Do I Need an Instrument Rating to Get a Commercial Pilot’s License?


The commercial license is a typical next step after gaining your private pilot’s license. Whether or not you want to end up flying for a living, lots of people will get their commercial rating for either the experience, the (minor) insurance premium break, or just as an asset in the event they ever want to fly for hire. If you plan on becoming a flight instructor you’ll need your commercial rating first.

But an even more common next step after becoming a private pilot is to get your instrument rating. So it’s a common question to ask do I need an instrument rating to get a commercial license?

An instrument rating is not required for a commercial pilot’s license but you will be restricted from carrying passengers more than 50 nautical miles and from flying for hire at night. If you complete your instrument rating these restrictions are removed.

In the rest of this post we’ll cover the verbatim regulation that addresses this topic, as well as look at some reasons you may or may not want to get an instrument rating along with your commercial pilot’s license.

Do I need an Instrument Rating to get a Commercial Pilot’s License?

Under Part 61 requirements, you do not need an instrument rating to receive your commercial pilot’s license.

However, an important caveat to getting your instrument rating in a Part 61 vs. Part 141 program is that Part 141 requires students to either already have their instrument rating, or be enrolled in an instrument rating program and have already passed the written test, prior to receiving their commercial license. 

For more reading on this topic, see our post on Part 61 vs. 141 Flight Schools – Requirements and Differences.

Restrictions on Commercial Pilot’s License If You Don’t Have an Instrument Rating

14 CFR 61.133(b)(1) says: “A person who applies for a commercial pilot certificate with an airplane category or powered-lift category rating and does not hold an instrument rating in the same category and class will be issued a commercial pilot certificate that contains the limitation, “The carriage of passengers for hire in (airplanes) (powered-lifts) on cross-country flights in excess of 50 nautical miles or at night is prohibited.” The limitation may be removed when the person satisfactorily accomplishes the requirements listed in § 61.65 of this part for an instrument rating in the same category and class of aircraft listed on the person’s commercial pilot certificate.”

While it isn’t cited in this same regulation, the term “night” is elsewhere defined within the regulations as the end of evening civil twilight to beginning of morning twilight: Twilight isn’t actually governed by a specific time (such as x minutes after sunset), but actually the moment in time when the sun is 6 degrees below the horizon. A good rule of thumb is that twilight ends approximately 30 minutes after sunset. If you’re interested, the Navy’s Air Almanac calculates it for you.

So if you’re carrying passengers for hire without an instrument rating, you’ll need to be on the ground by 30 minutes after the sun sets.

When You Might Not Need an Instrument Rating for Your Commercial Pilot’s License

Being restricted to 50 nautical miles and nighttime flights for hire seems pretty limiting on your commercial pilot privileges. So why would you want to get a commercial license if you’ll be that limited? Well, there are actually some pretty reasonable applications of limited commercial privileges you might not be nearly as limited as you think. Here are some examples.

Scenic Tours

These usually aren’t going to span more than 50 miles and would often times be during the day during good weather (so that the passengers can actually see). Unless you are flying extended legs through the Grand Canyon or elsewhere you probably aren’t going to need to fly more than 50 miles or at night to accomplish this mission, although you do need a commercial license if you’re going to get paid.

Crop Dusting

I went to commercial ground school with a few crop dusting pilots that did not have their instrument rating because the fields they were spraying were all well within 50 miles of the airport. All the spraying is also done in daylight hours and has to be in good enough VFR to be able to see the fields and complete their work. So this is a perfect situation where you would need a commercial license but the instrument rating limitation wouldn’t hold you back.

Skydive Pilot

This is another example where the job would be carried out almost exclusively during the daytime in good weather within 50 miles of the airport. Most times the skydiving takes place directly over the airport so you wouldn’t need to get anywhere close to 50 miles away. No instrument rating needed here.

Flight Instructor

Okay, you might be a little limited on this one. But by the book there is no regulation saying that you must possess an instrument rating in order to become a flight instructor. Granted you will be limited to not provide night instruction for hire or cross-country (which is defined with only a few exceptions as greater than 50 nautical miles from your originating airport), but you could still instruct otherwise. Practically speaking I think you’d be much more proficient as a CFI if you have your instrument rating but there is no regulation requiring it.

Float Pilot

Here’s another example of daytime flights that will take place in VFR conditions and likely not extend more than 50 miles from the airport. Granted, without an instrument rating you might be less hire-able as a pilot for this position but it likely wouldn’t hold you back per the regulations.

Car Traffic Spotting

You can probably get away without needing an instrument rating in this type of job unless the traffic you are spotting is more than 50 miles away from the airport (which is unlikely but definitely possible). It will need to be VFR and during the day anyways to spot the traffic so you won’t be limited on that front.

Why You DO Want an Instrument Rating along with a Commercial License

Above were some examples where you could pretty reasonably exercise your commercial pilot privileges while never truly needing an instrument rating. But unless you very clearly fit into one of those buckets (or something similar), there are a lot of reasons to get your instrument rating if you’re planning on having your commercial rating.

Airline Pilot

You will need an instrument rating here almost without exception. Maybe some small float plane operators might not need or require the instrument rating but if you’re planning to fly in an airline or air transport role, get your instrument rating.

An instrument rating is also required to get your ATP (Airline Transport Pilot) Certificate. For more reading on this, see our article comparing private pilot, commercial pilot, and ATP certificates.

Safety

The instrument rating was definitely where I progressed the most as a pilot. All other learning has taken place over time with various experiences, but the instrument rating took me to another level after getting my private. Not only will it make you safer pilot in marginal weather, it will make you a safer pilot in ANY situation. From becoming more familiar with your aircraft systems and instrumentation, to relying on instruments when visibility is worsening, to understanding IFR radio calls even when you’re flying VFR, the instrument rating will make you a more well-rounded pilot.

Versatility

If you’re planning on being a pilot with commercial privileges, even if you are starting out crop dusting or flying skydivers, it would greatly benefit you to already have your instrument rating so in the event more opportunities arise for pilot positions, you will already be eligible. The instrument rating can take a little while (covered below) and so if you can go ahead and crank it out it might save you a lot of time in the future and allow you to be more opportunistic when you hear of other employment opportunities.

Instrument Rating Requirements (Time and Cost)

For a more thorough explanation be sure to read our post How Long Does It Take to Get Your Instrument Rating along with How Much Does an Instrument Rating Cost. But generally speaking it takes around 40-45 flight hours of training that will take 1-6 months (depending on how often you fly) and cost around $8,000. Our articles cover some time and money saving tips on this topic so be sure to check them out if you want to learn more.

Commercial License Requirements (Time and Cost)

Again for a more thorough explanation be sure to read our posts How Long Does it Take to Earn a Commercial Pilot’s License. The commercial license is pretty easy but in terms of hours and expense it will really be determined by how many of the prerequisite flight experience hours you have already accomplished.

There are requirements like 250 hours of total time, 10 hours in a complex, turbine, or Technically Advanced Airplane (TAA), certain cross country length requirements, and more. Depending on how many of those you have already met it could be a pretty quick process or it could take you many months to complete all of them. In our post we cover all of those requirements so you can get an idea of how long it might take you.

Blue skies! (or really, truly, crummy skies if you’re working on your instrument rating)

Charlie Gasmire

Charlie Gasmire is a commercially licensed pilot and aircraft owner and has been flying since 2004. He holds both single and multi-engine commercial certificates, as well as a private single engine seaplane certificate, instrument rating, and tailwheel endorsement. He owns a 1975 Cessna 182P and shares the lessons learned both on AirplaneAcademy.com and his YouTube channel with tens of thousands of subscribers and millions of views. You can read more about Charlie’s story here.

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