Direct Answer: What Must a Pilot Hold and Carry to Act as PIC?
Under 14 CFR §61.3(a), a required pilot flight crewmember of a U.S. civil aircraft must have, in physical possession or readily accessible in the aircraft, a valid pilot certificate (or one of the temporary or special-purpose authorizations the rule lists) and an acceptable form of photo identification when exercising that certificate’s privileges. Under §61.3(c), the pilot must also hold the appropriate medical certificate issued under Part 67 when one is required for the operation.
The two facts pilots and operators most often get backwards:
- The pilot certificate has no expiration date — under §61.19(c)(1) it is issued without one, and stays valid unless surrendered, suspended, or revoked.
- The medical certificate does expire — and the flight review (§61.56) and recency rules (§61.57) lapse on their own schedules. A current certificate with a stale medical does not authorize PIC duties.
On request, all of it must be presented for inspection. Under §61.3(l), the Administrator, the NTSB, any Federal, State, or local law enforcement officer, and the TSA may each demand to see the certificate and photo ID. The §61.3 text says physical possession or readily accessible in the aircraft — it does not, in its own words, authorize an electronic-only certificate.
The certificate that never expires is not the document that grounds pilots
Because the pilot certificate has no expiration date, the documents that actually decide whether a pilot can legally act as PIC on a given day are the time-limited ones: the medical certificate under §61.23, the flight review under §61.56, and recency of experience under §61.57. For Part 135 crews, the operator’s per-crewmember file under §135.63(a)(4) adds its own layer. Tracking the documents that expire — not the one that does not — is where compliance actually lives. See medical certificate tracking and currency and recency of experience.
The Carry Rule: §61.3(a), (c), and What “Readily Accessible” Means
Section 61.3 is short, but it is the foundation for every other Part 61 document obligation. It answers three questions: what must a pilot have, where must they have it, and to whom must they show it. Below is each operative paragraph, paraphrased from the regulation text with the citation so you can verify it directly.
1. §61.3(a)(1) — The Pilot Certificate Itself
Under 14 CFR §61.3(a), no person may serve as a required pilot flight crewmember of a U.S. civil aircraft unless that person has in their physical possession, or readily accessible in the aircraft, a valid pilot certificate or authorization when exercising the privileges of that certificate. The rule lists the acceptable documents, which include a pilot certificate issued under §61.19, a temporary certificate issued under §61.17, a special-purpose pilot authorization issued under §61.77, a document conveying temporary authority to exercise certificate privileges issued by the Airmen Certification Branch, and certain temporary documents issued by Part 119 certificate holders (such as Part 135 operators) or fractional ownership program managers. A pilot operating under the authority of a foreign license carries that license when operating in the country that issued it.
“Readily accessible in the aircraft” is a meaningful phrase. The certificate does not have to be on the pilot’s person, but it must be reachable in the aircraft during the operation. The §61.3 text describes physical possession or ready accessibility in the aircraft; it does not, in its own words, say a digital photo of the certificate satisfies the rule. The FAA has addressed electronic presentation through policy and guidance over time, so a pilot intending to rely on an electronic copy should confirm current FAA guidance rather than assume §61.3 settles it.
2. §61.3(a)(2) — Photo Identification
The same paragraph requires the pilot to carry photo identification that is in their physical possession or readily accessible in the aircraft when exercising certificate privileges. Acceptable forms listed in §61.3(a)(2) include:
- A driver’s license issued by a State, the District of Columbia, or a U.S. territory or possession
- A government identification card issued by the Federal government, a State, the District of Columbia, or a U.S. territory or possession
- A U.S. Armed Forces identification card
- An official passport
- A credential authorizing unescorted access to a security identification display area at an airport regulated under 49 CFR part 1542
- Any other form of identification the Administrator finds acceptable
The photo ID requirement exists so the person presenting the certificate can be matched to the named holder. It is a small thing that becomes a finding precisely because it is easy to overlook in a ramp check.
3. §61.3(c) — The Medical Certificate
Under §61.3(c), a person generally may not act as pilot in command, or in any other capacity as a required pilot flight crewmember, unless that person holds the appropriate medical certificate issued under Part 67, or other documentation acceptable to the FAA, that is in their physical possession or readily accessible in the aircraft. The rule then carves out specific exceptions — for example, certain operations of gliders and balloons, BasicMed operations meeting the conditions in §61.23, and sport-pilot operations that allow a U.S. driver’s license in place of a medical for eligible light-sport aircraft.
For the Part 135 on-demand world, the practical answer is straightforward: a pilot in command typically needs at least a current second-class medical, and the validity period turns on class, operation, and age under §61.23. The medical is the document that expires, on a calendar-month basis, while the certificate it accompanies does not.
The Documents and How Long Each One Lasts
A pilot acting as PIC is really carrying a small stack of documents, each governed by its own rule and each with its own clock. The certificate never expires; almost everything that makes it usable does. The table maps each document to its governing CFR, whether it must be carried, and its duration.
| Document | Governing CFR | Carried in the Aircraft? | Duration |
|---|---|---|---|
| Pilot Certificate (with ratings / type ratings as applicable) | §61.3(a)(1); §61.19(c)(1) | Yes — physical possession or readily accessible in the aircraft | No expiration date — valid until surrendered, suspended, or revoked |
| Photo Identification | §61.3(a)(2) | Yes — must be presented with the certificate | Per the issuing document (e.g., driver’s license, passport) |
| Medical Certificate (Part 67) — when required for the operation | §61.3(c); §61.23 | Yes — must hold the appropriate class while exercising privileges that require it | Validity period varies by class, operation, and age (calendar-month based) |
| Flight Review Endorsement | §61.56(c) | In logbook; presented on request under §61.51(i) | Within preceding 24 calendar months to act as PIC |
| Recency of Experience (takeoffs/landings; instrument) | §61.57 | In logbook; presented on request under §61.51(i) | Rolling windows (e.g., preceding 90 days for passenger-carrying; 6 calendar months for IFR) |
| Logbook / Record of Aeronautical Experience | §61.51 | Must be presented for inspection on reasonable request under §61.51(i) | Retain experience used to meet recency / certificate requirements |
Data sourced from 14 CFR Part 61 as published on eCFR.gov. Verify against the current eCFR before relying for regulatory compliance determinations. Operation-specific requirements (Part 135, Part 91 subpart K, Part 121) layer additional obligations on top of the Part 61 baseline.
Why the Pilot Certificate Has No Expiration Date — §61.19
Section 61.19 sets the duration of airman certificates, and it is worth reading the paragraph structure because it is easy to misremember which letter says what. Under 14 CFR §61.19:
- §61.19(a) — a certificate issued with an expiration date may not be exercised after that date; a certificate issued without an expiration date is valid until surrendered, suspended, or revoked.
- §61.19(b) — addresses paper student pilot certificates issued before April 1, 2016 (an expiring legacy category).
- §61.19(c)(1) — a pilot certificate, including a student pilot certificate issued after April 1, 2016, is issued without an expiration date. This is the operative sentence for nearly every active pilot.
- §61.19(d) — a flight instructor certificate issued on or after December 1, 2024 is issued without an expiration date; ones issued before that date expire 24 calendar months after issuance, renewal, or reinstatement. (Holding a current CFI is separate from acting as PIC.)
The takeaway: a pilot certificate is a permanent credential. It does not get renewed, and there is no “expired pilot certificate” the way there is an expired medical. What lapses is currency and the medical — which is exactly why a compliance system should index those documents to the right rule and watch their dates, rather than treating the certificate as a date-bearing object.
The Endorsements That Make the Certificate Usable — §61.56 and §61.57
Two recurring requirements sit in the pilot’s logbook rather than on the certificate, and both are conditions on acting as PIC:
- Flight review — under §61.56(c), no person may act as PIC of an aircraft unless, since the beginning of the 24th calendar month before the month in which that pilot acts as PIC, that person has accomplished a flight review and had their logbook endorsed by the authorized instructor who gave the review.
- Recency of experience — under §61.57, passenger-carrying privileges require recent takeoffs and landings (generally within the preceding 90 days, with additional night and tailwheel conditions), and instrument privileges require recent instrument experience evaluated over a 6-calendar-month window. These are logbook-tracked, not certificate-tracked.
Because the flight review and recency live in the logbook, they are presented under §61.51(i) on a reasonable request rather than carried as a separate certificate. For the full breakdown of currency math, see recency of experience under §61.57, and for the logbook-versus-operator-file distinction, see pilot logbook vs. operator records under §61.51.
Type Ratings and Other Privileges — §61.31
The certificate the pilot carries is also where certain privileges are recorded. Under §61.31(a), a person who acts as PIC of a large aircraft (other than lighter-than-air), a turbojet-powered airplane, a powered-lift, or another aircraft type the Administrator designates must hold a type rating for that aircraft — and that rating appears on the certificate itself. Other privileges are added by a one-time logbook endorsement rather than a certificate rating: high-performance airplanes (§61.31(f)), complex airplanes (§61.31(e)), pressurized aircraft capable of high-altitude operations (§61.31(g)), and tailwheel airplanes (§61.31(i)).
For a Part 135 operator, the certificate-plus-type-rating picture connects directly to the per-crewmember file and to the second-in-command qualification rules. See SIC qualifications & type ratings and what pilot records Part 135 requires.
Who Can Demand to See It: §61.3(l) and §61.51(i)
Carrying the documents is only half the obligation. The other half is producing them on request. Two Part 61 provisions create overlapping inspection rights, and a Part 135 crewmember should understand both.
§61.3(l) — Certificate & Photo ID
Under §61.3(l), each person who holds an airman certificate, medical certificate, authorization, or license required by Part 61 must present it, with their photo identification, for inspection upon a request from:
- The Administrator (FAA)
- An authorized representative of the National Transportation Safety Board (NTSB)
- Any Federal, State, or local law enforcement officer
- An authorized representative of the Transportation Security Administration (TSA)
§61.51(i) — Logbook & Records
Under §61.51(i), a person must present their pilot certificate, medical certificate, logbook, or any other record required by Part 61 for inspection upon a reasonable request from the Administrator, an authorized NTSB representative, or any Federal, State, or local law enforcement officer.
This is where the flight review endorsement and recency entries are produced. The logbook is the evidentiary backbone for everything that is not printed on the certificate, which is why incomplete or disorganized logbooks turn a routine inquiry into a problem.
The pilot’s possession duty and the operator’s file duty are independent
A Part 135 certificate holder must maintain a current per-crewmember record under §135.63(a)(4) that includes the crewmember’s certificates, ratings, medical, and required checks. That operator obligation does not relieve the individual pilot of the §61.3 possession duty, and the pilot carrying the documents does not relieve the operator of maintaining the file. Both are cited independently. For the operator side, see what records a Part 135 operator must keep and Part 135 pilot records required by the FAA.
How FileFlo Keeps the Documents Audit-Ready
FileFlo is a compliance document intelligence platform. It does not issue certificates, fly the aircraft, administer checkrides, or replace the operator’s Director of Operations. What it does is take the documents that prove a pilot is legal to act as PIC — the certificate, the medical, the flight review endorsement, the type-rating evidence — classify each against the right CFR section, and watch the dates on the ones that expire so a lapse surfaces before a ramp check or a POI surveillance visit does.
Classifies each document against the right Part 61 / Part 135 section
Upload a pilot certificate scan, a medical certificate, a flight review endorsement page, or a Part 135 §135.63(a)(4) crewmember record, and FileFlo classifies it against the correct rule automatically. The certificate that never expires is filed as a permanent record; the medical and currency documents are indexed with their dates.
Tracks the documents that actually expire
The pilot certificate has no expiration under §61.19(c)(1), so FileFlo focuses date-tracking where it matters: the medical certificate under §61.23, the 24-calendar-month flight review under §61.56, and recency under §61.57. Approaching deadlines surface in advance instead of being discovered late.
Produces an inspection-ready packet on demand
When the FAA, NTSB, law enforcement, or TSA invokes §61.3(l) or §61.51(i) — or when a Part 135 POI requests crew records — FileFlo assembles a clean, organized packet of the relevant documents for an individual crewmember or the whole roster, rather than a scramble through folders.
A proof layer, not the operation
FileFlo keeps and proves the records. It does not hold the air carrier certificate, conduct training, or stand in for the DOM or chief pilot. The substantive responsibility stays with the pilot and the operator; FileFlo keeps the evidence current and exportable.
Check your pilot-document posture before your next ramp check or POI visit
FileFlo’s FAA Readiness Score tool evaluates your current documentation posture against the key Part 61 and Part 135 record requirements — no signup required. Takes under 3 minutes.
Run the FAA Readiness Score — FreePilot & Crew Records: Related Guides
Part 135 Medical Certificate Requirements & Tracking
Aviation CompliancePilot Currency & Recency of Experience (§61.57)
Aviation CompliancePilot Logbook vs. Operator Records (§61.51)
Aviation ComplianceWhat Pilot Records Does the FAA Require for Part 135?
Aviation ComplianceSIC Qualifications & Type Ratings
Aviation CompliancePilot Records Database (PRD) — Part 111 Requirements
Aviation CompliancePart 135 Required Management Personnel Qualifications
Aviation CompliancePart 65 Mechanic & Repairman Certificate Records
Aviation ComplianceFrequently Asked Questions
What certificates must a pilot carry to act as pilot in command?
Under 14 CFR 61.3(a), a required pilot flight crewmember of a U.S. civil aircraft must have in their physical possession, or readily accessible in the aircraft, a valid pilot certificate (or one of the temporary or special-purpose authorizations the rule lists) plus an acceptable form of photo identification when exercising the privileges of that certificate. Separately, 14 CFR 61.3(c) requires the pilot to hold the appropriate medical certificate issued under Part 67 (or other documentation acceptable to the FAA) when one is required for the operation. The regulation states physical possession or readily accessible in the aircraft; it does not, in its text, authorize carrying a certificate only as an electronic image, so a pilot relying on a phone copy should confirm current FAA policy before doing so.
Does a pilot certificate expire?
No. Under 14 CFR 61.19(c)(1), a pilot certificate, including a student pilot certificate issued after April 1, 2016, is issued without an expiration date. The certificate remains valid unless it is surrendered, suspended, or revoked, per 14 CFR 61.19(a). What does expire is the supporting documentation that makes the certificate usable: the medical certificate (14 CFR 61.23), the flight review endorsement every 24 calendar months (14 CFR 61.56), and the recency-of-experience requirements (14 CFR 61.57). A current certificate with a lapsed medical or an out-of-date flight review does not authorize acting as PIC.
What forms of photo identification satisfy 14 CFR 61.3(a)(2)?
The acceptable forms listed in 14 CFR 61.3(a)(2) include a driver’s license issued by a State, the District of Columbia, or a territory or possession of the United States; a government identification card issued by the Federal government, a State, the District of Columbia, or a territory or possession; a U.S. Armed Forces identification card; an official passport; a credential that authorizes unescorted access to a security identification display area at an airport regulated under 49 CFR 1542; and any other form of identification the Administrator finds acceptable. The point of the requirement is that the person presenting the certificate can be matched to the named holder.
Who can demand to inspect a pilot’s certificate?
Under 14 CFR 61.3(l), each person who holds an airman certificate, medical certificate, authorization, or license required by Part 61 must present it, along with their photo identification, for inspection upon a request from the Administrator, an authorized representative of the National Transportation Safety Board, any Federal, State, or local law enforcement officer, or an authorized representative of the Transportation Security Administration. A nearly parallel logbook-and-records inspection provision sits in 14 CFR 61.51(i). For a Part 135 crewmember, the operator’s own per-crewmember file under 14 CFR 135.63(a)(4) is a separate, additional obligation that the certificate holder must satisfy.
How is the medical certificate different from the pilot certificate?
They are two separate documents governed by two separate rules. The pilot certificate is issued without an expiration date under 14 CFR 61.19(c)(1). The medical certificate is issued under Part 67 and has a defined validity period that depends on its class, the operation, and the pilot’s age, per 14 CFR 61.23 — for example, a first-class certificate supports airline transport pilot privileges for a shorter window than the period for which the same certificate retains lower-class privileges. A pilot in command of a Part 135 on-demand flight typically needs at least a second-class medical. Because the medical expires on a calendar-month basis while the certificate does not, the medical is usually the document that triggers a grounding if tracking slips.
Is the flight review a certificate that must be carried?
No. The flight review under 14 CFR 61.56 is recorded as a logbook endorsement, not as a separate certificate, and it is generally not a document the pilot must carry in the aircraft. Under 14 CFR 61.56(c), no person may act as pilot in command of an aircraft unless, since the beginning of the 24th calendar month before the month in which that pilot acts as PIC, that person has accomplished a flight review and had their logbook endorsed by the authorized instructor who gave it. The endorsement lives in the pilot’s logbook and is presented on request under 14 CFR 61.51(i), which is one reason logbook record-keeping deserves the same discipline as the certificates themselves.
Do certain aircraft require a type rating noted on the certificate?
Yes. Under 14 CFR 61.31(a), a person who acts as pilot in command of a large aircraft (other than lighter-than-air), a turbojet-powered airplane, a powered-lift, or other aircraft the Administrator designates must hold a type rating for that aircraft. The type rating is endorsed on the pilot certificate itself, so the certificate that the pilot carries under 14 CFR 61.3(a) is also the document that proves the type rating exists. Several other privileges — high-performance, complex, pressurized high-altitude, and tailwheel airplanes under 14 CFR 61.31(e) through (i) — require a one-time logbook endorsement rather than a rating printed on the certificate.
How does this differ from the operator’s pilot file and the FAA medical-tracking obligations?
This page is about the certificates and documents a pilot must personally hold, carry, and present under Part 61. That is distinct from three related obligations FileFlo customers ask about: the Part 135 operator’s per-crewmember record file under 14 CFR 135.63(a)(4), which the certificate holder maintains; the operator’s ongoing tracking of medical certificate expirations under 14 CFR 61.23; and the recency-of-experience and currency rules under 14 CFR 61.57. The pilot’s personal possession requirement and the operator’s file requirement are both real and independent — satisfying one does not satisfy the other. See the cross-links throughout this page for each.
Chad Griffith
Founder, FileFlo — compliance document intelligence
This article is a compliance-document perspective, not legal, medical-certification, or flight-operations advice. Certificate eligibility, medical qualification, and currency determinations should be verified against the current eCFR and confirmed with your DOM, AME, or aviation counsel.
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