logging PIC Time: The Complete FAA Rules Under §61.51

Complete guide to logging PIC time under FAR §61.51. Covers acting as PIC vs sole manipulator, safety pilot PIC logging, student pilot PIC time, dual instruction, and common logging mistakes.

April 2026·8 min read read·Faraim Editorial

KEY POINT

Logging PIC time incorrectly is one of the most common mistakes pilots make — and it can jeopardize your certificate applications. Here's exactly when you can and cannot log PIC under §61.51.

Pilot-in-command time is the most valuable time in your logbook — and one of the most misunderstood. Under 14 CFR §61.51(e), PIC time may be logged under specific conditions. Getting it wrong can mean fraudulent logbook entries, which the FAA takes very seriously.

The Two Ways to Log PIC Time

Under §61.51(e), a pilot may log PIC time in two situations:

When the pilot is the sole manipulator of the controls of an aircraft for which they are rated
When the pilot is the sole occupant of an aircraft (solo flight)
When the pilot acts as PIC of an operation requiring more than one pilot (multi-crew aircraft)
When acting as PIC in accordance with the requirements of the pilot certificate held

Acting as PIC vs Sole Manipulator

This distinction causes the most confusion. 'Acting as PIC' means you bear legal responsibility for the flight — you are the final authority. 'Sole manipulator' means your hands are on the controls, regardless of who is officially the PIC.

Both can log PIC simultaneously. On a dual instruction flight where the student is flying (sole manipulator) and the CFI is legally the PIC, the student logs PIC as sole manipulator and the CFI logs PIC as the pilot responsible for the flight. Both entries are correct and legal.

Student Pilot PIC Time

A student pilot may log PIC time during solo flights. This is one of the more counterintuitive rules — student pilots aren't certificated PICs, but the FAA specifically allows them to log PIC time during authorized solo operations under §61.51(e)(1). The student must be authorized for solo flight and operating within the scope of their endorsements.

Safety Pilot and PIC Logging

When two pilots share a flight with one under the hood for instrument currency purposes, the logging rules are specific and were clarified in the FAA's Simmons legal interpretation (2011):

The pilot under the hood logs PIC as sole manipulator of the controls
The safety pilot may ONLY log PIC if they are designated as PIC for the flight before the flight begins
Both cannot log PIC simultaneously unless one is logging as sole manipulator
The safety pilot may always log SIC (second-in-command) time
If the safety pilot is designated PIC, they log PIC and the person under the hood logs sole manipulator PIC — total PIC logged for the flight = time in aircraft + time under hood

When You Cannot Log PIC

When flying an aircraft for which you are not rated (you may log SIC if appropriately certificated)
When a CFI is required and acting as PIC but you are not the sole manipulator
When you are a passenger with no control responsibilities
When flying as SIC in a single-pilot aircraft just to build time (SIC time, not PIC)

Logging Dual Instruction as PIC

When you receive dual instruction, you log the time as both dual received and, if you were the sole manipulator, as PIC. The CFI also logs PIC. Your logbook entry for a typical training flight shows: Total = 1.5 hrs, PIC = 1.5 hrs (sole manipulator), Dual Received = 1.5 hrs. This is correct and expected.

Always document who is the designated PIC in your logbook for any shared flight. A brief note ('designated PIC for this flight' or 'safety pilot, designated PIC') in the remarks protects you if the FAA ever reviews your logbook.