Direct Answer — What §91.205 Requires
14 CFR §91.205 requires that a powered civil aircraft with a standard U.S. airworthiness certificate carry the instruments and equipment specified for the kind of operation being conducted, and that those items be in operable condition. The required set is cumulative and keyed to the operation: (b) lists the VFR-day minimum (airspeed indicator, altimeter, magnetic direction indicator, tachometer per engine, fuel quantity, and more); (c) adds the VFR-night items (position lights, anticollision light system, electrical source, spare fuses); and (d) adds the IFR items (two-way radio and nav suitable for the route, gyroscopic instruments, sensitive altimeter, clock, generator or alternator). Because the lists stack, the same inoperative component can be legal for VFR day and disqualifying for IFR. §91.205 is also the baseline that both deferral paths in §91.213 test against — an item required by §91.205 for the operation cannot be deferred under an MEL or under the no-MEL path.
Installed is not enough — it has to work
The operative words in §91.205(a) are “in operable condition.” A required instrument that is on the panel but inoperative does not satisfy the rule for the operation it is required for. Your only legal options are to repair it, defer it (only if it is not required by §91.205 for that operation, via §91.213), or operate a kind of flight for which it is not required. And under §91.7(b), the pilot in command still owns the safe-flight determination on top of the equipment list.
The Core Rule — One Sentence That Anchors the Panel
The full title of the section is Powered civil aircraft with standard U.S. airworthiness certificates: Instrument and equipment requirements, and paragraph (a) carries the whole rule in a single idea: no person may operate such an aircraft unless it contains the instruments and equipment specified in the section for the kind of operation being conducted, and those instruments and equipment are in operable condition. Two halves matter equally. Specified for the operation means the list you read depends on whether you intend VFR day, VFR night, IFR, or high-altitude flight. In operable condition means present is not the same as compliant — a required item that does not work is the same problem as one that is missing.
Scope matters too, and it is set in paragraph (a). §91.205 governs powered civil aircraft with a standard U.S. airworthiness certificate. Aircraft holding other certificate categories — certain experimental, restricted, or special certificates — typically take their required-equipment baseline from the operating limitations issued with the certificate rather than from §91.205. So step one in any equipment question is confirming which certificate category your aircraft holds before treating the §91.205 lists as the complete answer.
- (a)General — the core requirement: required, operable equipment for the kind of operation, on standard-category aircraft.
- (b)Visual flight rules (day) — the base list every other operation builds on.
- (c)Visual flight rules (night) — the (b) list plus the night-specific items.
- (d)Instrument flight rules — the (b) and (c) equipment plus the IFR items.
- (e)Flight at and above FL 240 — adds approved DME or a suitable RNAV system when VOR nav is required.
- (f) / (g)Category II and Category III operations — additional equipment for low-visibility approaches.
- (h)Night vision goggle operations — equipment specific to NVG operations.
Primary regulations cited in this section: 14 CFR §91.205 (Powered civil aircraft — instrument and equipment requirements), 14 CFR §91.7 (Civil aircraft airworthiness).
The Lists by Operation — and Why They Stack
The single most useful thing to understand about §91.205 is that the lists are cumulative. VFR night requires everything in VFR day, then adds to it. IFR requires the VFR day and night equipment, then adds again. That is why a component that is perfectly deferrable for one kind of flight can be disqualifying for another — the floor rises with the operation. The representative items below are drawn from the rule; the controlling text is always §91.205 itself.
The VFR-day list under §91.205(b) includes an airspeed indicator; an altimeter; a magnetic direction indicator; a tachometer for each engine; an oil pressure gauge for each engine using a pressure system; a temperature gauge for each liquid-cooled engine; an oil temperature gauge for each air-cooled engine; a manifold pressure gauge for each altitude engine; a fuel gauge indicating the quantity of fuel in each tank; a landing gear position indicator if the aircraft has retractable gear; an approved anticollision light system for small civil airplanes certificated after March 11, 1996; approved flotation gear and a pyrotechnic signaling device when operated for hire over water beyond power-off gliding distance from shore; an approved safety belt with an approved metal-to-metal latching device; an approved shoulder harness per the applicable date conditions; and an emergency locator transmitter if required by §91.207.
Every item here is required for a VFR-day flight, so each one is a candidate that cannot be deferred under §91.213(d) for that operation — it is required by §91.205(b).
VFR night under §91.205(c) requires all of the VFR-day equipment plus approved position lights; an approved aviation red or aviation white anticollision light system on U.S.-registered civil aircraft; an adequate source of electrical energy for all installed electrical and radio equipment; and one spare set of fuses, or three spare fuses of each kind required, that are accessible to the pilot in flight. An item that is freely deferrable in daylight — position lights are the classic example — becomes required equipment after dark. The lesson for a deferral decision: the determination has to be tied to the specific operation you intend, not made for the aircraft in the abstract.
IFR under §91.205(d) requires the VFR day and night equipment plus two-way radio communication and navigation equipment suitable for the route to be flown; a gyroscopic rate-of-turn indicator (with the exceptions the rule states); a slip-skid indicator; a sensitive altimeter adjustable for barometric pressure; a clock displaying hours, minutes, and seconds with a sweep-second pointer or digital presentation; a generator or alternator of adequate capacity; a gyroscopic pitch and bank indicator (artificial horizon); and a gyroscopic direction indicator (directional gyro or equivalent).
Under IFR, far more of the panel is required equipment, so the deferral window is much narrower than it is for VFR day. A vacuum or attitude failure that might be a manageable deferral for a day VFR hop is squarely disqualifying for an IFR flight.
At and above FL 240 (24,000 feet MSL), if VOR navigation equipment is required under (d)(2), the aircraft must also be equipped with approved DME or a suitable RNAV system. The rule also handles in-flight failure: if that equipment fails at or above FL 240, the pilot in command must notify ATC immediately and then may continue to the next airport of intended landing where repairs or replacement can be made. This is a layered condition on top of the IFR list, tied to the high-altitude environment — not a separate standalone equipment set.
Two of the §91.205 items connect to their own dedicated rules and records, and they are worth pulling out. The emergency locator transmitter required by §91.205(b) is governed in detail by §91.207 — including the type required for commercial operations and the battery and removal provisions — which we cover in the aircraft ELT records under §91.207 guide. And while §91.205(d) requires the IFR navigation equipment, the periodic VOR equipment check that keeps it usable for IFR is a §91.171 requirement with its own logbook entry — see the VOR equipment check records under §91.171 guide. The static-system, altimeter, and transponder tests that underpin the IFR and high-altitude environment have their own records as well, covered in the altimeter and transponder inspection records guide.
Related Aviation Compliance Guides
How §91.205 Drives Every Deferral Decision
§91.205 does more work than its own paragraph. It is the baseline both deferral paths test against. When an instrument quits, the first question is never “can I defer it?” — it is “is this item required by §91.205 for the operation I intend to fly?” The answer to that decides whether deferral is even on the table.
The approved-MEL path — §91.213(a)–(b)
An operator with an approved Minimum Equipment List can defer specific items with a deferral record and a repair-category clock. But the MEL is built on top of the §91.205 baseline — it cannot authorize operation with an item inoperative if that item is required by §91.205 for the kind of operation. The MEL narrows what may be deferred; it never overrides the master required-equipment list.
Covered in depth
See the MEL & CDL deferral records guide.
The no-MEL path — §91.213(d)
For eligible Part 91 aircraft without an MEL, one of the four conditions — §91.213(d)(2)(iii) — expressly bars deferring any item required by §91.205 or any other rule of Part 91 for the specific kind of operation. So §91.205 is the gate. If the item is on the §91.205 list for your intended flight, the no-MEL path is closed for that flight.
Covered in depth
See the §91.213(d) no-MEL deferral guide.
The §91.205 decision sequence when an item is inoperative
- 1Identify the kind of operation you intend to fly — VFR day, VFR night, IFR, or at/above FL 240. The list you read depends on it.
- 2Check the inoperative item against the §91.205 list for that operation. If it appears, it is required equipment for that operation — full stop.
- 3If it is required by §91.205, neither the approved-MEL path (the §91.213(b) bar) nor §91.213(d) (no-MEL) can defer it for that operation. Repair it, fly a different kind of operation for which it is not required, or seek a special flight permit under §§21.197/21.199.
- 4If it is NOT required by §91.205, you still check the other §91.213(d)(2) bars — VFR-day type certification equipment, the aircraft equipment list / KOEL, and airworthiness directives — before deferring.
- 5Whatever the outcome, record it: a repair is a §43.9 maintenance entry; a no-MEL deferral is a §43.9 entry plus a placard; an MEL deferral follows the MEL procedures and the deferral record.
One more cross-reference closes the loop on the deferral question. An item that is required to be operational by an airworthiness directive can never be deferred on the no-MEL path either, under §91.213(d)(2)(iv) — which is why AD status is checked alongside §91.205 in any deferral decision. That status is tracked through your airworthiness directive compliance records. And the §91.205 navigation and instrument items often appear on the aircraft’s Kinds of Operations Equipment List as well — the aircraft-specific document the deferral rules in §91.213(d)(2)(ii) also test against.
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The Records — §91.205 Is an Operating Rule, but Proving It Is a Records Job
§91.205 itself does not tell you to file anything — it tells you what must be installed and working. But over the life of an aircraft, proving that the required equipment was installed, maintained, and kept operable is entirely a records exercise, and a handful of rules carry that weight. These are the documents an inspector relies on to confirm the panel actually meets §91.205.
1. The §43.9 maintenance record entry
When required equipment is repaired, replaced, or installed, the work is recorded in a maintenance record entry under §43.9. A §43.9(a) entry contains a description of the work performed, the date of completion, the name of the person performing the work, and the signature, certificate number, and kind of certificate of the person approving the aircraft for return to service. This is the durable proof that a required instrument that was inoperative is now operative again. Note that §43.9 covers maintenance and alteration entries — inspection entries are separately governed by §43.11.
2. The §91.417 maintenance records
The continuing airworthiness of installed equipment is tracked through the §91.417(a) records the owner or operator must keep: among them, total time in service of the airframe, engines, propellers, and rotors; the current status of life-limited parts; the time since last overhaul of items requiring overhaul; the current inspection status; the current airworthiness directive status with the method, AD number, and recurring-action dates; and copies of FAA Form 337 for major alterations. These records are how you demonstrate that the equipment §91.205 requires is not just present but maintained in airworthy condition.
3. The §43.11 inspection record (when a required item is found inoperative)
When an inspection turns up a required item that is inoperative, the inspection record itself is governed by §43.11 — the rule for the content, form, and disposition of inspection records under Part 91 and Part 125 and §§135.411(a)(1) and 135.419. If the aircraft is found not airworthy, §43.11 requires a signed and dated list of the discrepancies and unairworthy items to be provided to the owner or operator. A required §91.205 item that does not work is exactly the kind of discrepancy that drives this record.
The §43.9 / §43.11 distinction trips people up
Maintenance, preventive maintenance, rebuilding, and alteration entries go under §43.9; by its own terms §43.9 does not apply to inspections performed under Part 91, Part 125, §135.411(a)(1), or §135.419 — those inspection records are governed by §43.11. So a repair to a required §91.205 instrument is a §43.9 entry, while the annual or 100-hour inspection that discovers it inoperative is documented under §43.11. Keeping the two straight is part of having clean records.
The maintenance-entry mechanics are covered in depth in the §43.9 maintenance record entry requirements guide, the records the owner must keep are in the Part 91 aircraft records requirements, and the inspection-record rules that §43.9 carves out sit alongside the §91.409 annual inspection requirements. The documents an inspector expects on board are the ARROW airworthiness and registration documents.
Who Is Responsible — the Owner Maintains, the PIC Flies
§91.205 compliance is shared, and the split is worth being precise about because the records follow it.
The owner or operator — maintenance and records
Under §91.405, the owner or operator must have the aircraft inspected, must repair discrepancies between inspections as prescribed in Part 43, must ensure maintenance personnel make the appropriate entries indicating the aircraft has been approved for return to service, and must have any item permitted to be inoperative under §91.213(d)(2) repaired, replaced, removed, or inspected at the next required inspection. That is the records-and-maintenance side of keeping the §91.205 panel airworthy.
The pilot in command — the safe-flight determination
Under §91.7, no person may operate a civil aircraft unless it is in an airworthy condition, and the pilot in command is responsible for determining whether the aircraft is in condition for safe flight and must discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur. A complete §91.205 panel does not relieve the PIC of that judgment — and §91.205(a) makes operating without the required, operable equipment a violation regardless of who maintained it.
For commercial operators, this baseline sits underneath a layer of additional requirements. A Part 135 certificate holder reads §91.205 together with the Part 135 equipment and operating rules, and the inoperative-equipment discipline is part of the broader record set examined during oversight. If you operate under Part 135, the same equipment and records logic runs through the records a Part 135 operator must keep and is exactly the kind of evidence an inspector samples during a Part 135 surveillance audit. It intersects with operational control — the certificate holder, not the aircraft owner, answers for whether the operation stayed within the rules — and it is one of the record sets a maturing operator is expected to demonstrate as the Part 135 SMS 2027 deadline approaches.
The penalty exposure for operating outside the rules is real: under 14 CFR §13.301, the inflation-adjusted maximum civil penalty for a violation by a person is $75,000 (and $1,875 for an individual or small business concern) for violations occurring on or after December 30, 2024. That is one more reason the §91.205 baseline, and the records that prove it, are not a place to improvise.
FileFlo as the Required-Equipment Records Layer
FileFlo is a compliance document intelligence platform — a read-only proof layer that sits alongside your maintenance-tracking system and flight operations stack. It does not run your dispatch, your maintenance program, or your safety program, and it does not decide whether an item meets §91.205, whether it may be deferred, or whether the aircraft is airworthy. What it does is classify, index, and surface the maintenance entries, inspection records, and deferral documents that prove your required §91.205 equipment is installed, maintained, and accounted for when an inspector asks.
- Classifies uploaded §43.9 return-to-service and equipment entries against the governing reference (§91.205, §91.213, §43.9, §91.417)
- Indexes the §43.11 inspection records and any discrepancy list together with the corrective maintenance entry that closed it
- Surfaces each open §91.213(d) deferral so a required-vs-deferrable item is addressed by the next required inspection per §91.405(c)
- Tracks the §91.417(a) continuing-airworthiness records — total time, AD status, inspection status — that prove installed equipment is maintained
- Generates an inspector-format equipment-and-records view on demand: what is installed, what was repaired, what is deferred, and the supporting record for each
FileFlo classifies 600+ aviation document types and manages records across Part 91, Part 135, and Part 145 operators in a single platform. Pricing: Starter $89/mo, Professional $299/mo. 5-day free trial, no credit card required. FileFlo keeps the documents that prove compliance audit-ready — it does not provide or run a safety management system (SMS), dispatch system, or maintenance-tracking system.
Frequently Asked Questions
What is 14 CFR §91.205 and what does it require?
14 CFR §91.205 is the master required-equipment rule for powered civil aircraft that hold a standard U.S. airworthiness certificate. Its full title is Powered civil aircraft with standard U.S. airworthiness certificates: Instrument and equipment requirements. Paragraph (a) states the core rule: no person may operate such an aircraft unless it contains the instruments and equipment specified for the kind of operation being conducted, and those instruments and equipment are in operable condition. The rest of the section is a set of cumulative lists keyed to the operation — (b) for VFR day, (c) for VFR night, (d) for IFR, and (e) for flight at and above FL 240 — plus (f) Category II, (g) Category III, and (h) night vision goggle operations. So §91.205 is not a recordkeeping rule by itself; it defines the floor of installed, working equipment that every other deferral and inspection rule tests against.
What instruments does §91.205(b) require for VFR day flight?
Paragraph (b) lists the VFR-day minimum. The enumerated items include an airspeed indicator; an altimeter; a magnetic direction indicator; a tachometer for each engine; an oil pressure gauge for each engine using a pressure system; a temperature gauge for each liquid-cooled engine; an oil temperature gauge for each air-cooled engine; a manifold pressure gauge for each altitude engine; a fuel gauge indicating the quantity of fuel in each tank; a landing gear position indicator if the aircraft has retractable landing gear; for small civil airplanes certificated after March 11, 1996, an approved aviation red or aviation white anticollision light system; approved flotation gear and an approved pyrotechnic signaling device if the aircraft is operated for hire over water beyond power-off gliding distance from shore; an approved safety belt with an approved metal-to-metal latching device; an approved shoulder harness or restraint per the applicable date conditions; and an emergency locator transmitter if required by §91.207. This is the floor every other operation builds on — VFR night and IFR both start from the (b) list.
What does §91.205(d) add for IFR flight?
For IFR, paragraph (d) requires everything from the VFR-day list in (b) and the VFR-night list in (c), plus a defined set of IFR equipment. The enumerated additions include two-way radio communication and navigation equipment suitable for the route to be flown; a gyroscopic rate-of-turn indicator (with the specific exceptions the rule states); a slip-skid indicator; a sensitive altimeter adjustable for barometric pressure; a clock displaying hours, minutes, and seconds with a sweep-second pointer or digital presentation; a generator or alternator of adequate capacity; a gyroscopic pitch and bank indicator (artificial horizon); and a gyroscopic direction indicator (directional gyro or equivalent). Because the lists are cumulative, far more of the panel is required equipment under IFR than under VFR day, which is exactly why the same inoperative component can be deferrable for a day VFR flight and disqualifying for an IFR flight.
How does §91.205 drive an MEL deferral or a no-MEL deferral decision?
§91.205 is the test that both deferral paths run against. On the approved-MEL path, §91.213(a) sets the conditions for operating under an approved MEL while §91.213(b) bars the MEL from authorizing operation with an item inoperative if that item is required by §91.205 for the kind of operation — the MEL is built around the required-equipment baseline, not in spite of it. On the no-MEL path under §91.213(d), one of the four conditions, (d)(2)(iii), expressly bars deferring any item that is required by §91.205 or any other rule of Part 91 for the specific kind of flight operation being conducted. So before you can even ask whether an item may be deferred, you check it against the §91.205 list for the operation you intend to fly. If it is on that list, it is required equipment and neither deferral path is open for that operation — the item is repaired, or you operate a different kind of flight, or you seek a special flight permit.
Is §91.205 a recordkeeping rule? What records prove compliance?
§91.205 itself is an operating rule, not a records rule — it says what must be installed and operable, not what to file. But proving §91.205 compliance over time is a records exercise, and several rules carry that weight. When required equipment is repaired or installed, the work is documented in a maintenance record entry under §43.9 (description of work, date, name of the person performing it, and the signature, certificate number, and kind of certificate of the person approving return to service). Continuing airworthiness of installed equipment is tracked through the §91.417(a) records — total time in service, AD status, life-limited part status, and the rest. And when an inspection finds a required item inoperative, the inspection record and discrepancy list are governed by §43.11. The instruments may be on the panel, but the proof they are airworthy lives in these records.
What does flight at and above FL 240 require under §91.205(e)?
Paragraph (e) requires that an aircraft operated at and above FL 240 (24,000 feet MSL), if VOR navigation equipment is required under (d)(2), be equipped with approved distance measuring equipment (DME) or a suitable area navigation (RNAV) system. The rule also addresses failure in flight: if the DME or RNAV system fails at or above FL 240, the pilot in command must notify ATC immediately and then may continue operations at and above FL 240 to the next airport of intended landing where repairs or replacement of the equipment can be made. So this is a conditional addition layered on top of the IFR list, tied to the high-altitude environment, rather than a separate standalone list.
Does §91.205 apply to every aircraft?
No. By its own terms, §91.205 governs powered civil aircraft with a standard U.S. airworthiness certificate. Aircraft operating under other certificate categories — for example, certain experimental, restricted, or special airworthiness certificates — have their required-equipment baseline set differently, often through operating limitations issued with the certificate rather than through §91.205. The section is also a Part 91 rule, so operators under Part 135 read it together with the additional Part 135 equipment and operating requirements that apply to commercial operations. The safe practice is to confirm which airworthiness certificate category your aircraft holds before treating the §91.205 lists as the complete equipment baseline, because the rule keys off that category in paragraph (a).
Who is responsible for the aircraft meeting §91.205, the owner or the pilot?
Both, in different ways. The pilot in command bears the operating responsibility: under §91.7(b), the pilot in command is responsible for determining whether the aircraft is in condition for safe flight and must discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur — and §91.205(a) makes operating without the required, operable equipment a violation regardless of who installed it. The owner or operator carries the continuing maintenance and records responsibility: under §91.405, the owner or operator must have the aircraft inspected, ensure maintenance personnel make the appropriate entries indicating the aircraft has been approved for return to service, and have any item permitted to be inoperative under §91.213(d)(2) addressed at the next required inspection. FileFlo sits on the records side of that split — it keeps the documents that prove the equipment was maintained and any deferral was recorded; it does not make the airworthiness determination.
Prove every required instrument is installed, working, and documented
FileFlo classifies every uploaded §43.9 return-to-service and equipment entry against its governing reference, keeps the inspection record and the corrective maintenance entry indexed together, surfaces each open §91.213(d) deferral so it is addressed by the next required inspection, and generates a complete required-equipment-and-records view on demand. Starter plan $89/mo. Professional $299/mo. 5-day free trial — no credit card required.
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Written by Chad Griffith, Founder, FileFlo — compliance document intelligence. Reviewed June 13, 2026. FileFlo is a compliance document intelligence platform — not legal counsel or an A&P. Which instruments and equipment your specific aircraft must have installed and operable, and whether a given item may be deferred, must be verified against §91.205, your aircraft equipment list and type certification basis, applicable airworthiness directives, and a certificated A&P or IA before flight.