Restricted ATP Minimums

Robert Chapin

Easy-to-read details about the new ATP rules?  You found them!  I understand the need for simple explanations. There are six ways to get an ATP license now, each with different requirements.

This is my summary and comparison of the R-ATP minimums from 14 C.F.R. § 61.159 and § 61.160.

160 (a) 160 (b) 160 (c) 160 (d) 160 (f) 159
Age 21 years 21 years 21 years 21 years 21 years 23 years
Total Time as a Pilot 750 hours 1,000 hours 1,250 hours 1,250 hours 1,500 hours 1,500 hours
Cross-Country Time 200 hours 200 hours 200 hours see notes 200 hours 500 hours
Instrument Training Any § 141 § 141 § 141 Any Any
Commercial Training Any § 141 § 141 § 141 Any Any
Education Military Bachelor Associate Bachelor
Concentration Aviation Aviation Aviation
Certification see notes see notes see notes
Recognized Coursework 60 credits 30 credits 30 credits

General Requirements for All ATPs
Night Time 100 hours
AMEL Time 50 hours
Instrument Time 75 hours
PIC Time 250 hours
PIC Cross-Country Time 100 hours
PIC Night Time 25 hours
ATP CTP Requirement Effective Aug 2014
Knowledge Test Valid 5 years with ATP CTP
Medical Certificate 2nd Class

Important Notes

Under paragraphs (b), (c), and (d), you must graduate from a § 61.169 authorized institution.  The list of institutions is published at

There appears to be an error in the official version of paragraph (d).  At first reading, it seems to override § 61.159 leaving no cross-country time requirement.  The only requirements would be 1,250 hours total time and a transcript from an authorized institution.  However, I believe the intent of this paragraph is to require 1,250 hours total time and all other requirements of § 61.159.  By that reading, you would need 500 hours cross-country time.  It is also possible that the error is an omission by paragraph (e), in which case the intent is to require 200 hours cross-country time.  I expect this will be a matter of future amendments or interpretations by the FAA.

Further Reading

The full text of the ATP certification rules can be downloaded from the Federal Digital System – 14 C.F.R. § 61 Subpart G.

Age requirements can be found in § 61.153.  Knowledge test requirements can be found in § 61.39.  Medical requirements can be found in § 61.23.

You might be interested in my earlier article, First Officer Qualification Rule in Detail.

21 Mar 2014




Comment Feed


  • Shabab says:

    I was just wondering if you could email me how long the ATP written exam will be valid for if I take it before 1 Aug 2014.

  • Jake says:

    Thanks for posting this, I have a couple questions: If I got my Instrument at a flight school under part 61, is there any way to qualify for restricted ATP with less than 1500 hours? I am considering going back to a university and earning an Associates in Aviation, and switch to a part 141 school for my Commercial. Could this work?

    My second question is what qualifies as “aviation and aviation-related coursework that has been recognized by the Administrator as
    coursework designed to improve and enhance the knowledge and skills of a person seeking a career as a professional pilot”.

    Would A&P classes qualify?

    • Robert Chapin says:

      Hi Jake, there are exemptions being sought on behalf of individuals and universities. But to my knowledge, none have been granted so far.

      The recognized coursework is listed in the Letter of Authorization for each university. Because it’s specific to each institution, all I can say is maybe certain A&P courses would be recognized as Aircraft Systems credit. I believe recognized credits can be transferred from one authorized university to another.

      • Laura says:

        I work at a university with approval for the R-ATP, and I will tell you that only about half of our A&P courses were qualified by the FAA as “aviation and aviation-related coursework” and ultimately listed on our LOA.
        I know this discussion started a long time ago but just wanted to pitch in. On our school website, I made a detailed list of ALL our coursework approved by the FAA so it is as clear as possible to prospective and current students who need this information when choosing which school to attend.

  • Peter says:

    What is the difference between 61.160 (f) and 61.159. I have 520 TT and a CFII planning to take the ATP 7/14. I have a BS in Aero from ERAU, but my ratings were from part 61. I do not qualify for the 1000 hours?? What is it that I need for the ATP? I read of the need for 250 hours supervised by a PIC according 61.159 (5), I need this explained. Again, is it 200 or 500 cross country??
    Thank you,

    • Robert Chapin says:

      Hi Peter, you can qualify when you have 1,500 hours total time. If you do not have the 500 cross country required for full ATP then you can get the R-ATP under paragraph 160(f) with 200 cross country.

      The 250 hours of PIC time does not need to be supervised. If you are logging supervised SIC time at an airline and don’t have 250 PIC then you can use that time instead.

      • Brad says:

        Hi Robert, your last couple sentences got me thinking. In regard to 61.159 (a)(5)(i) and (ii), I am going to come up short on my PIC XC and PIC Night requirements. Unless…. I can count flying SIC time in a 135 operation. As it states, “or second in command performing duties of pilot in command while under the supervision of a pilot in command” leads me to think if I was in the left seat doing IOE or something. I never consider myself PIC, but we do switch roles from FP to NFP. Any thoughts?

  • Alex says:


    Running into some confusion regarding 61.160. I believe that for military (paragraph a) all we need are the hours mentioned in that paragraph and don’t need to get into the weeds regarding what Part (121, 141, etc) the school that gives the checkride’s qualification/certification is under so long as they are certified to perform checkrides. Is this correct? If not how hard is it to set up your own ATP checkride?

    • Robert Chapin says:

      Hi Alex, under 61.160(a) there are no FAA flight school requirements for qualified military pilots. In fact, under 61.153(d)(2) you might not even need an FAA pilot certificate to qualify. Enjoy!

  • Ana Pet says:

    Hi there Robert!

    Congratulations on your website! It is a very good and reliable source of information!
    I am a type rated copilot in the E190 (Embraer 190). I just completed 1500 hours total time, however I have less than 250 PIC time, so I need to log the time I was the Pilot Flying as Supervised PIC time to fullfil that requirement. I use Logten Pro. I would like to know if I need to get the signature of each and every Captain I’ve flown on each of those flights I was the PF? I only need about 80 hrs of Supervised PIC. Also how do I word an “endorsement” for them to sign on the remarks sedtion of the flight? Or should I just create a column “Supervised PIC” and log the time without having the captains sign in each fligh!? What is the best way to do this so when I do my ATP checkride everything is in order!?

    I really appreciate your help!
    Thanks a lot!

    • Robert Chapin says:

      Hi Ana, FAR 61.51(e)(1)(iv) does require certification by the supervising pilot if you are going to log that time.

      Pilot may log pilot in command flight time for flights … provided … the supervising pilot in command logs the pilot in command training in the the pilot’s logbook, certifies the pilot in command training in the pilot’s logbook and attests to that certification with his or her signature, and flight instructor certificate number.

  • Gerry Scoggin says:

    Hello Robert, I have a four year degree from Liberty University, which is on the FAA’s list of approved schools. I meet all of the requirements except I did not take the ATP written before 08/14. What do I have to do to meet the ATP requirements to get it? I am going to Sim to get a PIC type in a HS125, will this count as Sim time if I need it?

    • Robert Chapin says:

      Hi Gerry, §61.156 requires you to obtain an ATP CTP graduation certificate before you can take the written test. The CTP is likely not offered by your university, so you should find out if your new employer offers it when you get hired.

  • Will says:

    Do the “General Requirements for all ATPs” have to be met before the practical can be taken, or you just have to meet those before your restriction can be removed?

    I’m a military pilot but not an Aircraft Commander yet, so I’m lacking in PIC.

    • Robert Chapin says:

      Hi Will, §61.160(e) is clear on this point. A person who applies for reduced minimums “must otherwise meet the aeronautical experience requirements of §61.159.”

  • Justin Poynter says:

    Correct me if I am wrong. As I read the regulation the restricted ATP §61.160 does not only apply to those that have take an ATP CTP course but also to those who took the ATP written before August 1, 2014.

    • Robert Chapin says:

      Hi Justin, that is correct. The CTP is just a new prerequisite for the written knowledge test and is not required under 61.160.

  • Travis says:

    This is a great source of information. I am trying to break down how much of each flight time requirement has to be in airplanes. I am a military helo driver that is working on finishing up rTings right now and want to make each flight count towards what I need. Thanks!

    • Robert Chapin says:

      Hi Travis, that is a great question. It looks like the 250 hours PIC time, 100 PIC cross-country, and 25 PIC night in 61.159(a)(5) and the 50 hours multi-engine time in 61.159(a)(3) are both airplane requirements. Hopefully your helo time counts in all the other line items. 🙂

  • Kenneth says:

    I just want to clarify. I got my instrument and commercial ratings from a Part 61 school, I’m currently enrolled and nearing completion of my BS in Aero from ERAU. I passed my ATP written before the rule change. If I’m understanding this correctly, I’m not eligible for a R-ATP until 1500 hours at which point, I should just get my ATP.

  • Tracie says:

    I have been trying to understand some of the new regs, due to a change in career. However the information I have found in regards to the restricted ATP only applies to part 141 schooling and not part 61? Is that correct? I am short on night and instrument but meet all the other requirements, and trying to figure out where to go from here.

    • Robert Chapin says:

      Hi Tracie, you can credit up to 25 hours of simulation toward the 75 instrument, and you can credit up to 25 landings toward the 100 night requirement. If you already met the other requirements, then R-ATP doesn’t help because the night and instrument minimums are the same. Paragraphs b, c, and d do require training under part 141. Go find some night hours!

  • Andrew says:

    Thank you for your post, Robert. I am a bit confused on the requirements for § 61.159 applicants. Other than the cross-country time, does this rule require minimum PIC time, night time, instrument time, etc. like the full ATP? Or is it just 1,500 hours total time?

    • Robert Chapin says:

      Hi Andrew, §61.160(e) is clear on this point. A person who applies for reduced minimums “must otherwise meet the aeronautical experience requirements of §61.159.”

  • Mary says:

    Hi Robert,
    I graduated from Utah Valley University with my degree in Aviation Science with Professional Pilot emphasis, however, it was all done online and I did my flight training out of my own Skyhawk with a freelance instructor. I’m just going to go ahead and figure that I don’t qualify for the Restricted ATP of 1000 hours because I didn’t do the flight training at my university, which is a part 141 school. Or do I? I completed the classes and submitted my license’s and ratings in order to graduate. Does that count?

    • Robert Chapin says:

      Hi Mary, the “I don’t qualify … does that count?” type questions can be posed to the University. Without a certificate of eligibility, there is no way to take the checkride at 1,000 hours.

    • Laura says:

      Mary, did you get college credit for your training? Your school will have to check your college transcript with their individual letter from the FAA approving specific courses at their university.

  • Julien says:

    Hi, The required Instrument 75h, is it actual instrument or can it be simulated time?


    • Robert Chapin says:

      Hi Julien, “75 hours of instrument flight time, in actual or simulated instrument conditions.” That includes up to 25 hours in a flight training device.

  • Damon says:

    Can I be eligible to fly at age 21 with out a 2-year degree(160f)?

  • Mark says:

    In FAR 61.159(a)(6) it states, “Not more than 100 hours of the total aeronautical experience requirements of paragraph (a) of this section or §61.160 may be obtained in a full flight simulator or flight training device provided the device represents an airplane and the aeronautical experience was accomplished as part of an approved training course in parts 121, 135, 141, or 142 of this chapter.” Does this mean you can count up to 100 hours of simulator time toward the total time requirement of 1,500 hours? Or only toward the other simulator exemptions specifically stated in paragraph a?

    • Robert Chapin says:

      Hi Mark, the 100 hour credit applies to paragraph (a) only and not to the later paragraphs. As you can see, they have different equipment requirements.

  • Steve says:

    Robert, For military pilots do these qualify as PIC time that count towards the 500 hr minimum to upgrade to a Part 121 Captain?

    • PIC in a ME, turbine trainer A/C (eg. T-38) with a student on board? Even if the “operation” of the aircraft doesn’t require two pilots, the training “operation” does especially since I can’t fly from the backseat without a front seater.
    • Pilot Flying time logged during PIC upgrade training in a ME, turbine, multi-pilot A/C?
    • Any other creative places where PIC time can be counted?


    • Robert Chapin says:

      Hi Steve, see 61.51(e)(3) for CFI PIC time and then see 61.51(e)(1)(i) for receiving flight instruction on an aircraft for which you are already rated.

  • Diego says:


    how did you come to the conclusion that 160(d) requires Part 141 flight training? As far as I can tell, obtaining a bachelor’s degree from the FAA approved list, as well as having Part 61 flight training should suffice for the 1,250 hour requirement. Is flying Part 141 implied in the sentence “and otherwise satisfies the requirements of paragraph (b)”? If that’s the case, then the only difference between 160(b) and 160(d) is the amount of units you obtained upon graduation?


    • Robert Chapin says:

      Hi Diego, you might be interested in my other 61.160 articles. Some of them discuss Part 61 training. Currently, Purdue University is the only institution authorized to issue eligibility certificates under Part 61.

  • Luc says:


    regarding the R-ATP 1000 hrs and part 141 requirements, must the part 141 ground and flight training be taken at the University or institution that is accredited to deliver a R-ATP, or is there any exception to where the part 141 ground and flight must take place ?
    I did my ground and flight training at a part 141 school in 1997 (not an university). Is there a way to get a R-ATP at 1000 hrs if one enrolls in an accredited bachelor degree, gets all the credit and graduates, but already has his/her part 141 ground and flight training done at another school ? thanks

    • Robert Chapin says:

      Hi Luc, the FAA has been allowing transfers between authorized institutions only. Part 141 flight training is only one requirement, and it alone is not enough to become eligible at 1,000 hours.

  • Lyndsay says:

    Hi. My sons future plans are becoming a pilot. We have been doing research and talking with pilots. We have a university in mind that is a Part 141 university with a flight training program that offers a R-ATP. My son would obtain a Bach in Aeronautical Science as well as the flight training. The only issue is he will be 19 yrs old when he graduates this degree/program. The ATP requires 21 yrs old. His ultimate desire is to obtain the unrestricted-ATP at 23 yrs old. Any suggestions for us?

    • Robert Chapin says:

      Hi Lyndsay, my first impression is unrelated to aviation: Attempting to finish a bachelor degree by age 19 is a terrible idea. I commend your enthusiasm, but I encourage a more traditional path for education. Secondly, consider that the commercial pilot age limit is 18. This leaves a three year gap between commercial and airline certification if accelerated to the limits. It would be better to finish the degree program at 20 or 21 and then work toward the total pilot time for R-ATP.

  • Robert says:

    Hi Robert,
    I have a commercial multi instrument rating and have 1100tt. of which 500 is cross country, 100 night and more than 75 instrument. My question is can I use my flight engineer time (3000 hrs part 121tt) to supplement the 500 hrs when using a part 141 school to get the ATP? Thanks in advance for clearing the mud out of my eyes!

    • Robert Chapin says:

      This sounds like another “I don’t qualify … does that count?” question. Did you look under §61.159(c)(2)?

  • Steve says:

    Hi Robert,
    I am a military helo AC but I am also a qualified copilot in the C130 with 1500 hours of copilot time in the Herc. Per 61.51, I have ~750 hours as the “sole manipulator of the controls” of the C130 while being qualified as a C130 copilot.

    Does this count as PIC to meet minimums for ATP and to apply to a regional airline? Thank you for your insight.

    • Robert Chapin says:

      Hi Steve, a “qualified copilot” sounds like an SIC, which means you have 1,500 hours of SIC experience. When an airplane requires two pilots, it doesn’t matter who is controlling the airplane. Only one pilot is designated PIC / captain / commander.

    • David Allen says:

      I’m a former military pilot/current mei that does a lot of ATP practical ratings. The FAA allows military copilots to log their “primary” time as pic time. Primary time is logged on multi pilot aircraft when you are rated on that plane and the sole manipulated of the controls. In an odd twist though, the airlines generally don’t recognize primary time as pic time.

  • Daniel says:

    After I obtain my R-ATP certificate with the reduced minimums, do I just go to the FAA and get an official ATP certificate without the limitation of aviation experience once I have enough hours?

    • Robert Chapin says:

      Yes. You will need to apply again for ATP and removal of limitation, but there is no test involved. This is free at the FSDO. Just bring your logbooks.

  • JP says:

    Hi there, I have a question, ATM, I have 3.000 hours total, 2700 as a First Officer and only 100 hours as PIC, Do I need to get 150 PIC hours to complete the 250 requirement ? Or can I go for the flight test with my current flying condition ? Thank you very much.

    • Robert Chapin says:

      Hi JP, the question of “I don’t qualify … does that count?” has been posted three times now. I wish I could help but I’m not able to change the rules.

  • Julio says:

    Hi Robert, I am current flying a g450 with 1.360 Total time, with all flight general requirments.
    Ive got my Comercial/ Ifr/ mlte on part 141 flight school.
    What is that mean, Associated and bachelors?
    My question is:
    Can I have the R-ATP only having the required total flight time and have done my commercial IFR MLTE airman certificated in the part 141 flight school?

    Thank you

    • Robert Chapin says:

      Hi Julio, to be clear the answer is “no”. If you do not meet all of the minimums then you can not qualify “only having the required total.”

  • Cory S. says:

    Hey Rob!

    I do qualify for r-atp at 1000 hours, although I have not yet met my total time requirement. I do have 100+ hours of sim dual given in a part 141 program. Am I able to count 100 hours of those towards my total time considering I’ll be applying for a restricted atp?


    • Robert Chapin says:

      Hi Cory, there are no provisions under §61.51(h) or §61.159(a)(6) to credit “dual given” to your total time. Simulator credit may be obtained only by training received from and endorsed by a flight instructor, also known as “dual received”. Also, if you are applying for a job in connection with your ATP training, the allowance of any credits may be determined by the recruiter.

  • Kris D. says:

    I have a degree in Professional Aeronautics from Embry-Riddle and am currently an A&P mechanic but now I want to focus on flying for an airline. I am just starting out, working towards my private pilots license, but in order to qualify for the R-ATP at 1,000 hours, I would have to attend a university to get my commercial license? I could not go to any Part 141 that offers training for the commercial rating?


    • Robert Chapin says:

      Hi Kris, as an Embry-Riddle graduate, you are not automatically eligible for R-ATP. You can still seek eligibility through any of the R-ATP authorized institutions, and you will have to meet all of their requirements to get certified as eligible.

  • Michael Timpano says:

    I am currently a flight instructor who is eligible for the Restricted ATP. When i graduated college, I graduated with 58 credits that coincided with our Restricted ATP LOA. I am completing my multi and MEI which are one credit each. That would put me at the required 60 credits which is needed for the 1000 hours. However, those two credits would be obtained after I already graduated. Does this have any effect? Do the credits have to be obtained before graduation?

    Thank you

    • Robert Chapin says:

      Hi Michael, only the college can certify your eligibility, and probably only one or two people at your college deal with that process. You just need to ask the right people.

  • C.D. says:

    Thank you Robert for your research and very informative site. I have my instrument rating (many years ago-part 61 and also AMEL and non-aviation degrees) but still may wish to pursue an Associate’s or Bachelor’s in Aviation. If I complete 141 instrument training at an approved/accredited college, would I be able to take an instrument profeciency check instead of another checkride and application for a rating that I already have?? In other words, is the FAA 141 requirement for simply completing the structured instrument ground and flight training or also the rating itself? Or am I essentially barred from ever earning an R-ATP?

    It seems the FAA made the R-ATP regs so narrowly tailored that it makes it questionable and financially imprudent if anyone wants to go back and earn an aviation degree. The regs benefit young kids just starting college and effectively prejudice anyone who finished their education and much of their training in the past.

    • Robert Chapin says:

      Hi C.D., I think you have the gist of the program. Reduced minimum eligibility is designed for people who want to spend the next 6 years studying and working toward that rating. On the other hand, it sounds like you are already in a position to get the commercial rating and airline qualified in two years.

  • Erick Swanberg says:

    I am a retired UH-60 Blackhawk Instructor Pilot. I have over 6000hrs turbine helo time with a Comm/Inst helo rating. I have over 5900hrs Instructor/PIC time. What is the minimum fw time that I would need to qualify for the R-ATP

    • Robert Chapin says:

      Hi Erick, the reductions under the R-ATP program do not pertain to the certificate category. In other words, you are overqualified for R-ATP. What you need is a commercial airplane certificate and the 250 hours of PIC airplane experience to meet full ATP minimums.

  • Chris says:

    Of the 50 hours AMEL, can any of that be SIM time or is it required to be in the aircraft?

    • Robert Chapin says:

      Hi Chris, yes it is possible to credit simulator time from a Part 121 training program, for example. I was able to do this with less than 50 hours AMEL.

  • Connor Burns says:

    I currently attend a part 141 university, my degree is Professional pilot, I will graduate in May with a bachelor degree. I did my private, instrument and single engine commercial under part 141. But I did my multi engine add-on under part 61 after I got my Commercial ASEL. So will I qualify for the R-ATP at 1,250 hours? Because I have over 30 hours of aviation related courses approved by the FAA but do not have 60.

    • Robert Chapin says:

      Hi Connor, thank you for writing, and congratulations on your graduation.

      § 61.160(c)(3) requires an ATP applicant to hold a commercial pilot certificate, airplane category, and instrument rating, completed under an approved part 141 program. It does not restrict how you obtain a rating for class of aircraft, how you obtain the 1,250 hours, or anything beyond the commercial airplane and instrument curriculum.

  • Greg says:

    Hi there,
    Thanks for posting this information to make it a bit easier to understand for all of us who are going for our ATP certificates. I did have a question that revolves around the R-ATP. Currently I have around 860 hours of Total Flight time. I am a graduate of a part 141 institution, so the 1,000 hour requirement would apply for my situation. After reading through your posted information and through the FARs, I understand that “not more than 100 hours” of simulator time in a FTD or FFS is allowed to be applied to the 1000 hours of Total Pilot time. I have about 80 hours of FTD time that is eligible for use (not as an instructor, but as a student when I was in training for a certificate under 141), does that mean I’m closer to the R-ATP minimums than I originally thought? If this is correct, how does it get logged to apply towards my ATP and would my application be denied if the total flight time duration in an airplane was not 1000 hours?

    • Robert Chapin says:

      Hi Greg, that’s a great question. In today’s market, I think it is unlikely that the average airline is desperate enough to include FTD experience in your ATP application. It is the airline’s decision if and when to offer the ATP training, so you can have this conversation with recruiters about whether or not FTD time will affect your class date. Just because they can make the offer at 900 hours doesn’t mean that they will.

      Good luck and let me know if you learn something different about this.

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