Commercial Pilot Privileges and Limitations

What can you do?

So now that you’re a commercial pilot, what exactly can you do with your certificate to start making back all that $$$$$ you spent getting your ratings?

First let’s go over a few basic regulatory limitations:

  • If you do not have an instrument rating, you cannot carry passengers for hire more than 50nm from the point of departure or at night. (61.133(b)1)
  • You must have a valid 2nd class medical or higher that is still good for giving you 2nd class privileges or higher (what that means is if you have 1st class medical that is fine, but if it has been for example 14 months from the date of examination then it no longer grants you 2nd class privileges, it would at that point grant you 3rd class privileges).

Getting Paid!

So can you now go rent an aircraft from your old flight school and start offering to take people flying on scenic flights or fly them somewhere for their work?


Even though you are a commercial pilot and let’s assume you have a medical with 2nd class privileges or higher, that does not mean you can just start flying people around and charging them.  In fact, the same rules apply as when you were a private pilot where you still have to pay more than half of the “pro rata” share of flying the plane.

So how do I make $$$ ?

The FAA requires operators who are charging to carry passengers to have a valid “operating certificate”.  This operating certificate is for the Company that owns the plane and employees the pilot, not for the Pilot themselves.  An example of such an operating certificate would be a Part 135 Charter Certificate, Part 119 Tour Operator, or Part 121 Scheduled Airline Certificate (like the airlines all have).

Do I need to know what all those certificates are and how to get one?

Again, Nope….

You just need to know that you don’t have one and it is quite difficult and time consuming to get such a certificate from the FAA for a company.  As a newly minted commercial pilot you simply need to know you can’t put a sign on the side of the road that says “Pilot Jon’s Seenick Fright Tours”.

So what if I want to take people on scenic tours or charge to fly them places without going to work for a Company that already has an operating certificate?

If this is something you want to do or the DPE asks “how could you earn money with your commercial pilot certificate without going to work for someone else?” then the correct answer to this question is:

I would contact my local FSDO and ask to speak with a Safety Inspector, tell them who you are and what you are hoping to do, and ask them what the proper next steps are to get the ball rolling.

Do not try to use your superior knowledge of the regs to show off to the examiner and say you would apply for a Part 135 Certificate (you will be opening up a huge can of worms for yourself).

So who can I go work for?

You can work for any Company that holds a valid Operating Certificate.  It is your responsibiilty to verify they have a valid certificate and are not just saying they do.  If you fly an airplane for a Company that does not have a valid certificate you are violating the regs and the FAA will come after you too!

How do you know if they have a valid certificate?  All operating certificates are on file with the local FSDO, and you can simply call up and ask if that company has a valid certificate and what type of certificate it is.  They may only be certified to do Scenic Tour Flights under 91.147 and instead trying to tell you to fly someone all the way from Miami to the Bahamas and back.  Expect whoever you work for to put you on a DOT drug testing program and get you to take a “pre employment drug test”.  If they have you start flying for them and you have not taken a “pre employment drug test”, then there is a good chance they are not doing what they are supposed to be doing and you should ask FSDO to help you out and clarify things for you.

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