Welcome Guest. Sign in or Signup

2 Answers

Complex time for Commercial ASEL..

Asked by: 1338 views Commercial Pilot

In pursuing a commercial rating for ASEL can the 10 hours complex time requirement be satisfied by flying a complex multi-engine plane? 14 CFR 61.129 (a)(3)(ii) says the "...airplane must be appropriate to land or sea for the rating sought." It does not indicate that it has to be appropriate for the class of the rating sought.

My thought was that I could put in 10 hours dual in a multi-engine complex aircraft, test for Commercial ASEL, then spend a couple more hours in the multi and test for Multi Add-On. Kinda kill 2 birds with 1 stone. I know the multi time will be more expensive, but it would need to be done anyway for the multi add-on. This way would prevent me having the cost of 10 hours in a SE complex or TAA aircraft...and then still needing the multi time.

Ace Any FAA Written Test!
Actual FAA Questions / Free Lifetime Updates
The best explanations in the business
Fast, efficient study.
Pass Your Checkride With Confidence!
FAA Practical Test prep that reflects actual checkrides.
Any checkride: Airplane, Helicopter, Glider, etc.
Written and maintained by actual pilot examiners and master CFIs.
The World's Most Trusted eLogbook
Be Organized, Current, Professional, and Safe.
Highly customizable - for student pilots through pros.
Free Transition Service for users of other eLogs.
Our sincere thanks to pilots such as yourself who support AskACFI while helping themselves by using the awesome PC, Mac, iPhone/iPad, and Android aviation apps of our sponsors.

2 Answers



  1. Bryan on Apr 07, 2022

    I believe your interpretation is correct. I actually did mine the other way around–Commercial AMEL and then the ASEL add-on. Just over 26 hours of total multi time to do it that way.

    But for the regulation, the fact that they will accept “any combination” of 10 training hours in complex, turbine, or technically advanced means that they just want you to get a little bit of experience flying something more complicated than the Cherokee or 172 you might have been using to keep costs down. 10 hours isn’t enough to make you proficient in any of those areas, especially if you split it up. So as long as it is a land based plane for a land based rating, you’re good.

    0 Votes Thumb up 0 Votes Thumb down 0 Votes



  2. Russ Roslewski on Apr 08, 2022

    You are correct and I have done exactly this before. Don’t read more into the regulations than is already there. It just requires a Complex “Airplane” (and land or sea as appropriate). It could be a single, twin, turboprop or jet even. (Although those last two options are already covered by the next clause in the regulation about “turbine” airplanes, so they wouldn’t have to be “complex” – for example a Caravan or Twin Otter would be acceptable.)

    0 Votes Thumb up 0 Votes Thumb down 0 Votes


The following terms have been auto-detected the question above and any answers or discussion provided. Click on a term to see its definition from the Dauntless Aviation JargonBuster Glossary.

Answer Question

Our sincere thanks to all who contribute constructively to this forum in answering flight training questions. If you are a flight instructor or represent a flight school / FBO offering flight instruction, you are welcome to include links to your site and related contact information as it pertains to offering local flight instruction in a specific geographic area. Additionally, direct links to FAA and related official government sources of information are welcome. However we thank you for your understanding that links to other sites or text that may be construed as explicit or implicit advertising of other business, sites, or goods/services are not permitted even if such links nominally are relevant to the question asked.