Instrument Currency and the IPC: 61.57(c) and (d)

Instrument currency has nothing to do with hours. To act as pilot in command under IFR, or in weather below VFR minimums, 14 CFR 61.57(c)(1) requires that within the 6 calendar months preceding the month of the flight you "performed and logged" six instrument approaches, holding procedures and tasks, and intercepting and tracking courses through the use of navigational electronic systems. Six approaches with no holding is not current. Fifty hours of actual IMC with five approaches is not current either.

The second half of the rule is the part pilots misjudge. Lapse, and you get six more calendar months to fix it yourself. Lapse longer than that and 61.57(d) says you "may reestablish instrument currency only by completing an instrument proficiency check."

The passenger-carrying rules in 61.57(a) and (b) are a separate clock; the currency post covers those.

The three tasks in 61.57(c)

The regulation names exactly three things, and all three are required: "(i) Six instrument approaches. (ii) Holding procedures and tasks. (iii) Intercepting and tracking courses through the use of navigational electronic systems." They must be done in the category of aircraft "for the instrument rating privileges to be maintained," either "in actual weather conditions, or under simulated conditions using a view-limiting device."

Three details hide in that text. The six approaches have a count; holding and tracking do not, so one hold in the window satisfies (ii) as written. Category matters, so approaches in a helicopter do not keep an instrument-airplane pilot current (gliders have their own scheme in 61.57(c)(3)). And the tasks must be logged, not just flown, which is why 61.51(g)(3) requires "the location and type of each instrument approach accomplished" and "the name of the safety pilot, if required."

Nothing in 61.57(c) says you must be acting as PIC while you do the tasks. The text says "that person performed and logged." On that reading, approaches flown as sole manipulator while a current, rated pilot acts as PIC under IFR count, provided you log them properly.

What counts as an approach for currency

An approach counts for 61.57(c) when flown solely by reference to instruments and established on each required segment down to the MDA or DA/DH, with simulated conditions, if used, continued to that altitude (FAA InFO 15012, Logging Instrument Approach Procedures, September 8, 2015). The regulation itself does not define a loggable approach, so the FAA's Flight Standards Service published InFO 15012 to settle the hangar arguments. It is guidance, not regulation. Examiners quote it anyway.

The conditions, paraphrased: operate solely by reference to instruments; be established on each required segment to MDA or DA/DH; if simulating, keep the simulated IMC going until MDA or DA/DH. The InFO adds that "except when being radar vectored to the final approach course," the pilot flies the initial, intermediate and final segments from an initial approach fix or feeder route. The missed approach segment is the only one not required. A safety pilot or instructor "may simulate ATC radar vectoring," which is how a practice session fits six approaches into two hours.

In actual IMC the ceiling does not have to be at minimums. Break out at 1,500 feet on final and the approach still counts, as long as you were established on each segment and on instruments until the transition. The hood is stricter. Pulling it off 1,000 feet above MDA because the runway is in sight does not count, because the simulated conditions must continue to MDA or DA/DH.

The InFO cites "61.57(c)(1-5)" and ATD rules in "(c)(3)"; the paragraphs have since been reorganized, so read the eCFR rather than the 2015 footnotes.

How calendar months are counted

"Within the 6 calendar months preceding the month of the flight" means the window closes at the end of a month, never mid-month. Suppose you finish your sixth approach, a hold and some tracking on March 15, 2026. For a flight in September 2026, the six calendar months preceding September are March through August. March 15 is inside, so you are current through September 30. On October 1 the lookback becomes April through September, March drops out, and you are not.

The windows apply the "6 calendar months preceding the month of the flight" wording of 14 CFR 61.57(c)(1) and the "more than six calendar months" wording of 61.57(d)(1). The tasks do not have to come from one flight. They accumulate across the window, and each one must still be inside it: two approaches in April, three in June and one in August, with a hold in there somewhere, keeps you current through October 31. On November 1 the April pair drops out and you are back to four. One approach a month, with a hold inside every six-month window, never lapses. That is cheaper than the alternative.

The grace period and the IPC cliff

From October 1, 2026 in the example, you cannot act as PIC under IFR or in less than VFR conditions. From October 2026 through March 2027 you may still regain currency without an IPC: six approaches, holding and tracking under the hood with a safety pilot in VMC, or in an approved device, or as sole manipulator while someone else acts as PIC under IFR.

The cliff is "more than six calendar months." Currency ended September 30, 2026. October through March is six calendar months of lapse. April 2027 is more than six, and from then on 61.57(d)(1) allows only an instrument proficiency check. The grace period runs from when currency ended, not from the March 15 flight.

Treat the grace period as a to-do list, not a cushion. Six approaches with a safety pilot is one afternoon; an IPC is a scheduled CFII and an invoice.

Simulators and ATDs for currency

Every 61.57(c) task can be done in a full flight simulator, a flight training device or an aviation training device, "provided the device represents the category of aircraft for the instrument rating privileges to be maintained and the pilot performs the tasks and iterations in simulated instrument conditions" (61.57(c)(2)). The same paragraph allows "any combination of an aircraft, full flight simulator, flight training device, or aviation training device."

The current text sets no instructor-present requirement and no separate time limit for ATD currency. What it does require, through 61.51(g)(5), is that "a logbook or training record is maintained to specify the training device, time, and the content." The device's FAA letter of authorization (LOA) says what it is approved for; AC 61-136B, appendices B and C, says the LOA specifies allowable credit for "instrument recency of experience" for both basic and advanced ATDs. Ask for the LOA before you fly the session. Device time is not flight time and stays out of the flight-time columns, which How to log simulator time explains.

Safety pilot or actual conditions

A view-limiting device in an airplane requires a safety pilot in the other control seat under 91.109(c): at least a private pilot certificate with category and class ratings appropriate to the aircraft, adequate vision forward and to each side, and fully functioning dual controls (with a throwover-wheel exception). The safety pilot needs no instrument rating for a VFR practice flight. Who logs what in that airplane is covered in How to log safety pilot time.

Actual conditions need no hood and no safety pilot, but they need a current, rated acting PIC. If that is you, you must already be current. If it is the other seat, the "performed and logged" reading above lets you log the approaches as sole manipulator while the other pilot carries the responsibility. Write down which it was.

What an IPC must include and who may give it

An IPC must cover the areas of operation the instrument rating ACS lists for it, which for airplanes is the IPC table in FAA-S-ACS-8C, as required by 61.57(d)(1) through Appendix A to Part 61. Appendix A names FAA-S-ACS-8C, Instrument Rating Airplane, for both the rating and the IPC.

The ACS table (Appendix 1, "Instrument Proficiency Check") requires nothing from the first two areas of operation. It then requires holding (III.B), recovery from unusual attitudes (IV.B), intercepting and tracking navigational systems and DME arcs (V.A), every approach task in Area VI (non-precision, precision, missed, circling, landing), the Area VII tasks B, C and D (two engine-out tasks for multiengine airplanes only, plus an approach with loss of primary flight instruments), and postflight checks (VIII). On devices, the ACS allows an AATD for "the majority of the IPC as specified in the Letter of Authorization" issued for it, while the circling approach, the landing task and the multiengine tasks must be done in an aircraft or an FFS at Level B, C or D. A BATD cannot be used for any part of an IPC.

Who gives it is in 61.57(d)(3): an examiner, a military instrument check pilot for military members, a company check pilot for that operator's employees, an authorized instructor, or a person approved by the Administrator to conduct instrument practical tests. For most pilots that means a CFII. Paragraph 5.1.1 of AC 61-98E says the instructor "must hold an instrument rating on their pilot certificate and flight instructor certificate that is appropriate to the category and class of aircraft used," so a multiengine IPC needs a CFII who is also multiengine rated.

There is no failed IPC on paper. AC 61-98E, paragraph 5.4.1, tells the instructor not to endorse an unsatisfactory check but to log the session as "dual instruction given" instead. A satisfactory one gets the endorsement in AC 61-65K, item A.71, which certifies that the named pilot "has satisfactorily completed the instrument proficiency check of 14 CFR § 61.57(d) in a [M/M] aircraft on [date]."

A logbook entry that proves currency

Suppose a two-hour currency flight from KRDU in a Cessna 172, under the hood with a safety pilot, composed as an example rather than a record of a real flight. The entry needs the items in 61.51(b) and 61.51(g)(3): date, aircraft type and N-number, departure and arrival, total time, simulated instrument time, each approach by location and type, the holding and tracking, and the safety pilot's name.

The fields follow 14 CFR 61.51(b) and 61.51(g)(3), and the MDA/DA remark tracks InFO 15012. Two such flights in a window, or one with six approaches, and your logbook answers the currency question without a calculator. FlyFren's logbook tracks IFR currency from these fields, and like any tracker it can only count an approach entered with a location and a type.

Before the first IFR flight of a month, count. Six approaches, at least one hold, tracking, all dated inside the six calendar months before this one. If any of the three is missing, today is a currency flight with a safety pilot, not an IFR trip with passengers.

This article is educational and is not a substitute for the current regulations, the AIM, official weather briefings, or instruction from a CFI. Check the current text at the linked sources before you rely on any detail.