Part 135 instrument currency: the 6-approach rule and what resets the clock

A Part 135 flight crewmember acting as PIC under IFR must be instrument current under 14 CFR 135.297. The rule is separate from — and stricter than — the Part 61 instrument currency requirement at 61.57. If you are using Part 61 recency as your proxy, you are not using the right rule.

What 135.297 requires

Within the preceding six calendar months, the pilot must have performed and logged under actual or simulated instrument conditions:

• Six instrument approaches
• Holding procedures and tasks
• Intercepting and tracking courses through the use of navigation systems

"Six calendar months" means the month of the check plus the five preceding calendar months — the same convention as 61.57. A check performed in June counts back through January.

The approaches must be performed in the category of aircraft for the rating involved — or in a flight simulator, flight training device, or aviation training device that represents that category.

What counts as an instrument approach for currency

The approach must be flown to instrument minimums — or would have been if the conditions warranted it. Specifically:

• Actual IMC approaches count. Any approach flown in actual instrument meteorological conditions to published minimums, logged appropriately.
• Simulated approaches count — including under the hood in VMC, in a flight simulator (FSTD), or in a qualified ATD — as long as they are logged.
• Proficiency check approaches count. Approaches flown during a 135.297 or 135.293 check reset the currency clock.
• Approaches must be to minimums. A visual approach does not count, even if the weather was IFR. The approach must be conducted using the instrument approach procedure.

Approaches in a different aircraft category (e.g., a rotorcraft pilot logging approaches in an airplane) do not count toward currency for the other category.

What does not count

• Visual approaches, even in IMC
• Approaches flown as SIC when the pilot in question was not the pilot flying
• Approaches in a category not applicable to the rating
• Approaches not logged in the pilot's logbook or training record

The 135.297 check as an alternative

A pilot who has not performed the six approaches in the preceding six calendar months may not act as PIC under IFR. The only way to restore currency without going back and flying the approaches is to complete a 135.297(a) proficiency check with an authorized check airman. That check resets the currency clock.

Note that a 135.293 initial or recurrent check does not automatically satisfy 135.297 unless instrument approaches were included in that check and logged accordingly.

How the pre-dispatch gate handles instrument currency

The pre-dispatch currency check compares the proposed PIC's last logged instrument approach against the six-calendar-month window. If the last approach falls outside the window, the gate returns UNABLE with the citation (135.297) and the specific expiry date.

The common operational failure mode is not ignorance of the rule — it is that the approach was flown but not entered into the crew record in time for the dispatch system to see it. A pilot who flew six approaches last week but has not had the logbook updated is operationally current but looks expired to any automated gate. The fix is a crew records process, not a rule change.

135.297 vs. 61.57 — the key differences

The practical difference: a 61.57 IPC restores general currency but does not satisfy 135.297 unless the check airman is authorized under Part 135 and the check is logged as a 135.297 check. An IPC done with a CFII who has no 135 check-airman authority does not restore Part 135 instrument currency.