Commercial Pilot Privileges and Limitations: What You Can (and Can't) Do

So you've earned your commercial pilot certificate. Congrats! But before you start accepting every flight gig that comes your way, let's pump the brakes for a second. Earning your commercial certificate doesn't mean you can do everything a pilot can do for money. The FAA has specific rules about what commercial pilots can and cannot do, and understanding these privileges and limitations is critical to staying legal and keeping your certificate.

Key Takeaways

• ✈️ Commercial pilots can act as pilot in command for compensation or hire, but only within specific regulatory boundaries defined by 14 CFR § 61.133.
• ✈️ Without an instrument rating, you cannot carry passengers for hire beyond 50 nautical miles or at night, which severely limits your job opportunities.
• ✈️ Common carriage operations require Part 119 certification, meaning you can't just hang out a shingle and start a charter business with only a commercial certificate.
• ✈️ You must hold at least a second-class medical certificate to exercise commercial pilot privileges for compensation.

Ready to start your journey toward a commercial pilot certificate? Begin your training with Hillsboro Aero Academy today.

What Is a Commercial Pilot Certificate?

A commercial pilot certificate is your ticket to getting paid to fly. It's the certification level that allows you to operate aircraft for compensation or hire, moving beyond the recreational flying limits of a private pilot certificate.

According to 14 CFR § 61.133, a commercial pilot may act as pilot in command of an aircraft carrying persons or property for compensation or hire. They can also receive compensation for acting as pilot in command, provided they meet all applicable regulatory requirements.

But here's the catch. Just because you hold a commercial certificate doesn't mean you can accept every flying job out there. The FAA draws clear lines between what you can and cannot do.

The Big Privileges: What You CAN Do With a Commercial Certificate

Acting as Pilot in Command for Compensation

This is the core privilege. You can fly aircraft and get paid for it. Whether you're transporting cargo, flying aerial photography missions, or towing banners over the beach, your commercial certificate allows you to accept money for your piloting services.

You can also carry passengers or property for compensation or hire. This opens doors to charter operations, sightseeing flights, and other passenger transport services (within certain limitations we'll cover shortly).

Flight Instruction (With Additional Certification)

Commercial pilots who also hold a certified flight instructor (CFI) certificate can provide paid flight training. Teaching students is one of the most common ways new commercial pilots build flight hours while earning income.

Flight instruction falls under the Part 119 exceptions, meaning you don't need an air carrier certificate to teach. You just need your commercial certificate plus your CFI credentials.

Specialized Operations (Part 119 Exceptions)

The FAA allows commercial pilots to conduct certain specialized operations without obtaining an air carrier certificate under Part 119. These exceptions include:

Aerial work operations like crop dusting, aerial photography, pipeline patrol, and banner towing. These jobs let you use your commercial privileges without the heavy regulatory burden of Part 135 charter operations.

Nonstop sightseeing flights within 25 statute miles of the departure airport. These flights must begin and end at the same airport and comply with FAA Letter of Authorization requirements under § 91.147.

Ferry flights and training flights where you're moving aircraft or conducting aircraft-specific training. These operations are exempt from Part 119 requirements.

Commercial Pilot Privileges: WITH vs. WITHOUT Instrument Rating

Here's where things get real. Your commercial certificate comes with a major limitation if you don't hold an instrument rating in the same category and class.

The 50 Nautical Mile Rule

According to 14 CFR § 61.133(b)(1), if you hold a commercial pilot certificate in airplane or powered-lift category without an instrument rating, your certificate will contain this limitation: "The carriage of passengers for hire in airplanes on cross-country flights in excess of 50 nautical miles or at night is prohibited."

This isn't a suggestion. It's a hard regulatory limit. If you fly passengers for hire beyond 50 nautical miles from your departure point without an instrument rating, you're violating federal aviation regulations.

The Night Flying Restriction

The night restriction is equally strict. Commercial pilots without an instrument rating cannot carry passengers for hire at night, regardless of distance. Night is defined by FAR 1.1 as the time between the end of evening civil twilight and the beginning of morning civil twilight. The period from one hour after sunset to one hour before sunrise is distinct from this definition and applies specifically to the requirements for logging night landings to establish currency.

Pro Tip: The FAA doesn't mess around with this limitation. Pilots without instrument ratings are 4.8 times more likely to have weather-related accidents according to NTSB data. The 50 nm and night restrictions exist because these operations increase the risk of encountering challenging weather and reduced visibility conditions.

Want to unlock your full commercial privileges? Add an instrument rating to your certificate and remove these limitations for good.

The Limitations: What You CAN'T Do

You Cannot Conduct Common Carriage Without Part 119 Certification

This is the big one that trips up new commercial pilots. You cannot "hold out" your services to the general public without obtaining an air carrier certificate under Part 119.

Common carriage means advertising your aircraft and pilot services to anyone willing to pay. Think of it like running a taxi service but with airplanes. If you're holding yourself out as available to transport anyone who calls, that's common carriage.

Common carriage requires either Part 121 (scheduled airline operations) or Part 135 (on-demand charter) certification. These certifications involve comprehensive operational infrastructure, maintenance programs, crew training, and safety management systems. You can't just print business cards and start a charter company with only your commercial certificate.

Private carriage, on the other hand, involves transporting specific customers under contract without holding out to the public. Some private carriage operations can be conducted without Part 119 certification, but the line between private and common carriage is fact-specific and often murky.

Pro Tip: If you're unsure whether a proposed operation constitutes common or private carriage, contact your local Flight Standards District Office (FSDO) for guidance. Flying illegal charter operations can result in certificate revocation and significant fines.

Medical Certificate Requirements

To exercise commercial pilot privileges, you must hold at least a second-class medical certificate. A third-class medical won't cut it for commercial operations.

According to 14 CFR § 61.23, a commercial pilot operating for compensation or hire must maintain a valid second-class (or first-class) medical certificate. If your medical lapses, you cannot legally fly for compensation until you renew it.

Second-class medical privileges are valid for 12 months for commercial operations, regardless of age. After this 12-month period, the privileges downgrade to third-class for the remainder of the certificate's validity, the duration of which depends on whether you are under or over 40 years old. After expiration, the certificate downgrades to third-class privileges (private pilot only).

Learn more about FAA medical certificate requirements and what to expect during your aviation medical exam.

Currency and Recent Flight Experience

Even with a valid commercial certificate and medical, you must maintain currency to carry passengers. You need three takeoffs and three landings within the preceding 90 days in the same category, class, and type of aircraft (if a class or type rating is required).

For night currency, you need three takeoffs and landings to a full stop at night (one hour after sunset to one hour before sunrise) within the preceding 90 days. Without night currency, you cannot carry passengers at night, even if you hold an instrument rating.

These requirements are found in 14 CFR § 61.57 and apply to all pilots carrying passengers, not just commercial pilots. Let your currency lapse, and you'll need to complete the required landings (without passengers) before you can legally fly paying customers again.

Understanding Operational Control and Dry Leases

Here's a concept that confuses many commercial pilots: operational control. Who has operational control determines which regulations apply to a flight.

In a dry lease arrangement, the aircraft owner provides only the aircraft. The lessee supplies the crew and exercises operational control. Under a properly structured dry lease, a commercial pilot can operate the aircraft for compensation under Part 91 (general operating rules) without Part 135 certification.

In a wet lease, the lessor provides both the aircraft and the crew. The lessor retains operational control and must hold the appropriate operating certificates (usually Part 135 for commercial operations).

The distinction matters because an improperly structured "dry lease" that's actually a wet lease can result in illegal charter operations. The FAA examines who makes crew assignments, who schedules flights, who maintains the aircraft, and who has final authority over flight operations.

Pro Tip: If you're asked to fly someone's aircraft for compensation under a lease agreement, make sure the lease structure is legitimate. Consult with an aviation attorney if you're uncertain. Illegal charter operations can cost you your certificate.

Part 119 Exceptions: What You Can Do Without an Air Carrier Certificate

While common carriage requires Part 119 certification, the FAA has carved out specific exceptions where commercial pilots can conduct for-hire operations without an operating certificate.

Student instruction tops the list. Commercial pilots with CFI certificates can provide paid flight training without Part 119 certification.

Nonstop commercial air tours within 25 statute miles of the departure airport are permitted under § 119.1(e)(2), provided you obtain a Letter of Authorization under § 91.147. These sightseeing flights must begin and end at the same airport.

Aerial work operations including crop dusting, aerial photography, banner towing, pipeline patrol, and firefighting can be conducted without Part 119 certification under § 119.1(e)(4). These operations serve specific customers and don't involve holding out to the public.

Ferry and training flights under § 119.1(e)(3) allow commercial pilots to reposition aircraft or conduct crew training flights for compensation.

Parachute operations within 25 statute miles of the departure airport permit commercial pilots to fly jumpers to altitude under § 119.1(e)(6).

These exceptions represent legitimate ways to use your commercial privileges without obtaining expensive and time-consuming air carrier certification.

Building Your Commercial Pilot Career

Understanding your privileges and limitations is just the starting point. Most commercial pilots start their careers by building flight hours through instruction, aerial work, or other Part 119-exempt operations.

The typical career training path looks like this: earn your commercial pilot certificate, add your instrument rating (if you don't have it already), obtain your CFI certificate, and build hours while teaching. Once you hit 1,000 to 1,500 hours, you become competitive for charter, corporate, or regional airline positions.

Some pilots skip the instruction route and build hours through aerial photography, pipeline patrol, or banner towing. Others find cargo operations that hire low-time commercial pilots. The path varies, but understanding what you can legally do with your commercial certificate is essential.

Explore the different types of pilot licenses and where a commercial certificate fits into your aviation career training.

Common Mistakes New Commercial Pilots Make

Thinking the Commercial Certificate Allows All For-Hire Flying

Just because you can legally fly for compensation doesn't mean every for-hire operation is legal. Advertising charter services to the public without Part 135 certification is illegal, regardless of your certificate level.

Ignoring the Instrument Rating Limitation

Flying passengers for hire beyond 50 nautical miles or at night without an instrument rating is a certificate-action waiting to happen. The FAA doesn't look kindly on pilots who violate their certificate limitations.

Letting Medical or Currency Lapse

Your second-class medical has an expiration date. So does your passenger-carrying currency. Accepting a paid flight when you're not current or your medical has expired is a serious violation.

Misunderstanding Operational Control in Lease Situations

If you're flying someone's aircraft for money, make absolutely certain the arrangement is legal. Many "dry lease" operations are actually illegal wet leases that expose you to enforcement action.

Staying Legal and Building Your Career

The best approach? Be conservative. When you're unsure whether an operation is legal, don't do it until you've confirmed with an aviation attorney or your local FSDO.

Keep your medical current. Maintain your flight currency. Respect your certificate limitations. And if you don't have your instrument rating yet, make it a priority.

Your commercial pilot certificate opens doors, but only if you understand and respect the regulatory boundaries. Fly smart, fly legal, and build your career on a solid foundation of regulatory compliance.

Ready to take the next step in your pilot training? Learn about Part 61 vs. Part 141 training and find the path that works for you.

Frequently Asked Questions

What is the difference between commercial pilot privileges and limitations?
Commercial pilot privileges define what you are legally authorized to do with your certificate, such as acting as pilot in command for compensation or hire. Limitations are restrictions placed on those privileges, like the prohibition on carrying passengers for hire beyond 50 nautical miles or at night without an instrument rating. These limitations are established under 14 CFR § 61.133 and vary based on your ratings and qualifications.

Can I use a flight training device or flight simulator to meet commercial pilot requirements?
Yes, you can use approved flight training devices and flight simulators to log certain training hours toward your commercial pilot certificate. The FAA allows limited credit for simulator time, with specific hour allowances depending on the device's approval level. Basic Aviation Training Devices (BATDs) typically allow up to 10 hours of credit, while Advanced Aviation Training Devices (AATDs) may permit up to 20 hours toward commercial pilot aeronautical experience requirements.

Do I need ground training before taking the commercial pilot practical test?
Absolutely. You must receive and log ground training from an authorized instructor or complete an approved home-study course covering all aeronautical knowledge areas specified in 14 CFR § 61.125. Before your practical test, you need a logbook endorsement from your flight instructor certifying that you received the required ground training and are prepared for the knowledge test and practical test.

What does "private carriage" mean, and how is it different from "common carriage"?
Private carriage involves transporting specific customers under contract without holding out services to the general public. Common carriage means advertising your aircraft and pilot services to anyone willing to pay, essentially operating like a commercial airline or charter service. Common carriage requires Part 119 air carrier certification, while some private carriage operations can be conducted with just a commercial pilot certificate. The difference is whether you're holding yourself out to the public.

What operations are listed under Part 119 exceptions?
Part 119 exceptions listed in § 119.1(e) include student instruction, nonstop commercial air tours within 25 statute miles, ferry and training flights, aerial work operations (crop dusting, aerial photography, banner towing, pipeline patrol), sightseeing flights in balloons, parachute operations within 25 statute miles, certain helicopter operations, and emergency mail service. These operations can be conducted for compensation without obtaining an air carrier certificate.

Are there English language requirements for commercial pilots?
Yes. According to 14 CFR § 61.123, commercial pilot applicants must be able to read, speak, write, and understand the English language. This requirement ensures that pilots can communicate effectively with air traffic control, understand aviation publications, and participate safely in the National Airspace System. English proficiency is a non-negotiable eligibility requirement for commercial pilot certification.

What are the aeronautical experience requirements for a commercial pilot certificate?
The aeronautical experience requirements vary by aircraft category, class, and the specific training pathway. Under Part 61, requirements generally include at least 250 hours of total flight time, with specific allocations for pilot-in-command, cross-country, and instrument training. However, most HAA students are enrolled in the Part 141 Commercial course, which follows different minimums found in Part 141 Appendix D. Additionally, HAA offers a reduced minimums course with requirements that are less than those prescribed in Appendix D. Completion of the specific requirements for your enrolled course demonstrates you have adequate experience to act as pilot in command for compensation.

Can I log time in a flight simulator toward my commercial certificate?
Yes, but with limitations. Approved flight simulators and aviation training devices can be used to log time toward commercial pilot requirements. The specific credit depends on the device's Letter of Authorization (LOA) from the FAA. Flight training in simulators is valuable for practicing procedures, emergency scenarios, and instrument skills in a controlled environment, but you'll still need substantial actual flight time to meet total aeronautical experience requirements.

How do training flights differ from other commercial operations?
Training flights conducted under Part 119 exceptions allow commercial pilots to operate aircraft specifically for crew training purposes or aircraft-specific training without requiring Part 135 certification. These flights are distinct from passenger-carrying operations or cargo flights. Ferry flights and training flights under § 119.1(e)(3) represent legitimate ways commercial pilots can use their privileges to reposition aircraft or conduct qualification training for compensation.

What does "eligible" mean in the context of commercial pilot operations?
Being eligible for commercial pilot operations means meeting all regulatory requirements to exercise commercial privileges. This includes holding the appropriate pilot certificate and ratings, maintaining a valid second-class or first-class medical certificate, meeting currency requirements, and operating within the limitations of your certificate. Eligibility isn't just about having the certificate; it's about meeting every condition required to legally conduct each specific flight operation.

Can commercial pilots perform aerial work operations for compensation?
Yes. Commercial pilots can perform various aerial work operations for compensation without Part 119 certification. These operations include crop dusting, seeding and spraying, aerial photography and survey work, banner towing, pipeline and powerline patrol, and firefighting. These specialized services fall under Part 119 exceptions because they serve specific customers rather than holding out to the general public for common carriage.

What is the role of the pilot in command in commercial operations?
The pilot in command has final authority and responsibility for the operation and safety of the flight. For commercial operations, the pilot in command must hold at least a commercial pilot certificate (with appropriate ratings), maintain required medical certification, meet currency requirements, and ensure the flight complies with all applicable regulations. Commercial pilots acting as pilot in command for compensation bear heightened responsibility compared to private operations.

What class of medical certificate do I need for commercial pilot privileges?
You need at least a second-class medical certificate to exercise commercial pilot privileges for compensation or hire. A third-class medical certificate is insufficient for commercial operations, even though you can obtain your commercial pilot certificate with a third-class medical. The second-class medical ensures you meet higher health standards appropriate for carrying passengers or property for hire. First-class medicals also authorize commercial privileges.

Do commercial pilots need to sign logbook endorsements for certain operations?
Flight instructors (who are commercial pilots with CFI certificates) must sign logbook endorsements for students completing training milestones, solo operations, and knowledge or practical test preparation. As a commercial pilot receiving training for additional ratings or endorsements, you'll receive logbook endorsements from your instructor. Certain aircraft endorsements (high-performance, complex, high-altitude) require one-time logbook endorsements before you can act as pilot in command of those aircraft types.

What does it mean to "act" as pilot in command versus being the pilot in command?
To "act" as pilot in command means you are exercising the privileges and responsibilities of being the pilot in command during a flight. This includes making all operational decisions, ensuring regulatory compliance, and bearing legal responsibility for the safe conduct of the flight. When you act as pilot in command for compensation, you're using your commercial pilot privileges. Only one pilot can act as pilot in command during a flight, even if multiple qualified pilots are aboard.

Can a commercial pilot carry passengers and property simultaneously?
Yes. Commercial pilots can carry both passengers and property for compensation on the same flight, provided they operate within their certificate privileges and limitations. Combination passenger and cargo flights are common in commercial aviation. The pilot must ensure the aircraft doesn't exceed weight and balance limitations and that all cargo is properly secured according to regulations.

What is a "point of departure" in relation to the 50 nautical mile limitation?
The point of departure is the airport from which your flight originates. For commercial pilots without instrument ratings, the 50 nautical mile limitation is measured as a straight-line distance from this departure airport. If you fly passengers for hire to a destination more than 50 nautical miles from where you departed, you're violating your certificate limitation (unless you hold an instrument rating in that category and class).

Are there differences in commercial pilot privileges for different aircraft types?
Yes. Commercial pilot privileges are category and class-specific. A commercial pilot certificate with airplane single-engine land rating authorizes different operations than one with rotorcraft helicopter rating. Each category (airplane, rotorcraft, lighter-than-air, powered-lift) and class (single-engine, multi-engine, helicopter, gyroplane) has specific training requirements and privileges. You can only exercise commercial privileges in categories and classes for which you hold ratings.

What are the duties of a commercial pilot during flight operations?
Commercial pilot duties include conducting thorough preflight planning, ensuring the aircraft is airworthy, calculating weight and balance, obtaining weather briefings, making go/no-go decisions, maintaining positive aircraft control throughout the flight, communicating with air traffic control, monitoring aircraft systems, responding appropriately to emergencies, and ensuring passenger safety. Commercial pilots also bear responsibility for regulatory compliance and proper documentation of flight operations.

Can commercial pilots be limited or qualified in specific ways beyond the standard limitations?
Yes. The FAA may place additional limitations on a commercial pilot certificate based on the practical test aircraft used, medical conditions, or demonstrated proficiency. For example, if you take your commercial helicopter practical test in a helicopter with only one set of flight controls, your certificate will be limited to that type of helicopter. Medical limitations might restrict you to daytime VFR only or prohibit carrying passengers. These limitations remain until you demonstrate proficiency and receive an endorsement or updated certificate.

How does money or compensation affect what operations a commercial pilot can conduct?
Any time a commercial pilot receives money or compensation for piloting services, they must ensure the operation falls within their commercial privileges and applicable regulations. Accepting compensation transforms a flight from a Part 91 operation into a commercial operation subject to stricter rules. Even indirect compensation (someone pays for fuel in exchange for a flight) can trigger commercial pilot requirements. Understanding when compensation creates regulatory obligations is essential for staying legal.

Do commercial pilots need special preparation before conducting certain operations?
Yes. Different types of commercial operations require specific preparation beyond basic commercial pilot training. Aerial work operations require knowledge of specialized procedures and often aircraft-specific training. Sightseeing flights require obtaining Letters of Authorization. Operations in complex airspace or challenging weather require thorough preparation and planning. Commercial pilots should never accept a flying job without adequate preparation for the specific operation they'll conduct.

Can commercial pilots conduct operations at night, and are there special requirements?
Commercial pilots with instrument ratings can conduct operations at night for compensation. Those without instrument ratings cannot carry passengers for hire at night, regardless of distance. Night operations require specific training and experience as part of commercial pilot certification. Pilots must maintain night currency (three takeoffs and landings to a full stop at night within 90 days) to carry passengers at night. Night flying presents unique challenges requiring additional proficiency and judgment.

What details should commercial pilots document about their flights?
Commercial pilots must maintain accurate logbook records documenting flight time, pilot-in-command time, cross-country time, night time, instrument time, and specific training received. For commercial operations, pilots should document the nature of the operation, any compensation received, and compliance with applicable regulations. Proper documentation protects you in case of FAA inquiries and provides evidence of meeting currency and experience requirements for future ratings or job applications.

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This article presents a general overview of the field of aviation, including job opportunities within that field; it does not describe the educational objectives or expected employment outcomes of a particular Hillsboro Aero Academy program. Hillsboro Aero Academy does not guarantee that students will obtain employment or any particular job. Some positions may require licensure or other certifications. We encourage you to research the requirements for the particular career you desire.