Direct Answer: What Qualifies a Part 135 Second in Command?
Under 14 CFR §135.245(a), a Part 135 second in command must hold at least a commercial pilot certificate with appropriate category and class ratings and an instrument rating. The only carve-out is §135.245(b): a VFR-only helicopter SIC (other than over-the-top) needs the commercial certificate and category/class rating but not the instrument rating for that operation.
On top of the certificate, three currency clocks define whether an SIC is legal to fly on any given day:
- §61.55(b) SIC currency — familiarization, three takeoffs and three landings as sole manipulator, engine-out maneuvering, and CRM training within the preceding 12 calendar months
- §135.245(c) IFR instrument experience — six instrument approaches, holding, and course tracking within the preceding 6 calendar months (IFR SICs)
- §135.293 — the initial and recurrent knowledge and competency test (initial on hire; recurrent within the preceding 12 calendar months)
An SIC of a type-certificated-for-two aircraft also needs a type rating — either a full rating under §61.31(a) or an "SIC Privileges Only" type rating obtained under §61.55(d), which requires no practical test. The crewmember file under §135.63(a)(4) must carry all of it.
The SIC file is where operators get the regulatory layering wrong
A second in command sits at the intersection of two regulatory schemes — Part 61 pilot qualification and Part 135 operating rules — each with its own currency clock. The FAA-wide SIC floor in 14 CFR §61.55(a) only requires a private certificate, but Part 135 raises the SIC bar to commercial in §135.245(a). Tracking only one rule, or applying the §135.293 date to everything, is exactly how a non-current SIC ends up in the right seat on a revenue leg.
When Does Part 135 Require a Second in Command?
Before qualifications matter, you have to know whether the operation requires an SIC at all. Several independent triggers can mandate a two-pilot crew, and any one of them is enough.
1. The aircraft type certification
If the aircraft is type certificated for more than one required pilot flight crewmember, 14 CFR §135.99(a) prohibits operating with less than the minimum flight crew specified in the aircraft operating limitations or the Aircraft Flight Manual and required by Part 135 for the kind of operation conducted. The AFM and type certificate data sheet are the controlling documents.
2. Ten or more passenger seats
Under 14 CFR §135.99(b), no certificate holder may operate an aircraft without a second in command if that aircraft has a passenger-seat configuration, excluding any pilot seat, of ten seats or more. This is a seat-count rule — it does not turn on weather or flight rules. Note this is a distinct concept from the flight-attendant threshold in §135.107 / §135.117(d), which is keyed to aircraft certificated to carry 19 passengers or less; do not conflate the two.
3. OpSpecs, IFR rules, and the autopilot-in-lieu-of-SIC pathway
Your Operations Specifications can require a two-pilot crew for specific operations. Conversely, some single-pilot IFR or single-pilot passenger operations are authorized only with an approved autopilot used in lieu of a second in command under §135.105 and the corresponding OpSpec authorization. In practice, whether you rely on an SIC or an approved autopilot is an authorization the FAA grants, and the documentation of that authorization lives with your OpSpecs. See our OpSpecs explainer.
Why this matters for records: the moment a flight requires an SIC, the operator must be able to prove that the specific person in the right seat met §135.245, held the right ratings, and was current under §61.55 and (for IFR) §135.245(c). The flight-crew composition rule and the qualification rules are enforced together — a properly composed crew of an unqualified SIC is still a violation. For the parallel requirement that the operator decides and documents who is in operational control of each leg, see what operational control means in Part 135.
What a Part 135 Second in Command Must Hold
The SIC qualification stack is built from two regulatory layers: the Part 61 pilot-certification floor and the Part 135 operating-rule overlay. The table below maps each requirement to its governing CFR section, who it applies to, and the interval on which it must be renewed or held.
Use it as a build-from-scratch checklist for any new SIC and as a standing audit reference against your existing right-seat roster.
| Requirement | Governing CFR | Applies To | Interval |
|---|---|---|---|
| Commercial pilot certificate + appropriate category & class ratings | §135.245(a) | Every Part 135 SIC | Held continuously (certificate does not expire) |
| Instrument rating | §135.245(a); exception §135.245(b) | Every SIC except VFR-only helicopter (other than over-the-top) | Held continuously |
| Aircraft type rating (or "SIC Privileges Only" type rating) | §61.31(a); §61.55(d) | SIC of a large airplane, turbojet airplane, or powered-lift (and other type-rated aircraft) | Held continuously once issued |
| High-altitude endorsement (pressurized aircraft above 25,000 ft MSL) | §61.31(g) | SIC operating qualifying pressurized aircraft | One-time logbook endorsement |
| §61.55 SIC familiarization + 3 takeoffs/landings + engine-out + CRM | §61.55(b) | SIC of multi-required-pilot aircraft / SIC-required operations | Within preceding 12 calendar months |
| §135.245(c) IFR instrument experience (6 approaches, holding, course tracking) | §135.245(c) | SIC serving under IFR | Within preceding 6 calendar months |
| §135.293 initial + recurrent knowledge & competency test | §135.293 | Every PIC and SIC | Initial on hire; recurrent within preceding 12 calendar months |
| Second-class (or higher) FAA medical certificate | §61.23(a)(2)(ii) | SIC exercising commercial privileges | Calendar-month expiration by class and age |
Data sourced from 14 CFR Parts 61 and 135 as published on eCFR.gov. Verify against current eCFR before relying for regulatory compliance determinations. Certificate-holder responsibilities and OpSpec conditions extend beyond this table — consult your DOM and approved training program.
1. Commercial Certificate + Category/Class + Instrument Rating
14 CFR §135.245(a) sets the Part 135 SIC floor: at least a commercial pilot certificate with appropriate category and class ratings and an instrument rating. This is meaningfully higher than the FAA-wide SIC qualification in §61.55(a), which permits a private pilot certificate with the appropriate category/class and (for IFR) an instrument rating. When you operate under Part 135, §135.245(a) controls.
The single exception is §135.245(b): a second in command of a helicopter operated under VFR, other than over-the-top, must hold at least a commercial pilot certificate with an appropriate aircraft category and class rating — the instrument rating is not required for that specific VFR-only helicopter operation. Read narrowly: it does not exempt the helicopter SIC from an instrument rating once the operation is conducted under IFR.
2. At Least a Second-Class Medical Certificate
Because §135.245(a) requires the SIC to hold at least a commercial pilot certificate, the medical floor follows from 14 CFR §61.23(a)(2)(ii), which requires a second-class medical certificate to exercise commercial pilot privileges in an aircraft other than a balloon or glider. A first-class medical also satisfies this (a higher class is always acceptable), and an operator may require first class as a matter of policy.
Like every FAA medical, an SIC medical expires at the end of a calendar month computed from the date of examination, the class, and the pilot's age — it does not lapse on a printed mid-month date. Track it on calendar-month logic alongside the rest of the file. See our deeper treatment of Part 135 medical certificate tracking.
3. §135.245(c) IFR Instrument Experience (6 Calendar Months)
For an SIC to serve under IFR, 14 CFR §135.245(c) requires, within the preceding 6 calendar months, at least six instrument approaches, holding procedures and tasks, and intercepting and tracking courses through the use of navigational electronic systems. This is the SIC analog of the recent instrument experience the PIC must maintain, and it is separate from the §61.55 SIC currency.
SIC Type Ratings & Endorsements: §61.31 and the §61.55(d) Pathway
For larger and turbine aircraft, holding the certificate and being current is not enough — the SIC also needs the aircraft on the certificate as a type rating, plus any applicable endorsements. Two distinct rules govern this.
When a type rating is required
Under 14 CFR §61.31(a), a type rating is required for a person who acts as pilot in command of large aircraft (other than lighter-than-air), turbojet-powered airplanes, turbojet-powered powered-lift, and other aircraft specified by the Administrator. The second in command of an aircraft type certificated for more than one required pilot must also hold a type rating for that aircraft — obtained either as a full type rating (by practical test) or as the limited "SIC Privileges Only" rating under §61.55(d).
A full PIC-level type rating under §61.31(a) requires a practical test. That is the path most second officers take when they intend to upgrade.
The "SIC Privileges Only" type rating
14 CFR §61.55(d) lets a person obtain a second-in-command pilot type rating after completing the familiarization training in §61.55(b)(1) and the flight tasks in §61.55(b)(2). Under §61.55(d)(7), there is no practical test required for issuance of the "SIC Privileges Only" pilot type rating.
The applicant's logbook or training record must be endorsed by the person who provided the training (or a qualifying management official), and the applicant submits FAA Form 8710-1 with the instructor's recommendation. The resulting rating is recorded on the certificate with the SIC-privileges-only limitation.
Endorsements an SIC may also need
- High-altitude endorsement — under §61.31(g), ground and flight training plus a one-time logbook endorsement are required to act as PIC of a pressurized aircraft with a service ceiling or maximum operating altitude, whichever is lower, above 25,000 feet MSL. Many operators require the same endorsement of SICs as a matter of standardization.
- Complex and high-performance endorsements — §61.31(e) (complex airplanes) and §61.31(f) (airplanes with an engine of more than 200 horsepower) are one-time endorsements that may apply to the aircraft an SIC flies, depending on the fleet.
- The endorsements are one-time and live in the logbook — which is exactly why they go missing in an operator's crewmember file. The certificate holder should keep a copy of the endorsement, not rely on the SIC's personal logbook being available during a surveillance visit.
Logbook vs. operator record — keep your own copy
Type-rating limitations and §61.31 endorsements are recorded on the certificate or in the pilot's personal logbook, which the operator does not own. The §135.63(a)(4) crewmember file must independently document the SIC's ratings and qualifications, because "it's in the pilot's logbook" is not a substitute for the certificate holder's own record. For the distinction between a pilot's personal logbook and the operator's records, see pilot logbook vs. operator records under §61.51.
The §61.55 Currency Rule — and the Three Recent-Experience Rules People Confuse
The single most misread part of SIC compliance is currency. Three different regulations use similar language about takeoffs, landings, and recency — and they are not interchangeable.
14 CFR §61.55(b): the SIC 12-Calendar-Month Currency
Under 14 CFR §61.55(b), no person may serve as SIC of an aircraft type certificated for more than one required pilot flight crewmember, or in operations requiring an SIC, unless within the previous 12 calendar months that person has accomplished both of the following:
§61.55(b)(1) — Familiarization with the aircraft type
- Operational procedures for the powerplant, equipment, and systems
- Performance specifications and limitations
- Normal, abnormal, and emergency operating procedures
- The flight manual
- Placards and markings
§61.55(b)(2) — Flight tasks
- (i) Three takeoffs and three landings to a full stop as the sole manipulator of the flight controls
- (ii) Engine-out procedures and maneuvering with an engine out while executing the duties of pilot in command
- (iii) Crew resource management training
Under §61.55(c), if the person completes these requirements in the calendar month before, or the calendar month after, the month in which compliance is required, the training and practice are considered accomplished in the month they were due — the same calendar-month grace logic that runs through Part 135 currency. In practice these familiarization and flight tasks are most often satisfied inside an approved §135.293 / Subpart H training event, but the §61.55 requirement is its own line item and should be documented as such.
Three rules, three clocks — don't conflate them
SIC qualification & currency — being eligible to serve as second in command of a multi-pilot aircraft: familiarization + three takeoffs/landings + engine-out + CRM within 12 calendar months.
Part 135 recent experience — takeoffs and landings in the make and model (and additional requirements for night carriage of passengers) within the period specified in the rule. A separate operating-rule currency, distinct from §61.55. Read it directly at §135.247.
Personal recent flight experience — the Part 61 rule governing recency to act as PIC and to carry passengers (including night and instrument recency). Distinct again from both of the above.
A pilot can be current under one of these and out of compliance under another. The compliance record has to track each one on its own clock — which is the whole reason expiration-by-rule, not a single "currency date," is the right data model.
For the operator, every IFR-qualified SIC therefore generates a recurring set of events: a 12-calendar-month §61.55 currency, a 6-calendar-month §135.245(c) instrument experience, a 12-calendar-month §135.293 recurrent check, a calendar-month medical, plus any Subpart H training module renewals. Multiply that across a right-seat roster and the manual-spreadsheet approach stops being defensible. For the full crew-file picture, see what records a Part 135 operator must keep and our companion guide on Part 135 training program recordkeeping.
How FileFlo Keeps the SIC File Audit-Ready
An SIC file is one of the densest layering problems in a Part 135 crewmember record: two regulatory schemes, multiple currency clocks, and a type-rating limitation that is easy to overlook. FileFlo is a compliance document intelligence platform — it classifies, indexes, and tracks the documents that prove an SIC is qualified and current. It does not conduct training, administer checks, run your scheduling system, or replace your Director of Operations or chief pilot.
Classifies SIC documents against the right CFR section
Upload an SIC type-rating training record, a §61.55 currency endorsement, a §135.245(c) instrument-experience log, a §135.293 recurrent record, or a second-class medical — FileFlo classifies each against the governing section automatically, so the §61.55 currency does not get filed as a §135.293 check or lost behind a logbook scan.
Tracks each currency clock separately, on calendar-month logic
FileFlo computes expirations using the calendar-month rule, not rolling-day math, and tracks the 12-calendar-month §61.55 currency and the 6-calendar-month §135.245(c) instrument experience as distinct events — alerting 90, 60, and 30 days before the relevant calendar month closes.
Produces a per-crewmember binder for surveillance
When an FAA inspector asks for an SIC’s qualification records during a Part 135 surveillance visit, FileFlo assembles a §135.63(a)(4)-organized binder for that crewmember — certificate, medical, ratings, §61.55 currency, instrument experience, and training records — in seconds rather than an afternoon of file-pulling.
A proof layer — not the operation
FileFlo keeps the evidence that your SICs are qualified and current audit-ready. The substantive work — the training, the checks, the operational-control decisions — stays with your DOM, check airmen, and approved training provider. FileFlo proves it on demand.
Is every SIC in your right seat provably qualified today?
FileFlo's FAA Readiness Score evaluates your documentation posture against the key Part 135 crewmember-record requirements — no signup required. Takes under 3 minutes.
Run the FAA Readiness Score — FreePart 135 Crew & Records: Related Guides
What Pilot Records the FAA Requires for Part 135
Aviation RecordsPart 135 Medical Certificate Requirements & Tracking
Aviation RecordsPart 135 Training Program Recordkeeping Requirements
Aviation RecordsPart 135 Required Management Personnel Qualifications
Aviation RecordsPart 135 Check Airman & Flight Instructor Records
Aviation RecordsPart 135 Flight Time, Duty & Rest Records
Aviation RecordsPilot Records Database (PRD) — Part 111 Requirements
Aviation RecordsHow to Prepare for a Part 135 FAA Surveillance Audit
Audit PrepWhere the SIC file connects to the rest of your compliance system
SIC qualifications never live in isolation. The same surveillance visit that pulls a crewmember file will look at aircraft and maintenance records — the Part 91 aircraft records, airworthiness directive compliance, and CAMP maintenance recordkeeping — and operating documents like your General Operations Manual and OpSpecs.
On the crew side, the SIC file sits beside the drug and alcohol program records, flight locating and flight release records, and passenger briefing and cabin safety records. Operators flying special missions add HEMS records or TSA Twelve-Five security program records.
And the deadline most Part 135 operators are racing toward — the FAA SMS 2027 requirement — will only add to the document volume each crewmember and aircraft generates. The earlier the proof layer is in place, the less painful that transition is.
Frequently Asked Questions
What certificate and rating must a Part 135 second in command hold?
Under 14 CFR §135.245(a), no certificate holder may use a person, nor may any person serve, as second in command of an aircraft under Part 135 unless that person holds at least a commercial pilot certificate with appropriate category and class ratings and an instrument rating. There is one narrow exception in §135.245(b): a second in command of a helicopter operated under VFR other than over-the-top must hold at least a commercial pilot certificate with an appropriate aircraft category and class rating, but is not required to hold the instrument rating for that VFR-only helicopter operation. Note this is a higher bar than the FAA-wide SIC floor in 14 CFR §61.55(a), which only requires a private pilot certificate — Part 135 raises it to commercial.
When does Part 135 require a second in command at all?
Two separate rules drive whether you need an SIC. First, 14 CFR §135.99(a) requires at least the minimum flight crew specified in the aircraft operating limitations or Aircraft Flight Manual and required by Part 135 for the kind of operation. Second, §135.99(b) states that no certificate holder may operate an aircraft without a second in command if that aircraft has a passenger-seat configuration, excluding any pilot seat, of ten seats or more. Beyond those, the aircraft type certification itself (a type certificated for two required pilots) and your OpSpecs can require a two-pilot crew. A separate §135.105 / OpSpec autopilot authorization in lieu of an SIC is a distinct pathway that the FAA must approve.
What is the 12-calendar-month SIC currency requirement under 14 CFR §61.55?
Under 14 CFR §61.55(b), no person may serve as second in command of an aircraft type certificated for more than one required pilot flight crewmember, or in operations requiring an SIC, unless within the previous 12 calendar months that person has become familiar with the required aircraft information under §61.55(b)(1) and performed the flight tasks in §61.55(b)(2). The §61.55(b)(2) tasks are: (i) three takeoffs and three landings to a full stop as the sole manipulator of the flight controls; (ii) engine-out procedures and maneuvering with an engine out while executing the duties of pilot in command; and (iii) crew resource management training. The familiarization under §61.55(b)(1) covers operational procedures for the powerplant, equipment, and systems; performance specifications and limitations; normal, abnormal, and emergency operating procedures; the flight manual; and placards and markings.
How is §61.55 SIC currency different from the §135.247 Part 135 recent experience rule?
14 CFR §61.55 is a Part 61 pilot-qualification rule about serving as an SIC in a multi-pilot aircraft — it governs the 12-calendar-month familiarization and three-takeoff/landing currency. 14 CFR §135.247 is the Part 135 recent flight experience rule (takeoffs and landings in the make and model, and for night carriage of passengers, within a specified preceding period). They are distinct requirements with distinct lookback windows, and a pilot can satisfy one while being out of compliance with the other. Both differ again from 14 CFR §61.57, the Part 61 recent-flight-experience rule that governs personal currency to carry passengers. A complete SIC file should track all the applicable currency rules separately, because they expire on different clocks.
What is an "SIC Privileges Only" type rating and when is it needed?
When an aircraft is type certificated for more than one required pilot, a person serving as SIC needs a type rating for that aircraft for most operations. 14 CFR §61.55(d) provides a pathway to obtain a second-in-command pilot type rating limited to "SIC Privileges Only" after completing the familiarization training in §61.55(b)(1) and the flight tasks in §61.55(b)(2). Under §61.55(d)(7), there is no practical test required for issuance of the SIC Privileges Only pilot type rating — the applicant submits FAA Form 8710-1 with the required instructor endorsements. This is distinct from a full PIC type rating earned under §61.31(a), which does require a practical test. The SIC type rating limitation is recorded on the pilot certificate, and the underlying training record belongs in the crewmember file.
What instrument experience must a Part 135 SIC have to fly under IFR?
Under 14 CFR §135.245(c), no certificate holder may use any person, nor may any person serve, as second in command under IFR unless that person has, within the preceding 6 calendar months, logged at least six instrument approaches, holding procedures and tasks, and intercepting and tracking courses through the use of navigational electronic systems. This is in addition to holding an instrument rating under §135.245(a). It mirrors the PIC instrument experience requirement and creates a 6-calendar-month renewal event you have to track for every IFR-qualified SIC, separate from the SIC currency under §61.55.
Does a Part 135 SIC need the §135.293 competency check too?
Yes for §135.293. The §135.293 initial and recurrent knowledge and competency tests apply to each pilot in command and each second in command — every SIC must complete the initial §135.293 check before serving and the recurrent check within the preceding 12 calendar months. The §135.297 instrument proficiency check and the §135.299 line check, by contrast, are both pilot-in-command requirements (each rule is titled "Pilot in command") and are not required of an SIC; an IFR-qualified SIC instead satisfies §135.245(c) — six instrument approaches, holding, and course tracking within the preceding 6 calendar months. The result is that an SIC file overlaps heavily with a PIC file — certificate, medical, §135.293, the §135.245(c) instrument experience, Subpart H training — minus the §135.297 IPC and §135.299 line check, plus the §61.55 SIC currency and any SIC type rating record.
What medical certificate does a Part 135 SIC need?
A second in command exercising commercial pilot certificate privileges in a powered aircraft must hold at least a second-class medical certificate. Under 14 CFR §61.23(a)(2)(ii), a second-class medical is required to exercise commercial pilot privileges in an aircraft other than a balloon or glider. Because §135.245(a) requires the SIC to hold at least a commercial certificate, the practical floor is a current second-class FAA medical. Like all FAA medicals, it expires at the end of a calendar month computed from the date of examination, the certificate class, and the pilot’s age — so the crewmember file should track the SIC medical on calendar-month logic, not a flat anniversary date.
Chad Griffith
Founder, FileFlo — compliance document intelligence
This article is a compliance-document perspective, not legal, airworthiness, or flight-operations advice. Regulatory citations were checked against the eCFR but can change; always verify against the current 14 CFR and consult your Director of Operations, chief pilot, or aviation counsel for certificate-specific interpretation before making operational or compliance decisions.
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