A pilot’s logbook is more than a regulatory requirement. It is the permanent documentary record of a flying career. From the first dual lesson to the final professional application, the logbook tells the story of where, how, and under what authority you flew. It also becomes a legal document relied upon by examiners, employers, insurers, and sometimes, attorneys.
Because of that, how time is logged matters just as much as how it is flown.
Few areas generate more confusion than the distinction between acting as pilot in command and logging pilot-in-command time. That confusion increases significantly when Aviation Training Devices, particularly Basic Aviation Training Devices (BATDs) and Advanced Aviation Training Devices (AATDs), enter the picture.
This article clarifies:
Under 14 CFR 1.1, the pilot in command is defined, in part, as "the person who has final authority and responsibility for the operation and safety of the flight."
That authority is reinforced by 14 CFR 91.3, which assigns full responsibility for the operation of the aircraft to the pilot in command.
Only one person may act as pilot in command at any given time. This is a legal and operational role, not a logging privilege.
Logging pilot-in-command time is governed by 14 CFR 61.51(e). Logging is a record-keeping activity and does not require that the pilot be acting as pilot in command.
The FAA explicitly allows multiple pilots to log pilot-in-command simultaneously, provided each pilot independently meets the regulatory conditions for logging.
This distinction is critical for:
For student pilots, the rule is intentionally narrow.
Under 14 CFR 61.51(e)(4), a student pilot may log pilot-in-command time only when:
During dual instruction, the instructor acts as pilot in command, and the student logs dual-received (but not pilot-in-command).
During solo flight, the student is both acting as pilot in command and logging pilot-in-command time. This is true only in aircraft. No form of aviation training device is approved for logging pilot-in-command time, even during unsupervised simulator sessions. Read more about logging ATD time here.
Once certificated, logging options expand significantly.
Under 14 CFR 61.51(e)(1)(i), a pilot may log pilot-in-command time when rated in the category and class of aircraft and acting as the sole manipulator of the controls. This is true even if another pilot is acting as pilot in command.
For example, say you fly with a friend who is also rated. Before the flight, you agree that s/he will act as pilot in command. If you hand-fly for 30 minutes, you may still log that 30 minutes as pilot-in-command time because you were the sole manipulator.
A common misconception is that pilots cannot log pilot-in-command time while receiving instruction for endorsements such as complex, high-performance, and tailwheel.
This is incorrect. As long as the pilot is rated in the category and class, s/he may log pilot-in-command as sole manipulator while simultaneously logging dual received. The instructor may log pilot in command as an authorized instructor under 14 CFR 61.51(e)(3).
When flying simulated instrument conditions under 14 CFR 91.109(b), the safety pilot is a required crewmember, and the pilots must agree before the flight who is acting as pilot in command.
FAA interpretations confirm:
When training in Basic or Advanced Aviation Training Devices, the regulatory framework changes significantly.
Logging aviation training device time is governed primarily by 14 CFR 61.51, 61.57, and 61.65. AC 61-136B clarifies which tasks may be credited when ATDs are used under these Parts.
Since BATDs and AATDs are not aircraft and do not generate flight time under the aforementioned regulations, pilot-in-command time cannot be logged. This is true regardless of certificate level or instructor presence.
A certificated pilot using a Basic or Advanced Aviation Training Device without an instructor may log only what the regulations explicitly allow.
Pilot-in-command time, dual-received, dual-given, and total flight time are not permitted. However, while ATD time may not be logged as total flight time, it can and should be logged separately as ATD time where allowed.
Permitted entries include simulated instrument time, instrument approaches (if the device is approved for the task), holding procedures (if approved), and instrument currency tasks under 14 CFR 61.57(c).
When a CFI provides instruction in a Basic or Advanced Aviation Training Device, the pilot may log dual-received, simulated instrument time, instrument approaches and holding procedures (as authorized), and time toward an instrument rating or instrument currency (subject to regulatory limits).
The pilot may not log pilot-in-command time, total flight time, or cross-country time. Some pilots mistakenly log total time for aviation training device sessions. This is incorrect. ATD time is not flight time under FAA definitions and, as such, it should be logged separately.
For more information on logging ATD time, download our free guide to Understanding Aviation Training Devices.
A CFI providing instruction in an aviation training device may log dual-given, instructor time, and simulator or ATD time. S/he may not log pilot-in-command time or total flight time.
Although the instructor has authority over the session, PIC is defined only for aircraft operations, and ATDs fall outside that definition. This distinction is critical for CFIs who later apply for airline or Part 135 positions, where pilot-in-command definitions are scrutinized carefully.
The FAA distinguishes between aircraft operations where pilot-in-command authority exists and training devices where no aircraft, airspace integration, or legal pilot-in-command authority exists.
Even high-fidelity Advanced Aviation Training Devices are not aircraft under 14 CFR 1.1. Therefore:
This distinction is firm and frequently misunderstood.
While FAA regulations define what is legal to log, employers define what they will accept.
Airlines often interpret ‘pilot-in-command time’ to mean time in which the pilot signed for the aircraft and had operational command authority. They often want acting PIC or captain time. This can differ from FAA logging privileges.
In this context, best practices include the following:
The same principle applies to corporate aviation, charter operations, and military flight experience.
A clean, consistent, regulation-compliant logbook reduces checkride friction, prevents interview surprises, protects you in audits or disputes, and reflects professional discipline.
The FAA gives pilots considerable flexibility, but only within clearly defined boundaries, especially when simulators and training devices are involved.
You need to show that you understand the difference between authority and manipulation, aircraft and training device, and acting and logging. If you do, your logbook will tell a story that is accurate, defensible, and respected from flight one to final interview.