Check Airman or Company Instructor: Who Can Train, Who Can Check, and What the FAA Requires

Same cockpit, different authority

Consider a hypothetical. A Part 135 training manager heads into recurrent season two check pilots short. The senior company flight instructor already teaches the recurrent curriculum, knows the airplane cold, and has flown with every pilot on the roster. The manager asks whether that instructor can also sign off the competency check, the job most crews still call a check airman’s. The answer is no, not on the strength of the instructor role alone.

Teaching and checking are separate legal authorities under Part 135. They come with separate qualification paths, and only one of them carries an express requirement for FAA approval of specific duties. The person who administers a required check has to hold authority for that event, however well that person can teach.

The title on the role has also changed. An FAA final rule effective July 18, 2024 replaced “check airman” with “check pilot” in Part 135, so the title in many company manuals is now out of date.

The sections below cover what changed in 2024, what a check pilot needs, what an instructor can do, how other rule parts handle the question, which proposals are pending, and what training managers should audit.

Why the check airman title changed in Part 135

The change came in a final rule published at 89 FR 51415 to 51432 under the title Removal of Check Pilot Medical Certificate Requirement. It took effect July 18, 2024. In the preamble, the FAA described the switch from check airman to check pilot as a terminology update.

The older term is still in circulation. Part 125 regulations still use it, and so does statutory language, including Public Law 118-63, the FAA Reauthorization Act of 2024. Older handbooks, company forms, and everyday hangar talk use it as well. The two terms refer to the same Part 135 role, but only “check pilot” matches the current regulatory text.

The rule’s substantive change concerned medical certification. It resolved inconsistencies in how the medical requirement applied to these roles. Check pilots and instructors do not need a medical certificate solely to perform those functions in an aircraft. The exception is a check pilot or instructor serving as a required flightcrew member. That person must still meet the applicable flightcrew qualifications, including medical.

The rule also changed some section wording and paragraph numbering. Manuals, forms, and training records that cite pre-amendment paragraphs may now point to the wrong text. Operators should check their documents against the current eCFR rather than an older handbook or a copied reference.

Part 135 check airman requirements under 135.337 and 135.339

Two sections set the standard for a Part 135 check pilot. One covers qualification and approval. The other covers training and recurring observation.

Qualification and approval

Under 14 CFR 135.337, a check pilot must meet four requirements:

• Hold the certificates and ratings required to serve as pilot in command (PIC) in operations under Part 135.
• Complete the applicable aircraft training and PIC checks.
• Complete check pilot training under 14 CFR 135.339.
• Hold FAA approval for the check duties involved.

The section also separates an aircraft check pilot from a check pilot who serves only in a flight simulation training device (FSTD). The qualifications differ, and so does the scope of each approval.

The last element sets the boundary of the authority. FAA approval is for the duties involved. It does not cover any aircraft or any check. Before a check pilot administers a check, the operator has to confirm that the approval covers that aircraft and that event.

Training and the 24-month observation

Section 135.339 requires initial or transition check pilot training, as applicable. The curriculum covers four areas:

• check pilot duties and responsibilities
• applicable regulations and the certificate holder’s policies and procedures
• methods of evaluating pilot performance
• appropriate corrective action after an unsatisfactory check

The section also imposes an observation requirement. Within the preceding 24 calendar months, the check pilot must satisfactorily conduct a proficiency or competency check while observed by an FAA inspector or by an aircrew designated examiner employed by the operator. The observation may take place in whole or in part in an aircraft, a flight simulator, or a flight training device.

This is a separate regulatory event, and routine recurrent training is not a substitute for it. The check pilot has to conduct a check under observation by an eligible observer within the interval.

What a company flight instructor can and cannot do

The instructor path runs through different sections. Under 14 CFR 135.338, a flight instructor in the operator’s training program must hold the pilot certificates and ratings required to serve as PIC, complete the applicable aircraft training and checks, and complete instructor training under 14 CFR 135.340.

FSTD instructors have an additional currency alternative. They must have flown at least two flight segments as a required crewmember in the preceding 12 months, or completed an approved line-observation program. This provision applies to FSTD duties only. It does not substitute for aircraft check pilot qualification.

Section 135.340 requires initial or transition instructor training. It also requires an observed instruction event within the preceding 24 calendar months. The list of eligible observers is wider than for check pilots. It includes an FAA inspector, an operator check pilot, or an aircrew designated examiner employed by the operator.

The difference between the two roles comes down to approval. Section 135.337 expressly requires FAA approval for check pilot duties. Sections 135.338 and 135.340 set qualification, training, and observation requirements for instructors but do not contain that express approval. The two paths should not be treated as interchangeable.

For a training manager, a company flight instructor can train and teach to standard. Teaching authority does not confer checking authority, and an instructor cannot administer a required check without separate check pilot qualification and approval.

Which checks require a check pilot

The table below compares the roles that operators most often confuse.

The principal Part 135 checks and their intervals are:

• 14 CFR 135.293: pilot test and pilot competency check, generally every 12 calendar months.
• 14 CFR 135.297: PIC instrument proficiency check for IFR operations (the Part 135 IPC), every six calendar months.
• 14 CFR 135.299: PIC line check, every 12 calendar months.

These are the principal Part 135 pilot testing and checking events. The person administering each one must hold the authority specified for that particular event, and an instructor’s ability to teach does not confer it.

Check pilots, designated examiners, and other rule parts

Much of the confusion between company check pilots and designated examiners comes from treating different authorizations as the same thing. Other rule parts also handle checking differently from Part 135.

A DPE designation is not company check pilot approval

A Designated Pilot Examiner is appointed under 14 CFR 183.23 to conduct practical tests within that designation. An aircrew designated examiner (ADE) is part of an FAA-approved program associated with a specific operator. An Aircrew Program Designee (APD) is further authorized by the FAA to perform specified certification evaluations.

A DPE designation does not, by itself, make anyone a Part 135 check pilot or authorize that person to administer Part 135 checks.

Part 125 still says check airman

Under 14 CFR 125.295, the operator requests approval in writing. If the nominee passes the appropriate oral and flight test, the FAA may issue a letter of authority. The letter lists the checks the person may give and the aircraft category, class, and type covered.

Sections 125.287 and 125.291 identify the checks an authorized check airman may administer. AC 125-1A, dated September 15, 2016, describes the approval process in more detail, but it is advisory guidance. The regulation controls.

Part 91K and ordinary Part 91

Part 91K applies to fractional ownership programs. Under 91.1073, the program manager must have an approved training program with enough instructors and check pilots. Check pilot qualifications are in 91.1089 and instructor qualifications in 91.1091. Training and observation are covered in 91.1093 and 91.1095.

Section 91.1063 allows a program manager, if authorized by the Administrator, to use specified Part 121 or 135 training and testing rules instead. The sources reviewed for this article show no general check pilot approval system for ordinary Part 91. Instructor privileges and limitations are in 61.193 and 61.195, and 91.109 sets the conditions for flight instruction.

Contracted checking and the proposals on the table

Operators short on check pilots often turn to contracted checking. Under 14 CFR 135.324(a), another Part 135 certificate holder or a Part 142 training center may conduct training, testing, and checking under contract. Section 135.324(b) sets specific conditions for Part 142 centers. It does not set similarly detailed procedures when one Part 135 operator provides check pilots to another.

The Air Carrier Training Aviation Rulemaking Committee (ACT ARC) has addressed that gap. Recommendation 25-5 asks the FAA to clarify how cross-operator check pilot contracting should be approved and how inspectors should assess compatibility between operators. The committee found that current Order 8900.1 guidance does not clearly explain these arrangements and that oversight practices vary. Those are the committee’s findings, not FAA conclusions.

Recommendation 25-7 asks the FAA to consider a new category, an observer-seat-only check pilot (CP-OS). A CP-OS could conduct certain 135.299 line checks without a type rating in the aircraft. The proposal limits this to aircraft of the same category and class.

Two pilot unions filed nonconcurrences. The Air Line Pilots Association (ALPA) argued that category and class qualification alone may not give a check pilot enough aircraft-specific knowledge to evaluate a pilot’s performance. ALPA also opposed basing qualification standards on operator size. The Coalition of Airline Pilots Associations (CAPA) said the proposal may address logistical challenges for some operators but could risk reduced safety margins.

Both documents are recommendations, not rules. No NPRM that would put either into effect turned up in the listings reviewed, and FAA disposition of either recommendation could not be verified.

Separately, Section 336 of Public Law 118-63 requires the FAA to establish or assign a working group to review Part 135 check airman rules and policies. It also requires a briefing to Congress within one year of the working group being tasked. The section requires review and recommendations and does not itself change any qualifications. The tasking date and the status of the briefing could not be verified.

An audit list for training managers

Clear separation between roles, approvals, and records makes it easier to show a POI how an operator’s program works. The following actions cover the main points:

1. Build a role matrix that identifies who instructs, who administers each required check, and who certifies completion.
2. Keep auditable evidence of each check pilot’s qualifications and FAA-approved scope, broken down by aircraft, FSTD, and type of check.
3. Record each check pilot’s observation as its own entry, with the date, the observer, and the type of check observed.
4. Track FSTD instructor and FSTD check pilot currency separately from aircraft qualifications.
5. Schedule the correct check for each pilot’s role rather than treating every event as an interchangeable checkride.
6. Keep records that distinguish instruction, training certification, and regulatory check results. Section 135.323 makes the certificate holder responsible for training certifications in crewmember records, and computerized entries must identify the certifying instructor, supervisor, or check pilot.
7. Review any contracted checking arrangement with the POI before relying on it, and replace outdated references to the old title in manuals and forms.

International operators should confirm the requirements of the State of the Operator separately. The FAA rules discussed here do not settle those requirements.

Frequently asked questions

Can a former Part 121 check airman automatically check Part 135 pilots? Not on that basis alone. A Part 135 check pilot needs Part 135 qualification, check pilot training, and FAA approval for the specific duties. Confirm with the operator’s approved training program and the POI whether any prior experience is credited.

Can an FSTD-only check pilot conduct a line check in the aircraft? Section 135.337 distinguishes aircraft check pilots from FSTD-only check pilots, and the scope of each person’s approval controls. Before scheduling a line check, confirm that the person’s approval covers aircraft duties.

Does every company instructor need a separate FAA approval letter like a check pilot? The instructor path runs through 135.338 and 135.340, which do not contain the express FAA approval found in 135.337. The operator’s approved training program sets out how its instructors are qualified and documented.

Keeping the check airman and instructor roles straight

The old check airman title may stay in manuals and hangar talk for years, but the authority question is unchanged. Instructors train. Approved check pilots administer required checks within their scope. Records should show which person did which job, and the ACT ARC proposals remain proposals until the FAA acts on them.

Separating roles, approvals, and records works best when the training behind them is current and documented. Review your training program’s instructor and check pilot roles against current Part 135 text, then see how CTS Part 135 Training supports recurrent and initial training for your crews, and, for fractional, Part 91, and IS-BAO operators, how CTS IS-BAO/Part 91 Training fits your program.