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Commercial pilot · ACS CA.I.A · lesson pack

Pilot Qualifications (Commercial)

Why this one matters

Pilots flying for pay face pressure that private pilots rarely do: the customer is waiting, the job pays only if it flies, and declining feels like failing. Knowing exactly what the certificate allows, and the line where an operation needs an air carrier certificate, protects passengers and the pilot. So does keeping proficiency well above the legal minimum.

1 · Know these cold

  • •A commercial pilot may act as pilot in command of an aircraft carrying persons or property for compensation or hire, and may act as a pilot for compensation or hire, if qualified under the rules for that operation.(14 CFR 61.133(a))
  • •Without an instrument rating, an airplane commercial certificate is limited: no carrying passengers for hire on cross-country flights over 50 nautical miles or at night.(14 CFR 61.133(b))
  • •The certificate alone doesn’t let you carry persons or property for hire on your own: both common carriage (holding out to the public) and private carriage for hire need an operator with a Part 119 certificate (usually Part 135), unless the operation is one of the 119.1(e) exceptions. You fly for hire for such an operator, in a 119.1(e) operation, or as a pilot for someone else’s own Part 91 flying.(14 CFR 119.1, 119.5; AC 120-12A, Private Carriage Versus Common Carriage)
  • •Some commercial work is outside Part 119, such as banner towing, aerial photography or survey, crop dusting, pipeline patrol and ferry flights.(14 CFR 119.1(e))
  • •Commercial privileges need at least a second-class medical, valid for that purpose through the end of the 12th month. BasicMed can’t be used to exercise commercial privileges, though you can use it when flying with only private privileges.(14 CFR 61.23; 61.113(i))
  • •"Compensation" is broad: money, but also flight time, reimbursement or other things of value.(AC 120-12A, Private Carriage Versus Common Carriage)
  • •To act as PIC at all: a flight review (1 hour ground, 1 hour flight, endorsed) within the preceding 24 calendar months. To carry passengers: also 3 takeoffs and landings within 90 days, as sole manipulator, in the same category, class and type (if a type rating is required); full stop in a tailwheel airplane, and full stop between 1 hour after sunset and 1 hour before sunrise for night passengers.(14 CFR 61.56(a), (c); 61.57(a)-(b))

2 · The lesson

Earning the certificate and staying current
  • Eligibility: at least 18, read, speak and understand English, hold a private pilot certificate, and pass the knowledge and practical tests.(14 CFR 61.123)
  • For an airplane single-engine rating, 250 hours total, including: 100 in powered aircraft (50 in airplanes); 100 as PIC, including 50 in airplanes and 50 cross-country (10 of those in airplanes).(14 CFR 61.129(a)(1)-(2))
  • 20 hours of training: 10 of instrument training (5 in a single-engine airplane); 10 in a complex, turbine-powered or technically advanced airplane; a 2-hour day and a 2-hour night cross-country, each more than 100 nm straight-line from the start; and 3 hours of checkride preparation within the preceding 2 calendar months.(14 CFR 61.129(a)(3))
  • 10 hours solo (or as PIC with an instructor aboard) in a single-engine airplane, including a cross-country of at least 300 nm total with landings at three points, one at least 250 nm straight-line from the start, and 5 hours at night with 10 takeoffs and 10 landings at a towered airport.(14 CFR 61.129(a)(4))
  • The flight review is to act as PIC at all, not only with passengers: at least 1 hour of ground and 1 hour of flight training, endorsed, within the preceding 24 calendar months (or an approved equivalent such as a new certificate or rating or a WINGS phase).(14 CFR 61.56(a), (c)-(e))
  • Passenger currency is separate: 3 takeoffs and landings in the preceding 90 days as sole manipulator, same category, class and type (if required); touch-and-go is fine by day except in a tailwheel airplane; at night, 3 to a full stop between 1 hour after sunset and 1 hour before sunrise.(14 CFR 61.57(a)-(b))
  • Three different nights: log night time between the end of evening and start of morning civil twilight (Part 1); night passenger currency uses 1 hour after sunset to 1 hour before sunrise; position lights are required from sunset to sunrise. The 61.133(b) night limit uses the Part 1 definition.(14 CFR 1.1; 61.57(b); 91.209)
  • Log the training and experience used for a certificate, rating or recent experience.(14 CFR 61.51)
Privileges, limits and common carriage
  • You may be paid to fly and may carry persons or property for hire, within the rules for the operation you’re doing.(14 CFR 61.133(a))
  • Without an instrument rating: no passengers for hire beyond 50 nm cross-country or at night.(14 CFR 61.133(b))
  • Common carriage means holding out to the public, willing to carry anyone who pays. That needs an air carrier or operating certificate under Part 119.(AC 120-12A, Private Carriage Versus Common Carriage)
  • Examples outside Part 119 include aerial work like banner towing, aerial photography and survey, crop dusting, pipeline patrol and ferry flights.(14 CFR 119.1(e))
  • Nonstop sightseeing under 91.147 is an operator authorization, not a pilot privilege: the operator holds a Letter of Authorization, flights begin and end at the same airport and stay within 25 statute miles of it, follow the Part 136 Subpart A safety rules, and the operator runs an FAA drug and alcohol testing program. (Statute miles here; the 61.133(b) limit is 50 nautical.)(14 CFR 91.147; Part 136, Subpart A)
  • Flying a company’s own airplane for its own business (a corporate pilot) is a Part 91 operation: the company isn’t carrying anyone for hire, and you are paid as its pilot.(14 CFR 61.133(a); AC 120-12A, Private Carriage Versus Common Carriage)
  • When in doubt about an offer, ask the FSDO or an aviation attorney before you fly it.(AC 120-12A, Private Carriage Versus Common Carriage)
Medical certificates and documents
  • Second class for commercial privileges: through the last day of the 12th calendar month after the exam month, at any age. Then it serves for private privileges through the 60th month if you were under 40 at the exam, or the 24th if 40 or older.(14 CFR 61.23(d))
  • Don’t fly with a known medical condition that would make you unable to meet the medical standards, or while taking medication that does.(14 CFR 61.53)
  • Alcohol: no flying within 8 hours of drinking, while under the influence, or at 0.04 or more.(14 CFR 91.17)
  • Carry your pilot certificate, a medical certificate appropriate to the privileges, and government photo ID.(14 CFR 61.3)
  • BasicMed can’t be used to exercise commercial privileges: those need at least a second-class medical. It’s the privileges you use, not the certificate you hold: as a commercial pilot you may fly under BasicMed when exercising only private privileges. A flight instructor acting as PIC may instruct under BasicMed and be paid for the instruction, and since the 2024 Act a pilot examiner may give practical tests under it.(14 CFR 61.23(a)-(c); 61.113(i); FAA Reauthorization Act of 2024)
  • BasicMed eligibility comes first: you must have held a Part 67 medical certificate valid at any time after July 14, 2006; your most recent application must not have been denied, and your most recent certificate (including any special issuance) not suspended, revoked or withdrawn; and certain mental-health, neurological and cardiovascular conditions need a one-time special issuance before BasicMed.(14 CFR 61.23(c)(3); 68.9)
  • BasicMed limits, stated in full: an aircraft authorized to carry no more than 7 occupants with a maximum certificated takeoff weight of no more than 12,500 pounds; no more than 6 passengers on board; at or below 18,000 feet MSL; at or below 250 knots indicated; not for compensation or hire; and not outside the United States unless the country you fly in authorizes it (Mexico and the Bahamas do). You need a physician exam using the Comprehensive Medical Examination Checklist (CMEC) within the preceding 48 calendar months and the BasicMed medical education course within the preceding 24 calendar months, a valid U.S. driver’s license, and the CMEC and course certificate in your logbook. Current text, effective November 18, 2024; checked 2026-11-12.(14 CFR 61.113(i); 61.23(c)(3); Part 68)
Currency isn’t proficiency
  • Legal minimums are not enough for flying people for pay. Set personal minimums and practice above them.(Risk Management Handbook (FAA-H-8083-2A))
  • Commercial work often means new airplanes and avionics. Get a thorough checkout before carrying anyone in them.(Risk Management Handbook (FAA-H-8083-2A))
  • Know the pressures of paid flying (schedules, customers, money) and decide your go/no-go rules before the day.(Risk Management Handbook (FAA-H-8083-2A))

Want it all on one page, with scenarios? Read the full lesson.

3 · Say it out loud

Answer each one out loud, then check yourself and mark how it went.

  1. Remember Recall it

    “What does 61.133 let a commercial pilot do?”

  2. Understand Explain why

    “Why can’t a new commercial pilot start selling seats to the public on charter flights?”

  3. Apply Use it on a flight

    “A local company offers to pay you to fly its manager to meetings in its own airplane. Your medical is a third class. What do you check?”

4 · Common mistakes

  • Thinking the certificate allows charters.

    Carrying people or property for hire needs a Part 119 operator, unless 119.1(e) applies.

    Instead: Know where 61.133 ends and Part 119 begins.

  • Forgetting the medical class.

    Third class doesn’t cover commercial privileges.

    Instead: Second class, renewed every 12 months for paid flying.

  • Flying the legal minimum.

    Currency isn’t proficiency.

    Instead: Set and keep personal minimums.

5 · Quick check

Answer, then reveal. Flag anything you want to see again.

  1. 1. Minimum age for a commercial certificate?

  2. 2. Total time required for an airplane single-engine commercial (Part 61)?

  3. 3. Limit on a commercial airplane certificate without an instrument rating?

  4. 4. Medical class needed for commercial privileges, and for how long?

  5. 5. Can you use BasicMed to fly for hire?

  6. 6. Name two kinds of commercial work outside Part 119.

  7. Scenario7. You post an ad offering flights to anyone who pays. What have you created?

Trained it? Now prove it: practice pilot qualifications (commercial) out loud with our examiner.

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Connect it

One situation that runs across this lesson and its neighbors in the same ACS area. Decide first, then check.

Connect it · Preflight Preparation

A week after your checkride, a friend's company offers to pay you to fly three employees to a meeting in a rented 172. They want to leave at 6 a.m.; you have a full workday before.

Can you take the job, and what else matters? Decide, then see the worked answer

It turns on who provides the airplane and who has operational control. If you rent the 172 and provide the company pilot plus airplane, that's carrying persons for compensation, and offering it (holding out, under AC 120-12A) makes it common carriage. That needs an operator certificate under Part 119, with the flight run as an on-demand Part 135 operation, so decline. The lawful version is the company renting or leasing the airplane in its own name, holding operational control, and paying you only to fly it. That's a Part 91 flight, and your commercial certificate lets you be paid as its pilot (the FAA's Green (1993) and Ferris (1990) interpretations draw this line). None of the 119.1(e) exceptions, such as student instruction, nonstop commercial air tours under 91.147, ferry or training flights, or aerial work like banner towing, covers flying a company's employees to a meeting. 91.409(b) requires a 100-hour inspection for an aircraft carrying any person, other than a crewmember, for hire, or used for flight instruction for hire in an airplane the instructor provides. Company employees flown on the company's own business, without being charged, aren't passengers for hire in that sense, so it doesn't automatically apply to the Part 91 version; check the airplane's inspections either way. Then check yourself: a second-class medical for commercial privileges, a current flight review, and three takeoffs and landings in the last 90 days to carry passengers. Without an instrument rating, 61.133(b)(1) bars carrying passengers for hire on cross-countries over 50 NM or at night. Part 91 has no duty or rest limits, so fatigue is yours to manage: run IMSAFE honestly, and a 6 a.m. report after a full workday needs a real sleep opportunity first. If you won't get one, decline or move the departure. Pressure to please a client makes the call harder, not different.

14 CFR 61.23, 61.56, 61.57, 61.133, 91.409(b), 119.1; AC 120-12A; Risk Management Handbook (FAA-H-8083-2A)

Brings together: Pilot Qualifications · Airworthiness Requirements · Human Factors

Teaching this? The instructor lesson plan →

Study aid, not FAA guidance. Sources: 14 CFR; AC 120-12A; Risk Management Handbook (FAA-H-8083-2A); Commercial Pilot ACS (FAA-S-ACS-7B). Checked against current sources 2026-11-13.